Misappropriation of Controlled Pain Medication Due to Inadequate Delivery and Storage Controls
Summary
The deficiency involves the facility’s failure to fully implement its own policies for the delivery, receipt, and secure storage of controlled medications, resulting in the misappropriation of 120 hydrocodone-acetaminophen tablets prescribed for Resident #51. Resident #51 was originally admitted on 8/6/2024 with diagnoses including colon cancer and had a physician’s order for hydrocodone-acetaminophen 10-325 mg, one tablet three times daily. A Minimum Data Set dated 10/24/2025 documented a BIMS score of 9/15, indicating severe cognitive impairment. On 9/19/2025, during a routine medication pass, nursing staff discovered that the resident’s scheduled narcotic pain medication was missing when they attempted to obtain it from the StatSafe and were informed by the pharmacy that the facility should already have 120 tablets on hand. The facility’s internal investigation determined that the hydrocodone tablets for Resident #51 had not been administered, destroyed, or documented as wasted and were unaccounted for. Review of proof-of-use sheets, shift counts, and chain of custody records showed no documentation explaining the disposition of the medication. A nurse was identified as potentially involved in the missing medication based on the chain of custody review, and that nurse was no longer employed at the facility as of 9/14/2025. The incident was reported as misappropriation of 120 narcotic pain medications for Resident #51. Interviews and observations revealed that, at the time of the incident, pharmacy medications, including controlled substances, were delivered to the facility in regular cardboard boxes sealed with standard packaging tape, without locks or tamper-evident features. Nurses reported that these boxes were often left unattended in the front office among other facility and resident packages, and a nurse would have to search through multiple boxes to locate the pharmacy shipment. A single nurse would open the box, check inventory, and fill the medication cart with routine medications, and later call another nurse to sign off on the narcotic inventory sheet, even though the box itself could be easily opened and re-taped, including from the bottom. Staff interviews indicated that there was no clear, written procedure in the facility’s Pharmacy Services or Medication Storage policies describing who was responsible for receiving delivered medications, checking the box for tampering, or ensuring secure handling upon delivery. Policy review confirmed that, although the policies addressed storage and reconciliation of controlled substances, they did not address the actual delivery process or current courier methods, contributing to the conditions under which the controlled medications for Resident #51 were misappropriated. Additional staff interviews further supported that the delivery process lacked defined safeguards. RN B and RN C both described that pharmacy boxes arrived via UPS or FedEx, were not locked, and could be opened and re-taped without detection. They acknowledged that, even after the missing narcotic incident, pharmacy boxes sometimes continued to be retrieved from the front office among other packages, and there was uncertainty about who was responsible for inspecting boxes for signs of tampering. Observation of a pharmacy-labeled box delivered by UPS showed it to be a standard cardboard box with packaging tape and no locking or tamper-proof features. The Assistant DON confirmed that the facility’s policies did not specify the current procedures for receiving medications, did not address how medications were delivered, and did not identify who was responsible for checking in delivered medications or inspecting for tampering, which were key process gaps associated with the misappropriation of Resident #51’s controlled medication supply.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Surveyors found loose pills in drawers on two medication carts, indicating medications were not stored in their original packaging or assigned resident-specific areas as required by facility policy. On one cart, two loose tablets later identified as Carbidopa-Levodopa and Zofran were discovered with a medication aide who stated she was responsible for checking the cart at the start of her shift. On the second cart, four loose tablets identified as Allopurinol, Metoprolol, Lasix, and Amlodipine were found with another medication aide, who also reported routinely checking the cart for cleanliness and loose medications. The DON and ADM both reported they were unaware of the loose medications and stated that medication aides, nurses, and charge nurses were responsible for proper medication storage, monitored through administrative and pharmacy cart audits.
Surveyors found that the facility failed to follow its own medication storage policy when medicated ointments and solutions were left unsecured in several resident rooms. A resident with heart failure had Diclofenac ointment on the sink, another resident with bladder cancer had Ciclopirox topical solution on the nightstand, and a severely cognitively impaired resident with a history of cerebral infarction had hydrophilic wound dressing stored in a bedside basket on multiple observations. Staff, including an LPN, a wound care nurse, and the ADON, stated that medications and ointments were supposed to be kept on locked carts and not at the bedside, and that residents were not permitted to keep medications in their rooms, demonstrating noncompliance with the facility’s written storage policy and federal requirements.
Medication cart security was not maintained for Cart 700. Facility policy required the cart to be locked when out of the medication nurse’s sight, but an RN walked away from the cart and later entered a resident room while leaving it unlocked and unattended. The RN confirmed the cart should have been locked, and the President of Clinical Operations confirmed carts should be locked when unattended.
