A-750-2151
A-750- 2151 Index 1170.10
1172.2
NEW YORK STATE DEPARTMENT OF LABOR
UNEMPLOYMENT INSURANCE DIVISION
ADJUDICATION SERVICES OFFICE
September, 2013
INTERPRETATION SERVICE-BENEFIT CLAIMS
MISCONDUCT
Neglect of Duty
Healthcare workers
Falsification of
Records
A claimant, who falsifies medical records indicating she had administered medicine to three patients when she had not done so, has committed an act of disqualifying misconduct.
A.B. 571,264 A
The employer and the Commissioner of Labor applied
to the Appeal Board pursuant to Labor Law 534 for a reopening and
reconsideration of Appeal Board No. 566041, filed January 11,2013, which
reversed the decision of the Administrative Law Judge and overruled the initial
determination disqualifying the claimant from receiving benefits effective
December21, 2011, on the basis that the claimant lost employment through
misconduct in connection with that employment and holding that the wages paid
to the claimant by prior to January 11, 2013, cannot be used toward the
establishment of a claim for benefits .Upon consideration of the application to
reopen, after due notice to the parties, and the written statements submitted
on behalf of the employer and the Commissioner of Labor, the Board has decided
to reopen and reconsider its decision. The Board makes the following:
FINDINGS
OF FACT: The claimant worked for six years as a direct care worker/counselor in
a licensed residence for persons with profound developmental disabilities. The
policy of the employer requires that medication logs are to be signed AFTER
medication is given. The procedure, which was known to the claimant, required
the worker to pour the medication, give it to the resident, observe the
resident take the medication, and then note that the medication had been given
and that the patient was observed. The log is not signed before the medication
is given because the residents may suffer from psychiatric or emotional
problems and refuse to take their medication. Medications are poured for each
individual patient, one at a time. If the medication cannot be given, then it
is flushed. The claimant was trained in this medication procedure during a four
hour certification course. She recertifies on a yearly basis. The claimant also
undergoes annual in service training where medication policy is reviewed. The
claimant has 18 years experience administering medication. The employer has a
zero tolerance policy for falsification of medication documentation. On
December 20, 2011, the claimant was working the 3 p.m. to 11 p.m. shift. She
was scheduled to give 3 residents their medications at 9 p.m. One of the
resident's suffers from severe seizure disorder and is prescribed anti-seizure
medication. The three residents were sleeping at 9 p.m. The claimant signed the
medication log that she had given the drugs and observed the residents take
their medication. She then poured the medication for the three residents. She
did not administer the medication. The claimant had been feeling ill that day,
and when a coworker offered to take her home, she accepted. She asked another
coworker to wake the residents and give them their medication. The coworker did
not do so. The next morning, another direct care worker noticed that drugs had
been poured for three residents. She checked the log and noticed that the
claimant had indicated that she had administered the medication. The claimant
was called and she admitted that she had poured the medication but that she
hadn't administered it. The claimant was discharged pursuant to the no
tolerance policy.
OPINION:
We have reopened this case and reviewed our prior decision in light of the
statements submitted by the employer and the Commissioner of Labor. The
credible evidence establishes that the claimant was discharged because she
falsified medical logs indicating that she had administered medication to three
residents, when in fact she had not. The claimant's falsification of the
medical log led to the residents not receiving their required medication on the
night of December 20, 2011. Her action put these three individuals at risk of
severe health consequences. We are not persuaded by the claimant's argument
that she felt ill and left the residence due to illness before she could
administer the medication herself. The claimant's illness and leaving of the
home came after she had already violated the employer's reasonable medication
rule by pre- signing the medication log. The only excuse that the claimant has
for pre-signing the log was that she did so to keep track of what she was
doing. However, as evidenced by the consequences in this case, pre signing of
the log that drugs had been given, when they were not, did not properly track
the administration of the medication. We are also not persuaded by the
claimant's argument that she pre-signed that she had administered the drugs
because the residents were asleep and she didn't want to waken them. She would
have had to wake the residents under any circumstances to give them their
medication so pre-signing the log had no affect on the residents' sleep.
Additionally, by pre-signing the log that three residents had received their
medication, rather than administering the drugs one by one as per policy, put
three residents at risk. Finally, the failure of her coworker to administer
medication after claimant left the facility does not exonerate the claimant
from fault. It was her obligation to administer the medication and then sign
the log, not to sign the log in violation of policy. The Board has held that
the degree of care expected of a claimant must be commensurate with the
potential for harm. (Appeal Board Case No. 561,236) In this case three
severally disabled individuals, including one with seizure disorder, did not
receive their necessary medication because of claimant's falsification of the
medication log. The Court has also held that a claimant's failure to comply
with the employer's policies and procedure may constitute misconduct especially
where the claimant is employed as a medical professional whose failure to
adhere to prescribed safety procedures could jeopardize the
safety of a patient (Matter of Jill, 23 AD3d 979 {2005}; see also Matter
of Wright, 249 AD2d 668 {1998} and Matter of Martin, 299 AD2d 624 {2002}).
The lack of a prior warning is not controlling in this case. Because of the
potential for medical harm to the residents under its care the employer had a
no tolerance policy for falsification of medical records. The claimant knew of
the no tolerance policy. We must therefore conclude that under the
circumstances of this case the claimant is disqualified from receipt of
benefits.
DECISION:
The decision of the Appeal Board is rescinded. The decision of the
Administrative Law Judge is affirmed. The Department of Labor issued the
initial determination disqualifying the claimant from receiving benefits
effective December 21, 2011, on the basis that the claimant lost employment
through misconduct in connection with that employment and holding that the
wages paid to the claimant by OHEL
CHILDRENS HOME FUND prior to December 21, 2011, cannot be used toward
the establishment of a claim for benefits. The claimant is denied benefits with
respect to the issues decided herein.
COMMENTS
1.
This
decision is in accord with several Court and Appeal Board decisions (see above)
that have held that a patient does not
have to be actually harmed by the claimant s failure to follow policy and
procedures. The key element is the potential for harm.
2.
The
Court and Appeal Board decisions further demonstrate that a healthcare
professional is appropriately held to a high standard of care in the performance
of job duties, because of the potential for harm that could result from
mistakes.
3.
In
this decision the Appeal Board held the lack of a prior warning in this case is
not controlling as the claimant was aware of the employer s zero tolerance
policy.