Failure to Follow Anticoagulant Orders and Accurate Medication Administration Practices
Summary
The deficiency involves failure to follow physician orders and accepted standards of practice for anticoagulant management and medication administration documentation for two residents. One resident was admitted with a history that included valve replacement and was prescribed an anticoagulant 5 mg by mouth every other day, with INR labs to be drawn. A subsequent physician order directed that the anticoagulant be held pending INR results, and later an order was given for the resident to receive 5 mg daily and to resume the medication. The MAR showed nurses initialed administration of 2.5 mg on one date and 5 mg on three dates, even though the physician’s order indicated the 5 mg dose was on hold on two of those dates. Nursing documentation reflected elevated INRs of 3.38 and then 9.12, yet the 5 mg dose was still administered when the INR was 9.12, and there was no evidence that the physician was contacted for guidance when the INRs were elevated. Further review of lab results for this resident showed critically elevated coagulation values, including a prothrombin time of 94.9 seconds with an INR of 9.12, and later a prothrombin time of 180 seconds with an INR of 17.63. When the INR was critically elevated at 17.63, the physician ordered vitamin K 10 mg injection and INR labs to be drawn for two days. The record did not show that these ordered labs were drawn as prescribed, nor that staff followed up with the lab to ensure completion; the labs were not completed until a later date, by which time the resident’s condition had changed and deteriorated, requiring transfer to the hospital for further evaluation. Pharmacy dispensing records showed that 21 tablets of the 5 mg anticoagulant were dispensed and 20 tablets were returned at discharge, while the MAR contained four documented doses, raising questions about whether the medication was actually administered as charted. The DON confirmed that the ordered labs were not drawn on the specified days and that there was no evidence nurses contacted the physician before administering the anticoagulant when the INR was elevated. A second deficiency involved inaccurate medication administration and documentation for another resident. During an observed medication pass, a licensed nurse prepared and administered six oral medications, which were verified by the surveyor, and confirmed that no additional medications were to be given at that time other than an insulin dose that was held due to a blood glucose of 109. However, on the MAR, the nurse documented that she had also administered polyethylene glycol 3350 powder, 17 g by mouth twice daily for constipation, even though this medication had not been given during the observed pass. When questioned, the nurse acknowledged she had not administered the polyethylene glycol but had signed for it, then searched the medication cart, found none available, went to the supply room to retrieve a bottle, and subsequently administered the dose. She stated she must have retrieved the medication from another cart previously, despite its absence on the current cart at the time of the observation.
Plan Of Correction
Preparation and/or execution of this plan does not constitute admission or agreement by the provider of the truth of the facts alleged or conclusions set forth in the Statement of Deficiencies. This plan of correction is prepared and/or executed solely because it is required. (1) What corrective action(s) will be accomplished for those residents found to have been affected by the deficient practice? A. On [R] resident #1 was discharged from facility to Lawnwood Regional Medical Center. B. On [R] Physician was notified of prior events and current conditions for resident discharged to Lawnwood Regional Medical Center on [R]. No additional residents were affected at this time. C. On [R], comprehensive medication and lab review for resident #1 was completed to ensure all physician orders are current and being followed; resident transferred to hospital prior to additional interventions being implemented. D. As of [R], the licensed nursing staff identified in the deficient practice are no longer employed by the facility. (2) How you will identify other residents having potential to be affected by the same practice and what corrective actions will be taken: A. On [R], the Director of Nursing/Designee identified and reviewed current residents receiving [R]. The review included [R] verification of current physician orders, review of [R]/INR results and therapeutic ranges, confirmation of timely laboratory draws, and verification of appropriate medication and documentation. At the time of the review, there were no residents in the facility receiving [R]/ however, all other [R] therapies were reviewed. Any discrepancies identified during the review were immediately corrected, including physician notification and clarification orders. (3) What measures will be put into place or what systematic changes you will make to ensure A. By [R], the facility implemented system changes, including the establishment of an [R] Management Protocol outlining INR critical value parameters, required interventions for elevated INR levels, and mandatory physician notification guidelines. A Lab Tracking Log was also implemented to ensure all ordered laboratory tests are completed as scheduled, reviewed in a timely manner, and escalated appropriately when not obtained. In addition, High-Risk Medication Audits Tool for [R] was put into place to monitor compliance and medication safety practices. Education was completed with licensed nursing staff regarding the administration, monitoring, management of [R]/ including therapeutic INR ranges, timely physician notification, documentation requirements, and appropriate interventions for abnormal lab values. B. By [R], Licensed Nursing Staff will have been educated by Director of Nursing/Designee on the components of N0054 with an emphasis on medication administration safety, documentation accuracy, and appropriate clinical decision-making and escalation protocols. C. Newly hired licensed nursing staff will receive education by the Director of Clinical/Designed on the components of N0054 with an emphasis on medication administration safety, documentation accuracy, and appropriate clinical decision-making and escalation protocols. (4) How the corrective action(s) will be monitored to ensure the practice will not recur, i.e., what quality assurance program will be put in place: (A) The Director of Nursing/Designee will conduct audits on 5 residents on [R] weekly x 4 weeks, then biweekly x 4 weeks, then monthly x 1 month. Audits will include medication administration accuracy, lab completion and follow up, physician notification compliance. The findings of these quality monitoring's to be reported to the quality Assurance/Performance Improvement Committee monthly until the committee determines substantial compliance has been met.
Penalty
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