Failure to Account for and Manage Resident Trust Funds
Summary
The facility failed to properly account for and manage resident personal funds deposited in the Resident Trust Account for 30 out of 38 sampled residents. Record reviews showed that significant amounts of money were withdrawn from multiple residents' trust accounts for personal needs, shopping, insurance premiums, and burial accounts. However, there was no documentation or receipts to show what these funds were actually spent on, nor any evidence that the money was withdrawn at the request of the residents or their families. Interviews and a financial audit conducted by the facility's corporate office revealed discrepancies in the resident trust fund accounts. When questioned, the Financial Counselor (FC) responsible for managing these funds claimed that the money had been given to residents and their families. However, interviews with cognitively intact residents and family members confirmed that they had not received or requested any funds from the FC. The lack of supporting documentation and receipts for these transactions was confirmed by both facility records and law enforcement review. The investigation determined that the FC had misappropriated resident funds over several months. The absence of proper accounting and failure to obtain or retain receipts for the disbursed funds led to the inability to verify that the money was used for resident needs. This resulted in a significant deficiency in the facility's management of resident trust accounts, as required by regulations.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
The facility failed to properly manage resident trust funds by making multiple unauthorized online retailer purchases from the accounts of several residents with conditions such as CHF, Alzheimer’s disease, aphasia, epilepsy, ESRD, anxiety disorder, and type 2 DM, including both cognitively intact and cognitively impaired individuals who required staff assistance with ADLs. For each affected resident, fund statements showed specific debits that were not signed or authorized by the resident or a representative, despite a facility policy requiring signed vouchers or check request forms and invoices for withdrawals. In addition, the facility did not document that quarterly resident fund statements were provided to residents or their representatives for two consecutive quarters, and the Administrator confirmed both the unauthorized transactions and the absence of quarterly statements during interviews.
The facility failed to provide required quarterly trust account statements to multiple residents and a responsible party whose personal funds were managed in facility-held trust accounts. Several alert and oriented residents reported not receiving any quarterly statements despite having active trust accounts, including residents with documented capacity to make decisions and one with a BIMS score indicating intact cognition. Another resident’s responsible party reported never receiving statements for her family member’s trust account, even though the resident had severe cognitive impairment and the RP was designated to manage finances. The BOM stated that statements were only provided upon request and that none had been issued since his employment began, while the ADM stated statements were supposed to be automatically mailed but acknowledged there was no procedure to ensure they were sent or received, and no relevant policies were produced when requested.
The facility did not provide required quarterly financial statements to multiple residents who maintained personal fund accounts. Several residents reported having resident accounts but stated they were unaware of their account activity or balances because they had not received statements for the prior three months or upon request. The Administrator confirmed that quarterly statements were not being issued to these residents, resulting in noncompliance with state requirements for management of residents’ personal funds.
The facility failed to maintain complete and accurate accounting records for multiple residents’ personal funds held in a commingled trust account. Resident trust statements only showed balances without itemized deposits or withdrawals, and did not reflect any allocation of interest earned. Bank statements for the checking and savings accounts listed deposits under a single resident’s name and did not document other residents’ debits or credits, despite several residents having funds managed by the facility. An activity director reported managing several residents’ funds, paying for items like haircuts by check, but did not know how to record deposits and withdrawals in the electronic system, resulting in records that did not match bank statements. The Administrator confirmed that a sister facility’s business office handled deposits and transfers and acknowledged that the facility lacked proper tracking and individual ledgers for resident expenditures.
The facility failed to provide required quarterly written statements and maintain accurate records for resident trust fund accounts. A resident with intact cognition and mental health diagnoses reported never receiving a balance statement, not knowing her account balance, and only receiving partial funds when requesting money for bills, with no access to funds on weekends. Two other residents with cognitive communication deficits and cognitive impairment stated they were supposed to receive $75 monthly but were not given the full amount when requested, limiting their ability to purchase food. The ADM and a director confirmed the facility had not been keeping records of personal funds, including quarterly statements and withdrawals, and could not produce accurate trust fund statements or documentation of disbursements, despite a policy requiring documentation of all transactions and quarterly statements.
Failure to Provide Quarterly Personal Funds Statements: A resident with a personal funds account stated he had not received quarterly statements for several months. The S10PFS, who was responsible for providing the statements, confirmed the resident did not receive them while she was out of the facility for several months, despite the facility policy requiring quarterly statements and access upon request.
