Precise Home Care LLC

“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 staff interviews and medical record review, it was revealed that the agency failed to ensure they electronically transmitted each completed Outcome and Assessment Information Set (OASIS) assessment to the Center for Medicaid and Medicare Services (CMS) system within 30 days of completing the assessment of the beneficiary for eight patient records out of 25 patient records reviewed. The findings include: A review of the Home Health Agency (HHA) Error Summary by Agency Report error #3330 (record submitted late: the submission date is more than 30 days after the OASS assessment date) revealed a year-to-date error rate (1/1/24- 12/18/24) of 5.82% (159 records submitted late out of 2730 records submitted.) A quarter to date error rate (10/1/24- 12/18/24) revealed an error rate of 5.86% (36 records submitted late of out 614 records submitted) and a month to date error rate (12/1/24-12/18/24) revealed an error rate of 4.97% (8 records submitted late out of 161 records submitted.) On 12/18/24 at 12:30pm, in an interview with the Billing Supervisor, who has identified herself as the employee who transmitted the OASIS records, she was asked about her role in transmitting the OASIS records to CMS. She stated, “I review the records from a clerical standpoint. I am the only one who exports the records to CMS through the Internet Quality Improvement and Evaluation System (iQies).” She was asked how she knows when a record is ready to be transmitted. She stated, “We have reports and I keep a log based on the dates.” She was asked how long the agency from the date of OASIS assessment to transmit the record to CMS. She stated, “It’s supposed to be 30 days.” She was asked if the agency had any issues with getting the OASIS assessments transmitted to CMS within 30 days. She stated, “I know some of them are submitted late.” She was asked what reasons an OASIS assessment would be submitted later than 30 days. She stated, “Human error sometimes, I might miss one here and there. Like if I just miss one on my list, and I found out later because I’d catch it in my next batch and see one that wasn’t sent in one time. I’m not aware of any other reasons, I batch my submissions 1-2 times a week.” She was asked if she made aware of a record is submitted late. She stated, “Yes, a warning will pop up if it’s late.” She was asked if she can run a report that tells her how many records are submitted late. She stated, “No, I don’t know how I would see those numbers. I am the main person working in iQies.” She was asked of anyone in the office is able to run a report to show trends of late OASIS assessment submissions. She stated, “I’m not sure, let me find out.” In an interview with the Director of Nursing (DON) on 12/18/24at 12:45pm, he was asked if anyone in the office is able to run a report to show trends of late OASIS assessment submissions. He stated, “I don’t know about that, is it coming from our system? I’m sure we could find out. I don’t know how we would see those numbers but let me see what I can find out.” On 12/18/24 at 1:00pm, the DON stated, “I have this report from iQies that shows our late submissions for this month, it shows 8 records were submitted late.” The report revealed: Patient #18: OASIS discharge assessment date: 10/24/24; not exported when reviewed on 12/18/24 at 2:00pm, showed “export ready 12/18/24”. Patient #19: OASIS discharge assessment date: 10/24/24; exported 12/4/24. Patient #20: OASIS discharge assessment date: 10/25/24; exported 12/4/24. Patient #21: OASIS discharge assessment date: 10/25/24; exported 12/4/24. Patient #22: OASIS discharge assessment date: 10/6/24; exported 12/4/24. Patient #23: OASIS transfer assessment date: 10/10/24; exported 12/4/24. Patient #24: OASIS discharge assessment date: 10/18/24; exported 11/22/24. Patient #25: OASIS start of care assessment date: 10/31/24; exported 12/2/24. The DON was asked why these OASIS assessments were submitted late. He stated,” Well, some were due to billing, and the rest were probably just the clinicians submitted information late.” He was asked if the agency has any Quality Assurance (QA) plan addressing the late OASIS assessment submissions. He confirmed the agency did not have any QA plan regarding the late submissions.”

