Initial Comments:
A monitoring visit was conducted on December 9-10, 2024, to determine compliance with the Requirements of the 42 CFR Part 483, Subpart I Regulations for Intermediate Care Facilities. The census during the survey was 17 and the sample consisted of six individuals. Two deficiencies were cited.
Plan of Correction:
483.420(d)(3) STANDARD STAFF TREATMENT OF CLIENTS Name - Component - 00 The facility must have evidence that all alleged violations are thoroughly investigated.
Observations:
Based on documentation review, focused record review and staff interview, it was determined that the facility failed to ensure that all potential allegations of neglect were investigated. This was noted for the only two incidents of potential neglect reviewed. The findings included: A) An incident report, dated September 22, 2024, revealed that Individual #6 ' s mickey tube was dislodged during a transfer. Upon interview, the staff involved stated that she transferred Individual #6 by herself. A memo attached to the incident report reminded staff that individuals weighing over 50 pounds must be a two-person transfer, and also reminded staff to follow the individuals ' plan for transferring.
A focused review of Individual #6 ' s record revealed a physical therapy evaluation and examination, dated May 23, 2024. In a section of this document titled " Transfers " , it indicated the following: " sit to stand with hands held or support from behind. Two persons for all other lifts " . In addition, the section titled " Recommendations " indicated the following: " bring to a stand from her wheelchair with support; two person top/bottom " .
B) An incident report, dated October 18, 2024, revealed that Individual #6 was discovered by staff to have a swollen cheek and nursing was alerted for evaluation. Upon inspection, it was discovered that this individual had a small, thin, soft hair tie in her mouth. The nurse and staff used a bite block to remove the hair tie. Once it was removed, it was determined that it was still intact, and nothing had been ingested.
A focused review of Individual #6 ' s record revealed a behavior support plan (BSP), dated June 14, 2024, with the target behaviors of pica, attempted pica, successful pica, and evidence of pica. In a section of the BSP titled " Restrictive Procedure Implementation Plan " , it states the following: " Per OT evaluation, [Individual #6] may only wear large hair ties/scrunchie type ponytail holders (at least one inch in diameter and three inches long). Small elastic hair ties and hair ties with any embellishments (beads, sequins, ribbons) should not be worn. If [Individual #6] is observed to have such hair ties that do not comply with these recommendations, staff must remove it immediately and notify their supervisor. "
C) The facility administrator was interviewed on December 10, 2024, at 10:00 AM. The administrator confirmed that the above-mentioned incidents of an unauthorized transfer resulting in Individual #6 ' s Mickey tube becoming dislodged, and attempted pica, were not investigated by the facility.
Plan of Correction:Merakey Allegheny Valley School, 1291 Middletown Road, makes its best effort to operate in full compliance with both Federal and State Law. Nothing included in the Plan of Correction is an admission otherwise. Merakey Allegheny Valley School, 1291 Middletown Road has submitted this Plan of Correction to comply with its regulatory obligation and does not waive any objections to its merits or form any allegations contained herein. Please note that Merakey Allegheny Valley School, 1291 Middletown Road may contest the merits and/or form of any deficiency or finding alleged below and take reasonable steps to appeal them.
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Merakey Allegheny Valley School, 1291 Middletown Road will ensure that the facility has evidence that all alleged violations are thoroughly investigated.
Following recommendation, the Sr. Director immediately filed a suspected neglect report within the incident management reporting system for the affected, individual #6.
Re-training related to standardized process' involving incident reporting, required documentation and 5-day notification requirements will be presented to all supervisory staff to include the Director of Programs, Program Director, Program Managers, House Managers. In addition to re-training on the standardized process', supervisory staff will be trained on an additional documentation requirement to be included within the supervisors' preliminary findings. When completing the supervisors' preliminary findings, supervisory staff will be required to include an explanation to confirm that the findings do not meet the need to file an external report. Re-training will be completed by the Sr. Director or Designee by January 3rd, 2025. Additionally, Department Heads will be provided with re-training on the Office of Developmental Programs Bulletin related to Incident Management to include a review of reportable incidents. This re-training will be completed by the Sr. Director or Designee by January 3rd, 2025.
In order to monitor that the training was effective, the Sr. Director will continuously review internal incident reports ensuring that all alleged violations are reported appropriately and thoroughly investigated as necessary. Review of internal incident reports will be reflected on the report by the Sr. Directors signature. Any concerns identified during the review will be addressed via re-training or via standard disciplinary process.
