F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
J

Failure to Provide AHA-Compliant CPR to Tracheostomy-Dependent Full-Code Resident

Harborside Health & RehabilitationWashington, District Of Columbia Survey Completed on 03-03-2026

Summary

Facility staff failed to accurately provide cardiopulmonary resuscitation (CPR) to a resident who was a full code and dependent on a tracheostomy, resulting in a deficiency cited under 42 CFR 483.24, F678, Cardiopulmonary Resuscitation. The facility’s CPR policy required adherence to American Heart Association (AHA) guidelines, including immediate initiation of CPR when an individual is found unresponsive with absent or abnormal breathing, continuous chest compressions at a rate of 100–120 per minute, provision of rescue breaths, and not leaving the person alone except when absolutely necessary to call for help. The AHA guidance referenced in the report also specified that CPR for a person with a tracheostomy involves 30 chest compressions followed by 2 breaths delivered via the tracheostomy tube using an Ambu bag or mouth-to-trach, and that if the tracheostomy tube is dislodged or blocked, it should be replaced or the stoma covered to provide rescue breathing. The resident involved had multiple significant medical diagnoses, including acute respiratory failure with hypoxia, epilepsy, dysphagia following cerebral infarction, diabetes mellitus, and schizophrenia. The resident had a physician’s order for full code status and care plans identifying risks for respiratory and cardiac complications, with interventions such as administering medications and treatments as ordered, monitoring for signs and symptoms of respiratory and cardiac complications, and providing tracheostomy care and respiratory therapy services. An admission MDS indicated the resident was cognitively intact with a BIMS score of 13, had functional limitations in upper extremities but no lower extremity impairment, used a walker, required partial/moderate assistance for some transfers, and received oxygen, tracheostomy care, and respiratory therapy. During night shift rounds at approximately 3:00 AM, the nurse supervisor (Employee #6) found the resident lying supine on the floor near the doorway, unresponsive, without a pulse or respirations, with the inner cannula of the tracheostomy tube dislodged. The nurse supervisor reported performing a brief assessment, confirming the absence of pulse and respirations, and initiating chest compressions for about three minutes but did not provide any rescue ventilation via the tracheostomy site using an Ambu bag or other method. Contrary to AHA guidance and facility policy that require not leaving a collapsed person who needs CPR, the nurse supervisor stopped CPR and left the resident alone to go to the nurses’ station to get help, stating she did not use the call light or shout for help because it was 3:00 AM and she did not want to wake other residents. She also initially called a “Rapid Response” rather than a “Code Blue,” despite the resident being pulseless and not breathing. When the respiratory therapist (Employee #9) arrived in response to the calls, the resident was on the floor on his back with several people present who were not administering CPR. The respiratory therapist assessed that the resident was not breathing, retrieved the Ambu bag from the bedside, connected it to oxygen, and began chest compressions with one hand while providing rescue breaths with the other. The therapist observed that the tracheostomy tube was dislodged and on the floor and was able to reinsert it without incident before continuing CPR with assistance from another respiratory therapist. The DON later confirmed that staff are trained that a Code Blue is automatic when someone collapses and has no pulse or is not breathing. The evidence showed that staff actions deviated from AHA-based facility policy by leaving the resident during CPR, failing to provide appropriate rescue breathing via the tracheostomy, and initially calling a Rapid Response instead of a Code Blue for a pulseless, non-breathing resident, leading to the cited deficiency. The resident was subsequently pronounced deceased at 3:51 AM after EMS arrived and continued advanced cardiovascular life support. The surveyors determined that these failures constituted an Immediate Jeopardy situation related to the provision of CPR under F678.

Removal Plan

  • Remove Employee #6 from resident care pending investigation and re-education.
  • Re-educate all licensed nurses on AHA CPR/BLS requirements.
  • Re-educate all licensed nurses on performing continuous chest compressions without leaving the resident.
  • Re-educate all licensed nurses on proper ventilation for residents with tracheostomies (use of Ambu bag via trach; management of dislodged trach).
  • Re-educate all licensed nurses on clear differentiation between Code Blue and Rapid Response.
  • Include in education: 30 compressions at 100-120/minute.
  • Include in education: rescue breathing via tracheostomy.
  • Include in education: procedure if tracheostomy becomes dislodged.
  • Require all licensed staff to maintain current AHA BLS certification.
  • Implement mock Code Blue drills.
  • Post Code Blue vs Rapid Response criteria at nurses' stations.
  • Conduct an immediate 100% chart audit of all residents with physician orders for fall/safety assessments to verify appropriateness and implementation.
  • Verify all physician orders for fall/safety assessments on MAR/TAR are being implemented.
  • Address any missing documentation for ordered assessments.
  • Re-educate nurses on required documentation of ordered assessments.
  • Conduct a 100% audit of care plans for residents at risk for falls and update them to include more than one individualized, multi-factor fall prevention intervention.
  • Provide education on care plans, Code Blue vs Rapid Response, CPR response and compliance, and physician orders/implementation of fall/safety assessments.
  • Provide education by the educator/designee for all licensed staff starting night shift.
  • Provide education for all other licensed staff prior to or at the start of their shift.
  • Continue training until all licensed staff have been educated.

