Inaccurate and Incomplete Documentation of Controlled Substances on MARs and Narcotic Records
Summary
The deficiency involves the facility’s failure to maintain complete and accurate medical records, specifically related to documentation of controlled substance administration on Medication Administration Records (MARs) and Accountability Records (ARs)/Controlled Substance Inventory Records (CSIRs). Facility pharmacy policies required that the individual administering a medication immediately document the dose on the MAR after administration and, for controlled substances, also record the date and time, amount administered, remaining quantity, and initials on the AR, completed after the medication was actually given. Pharmacy audits and record reviews showed repeated discrepancies where narcotic doses were signed out or removed on ARs/CSIRs but not documented as administered on the corresponding MARs, and in one case, MAR documentation of narcotic administration was inconsistent with a negative urine opiate screen. For one resident with Alzheimer’s disease, dementia, and Parkinson’s disease who was cognitively intact per a BIMS score of 14, the pharmacy’s PRN controlled substance audits showed multiple dates on which Norco 5-325 mg doses were documented as removed on the AR, but there was no corresponding documentation of administration on the MAR. These undocumented MAR entries occurred on several consecutive days, indicating that either the administration was not recorded as required or the medication was removed without proper MAR documentation. Another resident with osteomyelitis, Alzheimer’s disease, and dementia, assessed with severe cognitive impairment (BIMS score of 5), had numerous hydrocodone-APAP 5-325 mg doses documented as removed on the AR across multiple dates, yet none of these doses were documented on the corresponding MAR. A third resident admitted with a right femur fracture and additional diagnoses including dementia, hypertension, and anxiety disorder, and assessed with severe cognitive impairment (BIMS score of 6), had MAR entries showing oxycodone-acetaminophen 5-325 mg administered twice daily over several days. However, a urine opiate screen obtained during that period was negative, with a normal reference range of negative, indicating the resident had not received the narcotic pain medication as documented on the MAR for those days. For another resident with mild dementia, a displaced left femur fracture, Type 2 diabetes, and chronic pain, the CSIR for oxycodone 5 mg showed four doses removed during a specified period that were not documented as administered on the MAR. Additional review showed doses removed from stock that were documented on the MAR only later, sometimes hours after removal, and some removed doses were never documented as administered on the MAR. For a fifth resident with an unspecified displaced fracture of the right humerus, unspecified dementia, and hypertensive chronic kidney disease, and who was cognitively intact with a BIMS score of 14, the pharmacy’s PRN controlled substance audit showed multiple Norco 5 mg doses documented as removed on the AR on different dates without corresponding documentation on the MAR. Staff interviews confirmed that facility practice and expectation were that narcotic medications must be signed out on both the narc sheet (AR) and the MAR, and that discrepancies in narcotic counts should be reported to the ADON or DON. The pharmacist reported that PRN and periodic audits comparing narcotic sign-outs to MAR documentation revealed poor documentation, and that these concerns had been shared with the DON. The staff educator was unsure whether anyone specifically educated new hires on MAR documentation or whether chart audits were performed, and the DON acknowledged being made aware of documentation concerns by the pharmacist but stated she had not seen inconsistencies and that the pharmacist’s concerns were not brought to the QAPI committee. The administrator stated she was unaware of the pharmacist’s concern and would have considered inconsistencies between AR and MAR to be medication errors.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
A resident with a Stage 4 pressure ulcer and a physician’s order for Tramadol 50 mg to be given on the day shift 30 minutes before wound care had multiple missing and unexplained entries on the MAR, even though the Treatment Record showed that wound care was performed daily. On several days, there were no nurse signatures for the ordered Tramadol, and on other days the MAR was marked as “out of parameters” without any supporting progress notes. The wound care nurse reported relying on the MAR to confirm that pain medication was given before she performed wound care, and the DON stated that nurses are expected to follow physician orders and document refusals, but the record did not contain adequate documentation to demonstrate proper administration or explanation of the ordered pain medication.
