Davita New London Dialysis

“IC-WEAR GLOVES/HAND HYGIENE CFR(s): 494.30(a)(1) Wear disposable gloves when caring for the patient or touching the patient’s equipment at the dialysis station. Staff must remove gloves and wash hands between each patient or station. This Standard is not met as evidenced by: 44675 Based on observations, facility documentation and interviews, the facility failed to perform a glove change and hand hygiene after contact with a hemodialysis station wallbox during cleaning and disinfection of the dialysis station . The findings included: Observation was conducted on 3/25/25 at 10:48 AM of Station #20 cleaning and disinfection of the hemodialysis station after a hemodialysis treatment identified Staff Person #4 disinfected the wallbox (contains connections for the dialysis machine to receive acid and base concentrations, treated water and disposal of waste products) with a bleach cloth. Staff Person #4 discarded the bleach cloth and proceeded to clean with hemodialysis chair and television with a new cloth without the benefit of removing her gloves and performing hand hygiene after contact with the wallbox. Review of the infection control for dialysis facilities policy directed that hand hygiene is to be performed after interacting with wallboxes.”

“IC-CATHETERS:GENERAL CFR(s): 494.30(c)(2) (2) The “Guidelines for the Prevention of Intravascular Catheter-Related Infections” entitled “Recommendations for Placement of Intravascular Catheters in Adults and Children” parts I - IV; and “Central Venous Catheters, Including PICCs, Hemodialysis, and Pulmonary Artery Catheters in Adult and Pediatric Patients,” Morbidity and Mortality Weekly Report, volume 51 number RR-10, pages 16 through 18, August 9, 2002. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR Part 51. This publication is available for inspection as the CMS Information Resource Center, 7500 Security Boulevard, Central Building, Baltimore, MD or at the National Archives and Records Administration (NARA). Copies may be obtained at the CMS Information Resource Center. For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_regulations/ibr_locations.html This Standard is not met as evidenced by: 44675 Based on observation, review of clinical records, interview, and policy review for one (1) of two (2) hemodialysis patients reviewed for central venous catheter care (Patient #16), the facility failed to perform catheter care per facility policy. The findings include the following: Patient #16 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three (3) times weekly for three (3) hours and fifteen (15) minutes with a right Central Venous Catheter (CVC). Observation was conducted on 3/25/25 at 10:30 AM of Patient #16’s CVC care and treatment initiation by Staff Person #1 (RN). At 10:32 AM Staff Person #1 cleaned the CVC exit site with a chlorhexidine swab (an anti-microbial disinfectant). She then cleaned each catheter limb and hub with an alcohol pad (total of two pads). Staff Person #1 proceeded to apply a Tegaderm dressing (a transparent medical dressing) over Patient #16’s CVC exit site without the benefit of removing gloves and performing hand hygiene after cleaning the CVC exit site and limbs. Staff Person #1 then aspirated about 5 ml from each CVC limb and flushed with saline, without the benefit of removing gloves and performing hand hygiene after apply the exit site dressing. Review of the central venous catheter (CVC) policy directed, in part, to clean the CVC exit site with a chlorhexidine swab for a minimum of thirty seconds. Then clean each CVC limb/cap with a new large alcohol prep pad starting close to the exit site and finishing with the cap. Remove gloves and discard, perform hand hygiene per procedure and re-glove. Place a sterile 2x2 gauze over the catheter exit site and seal the edges of gauze with tape. Remove gloves and discard, perform hand hygiene per procedure and re-glove. Attach sterile 10 ml syringes to the arterial and venous limbs and aspirate about 5 ml from each limb.”

