F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
D

Failure to Use Non-Pharmacological Interventions and Obtain Consent Before Extensive Psychotropic Use

Regency At TroyTroy, Michigan Survey Completed on 02-02-2026

Summary

The deficiency involves the facility’s failure to ensure necessary behavioral health care and services for a resident with dementia and Alzheimer’s disease, including consistent use of non-pharmacological interventions, appropriate indications for psychotropic medications, individualized behavioral care planning, and monitoring of behavioral health services. The resident was admitted with multiple diagnoses including dementia, Alzheimer’s disease, falls, major depressive disorder, and nasal bone fractures following a fall with syncope. An MDS assessment showed a BIMS score of 3, indicating severely impaired cognition and dependence on staff for all ADLs. A care plan addressing impaired communication related to confusion and a language barrier (primary language Arabic) was present, and a behavior care plan for actual behavior problems related to dementia with episodes of yelling and screaming was not initiated until ten days after admission. On multiple occasions, the NP and medical team ordered and adjusted psychotropic medications in response to reports of agitation, yelling, and screaming without consistent nursing documentation of the observed behaviors or of non-pharmacological interventions attempted beforehand. On one date, the NP documented increasing agitation, with reports from nursing staff and residents that the resident had been up all night screaming and yelling and that staff were unable to distract or redirect the behavior; Xanax 0.25 mg was added for anxiety, with an intervention to monitor non-pharmacological interventions. However, there was no corresponding nursing documentation of the agitation throughout the night and morning and no documentation of non-pharmacological interventions attempted. Over subsequent days, the NP discontinued Xanax and ordered Ativan 0.5 mg BID, a one-time dose of Seroquel 25 mg, and Seroquel 25 mg at bedtime, later increasing Seroquel to 50 mg in the evening and Xanax to 0.5 mg at bedtime, while continuing Zoloft and Remeron. The record showed no prior diagnosis of psychosis or anxiety, no documentation explaining why Ativan was added BID on a later date, and no documentation of behavioral descriptions or non-pharmacological interventions before administration of a one-time Ativan dose for reported anxiety and agitation. The facility also failed to obtain informed consent for multiple psychotropic medications and for behavioral health services, despite a policy requiring psychotropic informed consent before initiating or increasing such medications and a documented Statement of Capacity indicating the resident was incapable of making informed medical decisions, activating the daughter’s DPOA authority. A physician order for psychiatric services to evaluate and treat as indicated was present, but the record lacked evidence of behavioral health consultation or specialized mental health services arranged as referenced in the care plan. The behavior care plan, initiated several days after admission, included interventions such as administering medications as ordered, documenting behaviors and responses, using calm approaches, diversion, removal from situations, identifying underlying causes, and providing appropriate activities, but the record did not show consistent implementation or monitoring of these interventions. Interviews with the DSS and DON confirmed lack of involvement in behavioral planning, lack of consultation with behavioral health services, absence of team discussion prior to psychotropic use, and absence of behavioral monitoring and oversight of multiple psychotropic medications with similar classifications, with no further explanation or documentation provided by the end of the survey. Additionally, the facility did not implement interventions to monitor for adverse reactions or side effects of the antipsychotic and antianxiety medications administered, contrary to its Psychoactive Medication Management policy, which emphasized minimizing psychotropic use and using non-pharmacological interventions as the first choice. The care plan for potential fluctuations in mood referenced arranging specialized mental health services as indicated on the Level II assessment, but the record did not show that such services were arranged or utilized. The combination of missing behavior documentation, lack of non-pharmacological intervention records, absence of informed consent, delayed and insufficiently individualized care planning, and lack of monitoring for adverse effects collectively led to the cited deficiency for failing to provide necessary behavioral health care and services for this resident. Interviews further highlighted gaps in the facility’s behavioral health processes. The DSS, who started employment around the time of the resident’s stay, could not clearly identify the resident’s targeted behaviors beyond falls and attempts to get out of bed and reported no involvement in the behavioral plan of care or implementation of non-pharmacological interventions. The DSS also confirmed that behavioral health services were not consulted for the resident and acknowledged that the IDT should have met to discuss behavioral and medication needs and then approached the resident’s daughter for psychotropic medication consent. The DON identified the resident’s targeted behaviors as yelling out and being resistive to care and stated that the resident was being followed by the medical team but did not believe the resident had been referred to behavioral health services. The DON acknowledged concerns about multiple psychotropic administrations without documentation of prior non-pharmacological interventions, lack of oversight of multiple psychotropics of the same class, and lack of behavioral monitoring and management, with no additional documentation provided to address these issues.