Incomplete and inaccurate resident clinical records: The facility’s EMR did not accurately reflect one resident’s active psych diagnoses, with schizophrenia/bipolar history and schizoaffective disorder not carried through the MDS, care plan, diagnosis tab, or PL 1 screening. For another resident, the chart lacked a valid resident-signed MPOA and physician certification of incompetence, the admission agreement was signed by family and BOM only, and staff did not document the resident’s behaviors and statements despite noting she could express her needs and wanted to go home.
Inaccurate Meal Intake Documentation: A resident with DM, dysphagia, and protein-calorie malnutrition was observed eating less than 25% of a meal, but the POC documented 76-100% intake. The CNA said the resident usually ate only 25-50% of meals and that intake was sometimes documented based on what a coworker reported. The LPN/RCM and DON stated meal intake should be documented accurately.
A resident with intact cognition and diagnoses including CHF, COPD, respiratory failure with hypoxia, O2 dependence, sleep apnea, and A-fib had inconsistent documentation about the ability to self-administer nebulizer treatments. The MAR stated the resident could self-administer meds and nebulizers after set-up, but a self-administration assessment found the resident was not safe to self-administer inhalants without supervision. Surveyors also observed a handheld nebulizer still connected with medication remaining in the cup, while the MAR showed the treatment as completed and signed off by an RN.
The facility failed to accurately document PRN opioid pain medication administration on the MAR for four residents, despite corresponding removals recorded on controlled substance declining count sheets. On multiple occasions, an RN removed Oxycodone or Hydrocodone/Acetaminophen for pain from the controlled drug supply but did not chart the administrations on the MAR. In an interview, the RN reported relying on her own system, administering medications without checking the order and then failing to return to sign the MAR due to being busy and forgetting. The prior DON and current DON both stated they expect nursing staff to document pain medications on the MAR, and the NP reported she depends on MAR entries to evaluate residents’ responses to PRN pain treatment.
A resident with emphysema, muscle weakness, and a need for assistance with personal care had multiple scheduled medications that were not documented as administered on the MAR over two consecutive days. The MAR entries for midday and bedtime medications on one day and early morning medications on the following day were left blank, with no codes or notations indicating why the medications were not given. The DON later confirmed the resident was in the hospital during this period and stated that nursing staff should have documented this on the MAR and that there should never be blanks on the MAR, resulting in an incomplete and inaccurate medical record.
Incomplete Documentation of Ordered Pain Medication Prior to Wound Care
Penalty
Summary
Surveyors identified a deficiency in the facility’s maintenance of complete and accurately documented medical records related to pain medication administration prior to wound care for one resident with a pressure ulcer. The resident was admitted with diagnoses including peripheral vascular disease and had a care plan for a Stage 4 pressure ulcer that included administering medications and treatments as ordered. A significant change MDS indicated the resident had no cognitive impairment, required setup/cleanup assistance for eating and oral hygiene, had a Stage 4 pressure ulcer, received a scheduled pain medication regimen, and experienced moderate, occasional pain. A physician’s order dated 04/23/2026 directed that Tramadol 50 mg be given orally on the day shift for pain, 30 minutes before wound care. Review of the May 2026 Medication Administration Record (MAR) showed missing nurse signatures for the ordered Tramadol on multiple dates (05/02, 05/03, 05/09, and 05/10), despite the Treatment Record reflecting that wound care was performed daily on the day shift. On additional dates (05/04–05/06 and 05/11), the MAR entries for Tramadol were signed with code “4” indicating “out of parameters” by a registered nurse, but there were no associated progress notes explaining these entries. The wound care nurse reported that the resident had an order for Tramadol prior to wound care, that she performs wound care Monday through Friday, and that the floor nurse performs it on weekends, and she stated she checks the MAR to ensure the medication was given. The DON stated that nurses are to follow physician orders and document if a resident refuses medication. The facility’s pressure ulcer/skin breakdown protocol required pain assessment and documentation, but the medical record lacked adequate documentation to show that the ordered pain medication was administered or appropriately addressed on the identified dates.