Insulin Storage and Labeling Deficiency: The short hall med cart contained multiple insulin items that were not properly dated, including an open Lantus vial, an unopened Novolin vial, a Lantus pen, and a Novolog pen. The ADON said insulin containers should be dated for 28 days when removed from refrigeration and opened, but she was unsure when the items were taken out. The DON also confirmed insulin should be labeled with the expiration date when removed from the refrigerator, and the facility policy required pens to be dated when placed into use.
Loose medications were found in 2 of 8 observed med carts, including five loose pills in one cart, one loose pill in another, and one loose blue pill in a third cart. A bottle of Active Liquid Protein also lacked an open date. Staff interviews confirmed that carts are checked by nurses, unit managers, DON, and pharmacy, and the facility policy requires the date opened to be recorded on multi-dose containers.
Unlocked treatment cart and improper medication storage were observed in multiple areas. An unlocked, unattended treatment cart was found in a hallway, and the East Medication Room contained personal items mixed with medication supplies. Opened Tubersol vials in two refrigerators and multiple opened meds in the A Hall and C Hall medication carts were not dated, and an LPN confirmed several of the findings.
Loose Medications Found on Two Medication Carts
Penalty
Summary
The deficiency involves the facility’s failure to ensure that drugs and biologicals were stored properly on two medication carts. During an observation of the Station 1 medication cart with a medication aide, surveyors found two loose pills in a drawer. The medication aide acknowledged that the cart should not contain loose pills and stated she was responsible for the cart once she received the keys, usually checking it at the beginning of her shift for loose or expired medications and cleaning it prior to medication pass. The Director of Nursing (DON) later identified the loose pills as Carbidopa-Levodopa 25-100 and Zofran 4 mg. The facility’s policy on Medication Labeling and Storage, revised February 2023, states that medications and biologicals are to be stored in the packaging or dispensing systems in which they are received, and that medications are to be stored in an orderly manner with each resident’s medications assigned to an individual cubicle or drawer to prevent mixing. A similar issue was identified on the Station 2 medication cart, where four loose pills were found in the drawers during an observation with another medication aide. The DON identified these pills as Allopurinol 100 mg, Metoprolol 25 mg, Lasix 20 mg, and Amlodipine 5 mg. The second medication aide also stated that the cart should not contain loose pills and that she was responsible for checking the cart for cleanliness and loose medications at the beginning of each shift. In interviews, the DON and the Administrator both stated they were not aware that there were loose medications on the carts, and each indicated that medication aides and nurses or the charge nurse were responsible for proper storage of medications on the carts. Both referenced that nursing administration and the pharmacy consultant conducted periodic or monthly cart audits, and the DON and Administrator described potential negative outcomes such as residents missing medications or inventory control issues. These findings demonstrate that medications were not consistently stored in accordance with the facility’s policy and accepted professional principles.
Unsecured Medicated Ointments and Solutions Left in Resident Rooms
Penalty
Summary
Surveyors identified a deficiency in the facility’s labeling and storage of drugs and biologicals when medicated ointments and solutions were found unsecured in multiple resident rooms on the second floor. During observation, a container of Diclofenac ointment was seen on top of the sink in one resident’s room, and a container of Ciclopirox topical solution was observed on another resident’s nightstand. Both of these residents’ clinical records showed they had no cognitive impairment, with diagnoses including heart failure for one resident and malignant neoplasm of overlapping sites of the bladder for the other. Additional observations showed a tube of hydrophilic wound dressing stored in a basket on a different resident’s nightstand on two separate occasions. Clinical records for this resident indicated admission with a diagnosis of cerebral infarction due to embolism of the right middle cerebral artery and severe cognitive impairment. These findings conflicted with the facility’s written “Storage of Medications” policy, revised January 2026, which states that all drugs and biologicals are to be stored in locked compartments under proper environmental controls. Staff interviews confirmed that medications and ointments were expected to be kept on locked carts and not at the bedside, and that residents were not allowed to keep medications in their rooms, indicating that the observed bedside storage of medicated products did not comply with facility policy and regulatory requirements.
Plan Of Correction
The facility continues to ensure that all drugs and biologicals are stored appropriately. IMMEDIATE CORRECTIVE ACTION Medications were immediately removed from room for residents #58, #20, and #29 on 5/11/26. Residents #58, #20, and #29 were not adversely affected by alleged deficient practice. IDENTIFICATION OF OTHER RESIDENTS HAVING POTENTIAL TO BE AFFECTED All active residents in the facility can potentially be affected by the alleged deficient practice. No residents were adversely affected by the alleged deficient practice. Director of Nursing and/or designee conducted a facility-wide observation audit to ensure that drugs and biologicals are stored appropriately on 05/12/2026. SYSTEMATIC CHANGES The Director of Nursing and/or designee initiated ongoing in-service education with staff on standards. of drug and biological storage on 05/20/2026. MONITORING Nursing Supervisor and/or designee will conduct random observation audits to ensure drugs and biologicals are stored appropriately, 5 days a week for 1 month, then weekly for 3 months. The Director of Nursing and/or designee will report findings of observation/audits to the quality assurance committee monthly for 4 months to ensure continued substantial compliance.
