Health inspection·May 13, 2021

F 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Honor the resident's right to a dignified existence, self-determination, communication, and to exercise his or her rights. Based on record review, observation, staff interview, and review of the facility's policy, the facility failed to provide dining services in a dignified manner. This affected two (Residents #13 and #36) of five residents reviewed for nutrition. The facility census was 57. Findings include: 1. Review of the medical record for Resident #13 revealed an admission date of 02/11/16 with a diagnosis of Alzheimer's disease. Review of the Minimum Data Set (MDS) assessment, dated 02/18/21, revealed the resident was cognitively impaired and required extensive assistance of one staff with feeding. Review of the care plan, last updated 05/11/21, revealed the resident was at nutritional risk due to diagnosis of dementia and need for need for mechanically altered diet due to pocketing foods. The resident could feed herself using her hands to eat and required staff assistance needed to finish and eat adequately. Interventions included the following: serve pureed diet as ordered, provide assistance to eat as needed for optimal meal intakes, offer cueing to clear pocketed foods from mouth as needed, monitor for choking, pocketing food, or drooling, monitor for signs and symptoms of self-feeding difficulties, and serve meals in the dining room. Observation on 05/10/21 at 12:10 P.M. revealed Resident #13 was seated in the dining room with a plate of pureed food and utensils in front of her. Resident was using her fingers to eat the pureed food and was having difficulty feeding herself. There were no staff present in the dining room until 12:21 P.M. Further observation at 12:21 P.M. revealed State Tested Nursing Assistant (STNA) #455 entered the dining room and placed a spoon in Resident #13's hand and cued the resident so she was able to feed herself the pureed food with a spoon. Interview on 05/10/21 at 12:22 P.M. with STNA #455 confirmed Resident #13 needed assistance and cueing to use a spoon when eating pureed food in order to provide a dignified dining experience. 2. Review of the medical record for Resident #36 revealed an admission date of 11/24/20 with a diagnosis of vascular dementia without behavioral disturbance. Review of the MDS assessment, dated 04/10/21, revealed the resident was cognitively impaired and required supervision and set up help with eating. Review of the care plan, dated 01/13/21, revealed the resident was at nutritional risk due to Page 1 of 12 365470 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few dementia. Interventions included the following: serve regular diet as ordered, supplements as ordered, assistance to eat, cueing as needed for optimal intakes, monitor for chewing/swallowing problems such as coughing, choking, pocketing, or drooling, monitor for signs and symptoms of self-feeding difficulties, and serve meals in the dining room. Observation on 05/12/21 at 12:49 P.M. revealed STNA #455 was feeding Resident #13 her lunch when Resident #36 called for assistance. STNA #455 pushed Resident #13's plate out of the resident's reach and told the resident she would return soon. STNA #455 went to Resident #36 and fed her several bites of her food and remained standing over the resident as she did so. While STNA #455 was feeding/encouraging Resident #36 to eat, Resident #13 reached out for her plate of food but it was out of her reach. STNA #455 was the only staff person present in the dining room during the observation. Interview on 05/12/21 at 12:55 P.M. with STNA #455 confirmed staff should sit down and be eye level when assisting residents with feeding to provide a dignified dining experience. STNA #455 further confirmed she had moved Resident #13's food out of her reach because while she tended to Resident #36. STNA #455 confirmed Resident #13 was reaching for her food while STNA was assisting Resident #36 but she had deliberately placed the resident's food out of reach because she didn't think resident would be able to feed herself as resident's ability to self-feed was variable from day to day. Review of the facility's policy titled Dining and Meal Service, dated 2013, revealed the dining experience would be person-centered with the purpose of enhancing each individual patient's/resident's quality of life and would be supportive of each individuals' needs during dining and individuals would be assisted promptly and in a timely manner after the meal arrived. 