Plan Of Correction
The facility continues to ensure that resident's medical records are complete and accurately documented. IMMEDIATE CORRECTIVE ACTION Resident #62 was assessed by Director of Nursing upon notification of surveyor and resident #62 did not have any adverse outcome related to the alleged deficient practice on 5/13/26. IDENTIFICATION OF OTHER RESIDENTS HAVING POTENTIAL TO BE AFFECTED All active residents in the facility can potentially be affected by the alleged deficient practice. Director of Nursing and/or designee conducted a comprehensive chart audit to ensure that residents with pain medications were accurately documented on EMAR on 5/15/26. No residents were adversely affected by the alleged deficient practice. SYSTEMATIC CHANGES The Director of Nursing and/or designee initiated ongoing in-service education with clinical staff on standards of accurate medication administration documentation with emphasis on accurate documentation of Pain Medication Refusal. MONITORING Nursing Supervisor and/or designee will conduct random observation and/or audits to ensure accurate documentation of pain medication administration and refusal, 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 is achieved and maintained.
Incomplete and inaccurate resident clinical records
Penalty
Summary
The facility failed to maintain complete and accurate medical records for two residents. For one resident, the record contained diagnoses of major depressive disorder and schizoaffective disorder, while the admission MDS reflected depression and a history of schizophrenia and bipolar disorder that were not documented as active diagnoses. The care plan did not include bipolar disorder or schizoaffective disorder, the EMR diagnosis tab did not show bipolar disorder, the PL 1 Screening was coded No for Mental Illness despite documentation that the resident had a mental illness, and the EMR did not show submission of Form 1012. A psychiatry evaluation later documented a history of schizophrenia and bipolar disorder, described as schizoaffective disorder, depressive type, per hospital records and collateral review. For the second resident, the EMR did not contain a valid MPOA signed by the resident, and the admission agreement was signed only by the family member and the business office manager. The MPOA document in the record showed the signature acknowledged before a notary was that of the family member, not the resident. The EMR also did not contain physician certification that the resident lacked competence to make health care decisions, and it did not contain documentation signed by the resident authorizing the family member as legal guardian or agent under a medical power of attorney. Staff interviews confirmed that the resident could express needs and wants, and multiple staff members stated the MPOA was not valid because it was not signed by the resident. The record also did not include progress notes documenting the resident’s behaviors and statements while at the facility. An administrator note documented a discharge dispute involving the resident, the family member, and another family member, including the resident insisting on going home and law enforcement being called. Interviews with the Activities Director, LVN, ADON, MDS Coordinator, BOM, and Administrator reflected that the resident participated in activities, verbalized needs and wants, and discussed wanting to return home, but staff did not recall whether these statements were documented in the EMR. The facility policy stated that documentation must be complete, accurate, timely, and properly signed, and that active diagnoses and required forms should be placed in the clinical record.
Inaccurate Meal Intake Documentation
Penalty
Summary
The facility failed to accurately document the amount of food eaten for Resident 13, who was admitted with diagnoses including diabetes mellitus, dysphagia, and protein-calorie malnutrition. The quarterly MDS dated 02/12/2026 showed the resident was moderately cognitively impaired. During observation on 05/05/2026 at 12:09 PM, a meal tray was delivered to the resident’s room, set up on a bedside table, and the resident was observed eating slowly, eating less than 25% of the meal, then laying back in bed and closing their eyes while the tray remained in the room. Staff later removed the tray, but the POC documentation for lunch on 05/05/2026 recorded that Resident 13 ate 76-100% of the meal. During interview, the CNA stated the resident typically ate 25-50% of meals and never ate all of the food, and that if they did not pick up a tray they would ask a coworker what the resident ate before documenting it. The CNA stated they were told the resident ate 75-100% of lunch, so that is what was entered. The LPN/RCM stated staff should document meal intake accurately in POC, and the RN/DNS stated it was their expectation that all staff document meal intake accurately.
