Certified Homecare of South Florida

“Encoding and transmitting OASIS CFR(s): 484.45(a) Standard: An HHA must encode and electronically transmit each completed OASIS assessment to the CMS system, regarding each beneficiary with respect to which information is required to be transmitted (as determined by the Secretary), within 30 days of completing the assessment of the beneficiary. This Standard is not met as evidenced by: Based on record review, staff interview and the Home Health Agency’s Policy review, it was determined that the Home Health Agency failed to ensure 5 of 10 sampled patients’ completed Outcome and Assessment Information Set (OASIS) Assessments reviewed were electronically transmitted to the Centers for Medicare and Medicaid Services (CMS) within 30 days of completing the assessment of the patient (Patient #2, #3, #6, #8 and #10). The findings include: During pre-survey preparation, it was revealed that the Home Health Agency (HHA) failed to ensure completed Outcome and Assessment Information Set (OASIS) assessments were electronically transmitted to the Centers for Medicare and Medicaid Services (CMS) within 30 days of completing the assessment of the patient for 108 out of 173 records, resulting in a year to date (1/1/25- 2/15/25) error rate of 62.43%. Medical record review during the survey process revealed five patient records of ten patient records reviewed failed to have OASIS transmitted to CMS within 30 days: Patient #2 had an OASIS assessment completed on 11/29/24 which was not transmitted until 1/27/25; Patient #3 had an OASIS assessment completed on 11/22/24 which was not transmitted until 1/27/25; Patient #6 had an OASIS assessment completed on 12/10/24 which was not transmitted until 1/27/25; Patient #8 had 3 OASIS assessments completed on 11/26/24, 11/30/24, and 12/12/24 which was not transmitted until 1/27/25; and Patient #10 had an OASIS assessment completed on 12/14/24 which was not transmitted until 1/27/25. During an interview on 2/19/25 at 10:00am with the Director of Nursing, she was asked who transmits the OASIS data to CMS. She stated that was Employee J. During an interview on 2/19/25 at 11:00am with Employee J (who identified himself as the HHA’s Chief Financial Officer and co-owner) he was asked who transmits the OASIS data to CMS. He stated, “I submit the data.” He was asked when the OASIS assessments are to be transmitted to CMS. He stated, “Within 30 days of the start of care date.” He was asked if he was aware that the HHA’s error rate for year to date is 62.43% with 108/173 OASIS assessments not transmitted after 30 days. He stated, “I was not aware the number was that high, I was aware some records were submitted late. Sometimes we can’t get them coded quick enough and we don’t have the proper documentation to get it coded within the 30 days if we are missing documentation, such as the correct diagnosis. We don’t really have any issues with staff submitting their work within 5 days, and if any staff seems to have an issue, we do monitor that daily and speak to the staff to see if they are having any issues that they need help with. I’m going to crack down on everybody, my coder, my staff.” A review of the HHA’s policy titled, “Reporting of OASIS Information” (revised Oct. 2017) revealed: Policy: The Agency will report required data collected for the OASIS items. Purpose: To define encoding and transmittal of OASIS data. Procedure: The Agency will report electronically all OASIS data collected according to current federal and/or state requirements. Agency must encode and have the capability of transmitting OASIS data for each completed OASIS assessment at least monthly to the System.”