365470 Page 2 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0609 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Timely report suspected abuse, neglect, or theft and report the results of the investigation to proper authorities. Based on record review, staff interview, review of facility's Self-Reported Incidents (SRIs), and review of the facility's policy, the facility failed to report an allegation of physical abuse regarding a resident-to-resident altercation to the State Survey Agency, the Ohio Department of Health (ODH). This affected two (Residents #23 and #31) of two residents reviewed for abuse. The facility census was 58. Findings include: Review of the medical record for Resident #31 revealed an admission date of 09/05/18 with a diagnosis of Alzheimer's disease. Review of the Minimum Data Set (MDS) assessment revealed the resident was cognitively impaired. Review of the nursing progress note for Resident #31, dated 04/09/20, revealed the nurse was called to the dining room due to resident being slapped by another resident. The nurse assessed the resident for injuries and none were noted. Review of the medical record for Resident #23 revealed an admission date of 09/04/19 with a diagnosis of unspecified dementia with behavioral disturbance. Review of the MDS assessment, dated 03/10/21, revealed the resident was cognitively impaired. Review of the nursing progress note for Resident #23, dated 04/09/20, revealed the nurse was called to the dining room due to resident being slapped by another resident. Resident #23 confirmed she was slapped by another resident, but she was not injured. Review of the facility's SRIs revealed there were no reports filed regarding Residents #23 and #31. Interview on 05/12/21 at 2:45 P.M. with Executive Director (ED) #730 confirmed the facility did not report the resident-to-resident physical altercation between Residents #23 and #31 to the ODH. Review of the facility's policy titled Abuse, Neglect Misappropriation and Crime Reporting, dated 11/04/19, revealed the facility would report all allegations of abuse including resident to resident abuse to ODH. 365470 Page 3 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0610 Respond appropriately to all alleged violations. Level of Harm - Minimal harm or potential for actual harm Based on record review, staff interview, review of the facility's Self-Reported Incidents (SRIs), and review of the facility's policy, the facility failed to thoroughly investigate a resident-to-resident physical altercation. This affected two (Residents #23 and #31) of two residents reviewed for abuse. The facility census was 58. Residents Affected - Few Findings include: Review of the medical record for Resident #31 revealed an admission date of 09/05/18 with a diagnosis of Alzheimer's disease. Review of the Minimum Data Set (MDS) assessment revealed the resident was cognitively impaired. Review of the nursing progress note for Resident #31, dated 04/09/20, revealed the nurse was called to the dining room due to resident being slapped by another resident. The nurse assessed the resident for injuries and none were noted. Review of the medical record for Resident #23 revealed an admission date of 09/04/19 with a diagnosis of unspecified dementia with behavioral disturbance. Review of the MDS assessment, dated 03/10/21, revealed the resident was cognitively impaired. Review of the nursing progress note for Resident #23, dated 04/09/20, revealed the nurse was called to the dining room due to resident being slapped by another resident. Resident #23 confirmed she was slapped by another resident, but she was not injured. Review of the facility's SRIs revealed there were no reports filed regarding Residents #23 and #31. Interview on 05/12/21 at 2:45 P.M. with Executive Director (ED) #730 confirmed the facility did not conduct an investigation regarding the resident to resident physical altercation between Residents #23 and #31. Review of the facility's policy titled Abuse, Neglect Misappropriation and Crime Reporting, dated 11/04/19, revealed the facility would thoroughly investigate all allegations of abuse including resident-to-resident abuse. 365470 Page 4 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0677 Provide care and assistance to perform activities of daily living for any resident who is unable. Level of Harm - Minimal harm or potential for actual harm Based on record review, observation, and staff interview, the facility failed to ensure dependent residents were shaved during provision of grooming and hygiene care. This affected one (Resident #51) of 17 residents reviewed for hygiene. The facility census was 57. Residents Affected - Few Findings include: Review of the medical record for Resident #51 revealed an admission date of 05/11/20 with a diagnosis including dementia with behavioral disturbance, depression, and anxiety