“PA-APPROPRIATENESS OF DIALYSIS RX CFR(s): 494.80(a)(2) The patient’s comprehensive assessment must include, but is not limited to, the following: (2) Evaluation of the appropriateness of the dialysis prescription, This Standard is not met as evidenced by: 47491 Based on review of clinical records, interview, and review of facility documentation and policy for two (2) of five (5) patients (Patient #1 and #3) reviewed for hemodialysis treatments, the facility failed to ensure blood flow rates (BFR) were attained in accordance with physician’s orders, for one (1) of five (5) patients (Patient #6) reviewed for hemodialysis treatments, the facility failed to ensure arterial pressures did not exceed negative 260 in accordance with facility policy, and for one (1) of two (2) patients (Patient #13) reviewed for home dialysis treatments, the facility failed to ensure the patient was completing their peritoneal dialysis treatments in accordance with physician’s orders. The findings included: 1. Patient #6 had diagnoses that included end stage renal dialysis. The physician’s order directed for hemodialysis three (3) times weekly for four (4) hours with a 2.0 potassium/2.5 calcium bath, administered at a blood flow rate (BFR) of 400 and dialysate flow rate (DFR) of 800 while utilizing a left forearm arteriovenous fistula. On 3/19/25, the physician’s order directed a BFR of 350. Review of Patient #6’s treatment sheets identified the following: a. On 1/22/25, a BFR of 400 was administered at the initiation of treatment and maintained for thirty (30) minutes, lowered to 380 for two (2) hours and thirty (30) minutes, to 370 for thirty (30) minutes, and then to 350 for seven (7) minutes without documentation indicating the reason for the reduced BFR. b. On 2/7/25, a BFR of 400 was administered at the initiation of treatment and maintained for two (2) hours and fifty-eight (58) minutes and then lowered to 370 for fifty-nine (59) minutes without documentation indicating the reason for the reduced BFR. c. On 3/12/25, a BFR of 380 was administered for ninety-one (91) minutes and was decreased to 360 for ninety-five (95) minutes without documentation indicating the reason for the reduced BFR. d. On 3/19/25, a BFR of 350 was administered at the initiation of treatment, however, was lowered to 300 for thirty (30) minutes, and increased to 340 for two (2) hours and twenty-eight (28) minutes without documentation indicating the reason for the reduced BFR. 2. Patient #8 had diagnoses that included end stage renal disease. The physician’s order directed for hemodialysis three (3) times weekly for three (3) hours and thirty (30) minutes with a 2.0 potassium/2.5 calcium bath, administered at a blood flow rate (BFR) of 450 and dialysate flow rate (DFR) of 600 while utilizing a left forearm arteriovenous fistula. Review of Patient #8’s treatment sheets identified the following a. On 3/3/25, a BFR of 400 was administered at the initiation of treatment and maintained throughout treatment without documentation indicating the reason for the reduced BFR. b. On 3/10/25, a BFR of 450 was administered at the initiation of treatment for sixty-one (61) minutes and was lowered to 400 for the remainder of treatment without documentation indicating the reason for the reduced BFR. c. On 3/19/25, a BFR of 400 was administered for the entire treatment without documentation indicating the reason for the reduced BFR. Interview with the Facility Administrator on 3/26/25 a 2:32 PM identified staff should be documenting any change to the BFR/DFR on the vitals line in the electronic medical record, indicating why the physician’s order was not being followed. Review of the Pre-Intra-Post Treatment Data Collection, Monitoring and Nursing Assessment policy directed if the dialysis prescription was not being met (including dialysis flow rate or change to/inability to obtain prescribed blood flow rate) the reason will be documented and the licensed nurse informed. 3. Patient #6 had diagnoses that included end stage renal dialysis. The physician’s order directed for hemodialysis three (3) times weekly for four (4) hours with a 2.0 potassium/2.5 calcium bath, administered at a blood flow rate (BFR) of 400 and dialysate flow rate (DFR) of 800 while utilizing a left forearm arteriovenous fistula. On 3/19/25, the physician’s order directed a BFR of 350. Review of Patient #6’s hemodialysis treatments identified the following: a. On 1/22/25, arterial pressures (reflects pressure exerted to pull from the patients arterial limb of the vascular access) of -275mmHg (millimeters of mercury), -290 mmHg, -286 mmHg, -269 mmHg, -288 mmHg, -273 mmHg, -282 mmHg were obtained