483.460(k)(1) STANDARD DRUG ADMINISTRATION Name - Component - 00 The system for drug administration must assure that all drugs are administered in compliance with the physician's orders.
Observations:
Based on documentation review and staff interview, it was determined that the facility failed to ensure medications were administered in compliance with physician's orders. This was noted for five individuals in the facility (Individual #1, #2, #3, #4, and #5). The findings included:
A) Incident Reports from September 1, 2024 through present were reviewed on December 9, 2024. This review revealed that there were five medication errors within a twenty-four day period; between the dates of October 17 - November 10, 2024. All five medication errors were made by the same licensed staff. Medication errors were as follows:
1) Individual #1
Vitamin D3 400 Units (IU): Take three tablets (1200IU) via g-port of J/G tube daily at 5:00AM. On October 17, 2024, Individual #1 received the wrong dose of Vitamin D3. This error was found and reported on October 25, 2024.
2) Individual #2
Atorvastatin 10 milligrams (mg): Take one tablet via g-tube daily at 12:00AM. On October 21, 2024, this medication was not administered. This error was found and reported on October 25, 2024.
3) Individual #3
Clonazepam 1mg: Take one tablet via g-tube in the morning. Take one and half tablets via g-tube at bedtime. On October 31, 2024, Individual #3 received the wrong dose of Clonazepam at 8:00PM. This was found and reported on November 3, 2024.
4) Individual #4
Vitamin C 500mg: Take one tablet via g-port of J/G tube twice daily. On November 9, 2024, at 11:00PM, this medication was not administered. This error was found and reported on November 10, 2024.
5) Individual #5
Eliquis 5mg: Take one tablet via g-port of J/G tube twice daily. On November 10, 2024, at 12:00AM, this medication was not administered. This error was found and reported on November 11, 2024.
B) The Health Services Supervisor (HSS) was interviewed on December 10, 2024, at 8:45 AM. The HSS confirmed that the medications for Individuals #1, #2, #3, #4, and #5 were not administered in compliance with the physician's orders.
Plan of Correction:Tag 0368
Merakey Allegheny Valley School (AVS), Hummelstown Campus makes its best effort to operate in full compliance with Federal and State Law. Nothing included in this Plan of Correction is an admission otherwise. Merakey AVS Hummelstown Campus has submitted this Plan of Correction in order to comply with its regulatory obligation and does not waive any objections to the merits or form of any allegations contained herein. Please note that Merakey AVS Hummelstown Campus may contest the merits and/or form of any deficiency or finding alleged below and take reasonable steps to appeal them.
DRUG ADMINISTRATION: The system for drug administration must assure that all drugs are administered in compliance with the physician's orders.
All errors noted were by one nurse. At the time of each identified error reviewed during survey, the staff was counseled regarding the specifics of the error. In addition, on 11/13/24 the HSS and AHSS met with the nurse and took a MAR and walked step by step through the administration process. Pointers were given such as using the dot system when pouring meds, pouring in order of the MAR, turning blister cards over as each individual has received their meds providing a visual check in the med cart drawer of who still needs their medications, checking all cards at the end of each med time to make sure all blisters are empty and are initialed and dated. She also reviewed the Medication Administration protocol and signed a Staff Attendance (SA) Sheet. Since this additional training was completed, she has not had another error.
All nursing staff will receive training on Merakey's Protocols and Standards - Administration of Medication including, but limited to identifying individuals who require medication administration during the shift to prevent omissions and double-checking blister packs and med cups after dose has been removed from the card for administration to prevent wrong dose errors so that all medications are administered in compliance with the physician's orders. This training will be documented on a SA sheet and will be completed by 01/03/2025. The SA sheets will be sent to the Staff Development Coordinator to verify all nurses have received training.
Monitoring of medication administration to ensure all nursing staff are administering all medications per the Physicians Orders will be completed by the Assistant HSS (AHSS) or HSS. This will be done through random med pass audits on varied days and times. Documentation of this monitoring will be kept on the Medication Pass Audit form. The Medication Pass Audit is a visual observation of the staff performing administration of medications and treatments. This visual process includes, but is not limited to, ensuring that all drugs are administered In compliance with the physicians orders. If this monitoring reveals that staff are following the Medication Administration procedure correctly, then the monitoring will begin to be tapered to bi-weekly for two months, then monthly for a period of two months, and then as needed.
If during this process, it has been identified that the staff observed are not administering medications as per Physician Orders and Merakey AVS Protocol, retraining will be provided individually to that person and the random audits will be increased in frequency. Staff who fail to follow policy will be referred to the Senior Director, Residential, for corrective action.
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