disorder. Review of the Minimum Data Set (MDS) assessment, dated 04/12/21, revealed the resident was cognitively impaired and required extensive assistance of one staff with personal hygiene and grooming. Review of the care plan, dated 05/18/20, revealed the resident had a self-care deficit related to dementia and decreased physical function. The goal was for the resident to have proper hygiene and grooming daily and as needed. Interventions included monitoring for any improvement/decline in self-participation, encourage to complete tasks on their own and assist as needed. Observation of Resident #51 on 05/10/21 at 11:24 A.M. revealed the resident had long hairs (approximately one half inch) growing from her chin. Interview on 05/10/21 at 11:26 A.M. with State Tested Nursing Assistant (STNA) #435 confirmed Resident #51 had long hairs growing from her chin and that shaving the resident should be done on shower days. STNA #435 further confirmed she was not sure when Resident #51 had last received a shower. Interview on 05/10/21 at 11:28 A.M. with Licensed Practical Nurse (LPN) #395 confirmed Resident #51 had long hairs growing from her chin and the resident was not able to shave herself. Interview on 05/13/21 at 11:00 A.M. with LPN #565 confirmed Resident #51's shower days were Wednesday (05/12/21) and Saturday on the evening shift and she should be shaved on those dates. LPN #565 confirmed the STNAs completed shower sheets with every shower but could not find any shower sheets for Resident #51 for the month of May 2021. This deficiency substantiates Complaint Number OH00111766. 365470 Page 5 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0695 Provide safe and appropriate respiratory care for a resident when needed. Level of Harm - Minimal harm or potential for actual harm Based on record review, observation, staff interview, and review of the facility's policy, the facility failed to ensure oxygen tubing was dated to indicate the date on which the tubing was changed/initiated. This affected one (Resident #51) of one resident reviewed for respiratory care. The facility identified eight residents on oxygen therapy. The census was 57. Residents Affected - Few Findings include: Review of the medical record for Resident #51 revealed an admission date of 05/11/20 with a diagnosis including dementia with behavioral disturbance, depression, and anxiety disorder. Review of the Minimum Data Set (MDS) assessment, dated 04/12/21, revealed the resident was cognitively impaired. Review of the physician orders, dated May 2021, revealed an order for oxygen per nasal cannula up to five liters continuously to maintain oxygen saturation levels above 92 percent (%). Review of the Medication Administration Record (MAR) and the Treatment Administration Record (TAR) for May 2021 for Resident #51 revealed it was silent regarding administration of oxygen and regarding changing the oxygen tubing. Observation on 05/10/21 at 11:17 A.M. revealed Resident #51 had oxygen in place per nasal cannula at five liters. The oxygen tubing was not dated. Interview on 05/10/21 at 11:19 A.M. with Licensed Practical Nurse (LPN) #395 confirmed the oxygen tubing for Resident #51 was not dated and she was unsure when it had last been changed. Observation on 05/12/21 at 12:31 P.M. revealed Resident #51 had oxygen in place per nasal cannula at five liters. The oxygen tubing was not dated. Interview on 05/12/21 at 12:32 P.M. with LPN # 530 confirmed the oxygen tubing for Resident #51 was not dated and further confirmed the May 2021 MAR/TAR for the resident did not include documentation of oxygen administration or changing of tubing. Review of the facility's policy titled Oxygen Administration and Handling, dated 10/10/20, revealed oxygen tubing should be dated when opened and should be changed at least weekly. 365470 Page 6 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0755 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Provide pharmaceutical services to meet the needs of each resident and employ or obtain the services of a licensed pharmacist. Based on record review, staff interview, and review of the facility's policy, the facility failed to administer insulin and intravenous (IV) antibiotics as ordered by the physician. This affected two (Resident #13 and #51) of six residents reviewed for unnecessary medications. The facility census was 57. Findings include: 1. Review of the medical record for Resident #13 revealed an admission date of 02/11/16 with a diagnosis of Alzheimer's disease. Review of the Minimum Data Set (MDS) assessment, dated 02/18/21, revealed the resident was cognitively impaired. Review of the resident's Medication Administration Record (MAR), dated April 2021, revealed