Failure to Follow Anticoagulation Orders and INR Monitoring
Summary
The deficiency involves the facility’s failure to ensure that a resident on anticoagulation therapy received necessary treatment and care in accordance with professional standards, including ordered monitoring, medication administration, and accurate documentation. The resident was admitted with a history of valve replacement and was prescribed a specific anticoagulant dosage regimen and associated lab monitoring (INR and CMP) beginning on designated dates. Initial INR labs were reported as invalid, and subsequent orders included holding the anticoagulant pending INR results, then resuming at adjusted doses based on those results. The MAR shows nurses initialed doses of 2.5 mg and 5 mg as administered on multiple days. Documentation reflects that on one date the resident’s INR was 3.38 and on a later date the INR was 9.12, yet the 5 mg dose was still administered despite the elevated INR, and there is no evidence that the physician was contacted at those times for guidance regarding whether to administer the medication. When the resident’s INR later reached a critically elevated level of 17.63, the physician ordered vitamin K 10 mg injection and daily INR labs for two days. Review of lab results and records shows no evidence that these ordered labs were drawn on the specified days, nor that staff followed up with the lab to ensure the orders were carried out; labs were not completed until several days later. By that time, the resident had a documented change in condition, becoming nonresponsive and not eating, which led to additional interventions and eventual transfer to the hospital. The DON confirmed that the ordered labs were not drawn on the specified days, that there was no evidence nurses contacted the physician before administering the anticoagulant when the INR was elevated, and that pharmacy records showed 20 of 21 dispensed 5 mg tablets were returned upon discharge despite MAR entries indicating four doses had been given. The DON also reported that no tablets were removed from the emergency drug kit and that the facility had not had any residents on this medication in over a year.
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. As of [R] , there are no residents on [R] . No additional residents were identified as negatively [R] . (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 verification of current physician orders, review of INR results and therapeutic ranges, confirmation of timely laboratory draws, and verification of appropriate medication and documentation. At the time of 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 of orders. (3) What measures will be put into place or what systematic changes you will make to ensure A. By [R] , License Nursing staff will have been educated by the Director of Nursing/Designee on the components of N0201, including the use of the [R] management protocol, documentation of indication and monitoring, appropriate response to laboratory results, and timely physician notification, with an emphasis on avoidance of unnecessary drugs and compliance with monitoring requirements for [R] B. Newly hired license nursing staff will receive education by the Director of Nursing/Designee on the components of N0201, including the use of the [R] management protocol, documentation standards, critical lab value reporting and escalation processes, and physician communication expectations during orientation as part of the facility's systematic changes. (4) How the corrective action(s) will be monitored to ensure the practice will not recur, ie., what quality assurance program will be put in place: A. The Director of Nursing/designee will conduct [R] monitoring audits weekly for 4 weeks, then biweekly for 4 weeks, and monthly x 1 month. Audits will review appropriate drug use, compliance with laboratory monitoring, timely physician notification, and accuracy of documentation. 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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