while administering treatment at a blood flow rate (BFR) of 380 for two (2) hours and thirty (30) minutes, at -289 mmHg while administering treatment at a BFR of 370 for thirty (30) minutes, and -267mmHg while administering treatment at a BFR of 350 for seven (7) minutes without documentation indicating any interventions were done. In total, elevated arterial pressure rates occurred for three (3) hours and seven (7) minutes of Patient #6’s four (4) hour treatment. b. On 2/5/25, arterial pressures of -274 mmHg, -280 mmHg, -279 mmHg, -270 mmHg, -276 mmHg, and -271 mmHg were obtained while administering treatment at a blood flow rate (BFR) of 400 for two (2) hours and thirty-one (31) minutes without documentation indicating any interventions were done. In total, elevated arterial pressure rates occurred for two (2) hours and thirty-one (31) minutes of Patient #6’s four (4) hour treatment. c. On 3/3/25, arterial pressures of -282 mmHg, -286 mmHg, -281 mmHg, and -285 mmHg were obtained while administering treatment at a blood flow rate (BFR) of 400 for one (1) hour and thirty-one (31) minutes. At 2:51 PM, the BFR was decreased to 350 and an arterial pressure of -260 mmHg was obtained, however at 3:21 PM, an arterial pressure of -272 mmHg was obtained, at 3:54 PM, an arterial pressure of -276 mmHg was obtained, and at 3:56 PM an arterial pressure -271 mmHg was obtained without any interventions documented or adjustments to the BFR made to further decrease the high arterial pressure. In total, arterial pressures greater than -260 mmHg occurred for three (2) hours and six (6) minutes of Patient #6’s four (4) hour treatment. Interview with the Facility Administrator on 3/26/25 at 2:35 PM identified staff should notify the charge nurse if arterial pressures consistently exceed -260 and that interventions should be initiated to bring the arterial pressure below -260, either by decreasing the blood flow rate (BFR) and/or adjusting the needle that’s withdrawing the blood flow the patient’s access to avert the risk of hemolysis. Review of the Arterial and Venous Pressure Monitoring policy directs pre-pump arterial pressures should not exceed -260 mmHg and that pressures in excess of -260 mmHg indicate inadequate inflow from the vascular access. 4. Patient #13 had diagnoses that included end stage renal disease. Physician’s order dated 12/2/24 directed to daily peritoneal dialysis treatments including five (5) exchanges of 1500 milliliters over a nine (9) hour treatment, using one (1) 1.5% dialysate solution and (1) 2.5% dialysate solution with treatment for weight between 125 pounds and 137 pounds. a. Review of December 2024 treatment sheets identified Patient #13 completed treatments on 12/1/24, 12/2/24, 12/4/24, 12/5/24, and 12/7/24, however Patient #13 failed to follow the physician’s fluid use guidelines with these treatments and used either two (2) 1.5% dialysate solution or two (2) 2.5% dialysate solution with treatment when the fluid use guideline directed him/her to use one (1) 1.5% solution and one (1) 2.5% solution when his/her weight was between 125.3 pounds and 132.1 pounds. b. Review of February 2024 treatment sheets identified Patient #13 completed treatments on 2/10/25, 2/13/25, 2/15/25, 2/16/25, 2/18/25, 2/19/25, 2/20/25, 2/21/25, 2/23/25, 2/25/25, 2/26/25, and 2/27/25, however Patient #13 failed to follow the physician’s fluid use guidelines with these treatments and used one (1) 1.5% dialysate solution and one (1) 2.5% dialysate solution with treatment when the fluid use guideline directed him/her to use two (2) 1.5% dialysate solutions for weights between 120 pounds and 124 pounds 2/1/25 to 2/24/25 and weights between 120 pounds and 129 pounds 2/24/25 to 2/27/25. Interview with the Peritoneal Dialysis Nurse (PDN) on 3/25/26 at 2:58 PM identified peritoneal dialysis patients were trained to properly fill out home treatment sheets (both electronic and written) and to follow physician’s orders. The PDN further indicated he/she had provided verbal education to Patient #13 regarding his/her adherence to the fluid guidelines order and not taking it upon himself/herself to select alternate dialysate concentrations, however had failed to document that the patient was educated. Review of the Peritoneal Dialysis Home Training Agreement (PDHTA) directed patients to follow their dialysis prescription as ordered by their physician upon the successful completion of the home dialysis training program and to not make changes to his/her treatment without authorization from the physician and/or home training team. The PDHTA further directed the patient to document all treatments accurately and completely.”