Penalty

No penalty information released
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

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See other F0740 citations
Failure to Implement Psychiatric Recommendations and Update Behavior Care Plan Leading to Resident Altercation
G
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

A resident with impulse disorder, mood and anxiety diagnoses, and a history of escalating verbal and physical aggression had multiple documented incidents of threats, object throwing, and assault with a cane. Despite a psychiatric consult recommending PRN trazodone for agitation, anxiety, and insomnia, the provider order listed insomnia only, and the care plan was not updated with specific interventions to address the resident’s physically aggressive behaviors after several documented events. Subsequently, the resident struck another resident with a cane, causing a facial laceration that required wound closure and ongoing treatment.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Implement Behavior Monitoring for Exit-Seeking Resident
D
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

A resident with a history of cerebral infarction and cognitive communication deficit was care planned as being at risk for elopement due to confusion, inability to express needs, and repeated statements about wanting to leave and go home. Interdisciplinary documentation described a consistent pattern of exit-seeking behaviors, including leaving on LOA with a family friend and not returning until the next day, requiring EMS assistance and hospital evaluation upon return, and later being found off facility grounds along a roadside. Despite these ongoing behaviors and the facility’s written Behavior Management Program requiring monitoring forms for residents with problematic behaviors, the clinical record contained no behavior tracking or monitoring specific to the resident’s exit-seeking behaviors, and staff acknowledged that such monitoring should have been in place.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Initiate Behavioral Health Response During Verbal Escalation Leading to Resident Assault
D
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

A resident with schizophrenia, anxiety, and depression, who had a history of negative behaviors and identified triggers such as rude or "mouthy" people, became involved in a verbal argument with another cognitively intact resident in a dining area. Staff present were aware of this resident’s triggers and care-planned coping strategies but only reminded the other resident not to throw a drink and did not initiate the facility’s behavioral health response (Code [NAME]) or actively use non-pharmacological interventions at the start of the escalation. After repeated verbal warnings, the second resident threw a drink, prompting the first resident to get up and repeatedly strike the other in the face, causing visible bruising to the nose and forehead before staff separated them and called a Code [NAME].

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Provide Behavioral Health Services for Residents With Self-Harm and Aggressive Behaviors
J
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

The facility failed to provide necessary behavioral health care and services for two residents with known self-harm and aggressive behaviors. One resident with quadriplegia, depression, anxiety, and a documented history of self-mutilation by finger biting had repeated episodes of biting his/her fingers to the point of severe lacerations, bone exposure, and eventual amputation, often linked to frustration and delayed smoking. Despite multiple hospitalizations and clear documentation of chronic self-harm and disruptive behavior, the care plan initially lacked self-injury interventions, no specific safety plan or intensive/1:1 monitoring was implemented, and there was no documented ongoing notification of psychiatry or the primary physician about escalating behaviors. Staff interviews showed that many staff knew of the resident’s chronic self-mutilation and verbal aggression but were unaware of any special interventions or monitoring requirements, and the resident was left alone in the room, hall, and on the patio, where another finger was bitten off. Another resident with aggressive behavior and repeated pulling of the fire alarm also lacked documented individualized behavioral interventions or psychiatric follow-up, contrary to the facility’s own Behavioral Emergency and Intensive Monitoring policies.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Provide Trauma Evaluations and Effective Behavioral Health Interventions
E
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

The facility failed to provide necessary behavioral health services, including trauma evaluations and meaningful interventions, for several residents involved in physical altercations and with significant psychiatric histories. After two residents were physically assaulted by roommates and sustained injuries, psychiatric providers were notified but did not document trauma-focused evaluations or address contributing behaviors such as wandering. Two other residents with schizophrenia, schizoaffective disorder, violent behavior, and documented noncompliance with psychotropic medications were involved in repeated aggressive incidents toward peers and staff, yet records showed only routine refusals of medication without evidence of effective, individualized behavioral interventions. The facility acknowledged a high-behavior population and a pattern of resident altercations, along with dissatisfaction with the psychiatric NP’s limited and delayed evaluations.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Provide Behavioral Health Services for Depressed Resident Leading to Suicide Attempt
D
F0740 F740: Ensure each resident must receive and the facility must provide necessary behavioral health care and services.
Short Summary

A resident with major depressive disorder, anxiety, and multiple psychotropic medications had documented moderately severe depression on PHQ-9 and MDS assessments, along with care plans that listed psychiatrist consults and social services visits only "as indicated." Although the resident had signed consent for psychological services and family sent a text to the social worker reporting that the resident was very depressed, talking about making very bad decisions, and requesting therapy, no referral was made and there is no evidence the resident was ever seen by behavioral health providers. In the weeks before the event, the resident reported increased anxiety and received PRN Hydroxyzine on multiple days without clear documentation of the indication, and no behaviors were charted. The situation culminated when the resident ingested antifreeze in an apparent suicide attempt, telling staff he did not want to be alive anymore, demonstrating the facility’s failure to provide necessary behavioral health care and services.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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