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

Invalid DNRO Led to CPR Against Resident’s Stated DNR Wishes

Vivo Healthcare West OrangeOcoee, Florida Survey Completed on 03-05-2026

Summary

The deficiency involves the facility’s failure to ensure a resident’s Do Not Resuscitate (DNR) wishes were honored due to an invalid Florida Do Not Resuscitate Order (DNRO) form being provided to Emergency Medical Services (EMS). The resident, an elderly male with a history of stroke, type 2 diabetes, heart failure, HIV, coronary artery disease, renal insufficiency, and non-Alzheimer’s dementia, was admitted with a documented DNR order in the electronic medical record (EMR). A hospital transfer form indicated he was alert but disoriented, required a surrogate for decision making, and was a DNR. The EMR contained a Florida DNRO form dated and signed only by the hospital physician, with no signatures from the resident or an authorized representative, and no power of attorney, health care surrogate, or proxy documents were scanned into the EMR. On the morning of the incident, a CNA found the resident unresponsive at approximately 5:45 AM and notified the assigned RN. The RN assessed the resident, was unable to obtain a blood pressure, pulse, or respirations, and left the room to verify the code status in the EMR, which confirmed the resident was a DNR. Despite this, the RN called EMS and documented that she could not obtain vital signs. She later stated she thought she saw the resident take small breaths and called EMS based on a prior company policy, but could not explain the discrepancy between her observation and her documentation that respirations were absent. When EMS arrived, the RN showed them the DNR order in the EMR, and EMS requested a physical copy of the Florida DNRO form. The RN was unable to locate a paper DNRO form and instead printed the scanned hospital DNRO onto goldenrod paper. EMS determined the form was invalid because it lacked the signature of the resident or his authorized representative and therefore initiated CPR. EMS performed three rounds of CPR before discontinuing efforts and pronouncing the resident deceased at 6:40 AM. Interviews with the resident’s daughter confirmed she was his health care proxy, that she had informed facility staff of his wish to be a DNR, and that she was later told EMS performed CPR because the Florida DNRO form had not been signed. The Social Services Director and facility leadership acknowledged that staff had recognized the hospital DNRO form was incomplete prior to the event but failed to ensure a valid, signed Florida DNRO form was obtained and available, resulting in EMS performing CPR contrary to the resident’s documented DNR status. The facility’s policies for CPR and documentation required adherence to residents’ advance directives and accurate, complete documentation in the medical record. Staff interviews and the facility’s internal investigation confirmed that although the DNR order was present in the EMR and the need for a surrogate and DNR status had been identified, the Florida DNRO form remained incomplete and unsigned by the resident or his proxy at the time of the emergency. During the emergency response, the absence of a valid DNRO form led EMS to determine that CPR must be initiated. This sequence of actions and inactions—failure to complete and validate the DNRO form, lack of proper documentation of the proxy’s authorization on the DNRO, and reliance on an invalid hospital DNRO—resulted in the resident receiving CPR against his stated wishes.

Removal Plan

  • Initiated an internal investigation including resident record review and staff interviews; notified the Department of Children and Families, the Florida Agency for Health Care Administration, and local law enforcement; validated notification of the attending physician/medical director and the resident’s responsible party regarding the event.
  • Conducted a 100% audit of all current residents’ code status and care plans; verified the presence of a valid Florida DNRO form for each applicable resident in the EMR.
  • Conducted code blue drills across all shifts.
  • Implemented Emergency Response Binders containing the Florida DNRO form for applicable residents, a facility Florida DNRO verification checklist, and a code status reference guide for staff; placed binders at each nurses’ station, the rehabilitation department, and the social services office.
  • Provided education to licensed nurses, the Social Services Director, and the Admissions Coordinator on the location of goldenrod (yellow) paper for printing Florida DNRO forms.
  • Educated staff that CPR must be initiated by EMS unless a valid Florida DNRO form is physically available.
  • Established designated locations for goldenrod (yellow) paper for Florida DNRO forms to prevent delays.
  • Held an Ad Hoc QAPI committee meeting to review education and audits.
  • Completed a 100% chart audit of advance directives including code status, DNR orders, and Florida DNRO forms.
  • Educated all licensed nurses on Resident Rights regarding Advance Directives; verification of code status and advance directives; DNR orders; Florida DNRO forms and requirements; CPR policy and EMS response requirements; communication of code status; location of goldenrod (yellow) paper for printing Florida DNRO forms; and complete and accurate documentation in the EMR; administered a post-test to ensure understanding.
  • Trained all licensed nurses and had them complete post-tests; continued education to include new employees.
  • Conducted Code Blue Drills with licensed nurses; scheduled remaining staff to complete a code blue drill upon return from leave.
  • Held Ad Hoc QAPI meetings and a Monthly QAPI meeting with Administrator, Director of Nursing, Medical Director, and administrative staff to review and revise education, audits, code blue drills, and post-tests as indicated.
  • Conducted staff interviews across all shifts to validate knowledge of advance directives, code status verification, Florida DNRO form completion, and location of Emergency Response Binders; validated education, audits, and code blue drill participation through interviews and review of attendance sheets and post-tests.

Penalty

Inspection fine: $26,130
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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
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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
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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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