an order for the IV antibiotic Cefazolin to be administered three times daily from 04/16/21 to 05/05/21 for treatment of a urinary tract infection (UTI). Review of the April 2021 MAR revealed the following doses were not administered and the MAR did not note a refusal or rationale for not administering the medication: 04/17/21 at 7:00 A.M., 2:00 P.M., and 6:00 P.M., 04/18/21 at 7:00 A.M. and 2:00 P.M., 04/25/21 at 7:00 A.M., 04/28/21 at 7:00 A.M., 2:00 P.M., and 6:00 P.M. Review of the resident's MAR, dated May 2021, revealed the following doses were not administered and the MAR did not note a refusal or rationale for not administering the medication: 05/01/21 at 6:00 P.M., 05/05/21 at 2:00 P.M. Further review of the MAR revealed the medication was discontinued on 05/06/21. Review of the nurse progress notes for Resident #13 dated 04/16/21 through 05/05/21 revealed the notes were silent regarding physician notification of the missed doses and/or refusals or rationale for missed doses. Interview on 05/13/21 at 2:08 P.M. with Registered Nurse (RN) #835 confirmed Resident #13's medical record did not include physician notification of the missed doses and/or refusals or rationale for missed doses of IV antibiotics in April 2021 and May 2021. Review of the facility's policy titled Medication Administration, dated 11/20/20, revealed the facility would ensure staff administered medications as ordered within two hours of the prescribed times and would monitor and document medication administration and the effectiveness of all medications administered. 2. Review of the medical record for Resident #51 revealed an admission date of 05/11/20 with a diagnosis of diabetes mellitus. Review of the Minimum Data Set (MDS) assessment, dated 04/12/21, revealed the resident was cognitively impaired. Review of the care plan, dated 01/20/21, revealed the resident was at risk for hypo/hyperglycemia. Interventions included medications as ordered, monitor finger sticks as ordered, notify the physician of abnormal results, monitor for signs and symptoms of hypo/hyperglycemia and provide routine sliding scale insulin per orders. Review of the resident's MAR, dated May 2021, revealed the resident did not receive nighttime dose 365470 Page 7 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0755 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few of insulin on 05/01/21 and 05/02/21 or the morning dose of insulin per sliding scale on 05/11/21. There was not blood sugar recorded for the morning on 05/11/21 Interview on 05/13/21 at 2:08 P.M. with Registered Nurse (RN) #835 confirmed Resident #51's medical record did not include physician notification of the missed doses and/or refusals or rationale for missed doses of insulin in May 2021. Review of the facility's policy titled Medication Administration, dated 11/20/20, revealed the facility would ensure staff administered medications as ordered within two hours of the prescribed times and would monitor and document medication administration and the effectiveness of all medications administered 365470 Page 8 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0758 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Implement gradual dose reductions(GDR) and non-pharmacological interventions, unless contraindicated, prior to initiating or instead of continuing psychotropic medication; and PRN orders for psychotropic medications are only used when the medication is necessary and PRN use is limited. **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on medical record review, staff interview, review of the online Medscape resource, and review of the facility's policy, the facility failed to ensure antipsychotic medications were administered for appropriate clinical indications, monitored for target behavioral symptoms, and considered for gradual dosage reductions when indicated. This affected two (Residents #51 and #152) of six residents reviewed for unnecessary medications. The facility census was 57. Findings include: 1. Review of the medical record for Resident #152 revealed an admission date of [DATE] with a diagnosis of Alzheimer's disease. Resident #152 had no diagnoses of psychosis or other specific medical conditions to justify the use of antipsychotic medications. Review of the physician's order, dated [DATE], revealed the resident had an order for the antipsychotic medication Seroquel 75 milligrams (mg.) to be administered routinely three times daily. Review of the resident's Medication Administration Record (MAR), dated [DATE], revealed it did not include monitoring of targeted behaviors associated with the use of Seroquel. The resident received Seroquel routinely three times daily as ordered. Review of the medical