Tru Community Care

“Program scope CFR(s): 484.65(a)(1),(2) Standard: Program scope. (1) The program must at least be capable of showing measurable improvement in indicators for which there is evidence that improvement in those indicators will improve health outcomes, patient safety, and quality of care. (2) The HHA must measure, analyze, and track quality indicators, including adverse patient events, and other aspects of performance that enable the HHA to assess processes of care, HHA services, and operations. This Standard is not met as evidenced by: Based on record review and interview, the agency failed to ensure the agency’s quality assessment and performance improvement (QAPI) program tracked quality indicators and aspects of performance to assess the agency’s services. Specifically, the QAPI program did not track whether the plan of care (POC) included complete orders or whether the comprehensive assessment was completed in a timely manner. This had the potential to affect all patients admitted to the agency. (Cross-reference G580 and G520) Findings include: 1. Clinical records for 7 patients were reviewed between 9/15/25 and 9/18/25. For 5 of 7 patients, the plan of care (POC) did not contain individualized orders. Additionally, for 2 of 7 sample patients, comprehensive initial assessments were not completed within 5 calendar days of the start of care. 2. During an interview at 9:15 a.m. on 9/18/25, the agency administrator (Staff #7) stated that the staff member who was responsible for verifying the comprehensive assessments were completed on time was new to the role and had not been auditing the medical records. 3. During an interview at 10:29 a.m. on 9/18/25, Staff #7 stated the clinical manager would have been the person responsible for auditing the 5-day comprehensive assessments for compliance. Staff #7 stated that the clinical manager had resigned in August 2025. Additionally, Staff #7 stated “We cannot locate any evidence of compliance audit completion.””

“5 calendar days after start of care CFR(s): 484.55(b)(1) The comprehensive assessment must be completed in a timely manner, consistent with the patient’s immediate needs, but no later than 5 calendar days after the start of care. This Element is not met as evidenced by: Based on record review and interview, the agency failed to ensure the comprehensive assessment was completed within 5 calendar days after the start of care for 2 of 7 sample patients. Specifically the initial assessment for occupational therapy (OT) was not completed in a timely manner consistent with patients’ immediate needs. (Patients #1 and #4) Findings include: 1. Clinical records for 7 patients were reviewed between 9/15/25 and 9/18/25. For 2 of 7 sample patients, the initial assessments were not completed within 5 calendar days of the start of care. a) Patient #1 was admitted to the agency on 8/15/25, with a primary diagnosis of malignant neoplasm of the colon. Record review revealed a referral to the agency, dated 8/15/25, which included occupational therapy (OT) evaluation and treatment​. Review further revealed the OT initial assessment was completed on 9/9/25. b) Patient #4 was admitted to the agency on 6/26/25, with a primary diagnosis of multiple myeloma in relapse. Record review revealed the initial assessment for OT was completed on 8/2/25. 2. During an interview at 9:15 a.m. on 9/18/25, the agency administrator (Staff #7) stated that the staff member who was responsible for verifying that all the assessments that were supposed to be included in the comprehensive assessment, including PT and OT initial assessments, was new to the role and had not been verifying the comprehensive assessments were completed in a timely manner. Staff #7 acknowledged that the comprehensive assessment (including therapy assessments) should be completed within 5 days of the start of care.”

“Only as ordered by a physician CFR(s): 484.60(b)(1) Drugs, services, and treatments are administered only as ordered by a physician or allowed practitioner. This Element is not met as evidenced by: Based on record review and interview, the agency failed to ensure services and treatments were administered only as ordered by a physician or allowed practitioner for 5 of 7 sample patients. Specifically, contracted staff provided care without complete and individualized orders. (Patients #1, #2, # 3, #4, #5) Findings include: 1. Clinical records for 7 patients were reviewed between 9/15/25 and 9/18/25. For 5 of 7 sample patients, the plan of care (POC) did not contain orders and frequencies for all services the home health agency was providing. a) Patient #1 was admitted to the agency on 8/15/25, with a primary diagnosis of malignant neoplasm of the colon. Record review revealed a referral to the agency from a physician, dated 8/15/25, which included physical therapy (PT) and occupational therapy (OT) evaluation and treatment​. Review further revealed 1 OT visit and 3 PT visits were made; however the individualized POC​ for Patient #1 did not contain orders or specify the frequency of visits for PT or OT. b) Patient #2 was admitted to the agency on 6/25/25, with a primary diagnosis of chronic obstructive pulmonary disease. Record review revealed 16 PT visits were conducted by contracted clinicians; however the individualized POC​ for Patient #2 did not contain orders or specify the frequency of visits for PT. c) Patient #3 was admitted to the agency on 4/22/25, with a primary diagnosis of heart failure. Record review revealed an order, dated 7/3/25, for physical therapy to evaluate and treat Patient #3​. Review further revealed ongoing PT visits by a contracted clinician; however the individualized POC​ for Patient #3 did not contain orders or specify the frequency of visits for PT. d) Patient #4 was admitted to the agency on 6/26/25, with a primary diagnosis of multiple myeloma in relapse. Record review revealed an order, dated 7/2/25, for PT and OT to evaluate and treat Patient #4. Review further revealed 14 PT visits and 3 OT visits by contracted clinicians; however the individualized POC​ for Patient #4 did not contain orders or specify the frequency of visits for PT or OT. e) Patient #5 was admitted to the agency on 3/19/25, with a primary diagnosis of chronic obstructive pulmonary disease. Record review revealed an order from a physician for start of care, dated 3/19/25, to “Initiate PT.” Review further revealed PT visits by a contracted clinician; however the individualized POC​ for Patient #5 did not contain orders or specify the frequency of visits for PT. 2. During an interview at 2:45 p.m. on 9/16/25, the agency Director of Palliative Services (Staff #3) stated clinicians providing PT and OT were contracted through another agency. Staff #3 stated the orders for PT and OT could not be placed in the POC because the system the agency used was not compatible with the system the agency contracted with. 3. During interviews with Staff #3 at 8:58 a.m. and 9:10 a.m. on 9/17/25, Staff #3 stated ​the orders for PT and OT should be obtained from the physician and placed on the POC. Staff #3 stated it appeared the orders for PT and OT were not being sent to the physician to be signed and placed in the medical record and POC. Staff #3 acknowledged that an order should be obtained from the physician and then the order and frequency should be included on the POC. 4. During an interview with a physical therapist (Staff #4) at 11:15 a.m. on 9/17/25, Staff #4 stated PT visits for the home health patients were communicated through an online application that the contracted agency used, or were sometimes communicated through the home health agency’s nurse. Staff #4 stated that orders for initial and ongoing PT visits were not on the POC. 5. During an interview with a registered nurse (Staff #6) at 2:36 p.m. on 9/17/25, Staff #6 stated that when new patients were admitted to the home health agency, the process for initiating PT and OT visits was for the admission nurse to ask the patients if they wanted PT and/or OT services, and to check for physician referral orders. Staff #6 stated that if patients needed PT or OT, then the agency that the home health agency contracted with would send the order to the physician, and the contracted agency would then send the order to the home health agency.”