Unauthorized Use and Poor Accounting of Resident Trust Funds
Penalty
Summary
The deficiency involves the facility’s failure to properly manage resident personal funds, including making unauthorized purchases from resident trust accounts and failing to provide required quarterly account statements. For multiple residents, surveyors identified debits to online retailers that were not signed or authorized by the residents or their representatives, despite facility policy requiring such authorization via vouchers or check request forms. The facility also did not document that quarterly resident fund statements were sent to the residents or their representatives for the fourth quarter of 2025 and the first quarter of 2026. One affected resident had congestive heart failure, Alzheimer’s disease, and aphasia, was severely cognitively impaired, and required staff assistance with ADLs. This resident’s fund statement showed debits for online retailer purchases in specific amounts on two dates, and the resident’s representative had not authorized these transactions. The Administrator verified that these purchases were made from the resident’s funds without authorization and confirmed that quarterly statements for the relevant quarters had not been provided to the resident or representative. Another resident, cognitively intact with type 2 diabetes mellitus, PTSD, and osteoarthritis, had a substantial increase in account balance over a quarter, yet there was no documentation that quarterly statements were sent, which the Administrator also confirmed. Additional residents with varying levels of cognitive impairment and medical conditions, including type 2 diabetes mellitus, pulmonary hypertension, generalized anxiety disorder, epilepsy, end stage renal disease, aphasia following cerebral infarction, anxiety disorder, cerebral infarction, and Alzheimer’s disease, were similarly affected. Their quarterly fund statements showed multiple debits to an online retailer on various dates and in specific amounts, none of which were signed or authorized by the residents or their representatives. For each of these residents, record review showed no documentation that quarterly statements for the fourth quarter of 2025 or the first quarter of 2026 were sent, and in interviews, the Administrator consistently verified both the unauthorized nature of the purchases and the failure to provide the required quarterly statements. Review of the facility’s undated Resident Trust Funds policy showed that resident fund withdrawals were supposed to be supported by signed vouchers or check request forms and invoices, which was not followed in these cases. Across all six residents reviewed for this issue, the survey findings demonstrated that the facility did not maintain resident fund accounts using basic accounting principles as required by its own policy. Unauthorized online purchases were repeatedly charged to resident accounts without the required signatures or documented consent, and there was a systemic lack of documentation that quarterly fund statements were provided to residents or their representatives for two consecutive quarters. These actions and omissions formed the basis of the cited deficiency related to the management and safeguarding of resident personal funds.
Failure to Provide Quarterly Trust Account Statements to Residents and Representatives
Penalty
Summary
The deficiency involves the facility’s failure to provide required quarterly trust account statements to residents or their responsible parties (RPs) for resident funds managed by the facility. Surveyors interviewed multiple residents and an RP and reviewed medical and financial records. One resident, who was alert and oriented at the time of interview, stated he did not have a bank account or receive mail at the facility, but record review showed his trust account with the facility was opened on November 26, 2025, and his BIMS score indicated severe cognitive impairment. Another resident, alert and oriented, reported that her Social Security checks were sent directly to the facility and that she had a share-of-cost obligation, but she did not receive quarterly statements to track deposits and withdrawals; records showed her trust account was opened on August 1, 2024, and she had capacity to make decisions. A third resident, cognitively intact with a BIMS score of 14, stated he had not received quarterly statements for his trust account, which records showed was opened on November 30, 2018. A fourth resident, who had capacity to make decisions per the history and physical, stated he was unaware if he had a trust account and had not received a quarterly trust account statement, despite records indicating his trust account was opened on September 15, 2025. A fifth resident was alert but nonresponsive and could not be interviewed; her medical record showed severe cognitive impairment with a BIMS score of 0, and that her daughter was the RP. In a phone interview, the RP stated she had never received quarterly statements for this resident’s trust account, which had been opened on September 1, 2024. During a concurrent interview and record review, the Business Office Manager (BOM) stated that the facility’s process was to provide quarterly trust account statements only upon demand request by the resident or RP, and further stated that since his employment began on February 17, 2026, the business office had never provided quarterly trust account statements to residents or RPs. The Administrator later stated that quarterly statements were supposed to be automatically mailed from the business office, but acknowledged there was no procedure in place to ensure residents or RPs actually received the statements and confirmed with the corporate Director of Accounts Receivable that residents or RPs should have been receiving quarterly trust account statements. When policies related to resident trust accounts and quarterly statements were requested, the facility did not provide them.