record for Resident #152 revealed it did not include a baseline care plan regarding the use of Seroquel. Interview on [DATE] at 12:40 P.M. with Licensed Practical Nurse (LPN) #565 confirmed Resident #152 received Seroquel three times daily and his record did not include targeted behaviors for the use of Seroquel or any kind of behavior monitoring or tracking. Interview on [DATE] at 2:08 P.M. with Registered Nurse (RN) #835 confirmed Resident #152's medical record did not include the following: a diagnosis or specific medical condition related to Seroquel use, a baseline care plan regarding the use of Seroquel, or monitoring of targeted behavioral symptoms. Review of the facility's policy titled Psychotropic Medications, dated [DATE]. revealed psychotropic medications will be administered pursuant to rule §483.45 in the Code of Federal Regulations (CFR). Review of the online resource Medscape revealed Seroquel included a black box warning indicating the medication placed elderly patients with dementia related psychosis at increased risk of mortality and medication was not approved for the treatment of patients with dementia-related psychosis. 2. Review of the medical record for Resident #51 revealed an admission date of [DATE] with diagnoses including dementia with behavioral disturbance, depression, and anxiety disorder. Resident #51 had no diagnoses of psychosis or other specific medical conditions to justify the use of antipsychotic medications 365470 Page 9 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0758 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Review of the Minimum Data Set (MDS) assessment, dated [DATE], revealed the resident was cognitively impaired, antipsychotics were received on seven out of seven days in the review period, no gradual dose reduction (GDR) had been attempted and the physician had not documented a GDR as clinically contraindicated. Review of the resident's care plan, dated [DATE], revealed the resident had altered behavior related to diagnoses of dementia with behaviors and resident could become agitated when attempting to locate deceased husband. Interventions included to address inappropriate behavior consistently as it occurs, consult with psychiatrist/psychologist as needed, medications as ordered, monitor for effectiveness/adverse/side effects, consult with social worker as needed, educate family on diagnosis of dementia and not to remind resident of husband's passing. Review of the physician's orders, dated [DATE], revealed an order for Zyprexa (an antipsychotic) to be administered routinely twice per day. Review of the medical record for Resident #51 revealed it did not include an assessment of abnormal involuntary movements associated with long term antipsychotic use and it did not include monitoring of targeted behaviors associated with the use of Zyprexa. Review of the MAR for [DATE] revealed the resident received Zyprexa twice daily routinely. Interview on [DATE] at 12:40 P.M. with Licensed Practical Nurse (LPN) #565 confirmed Resident #51's record did not include targeted behaviors for the use of Zyprexa nor did the record include behavior monitoring. Interview on [DATE] at 2:08 P.M. with Registered Nurse (RN) #835 confirmed Resident #51's medical record did not include the following: a diagnosis or specific medical condition related to Zyprexa use, an assessment of abnormal involuntary movements associated with long term antipsychotic use, attempted GDR and/or documentation of medical contraindication, or monitoring of targeted behavioral symptoms. Review of the online resource Medscape revealed Zyprexa included a black box warning indicating the medication placed elderly patients with dementia related psychosis at increased risk of mortality and medication was not approved for the treatment of patients with dementia-related psychosis. 365470 Page 10 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0760 Ensure that residents are free from significant medication errors. Level of Harm - Minimal harm or potential for actual harm **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review, review of the facility's policy, and staff interview, the facility failed to prevent a significant medication error when Resident #20 was given another resident's medications. This affected one resident (#20) of resident reviewed for medication administration. The facility census was 57. Residents Affected - Few Findings include: Medical record review for Resident #20 revealed the resident was admitted to the facility on [DATE] with diagnoses including hypertension unspecified heart failure, acute kidney injury, and unspecified dementia without behavioral disturbance. Review of the Minimum Data Set (MDS) assessment, dated 03/03/21, revealed Resident #20 had moderately impaired cognition, did not wander, and did not reject care. Review of the physician orders, for May 2021, revealed Resident #20 had active orders for acetaminophen (treats minor pain), acidophilus (probiotic), Albuterol sulfate (treats and prevents bronchospasm), calcium 500 milligrams (mg.) plus D, famotidine (treats gastroesophageal reflux disease), Levothyroxine (treats hypothyroidism), Metoprolol Succinate (treats high blood pressure), Miralax (stool softener), multivitamin with minerals, and Vitamin D3 (vitamin). Review of the progress note, dated 05/06/21 at 9:50 A.M., revealed Licensed Practical Nurse (LPN) #55 reported to Registered Nurse (RN) #65 she had administered another resident's medication to Resident #20 by mistake. Medications administered included Tylenol (treats mild pain) 650 mg, Buspar (anti-anxiety medication) 10 mg., Lactulose (laxative) 30 mg., and Oxycodone (narcotic pain medication) 5.0 mg. RN #65 stated she notified the doctor and family. Review of the facility's Medication Error Log, no date, revealed LPN #55 committed and reported a medication error on 05/06/21. The corrective action taken included staff education about the Five Rights of Medication Administration. Interview on 05/11/21 at 03:07 P.M. revealed RN #65 stated on 05/06/21, the agency nurse (LPN #55) walked into the wrong room and gave medications to Resident #20 which belonged to another resident. The LPN #55 informed RN #65 immediately of what happened and what medications were given. The RN stated she looked at the medications given in error and made a list of potential side effects to monitor for before she explained to the doctor, in facility at the time of occurrence, what had happened. The doctor said the resident should be fine but recommended to monitor Resident #20 for diarrhea and drowsiness and hold routine medications. The agency nurse monitored Resident #20 frequently for vitals and adverse effects and passed on to continue monitoring in shift-to-shift report. Review of the facility's policy titled Medication Error Report, dated 08/15/20, revealed in case of medication error, the nurse provides emergency care as needed, notifies the supervisor, physician, and resident's responsible party, assesses vital signs and adverse effects frequently, reported follow-up care in shift report, and documented each shift until the resident was stable. 365470 Page 11 of 12 365470 05/13/2021 Ohio Living Llanfair 1701 Llanfair Avenue Cincinnati, OH 45224

F 0880 Provide and implement an infection prevention and control program. Level of Harm - Minimal harm or potential for actual harm Based on observation, staff interview, and review of the facility's policy, the facility failed to ensure staff performed appropriate hand hygiene during meals. This affected three (Residents #13, #23, and #36) of 14 residents on the Grove Unit. The facility census was 57. Residents Affected - Few Findings include: Observation on 05/10/21 at 12:21 P.M. revealed State Tested Nursing Assistant (STNA) #455 entered the dining room after returning from a break off the floor, and did not perform hand hygiene before providing hands on assistance with eating to Residents #13, #23, and #36. STNA #455 did not sanitize her hands between assisting Residents #13, #23, and #36. Interview on 05/10/21 at 12: 40 P.M. with STNA #455 confirmed she did not wash or sanitize her hands upon returning to the floor following her break and did not wash or sanitize hands in between providing hands on assistance with eating to Residents #13, #23 and #36. Observation on 05/12/21 at 12:49 P.M. revealed STNA #455 was feeding Resident #13 her lunch and was wearing gloves. Then STNA #455 removed her gloves and discarded them, donned a pair of new gloves from her pocket and assisted Resident #36 with eating for approximately one minute. STNA then removed her gloves and discarded them, donned a new pair of gloves from her pocket and went back to provide additional hands-on assistance with feeding to Resident #13. The STNA was observed not to perform any hand hygiene between her glove changes from Resident #13 to Resident #36 and then Resident #36 to Resident #13. Interview on 05/12/21 at 12:55 P.M. with STNA #455 confirmed she did not wash or sanitize her hands between residents, and she thought changing gloves between residents eliminated the need for her to perform hand hygiene. Review of the facility's policy titled Hand Hygiene, dated 05/15/20, revealed hand hygiene should be performed before and after patient contact and glove use did not eliminate the need for hand hygiene. This deficiency substantiates Complaint Number OH00111766. 365470 Page 12 of 12