Medication Cart Left Unlocked and Unattended
Penalty
Summary
The facility failed to ensure medications were securely stored in 1 medication cart, Cart 700, out of 3 medication carts reviewed. The facility policy titled, Medication Administration General Guidelines, dated 9/18, stated that during medication administration, the medication cart is to be kept closed and locked when out of sight of the medication nurse. During observation on 5/12/2026 at 7:40 AM, RN A walked away from Cart 700, leaving the cart unlocked and unattended. During another observation on 5/12/2026 at 8:01 AM, RN A entered room [ROOM NUMBER] and again left the medication cart unlocked and unattended. RN A later confirmed she should have locked the medication cart when it was left unattended, and the [NAME] President of Clinical Operations confirmed the medication carts should be locked when left unattended.
Insulin Storage and Labeling Deficiency
Penalty
Summary
The facility failed to ensure drugs and biologicals used in the facility were labeled in accordance with currently accepted professional principles, including the expiration date for 1 of 2 medication carts reviewed for medication storage. During an observation and interview with the ADON, the short hall medication cart was found to contain a Novolog insulin pen dated [DATE], an open Lantus insulin vial that was undated, an unopened Novolin insulin vial in the manufacturer’s box that was undated, a Lantus insulin pen that was undated, and a Novolog insulin pen that was undated. The ADON stated that all insulin containers should be dated for 28 days when removed from the refrigerator and opened, and she was unsure when the five insulin containers had been removed from the refrigerator. The ADON said it was the nurse’s responsibility to maintain the contents of the carts and that the nurse responsible for the cart had left work early. She was unsure whether the date on the Novolog pen was the expiration date or the date the pen was opened. In an interview with the DON, she stated that all insulin containers should be labeled with the expiration date by the nurse as soon as they are removed from the refrigerator, and she was unsure why the cart contained inaccurately labeled insulin pens and vials. The facility policy titled Insulin Pen Use stated that once an insulin pen is taken out of cool storage, it can be used for up to 28 days and must be dated when placed into use.
Loose medications and missing open date in medication carts
Penalty
Summary
The facility failed to ensure drugs and biologicals used in the facility were labeled and stored in accordance with accepted professional principles for 2 of 8 medication carts observed. During observation on 05/07/2026, RN B’s medication cart contained five loose pills, and RN A’s medication cart contained one loose pill. LVN D’s medication cart also contained one loose, small round blue pill, and a bottle of Active Liquid Protein did not have an open date written on it. Staff interviews confirmed that loose medications were found in the carts and that the open date was not documented on the liquid protein container. During interviews, RN B stated nurses, unit managers, the DON, and pharmacy check medication carts, and that pharmacy checks them monthly. RN A stated loose pills in the medication cart could cause confusion. LVN D stated staff would not be able to identify a medication if it was loose in the cart and reported loose pills were disposed of in the pill incinerator. The DON stated nurses should clean their medication carts after each shift and that staff are expected to write the open date on medications, while the ADM stated staff should check their medication carts to ensure there are no loose pills. The facility policy stated the expiration or beyond-use date is checked before administering medications and that when opening a multi-dose container, the date opened is recorded on the container.
Unlocked Treatment Cart and Improper Medication Storage
Penalty
Summary
The facility failed to properly secure a treatment cart while it was not in use and failed to properly store medications in the East Medication Room, the A Hall Medication Cart, and the C Hall Medication Cart. Facility policies reviewed indicated medication carts are to be kept closed and locked when out of sight of the medication nurse, and compartments containing drugs and biologicals are to be locked when not in use. The policy also stated that when opening a multi-dose container, the date opened shall be recorded on the container. During an observation on the East side, the treatment cart was found in the hallway near a room, unlocked and unattended. An LPN confirmed the cart had been left unlocked and unattended. In the East Medication Room, surveyors observed personal items and clothing stored with medication-related supplies, including cups, a tote bag, sweaters, pants, blankets, wheelchair cushions, and leg rest bags. The East first hall and second hall refrigerators each contained two opened vials of Tubersol solution that were not labeled with a date. In the A Hall Medication Cart, surveyors observed opened Nystatin liquid, Latanoprost eye drops, and a Trelegy Ellipta inhaler that were not dated, along with a coffee cup, pastry, sliced red peppers, and a personal cell phone in the cart compartment; an LPN confirmed the items belonged to her. In the C Hall Medication Cart, surveyors observed opened Robitussin cough suppressant, Milk of Magnesia, Miralax powder, and lactulose liquid that were not labeled with a date, and an LPN confirmed the findings.
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