“Infection Prevention CFR(s): 484.70(a) Standard: Infection Prevention. The HHA must follow accepted standards of practice, including the use of standard precautions, to prevent the transmission of infections and communicable diseases. This Standard is not met as evidenced by: Based on observation, record review and staff interviews, the Home Health Agency failed to ensure the Home Health Agency’s staff followed accepted standards of practice and the Home Health Agency’s policies to prevent transmission of infection and communicable diseases for 2 of 4 sampled staff observed during home visits, (Staff member F, Licensed Practical Nurse and Staff member H, Physical Therapy Assistant). The findings include: 1) On 2/19/25 beginning at 9:10 AM, a home visit observation was made of staff member F, Licensed Practical Nurse (LPN), providing wound care to Patient #10. The nurse was observed to place her nursing bag and a plastic tote with wound care supplies directly on the table in the patient’s living room area, she was not observed to clean the area prior to setting the bag on the table. She was then observed to remove a Blood Pressure cuff, Oxygen saturation monitor and a thermometer from the nursing bag. After taking the patient’s Blood Pressure, Temperature and Oxygen saturation levels she was observed to return the items to the nursing bag, at no time were the items observed to be disinfected prior to using on the patient or returning them to the bag. On 2/19/25 at approximately 9:45 AM, an interview was conducted with staff member, F, LPN during which she was asked if she had used a barrier under the nursing bag and the plastic tote to which she stated that she had not but she should have. When asked about cleaning her equipment before returning it to the bag she stated that she had cleaned the diaphragm of her stethoscope with a small alcohol wipe but offered nothing related to cleaning the other items. 2) On 2/19/25 beginning at 10:20 AM, a home visit observation was made of staff member H, a Physical Therapy Assistant (PTA) who was visiting with Patient #9. The PTA arrived to the patient’s apartment carrying a cream-colored tote bag, which she placed directly on the floor next to the patient’s chair without the use of a barrier. She was then observed to obtain the patient’s Blood Pressure and Temperature with a Blood Pressure cuff and thermometer which she removed directly from the tote bag. After obtaining the patient’s Blood Pressure and Temperature, she returned both items to her bag without sanitizing them. She then removed a gait belt from her bag and secured it around the patient’s waist. The PTA used the belt to assist the patient with ambulating in the hallway holding the patient steady with her hand grasping the belt at the patient’s back. She was observed to return the gait belt to the tote bag, at no time was she observed disinfect the gait belt belt prior to returning it to the tote bag. On 2/19/25 at approximately 10:45 AM, an interview was conducted with staff member H, PTA during which she was asked about using a barrier for her bag, she stated that she does not do that and usually just places it on the floor. She stated she has bleach wipes to use on the exercise equipment in the gym on the 2nd floor but she does not disinfect the equipment in her bag. She stated that she was not aware that she needed to use a barrier or disinfect her equipment, other than the exercise equipment. On 2/19/25 at approximately 12:43 PM, an interview was conducted with the Director of Nursing (DON) during which she stated that it is her expectation that all bags the staff bring into a patient’s home would either be hung from a doorknob or placed on a barrier, “always”. She also stated that staff are to wipe all equipment before and after use on the patient. This would include Blood Pressure cuffs, Thermometers, gait belts, etc. She stated that staff request what they would like to clean their equipment with, offering that some staff prefer to use alcohol wipes, and some prefer larger wipes “I order what they request”. She reviewed the in-services for the 12 months of 2024 for education on bag technique and cleaning the equipment and was unable to find an in-service on these topics but stated she would do one for the February staff in-service. She stated that all staff get an e-mail with an attachment that is the in-service, but they are not mandatory. Mandatory in-services are conducted in October which includes Clinical Laboratory Improvement Amendment (CLIA), Hurricane, Biohazard, and Emergency Preparedness. Other in-services are “at leisure” (not mandatory). She stated that contracted staff are included in the e-mail with in-services. She stated that infection control is discussed upon hire but not again unless they have an issue. She offered that she would review this during the next in services in February. A review of the Policy “Exposure Control Plan:” notes under the purpose, “To prevent and control the exposure of home care staff and patients/caregivers to infections and hazardous products.” Under the section titled “Nurse, Home Health Aide and other Staff Bags” the policy states “Bags used by nurses, home health aides and other staff which contain equipment, e.g. a thermometer, stethoscope, blood pressure cuff, etc. and are brought into the home are classified as clean on the inside. The outside of the bag, because it is exposed to all environments is consider “soiled.” Under the section titled “Nursing bag technique it states, “Upon entering the home, place the bag on a clean surface: paper towels or plastic bag may be used to create a clean area if indicated.” The policy goes on to state, “Thermometers will be wiped with alcohol pad after each use. The effectiveness of this technique is dependent on vigorous friction. Allow to air dry.” “Stethoscopes and blood pressure cuffs will be cleaned with Agency approved disinfectant after each use by the employee who has possession of the equipment.””