Failure to Provide Required Quarterly Resident Account Statements
Penalty
Summary
The facility failed to properly manage residents’ personal funds by not providing required financial statements to residents with active accounts. During interviews conducted on April 23, 2026, between 11:00 a.m. and 3:00 p.m., five of eleven sampled residents (Residents 2, 3, 5, 7, and 11) reported that they had resident trust accounts but were unaware of their account activity or total balances because they had not received quarterly statements reflecting the last three months of transactions. These residents also had not received statements upon request. In a subsequent interview on April 23, 2026, at 3:30 p.m., the Administrator confirmed that quarterly financial statements were not being provided to these residents, constituting noncompliance with 28 Pa. Code 201.18(b)(2)(3) regarding management of residents’ personal funds. No additional medical history or clinical conditions for the involved residents were described in the report.
Failure to Maintain Accurate Accounting Records for Resident Trust Funds
Penalty
Summary
The facility failed to properly maintain complete and accurate accounting records for resident personal funds held in a commingled trust account for ten residents. Trust statements provided for these residents only showed a single balance figure without any itemized accounting of deposits (credits) or withdrawals (debits), and did not identify or allocate any interest earned on the funds. Individual balances ranged from small positive amounts to a negative balance for one resident, but there was no supporting transaction detail. Review of the facility checking account statements over several months showed deposits recorded only under one resident’s name, with no documentation of other residents’ debits or credits, despite multiple residents having funds managed by the facility. The related business savings account showed minimal interest earnings, but there was no evidence that this interest was tracked or attributed to individual residents’ accounts. During interviews, the activity director reported managing funds for seven residents but stated she did not have access to the bank account and believed it was a non–interest-bearing account. She described paying for resident items such as haircuts by check and then giving the checks to the Administrator, and acknowledged that although the electronic record system had an area to record deposits and withdrawals, she did not know how to use it, resulting in records that did not match the bank statements. She also stated she printed and mailed balance-only statements to families every three months. The Administrator reported that a business office staff member at a sister facility handled deposits into savings and transfers to checking, and acknowledged that the bank statements only reflected one resident’s name and that the facility lacked appropriate education and systems to track and deposit resident funds with individual ledgers showing each resident’s expenditures.
Failure to Provide Quarterly Trust Fund Statements and Maintain Accurate Personal Funds Records
Penalty
Summary
The deficiency involves the facility’s failure to properly manage and document residents’ personal trust funds, including not providing required quarterly written statements for three residents with accounts held by the facility. One cognitively intact resident with major depressive disorder and generalized anxiety disorder reported having a trust fund but stated she never received a balance statement and did not know how much money she had, suggesting this had been occurring since the prior year. She reported having to ask the facility for money to pay her phone bill and only receiving whatever amount staff said was available, without being able to obtain the full amount requested, and stated she could not request money on weekends. Two other residents with cognitive communication deficits and varying levels of cognitive impairment reported they were supposed to receive $75 per month but were not given the full amount when requested. One resident stated he did not receive the full $75 at once despite asking, which affected his ability to buy outside food. Another resident stated she was supposed to get $75 per month, but the facility would not give her the full amount because the facility would “run out,” and she used extra money to pay for food. In an interview, the Administrator and Director of Special Projects acknowledged the facility had not been keeping records of residents’ personal funds, including quarterly statements and withdrawals, and that they could not print accurate trust fund statements or provide evidence of money disbursements because trust fund transactions were not being accurately recorded, contrary to the facility’s written policy requiring documentation of all withdrawals and provision of quarterly written statements.
Failure to Provide Quarterly Personal Funds Statements
Penalty
Summary
The facility failed to provide quarterly personal funds statements for Resident #12, who had a personal funds account deposited with the nursing home. During interview, Resident #12 stated he had not received a quarterly statement for several months. Review of the facility’s Resident Personal Funds policy showed that the individual financial record must be available to the resident through quarterly statements and upon request. The S10PFS stated she was responsible for providing quarterly personal funds statements to residents with personal funds accounts and confirmed that she had been out of the facility from January 2025 to September 2025 and that Resident #12 did not receive quarterly statements during that time.
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