“PA-ASSESS ANEMIA CFR(s): 494.80(a)(4) The patient’s comprehensive assessment must include, but is not limited to, the following: (4) Evaluation of factors associated with anemia, such as hematocrit, hemoglobin, iron stores, and potential treatment plans for anemia, including administration of erythropoiesis-stimulating agent(s). This Standard is not met as evidenced by: 44675 Based on a review of clinical records, interview, and policy review for on (1) of two (2) hemodialysis patients reviewed for anemia (Patient #11), the facility failed to draw weekly hemoglobin labs for a patient who was on an anemia medication hold per facility protocol. The findings include the following: 1. Patient #11 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three times weekly for three (3) hours with a left upper arteriovenous fistula (AVF) and an estimated dry weight (EDW) of 46.5 kg. A physician’s order dated 1/9/25 directed Mircera 100 mcg ( a medication given to treat anemia) every two (2) weeks for anemia. Review of Patient #11’s labs dated 1/21/25 identified Patient #11’s hemoglobin was 12.6. The physician’s order for Mircera 100 mcg every two (2) weeks for anemia was discontinued on 1/23/25 per protocol. Review of Patient #11’s labs failed to identify a weekly hemoglobin was drawn and assessed for the week of 1/26/25 - 2/1/25. Review of Patient #11’s hospitalization log identified Patient #11 was hospitalized from 2/1/25 - 2/7/25 due to ketoacidosis (diabetes complication). Review of Patient #11’s labs dated 2/11/25 identified Patient #11’s hemoglobin was 9.1 (3.5 decrease in three (3) weeks). Interview with the Clinical Services Manager on 3/26/25 at 12:01 PM identified when the protocol recommends a change, a staff member must review it and accept it. Therefore Patient #11’s Mircera discontinuation order was reviewed by a staff member on 1/23/25. Patient #11 was in the facility for treatment on 1/28/25 and there was a missed opportunity for a hemoglobin draw. She identified Patient #11 was discharged from the hospital on 2/7/25 and 2/11/25 was the first opportunity for a hemoglobin draw. Review of the Mircera protocol identified the target hemoglobin is less than or equal to eleven (11), at the lowest dose that will maintain a hemoglobin level sufficient to reduce the need for a blood transfusion. For a hemoglobin greater than 12.0, Mircera is placed on hold. The hemoglobin is monitored weekly when Mircera is on hold for less than ninety (90) days. A one time hemoglobin will be drawn post hospitalization.”

“PA-MSW-PSYCHOSOCIAL NEEDS CFR(s): 494.80(a)(7) The patient’s comprehensive assessment must include, but is not limited to, the following: (7) Evaluation of psychosocial needs by a social worker. This Standard is not met as evidenced by: 47491 Based on clinical record review, interview, and review of facility documentation and policy for two (2) of seven (7) patients (Patient #1 and #3) for assessments, the facility failed to ensure that quarterly social workers assessments were completed. The findings included: 1. Patient #1 had diagnoses that included end stage renal failure. The physician’s order directed hemodialysis three (3) times weekly for three (3) hours and forty-five (45) minutes with a 2.0 potassium/2.5 calcium bath, administered at a blood flow rate of 450 and dialysate flow rate of 800 while utilizing a right upper arm arteriovenous fistula. Review of Patient #1’s clinical records identified Social Work Quarterly Assessments were completed 10/30/23 and 8/2/24, however failed to identify assessments were completed for the quarter including November 2023, December 2023, and January 2024 and for the quarter including February 2024, March 2024, and April 2024. 2. Patient #3 had diagnoses that included end stage renal failure. The physician’s order directed hemodialysis three (3) times weekly for three (3) hours and thirty (30) minutes with a 1.0 potassium/2.5 calcium bath, administered at a blood flow rate of 350 (BFR) and dialysate flow rate (DFR) of 600 while utilizing a right upper arm arteriovenous fistula. Review of Patient #3’s clinical records identified Social Work Quarterly Assessments were completed 9/28/23 and 7/23/24, however failed to identify assessments were completed for the quarter including January 2024, February 2024, and March 2024. Interview with the Facility Administrator (FA) on 3/26/25 at 2:30 PM identified the facility was without a Social Worker during the timeframe the quarterly social work assessments were not completed. The FA further identified the facility had a social worker from another clinic covering, however was not as diligent with completing the workload as was expected. The FA indicated that social work assessments were to be completed quarterly. Review of the Social Work Intervention and Documentation Requirements policy directed social work progress notes should be completed quarterly or more frequently as needed.”