“Performance improvement projects CFR(s): 484.65(d)(1)(2) Standard: Performance improvement projects. Beginning July 13, 2018 HHAs must conduct performance improvement projects. (1) The number and scope of distinct improvement projects conducted annually must reflect the scope, complexity, and past performance of the HHA’s services and operations. (2) The HHA must document the quality improvement projects undertaken, the reasons for conducting these projects, and the measurable progress achieved on these projects. This Standard is not met as evidenced by: Based on staff interviews and agency policy and procedure review, it was determined that the agency failed to ensure they documented the quality improvement projects undertaken with measurable progress achieved on these projects. The findings include: On 12/19/24 at 9:30am, in an interview with the Director of Nursing (DON) and the Alternate Director of Nursing (ADON) they were asked if the agency had any quality/performance improvement projects in place. The ADON stated, “Improvement on Documentation is the only one we have right now.” The ADON page provided one page for review and stated this was their current project. The page was undated. She was asked if there were any other pages to show the data collected, the progress or if any goals have been met. She stated, “No, it’s just this one page.” The undated page revealed: “Performance Improvement Project: A new project began in the 4th quarter of 2023 based on data from the star rating report card and in-house chart audits. Of note, there is a concern for lack of understanding of the actual intent of specific OASIS (Outcome and Assessment Information Set) questions, which is further complicated by lack of uniformity in the manner in which clinicians are completing the Start of Care assessment and related paperwork. A committee was created to discuss/implement a plan of action to address potential documentation deficits which may lead to inaccurate reporting of the patient’s actual progress in key areas from start of care to discharge. Both field and office clinical staff were invited to take part in the committee, with the first meeting held January 2024. Attendees included the DON, QAPI director, QA auditor, Office Manager and Field RN. The meeting consisted of a general discussion on documentation concerns and the committee goals for identifying potential knowledge deficits, developing an education program for both new and retained employees as well as post-education follow up. In house chart audits are being conducted with individual education provided to field staff on areas of concerns.” She was asked if there has been any data collected or reviewed, or any plan implemented to guide the agency toward improvement on the project. She stated, “Yes, one of our field nurses had been working as a peer trainer, but she’s had medical issues, and she hasn’t been able to work on the project, she’s been out since October 2024. We plan on having smaller groups.” She was asked to explain the performance project. She stated, “We identified the issue in December 2023, and we invited staff to come a meeting in Jan 2024 to brainstorm, but I do not have a sign in sheet or agenda for that meeting. Moving forward from that meeting, we were planning on having the field nurse I mentioned go out with clinicians to provide hands on teaching and meet with them after the visit to review how best to interpret the visit based on the OASIS collection. She was asked if any of those visits took place. She stated, “She did some visits with newer staff, but she did not get to any longer established staff.” She was asked if there was any documentation of data collected from the visits that were conducted. She stated, “No. The plan going forward is to do small group trainings in the office consisting of mainly going over the OASIS questions.” On 12/19/24 at 10:45am, in an interview with the Officer Manager, she stated “We are so small of a company, that we know all the patients and staff, and we don’t really have any data in writing, we just know who is doing what and who is improving, but I see what you are saying, that we should be able to show the data to show if we have improvement or we don’t have improvement.” A review of the agency policy titled “Quality Assurance and Performance Improvement” (undated) revealed: Policy: Agency shall establish a QAPI plan to continuously measure, assess, and improve the performance of clinical and other processes. This plan will be based on the organization’s mission and goals and designed to improve patient outcomes and the perceptions of clients/families about the quality and value of services. The agency will adopt a performance improvement model to guide the process. Agency’s QAPI plan is reviewed annually and revised as necessary. Special Instructions: 2. Data will be collected to allow the agency to monitor its performance. 4. Data will be systematically collected to measure process, outcome, and quality indicators.”

“Participate in the HHA’s QAPI program; CFR(s): 484.75(b)(8) Participation in the HHA’s QAPI program; and This Element is not met as evidenced by: Based on staff interviews and agency policy and procedure review, it was determined that the agency failed to ensure skilled staff provided input and participated in the agency’s Quality Assessment and Improvement (QAPI) plan. The findings include: In an interview with the Director of Nursing (DON) and Alternate Director of Nursing (ADON) on 12/19/24 at 9:30am, there were asked to review the agency’s Quality Assurance and Performance Improvement (QAPI) plan. They were who participates in the agency’s QAPI committee. The DON stated the Administrator, the Office Manager, and the Billing Supervisor. He was asked if he and the ADON and any field clinicians are on the QAPI committee. He stated no, we don’t go to the meetings. He was asked if he or the ADON had attended any of the last four QAPI meetings. He stated no, the ADON also stated no. He was asked if any of the agency skilled staff had attended or participated in any QAPI meetings in the past year. He stated no. He was asked to provide the QAPI agenda sign in sheet/agenda for the past year. He provided three agendas. One was dated 1/22/24, one was dated 4/29/24, and one was dated 7/5/24. Each showed in attendance were the Administrator, the Office Manager, and the Billing Supervisor. The agendas were each titled “Board of Managers Meeting”. The DON was asked if these agendas represented the quarterly QAPI meetings. He stated yes. The DON was asked if the agency Medical Director attended these QAPI meetings in person or by phone. He stated no. He was asked to confirm if he, the ADON, or any field clinicians had attended the meetings for the agendas provided. He stated no, he and the others had not attended. On 12/19/24 at 10:45am, in an interview with the Office Manager, she stated “The agendas that were provided by the DON and ADON were more like board of directors meetings, but that’s what we have for the QAPI meetings.” She was asked if the DON and ADON attend these meetings. She stated no, they were not at any of the meetings. She was asked if the Medical Director had attended any of the meetings, either in person or by phone. She stated no. She was asked if any of the agency’s skilled staff had attended any of the QAPI meetings in the past year. She stated no. A review of the agency policy titled “Quality Assurance and Performance Improvement” (undated) revealed: Special Instructions: Program will reflect participation by all services and level of staff.”