Inconsistent documentation of self-administration status for nebulizer treatments
Penalty
Summary
The facility failed to ensure documentation of one sampled resident’s ability to self-administer medication was consistent and accurate throughout the medical record. The resident’s quarterly MDS, accepted on 4/6/26, identified intact cognition and multiple diagnoses including heart failure, COPD, respiratory failure with hypoxia, dependence on supplemental oxygen, sleep apnea, and atrial fibrillation. The resident required moderate assistance from one staff member for transfers, dressing, and hygiene. On 5/4/26 at 5:30 p.m., surveyors observed a handheld nebulizer in the resident’s room still connected to the nebulizer machine, with approximately half of the medication remaining in the cup, while the resident was not present. The May 2026 MAR documented that the resident received an ipratropium/albuterol nebulizer treatment at 2:00 p.m. and that RN-B signed off the treatment as completed. The MAR also stated the resident was able to self-administer oral medications and nebulizers after set-up. However, the resident’s 4/13/26 self-administration assessment completed by RN Consultant-B stated the resident was not capable of self-administering inhalants or using inhalers without supervision and was not safe to self-administer at that time. During interview, RN Consultant-B acknowledged the assessment was accurate and agreed he did not update the MAR to show the resident was no longer safe to self-administer nebulizer treatments. The interim DON stated it was her expectation that the MAR be updated immediately following the change with re-assessment.
Failure to Accurately Document PRN Controlled Substances on MAR
Penalty
Summary
The deficiency involves the facility’s failure to accurately document the administration of controlled substances on the Medication Administration Record (MAR) for four residents, despite corresponding entries on the controlled substance declining count sheets. For one resident with an order for PRN Oxycodone 5 mg every 8 hours, Nurse #1 repeatedly documented removal of tablets on the declining count sheet on multiple dates and times, but did not document administration on the MAR for those same dates and times. A second resident with an order for PRN Hydrocodone/Acetaminophen 5 mg/325 mg every 6 hours had doses removed per the declining count sheet on two occasions, yet Nurse #1 did not record those administrations on the MAR. A third resident with PRN Oxycodone 5 mg orders (first every 4 hours for up to 7 days, then every 6 hours) had doses removed on two separate days at 8:00 AM and 12:00 PM, but again, Nurse #1 failed to document these administrations on the MAR. A fourth resident with an order for PRN Oxycodone 5 mg every 6 hours for 3 days had a dose removed per the declining count sheet, but there was no corresponding documentation on the MAR for that date. In a phone interview, Nurse #1 stated that her “system was not good,” that she knew which medications residents received and would administer them without looking at the order, and that she did not sign the MAR because she was too busy and forgot to return to complete the documentation. The previous DON stated she expected nursing staff to sign off on the MAR whenever administering pain medications and emphasized the importance of MAR documentation to determine if pain was being managed. The Nurse Practitioner reported that she relies on the MAR to assess residents’ responses to PRN pain medications, and the current DON stated she expected accurate documentation of pain medication administration on the MAR and identified that the nurse did not follow the medication administration process, which includes documentation.
Incomplete MAR Documentation for Hospitalized Resident
Penalty
Summary
The deficiency involves the facility’s failure to maintain a complete and accurately documented medical record for a resident, specifically on the medication administration record (MAR). Resident #11, admitted with emphysema, muscle weakness, and a need for assistance with personal care, had multiple scheduled medications that were not documented as administered on specific dates. On 4/16/26, the resident’s midday and bedtime medications were not recorded as given, and on 4/17/26, the early morning medications were not recorded as given. The MAR contained blank spaces with no code or notation explaining why the medications were not administered. During an interview on 4/30/26 at 4:52 PM, the DON stated that Resident #11 was in the hospital on 4/16 and 4/17 and that the nurses administering medications should have documented this on the MAR, adding that there should never be blanks on the MAR. This failure to document the reason for non-administration of medications on the MAR for Resident #11, who was hospitalized during the relevant time, resulted in an incomplete and inaccurate medical record, as identified through record review and staff interview.
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