“MD RESP-ENSURE ALL ADHERE TO P&P CFR(s): 494.150(c)(2)(i) The medical director must- (2) Ensure that- (i) All policies and procedures relative to patient admissions, patient care, infection control, and safety are adhered to by all individuals who treat patients in the facility, including attending physicians and nonphysician providers; This Standard is not met as evidenced by: 44675 Based on observations, clinical record review, interview and review of facility policy for five (5) Patients (Patients #15, #17, #18, #20, and #21), reviewed for vascular access, the facility failed to use hemodialysis access clamps in accordance with facility policy, for one (1) of five (5) patients (Patient #8) reviewed for hemodialysis treatments, the facility failed to enter pre-treatment assessments into the electronic medical record in accordance with facility policy, and for two (2) of three (3) patients (Patient #15 and #22) reviewed for dialysis treatments, the facility failed to allow heparin to dwell three (3) to five (5) minutes following administration and prior to treatment initiation. The findings included: 1. a. Patient #15 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three (3) times weekly for three (3) hours and thirty (30) minutes with a left upper arteriovenous fistula (AVF). Observation of Station #20 on 3/24/25 at 1:15 PM identified Patient #15 completed treatment and Staff Person #1 removed both of Patient #15’s hemodialysis needles and applied two clamps on Patient #15’s access. At 1:34 PM the clamps were removed by Staff Person #1 and Staff Person #1 proceeded to tape over Patient #15’s access without checking for hemostasis of the two needle sites and did not listen to the bruit of the access (sound that indicates blood flow in the access). b. Patient #17 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three (3) times weekly for four (4) hours with a left upper arteriovenous fistula (AVF). Observation of Station #21 on 3/25/25 at 11:15 PM identified Patient #17 with two clamps on Patient #17’s hemodialysis access. At 11:29 AM a staff member removed Patient #17’s clamps and proceeded to tape over Patient #17’s access without checking for hemostasis of the two needle sites and did not listen to the bruit of the access. c. Patient #18 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three times weekly for three (3) hours and thirty (30) minutes with a left upper arteriovenous fistula (AVF). Observation of Station #19 on 3/26/25 at 9:41 AM identified Patient #18 completed treatment and Staff Person #1 removed both of Patient #18’s hemodialysis needles and applied two clamps on Patient #19’s hemodialysis access. At 9:53 AM the clamps were removed by Staff Person #4 and Staff Person #4 proceeded to tape over Patient #18’s hemodialysis access without checking for hemostasis of the two needle sites and did not listen to the bruit of the access. d. Patient #19 was admitted to the clinic with diagnoses that included ESRD. Review of the physician’s orders directed hemodialysis three (3) times weekly for three (3) hours and fifteen (15) minutes with a left upper arteriovenous fistula (AVF). Observation of Station #21 on 3/26/25 at 9:51 AM identified Patient #19 completed treatment and Staff Person #3 removed both of Patient #19’s hemodialysis needles and applied two clamps on Patient #19’s access. At 10:06 AM the clamps were removed by Staff Person #3 and Staff Person #3 proceeded to tape over Patient #21’s access without checking for hemostasis of the two needle sites and did not listen to the bruit of the access. At 10:09 AM Patient #19 identified he/she was bleeding. Staff responded and two clamps were applied on Patient #19’s access again. At 10:27 AM a staff member removed the clamps and taped over Patient #19’s access without checking for hemostasis of the two needle sites and did not listen to the bruit of the access. e. Patient #20 had diagnoses that included end stage renal disease. A physician’s order directed to hemodialysis treatments three (3) times weekly for three (3) hours per treatment using a left upper arm arteriovenous fistula (AVF). Observation of Station #4 on 3/26/25 at 9:10 AM identified Patient #20 had concluded his/her dialysis treatment and had two (2) clamps applied to his left upper arm, over the access cannulation sites, to apply pressure and allow the sites to clot. Further observation identified staff removed both clamps from Patient #20’s access at 9:28 AM. Surveyor identified Patient #20 had blood on both gauze bandages that were placed over his cannulation sites after the clamps were removed. Further observation identified Staff Person #5 had removed the clamps and reinforced the bandages with adhesive tape without changing the blood soiled gauze pads. f. Patient #21 had diagnoses that included end stage renal disease. A physician’s order directed to hemodialysis treatments three (3) times weekly for three (3) hours per treatment using an arteriovenous fistula in the right forearm. Observation of Station #20 on 3/26/25 at 9:10 identified Patient #21 had concluded his/her dialysis treatment and had two (2) clamps applied to his right forearm, over the access cannulation sites, to apply pressure and allow the sites to clot. Further observation identified staff both removed clamps from Patient #21’s access at 9:16 AM. Interview with the Clinical Services Manager on 3/27/25 at 11:51 AM identified the policy directs only one clamp should be used on a patient’s access at one time. She identified there is nothing stating the facility can use two clamps on a patient’s access at one time in Governing Body. Review of the post dialysis vascular access care: fistula/graft using safety fistula needles policy identified if clamps are to be used, refer to the procedure utilizing vascular access clamps. It identified if clamps are used incorrectly, they may cause clotting of the vascular access. Review of the utilizing vascular access clamps policy directed only one clamp should be used at a time including checking for thrill and bruit above and below the clamp. It identified bruit and thrill must be re-checked a minimum of every ten (10) minutes while using access clamps and documentation performed in the patient’s treatment record. It identified if thrill is not palpable or bruit heard, blood flow in the access is diminished and clotting may occur. 2. Patient #8 had diagnoses that included end stage renal dialysis. The physician’s order directed for hemodialysis three (3) times weekly for three (3) hours and thirty (30) minutes with a 2.0 potassium/2.5 calcium bath, administered at a blood flow rate (BFR) of 450 and dialysate flow rate (DFR) of 600 while utilizing a left forearm arteriovenous fistula. Review of Patient #8’s treatment sheets identified the following: a. On 3/7/25, Patient #8’s hemodialysis treatment was initiated at 11:43 AM, however his/her pre-treatment assessment was not entered into the electronic medical record until 1:24 PM, one (1) hour and forty-one (41) minutes after treatment had started. b. On 3/21/25, Patient #8’s hemodialysis treatment was initiated at 10:46 AM, however his/her pre-treatment assessment was not entered into the electronic medical record until 12:10 PM, one hour and twenty-six (26) minutes after treatment had started. Interview with the Facility Administrator on 3/26/25 at 2:38 PM identified pre-treatment assessments should be entered into the electronic medical record within one hour of the start of a patient’s treatment. Review of the Pre-Intra-Post Treatment Data Collection, Monitoring and Nursing Assessment policy directed the licensed nurse would round on those patients without reported abnormal findings and complete the nursing assessment within one (1) hour of dialysis treatment initiation. 3. a. Patient #15 had diagnoses that included end stage renal disease. Physician’s order directed to hemodialysis treatments three times weekly for three (3) hours and thirty (30) minutes per treatment, using a right upper arm arteriovenous fistula, and a loading dose of 1,000 units of heparin. Observation on 3/26/25 at 9:47 AM identified Patient #15 had been cannulated with both arterial and venous needles to initiate treatment and had been administered his/her 1,000 units of heparin pre-treatment. Further observation on 3/26/25 at 9:49 AM identified Patient #15’s treatment had been started, two (2) minutes following the administration of heparin. b. Patient #22 had diagnoses that included end stage renal disease. Physician’s order directed hemodialysis treatments three (3) times weekly for three (3) hours and thirty (30) minutes per treatment, using a left upper arm arteriovenous fistula, and a loading dose of 1,000 units of heparin. Observation on 3/16/25 at 9:03 AM identified Patient #22 had been cannulated with both arterial and venous needles to initiate treatment and had been administered his/her 1,000 units of heparin pre-treatment. Further observation on 3/26/25 at 9:04 AM identified Patient #22’s treatment had been started, one (1) minute following the administration of heparin. Interview with the Facility Administrator on 3/26/25 at 2:40 PM identified the facility’s standard of practice was to allow heparin to dwell three (3) to five (5) minutes following administration pre-treatment. Review of the Anticoagulation policy directed the facility to deliver anticoagulation therapy that reduces clotting within the extracorporeal circuit and prevent complications such as blood loss, to optimize dialyzer efficiency, and adequacy of dialysis. The policy further directed to anticoagulate the patient, the initial loading dose of heparin is administered through the venous fistula needle or venous port of the central venous catheter (CVC) at least three (3) to five (5) minutes prior to the initiation of the hemodialysis treatment.”