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2801 GESSNER ROAD

HOUSTON, TX 77080

PATIENT RIGHTS: RESTRAINT OR SECLUSION

Tag No.: A0167

Based on record review and interview, the facility failed to:

A. Ensure a restraint was implemented safely for 1 of 1 patients (Patient #1) as evidenced by the staff not treating emergency behavioral medication administration as a restraint, and;

B. Ensure the facility's policy on restraints was consistent with the regulatory definition of restraint, CFR 482.13(e)(1)(i)(B).



Findings included:

A:

Review of facility policy #PC.4.02 titled "Restraint/Seclusion/Emergency Medication" last revised 4/6/20 showed that an Emergency Medication is a psychoactive medication used to treat sudden onset of symptoms that escalate into a psychiatric emergency. These medications are treated as restraint and seclusion and shall be documented accordingly. In addition, these medications are ordered as a one-time "now" dose and have not been planned in advance.

Record review on 1/27/23 during time of survey of Patient #1's clinical records showed that on 9/15/21, there was an order from Physician Assistant (PA) Staff #B for patient to receive the emergency medications Haldol 10 mg intramuscularly (IM), Ativan 2 mg IM, and Benadryl 50 mg IM x1 (now, once). The order was subsequently cosigned by MD-Staff #C. The patient's medication administration record show the patient received these drugs on 9/15/21 at 13:40 (1:40 pm) administered by RN-Staff #D.

Review of nursing progress notes authored by RN-Staff #D dated 9/15/21 at 14:05 (2:05 pm) showed that the patient's doctor was informed that patient hit staff in the face and was then medicated with Haldol 50 mg Intramuscularly (IM), Ativan 2 mg IM, Benadryl 50 mg IM x1 (now, one time) in left gluteal region.

Further review of patient's clinical chart failed to show required monitoring or evaluation of patient's physical and mental status after the emergency medication administration and there was no one hour post intervention face-to-face assessment.

In an interview on 1/27/23 at 11:00, RM-Staff #A stated that in response to the emergency medication administration, there should have been an incident report generated along with a restraint and seclusion 'packet' documentation completed that included the ongoing monitoring of the patient post medication administration, physical and mental assessment, response to intervention, debriefing, and one hour face-to-face post restraint assessment.

B.

Review of facility policy # PC.4.02 titled "Restraint/Seclusion/Emergency Medication" last revised 4/6/20 showed that an Emergency Medication is a psychoactive medication used to treat sudden onset of symptoms that escalate into a psychiatric emergency that is "declined by the patient". However, the patient declining an emergency medication is not consistent with the regulatory definition of CFR 482.13(e)(1)(i)(B) which makes no mention that the patient has to decline receiving the medication for it to be considered an emergency medication.

(FED - A0160 - PATIENT RIGHTS: RESTRAINT OR SECLUSION 482.13(e)(1)(i)(B). Regulation Definition: [A restraint is-] (B) A drug or medication when it is used as a restriction to manage the patient's behavior or restrict the patient's freedom of movement and is not a standard treatment or dosage for the patient's condition).