Penalty

Inspection fine: $85,666
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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

Below are regulatory guidelines relevant to this citation:

See other F0678 citations
Failure to Provide Required CPR and Activate EMS for Full Code Resident
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple cardiopulmonary conditions and a documented full code status was found unresponsive without pulse or respirations during the night shift. A CNA notified the RN, who either instructed CNAs to clean and cover the resident or, per her and an LPN’s account, called a code blue and performed CPR with the LPN for about 20 minutes before stopping, without calling 911. The RN believed the resident was on hospice and did not verify code status, then notified the DON, provider, and family instead of EMS. Several hours later, after the DON called the facility and asked whether 911 had been contacted, the RN called 911 and briefly reinitiated CPR shortly before EMS arrived and pronounced the resident deceased, documenting postmortem changes. The facility’s investigation and root cause analysis found that staff failed to follow policy requiring immediate EMS activation and continuous CPR for full code residents until EMS arrival, leading to an Immediate Jeopardy finding.

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 CPR for Resident With Unknown Code Status
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple chronic conditions and severe cognitive impairment was found unresponsive and not breathing, with no documented code status, POLST, or DNR in the medical record. Nursing staff verified the absence of respirations and pulse but did not initiate CPR or call 911. An LPN reported she proposed starting CPR due to the unknown code status, but an RN declined. Leadership and clinical staff stated in interviews that facility practice and expectations are that, when a code status is unknown or no POLST is on file, the resident is to be treated as full code and CPR should be initiated.

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.
Inaccurate Crash Cart Audits and Missing Emergency Equipment
E
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

The facility failed to maintain accurate and complete crash cart audits for multiple full-code residents. Surveyors, accompanied by the DON, found that daily crash cart checks did not include verification of supply expiration dates, and that an extension cord documented as present on several audit dates was not actually in the cart. Audit logs also conflicted with the cart’s contents by indicating that required items such as eye protection, saline, and clear plastic were present when they were not. These findings were inconsistent with the facility’s policy requiring the crash cart to be checked every 24 hours and after each use, with prompt replacement of equipment and supplies.

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 CPR and Contact EMS for Full Code Resident Found Unresponsive
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with NASH, diabetes, ascites, obesity, and a documented Full Code status was found unresponsive during early morning med pass, cool to the touch and without measurable vital signs. Her care plan and orders required staff to call 911 and start CPR and life-saving measures if she had no pulse or respirations, but the LPN and RN who assessed her did not initiate CPR, did not contact EMS, and did not verify her code status in the medical record at the time. The resident had not been checked for several hours overnight despite policies requiring at least q2h rounding for changes in condition. There was no documentation that she had been deceased for an extended period, no report of rigor mortis, and no evidence of any change in condition prior to being found unresponsive, resulting in a cited deficiency for failure to follow code status and emergency response 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 Verify and Honor DNR Status Before Initiating CPR
D
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with documented dementia, depression, coronary artery disease, and a clearly established DNR/DNI status on the care plan, orders, and MOLST was found unresponsive in the bathroom without pulse or respirations. An LPN, notified by a CNA, initiated CPR without checking the resident’s code status in the paper chart or EMR. When the RN supervisor arrived and asked about code status, the LPN incorrectly reported the resident as full code, and another RN assisted with chest compressions without verifying code status. Staff experienced confusion and delay locating the MOLST and paper chart, and EMS requested confirmation of the resident’s code status. The MOLST ultimately confirmed DNR/DNI, but CPR had already been performed until EMS consulted their provider and stopped the code, after which the resident was pronounced deceased.

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 Timely and Complete CPR to a Full Code Resident
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple cardiac and renal conditions and a documented Full Code status was found unresponsive and not breathing by a transportation aide, who immediately sought help from an LPN and the assigned RN. The LPN refused to assist, stating it was not their resident, and the RN twice delayed responding despite being told it was an emergency, leading to a reported five- to ten-minute delay before any nurse entered the room. An LPN from another unit eventually initiated chest compressions, and other nurses joined, but no artificial respirations were provided at any time, even though the resident was apneic and an Ambu bag was available. This response did not follow the facility’s CPR policy or AHA guidelines for trained healthcare providers, which require full BLS with both compressions and rescue breaths for a Full Code resident prior to EMS arrival, and the situation was cited as Immediate Jeopardy with actual serious harm and subsequent death.

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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