DENVER, CO - A federal inspection at Hilltop Park Post Acute revealed multiple violations of resident rights regulations, including failures to provide mandatory financial statements to residents and their legal representatives, as well as conducting improper facility-initiated discharges.
The July 29, 2024 inspection documented violations affecting residents' financial oversight and discharge procedures, raising concerns about the facility's compliance with federal nursing home regulations.
Financial Management Failures
Federal inspectors found that Hilltop Park failed to provide required quarterly financial statements to at least two residents whose personal funds were managed by the facility. Under federal regulations, nursing homes that manage resident funds must provide detailed quarterly statements and maintain proper authorization from residents or their legal representatives.
Resident #9, a cognitively intact individual under 65, reported that neither he nor his financial power of attorney had received any personal funds statements since his admission. His legal representative confirmed she had repeatedly requested the financial statements from the business office manager but received no response, despite providing documentation of her power of attorney status multiple times.
Resident #12, an 89-year-old resident with dementia, presented a similar situation. Both her primary and secondary legal representatives reported never receiving quarterly statements, despite the facility managing the resident's funds since October 2018. The secondary representative noted she was told she had "no say" in the resident's finances, despite being legally authorized to make decisions about the resident's care.
Authorization Documentation Problems
The inspection revealed critical gaps in financial authorization procedures. Both residents' "Authorization and Agreement to Manage Resident Funds" forms remained unsigned by either the residents or their legal representatives. This documentation is required under federal regulations before facilities can legally manage resident funds.
The business office manager demonstrated confusion about the residents' legal status, incorrectly believing Resident #9 had a conservator when he was competent and had appointed a financial power of attorney. For Resident #12, the manager claimed to be working with a guardian, though the inspection documented legal representatives, not guardians.
Federal regulations require nursing homes to maintain accurate records of all financial transactions using generally accepted accounting principles and notify residents when their account balances approach spending limits that could affect their care eligibility.
Discharge Procedure Violations
The facility also violated federal discharge regulations in the case of Resident #6, a 66-year-old individual with hypertension, diabetes, and cognitive impairment. The resident received an involuntary discharge notice on June 14, 2024, but the facility failed to follow proper procedures.
Federal regulations require specific documentation for facility-initiated discharges, including physician orders, detailed explanations of why the resident's needs cannot be met at the facility, and documentation of attempts to address those needs. None of this documentation was present in Resident #6's medical record.
Missing Physician Authorization
The medical director confirmed he had not been informed of the facility-initiated discharge for Resident #6, violating requirements that physicians must provide orders for discharge or transfer. The facility's own policy requires physician orders for all discharges and transfers.
The director of nursing explained that Resident #6 exhibited behavioral issues, including throwing food and creating potential safety hazards. However, federal regulations require that facilities work to address behavioral issues before pursuing discharge, and all interventions must be documented.
Inadequate Discharge Planning
Federal inspectors found no evidence of proper discharge planning in Resident #6's record. The facility failed to document specific needs that couldn't be met, attempts to address those needs, or how the receiving facility would better serve the resident. No progress notes regarding the discharge appeared in the medical record until the actual day of transfer.
The nursing staff acknowledged they had not been sending comprehensive care plans with transferred residents, a violation of federal requirements. Care plans contain essential information about residents' goals and treatment approaches that receiving facilities need to provide continuity of care.
Regulatory Standards
Federal nursing home regulations require facilities to protect residents' rights to remain in the facility unless specific criteria are met. When discharges are necessary, facilities must provide 30-day notice, document the medical necessity, offer appeal rights, and ensure safe transfers with complete medical information.
For financial management, facilities that choose to manage resident funds must provide quarterly statements, maintain signed authorization forms, and notify residents when spending adjustments are needed to maintain care eligibility.
Facility Response
The inspection classified both violations as causing "minimal harm or potential for actual harm" but affecting multiple residents. The facility must submit a plan of correction addressing each identified deficiency and demonstrating how similar violations will be prevented.
These violations highlight the importance of proper oversight in nursing home financial management and discharge procedures, as vulnerable residents depend on facilities to protect both their financial interests and their right to appropriate care placement.
Full Inspection Report
The details above represent a summary of key findings. View the complete inspection report for Hilltop Park Post Acute from 2024-07-29 including all violations, facility responses, and corrective action plans.
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