Elite Home Health Group LLC

“Transfer and discharge CFR(s): 484.50(d) Standard: Transfer and discharge. The patient and representative (if any), have a right to be informed of the HHA’s policies for transfer and discharge. The HHA may only transfer or discharge the patient from the HHA if: This Standard is not met as evidenced by: Based on review of the Home Health Agency (HHA)’s Policy and Procedure, record review and interview, the Home Health Agency (HHA) failed to follow their own Policy and Procedure to ensure that their patients received a Notice of Medicare Non-Coverage (NOMNC) form prior to discharge from the HHA’s services for 3 of 3 sampled patients (Patient #3, #4, and #5). The findings Included: 1) Review of the HHA’s Policy and Procedure, provided by the Director of Nursing (DON) titled, “Transfer and Discharge policy” undated, documents, “…at least 2 days before discharge (final) visit, the patient/client will receive the notice of discharge, with instructions on the purpose of the form. The patient will be required to sign the Notice of Medicare Non-Coverage (NOMNC)…at the visit before discharge (at least two days prior to discharge) …he/she will be given instructions of Right to Appeal the decision to discharge…”. On 01/08/24 at 12:15 PM, during an interview and a side-by-side review of Patient #3’s record with the DON reveals documentation of a “Start of Care” on 07/26/23 for Skilled Nursing visits and Physical Therapy evaluation. Further review reveals a “Recertification Assessment” visit, dated 09/21/23 done by the Physical Therapist (PT) that documented the PT frequency as two times a week for two weeks and then once a week for five weeks; the DON stated that the Skilled Nursing visits were discontinued, and PT continued with therapy until discharge. Continued review reveals a “Discharge Assessment” visit, dated 11/07/23 done by the PT; the DON stated that patient’s therapy goals were met; Patient #3 was discharged by PT on 11/07/23 and the PT did the “Discharge Assessment;” the DON searched Patient #3’s clinical record and the HHA’s office for documents to be uploaded to the patient’s record and stated she did not see a NOMNC done for this patient. During the review and interview, on 01/08/24 at 12:15 PM, the DON stated that the HHA only takes “Traditional Medicare” insured patients and no other insurances plans; he DON stated that when a patient is ready for discharge, the field nurse calls the doctor, lets the provider know that the patient has been discharged, then the nurse completes a “Discharge Assessment,” fills out the NOMNC form and the patient receives a copy; the DON stated that every discharged patient needs a NOMNC done by either a Skilled Nurse or PT, regardless of the patient being discharged by a Skilled Nurse or PT; the DON added that it’s been a “thorn in her side” trying to get them in and the DON stated the NOMNC is done 2-3 days before discharge. On 01/08/24 at 12:44, a telephone interview was conducted with Staff A, Registered Nurse (RN) who has worked for the HHA for 2 years; Staff A stated she does home visits, “Start of Care, Recertification and Discharge Assessments,” Staff A stated that she completes a NOMNC form, the second to the last visit for the patient to appeal if they want to appeal. On 01/08/24 at 12:52 PM, an interview was conducted Staff B, RN who has worked for the HHA for 8 and half years; Staff B stated she does “Infusion Therapy, Wound Care, Supervisory visits, and Discharge Assessments;” Staff B stated that 2-3 days before a patient’s discharge, she will provide the patient with the NOMNC form and give a copy to the patient. On 01/08/24 at 2:41 PM, a telephone interview was conducted with Staff C, Physical Therapist (PT) who stated that his Physical Therapy Assistant (PTA) will follow the cases, and 48 hours prior to the patient’s discharge, the PTA gets the Notice of Medicare Non-Coverage (NOMNC) form completed, if not he gets the form done when he does the last visit; Staff C stated he believed Patient #3’s NOMNC was completed and sent to the Home Health Agency; Staff C was apprised that the DON was not able to find the competed form. 2) On 01/08/24 at 1:52 PM, during an interview and side-by-side review of Patient #4’s record was conducted with the DON that reveals the patient’s record documents a “Start of Care on 05/20/23 for Skilled Nursing visits and Physical Therapy Evaluation. Further review reveals a “Recertification Assessment” visit dated 09/14/23 done by the Skilled Nurse documented the Skilled Nurse visit frequency two times a week for two weeks, then one time a week for one week and PT frequency two times a week for two weeks and then once a week for five weeks; the DON stated that the Skilled Nursing visits were discontinued, and PT continued with therapy until discharge. Continued review revealed a “Discharge Assessment” visit dated 10/13/23 done by the PT; the DON stated that patient’s therapy goals were met; Patient #4 was discharged by PT on 10/13/23 and added that PT did the “Discharge Assessment” but did not do the NOMNC; the DON searched for Patient #4’s completed NOMNC and stated she did not see a NOMNC done for the patient; during the review, the DON stated that the HHA only takes Traditional Medicare insured patients, and no other insurance plans; the DON stated that when a patient is ready for discharge, the field staff calls the doctor, lets the provider know that the patient has been discharged, then the Nurse or PT completes a “Discharge Assessment, and fills out the NOMNC. On 01/08/23 at 2:00 PM, during an interview, the DON stated that the NOMNC form is part of the patient’s admission folder and is left in the home for when the patient is discharged; the DON stated that every discharged patient needs a NOMNC done 2-3 days before discharge; that she tries to do staff meetings monthly and every meeting she brings up the problem related to the NOMNC not been done on discharge. 3) On 01/08/24 at 2:01 PM, during an interview and a side-by-side review of Patient #5’s record was conducted with the DON; the patient’s record documented the “Start of Care” on 09/01/23 for Skilled Nursing visits for wound care with a visit frequency of one time a week for one week, then three times a week for four weeks. Continued review reveals a “Discharge Assessment visit dated 12/22/23 done by the Skilled Nurse; the DON stated that the wound was healed, and the patient was discharged by the Skilled Nurse on 12/22/23; the DON added that the Skilled Nurse did the “Discharge Assessment but did not do the NOMNC. The DON searched for Patient #5’s completed NOMNC and stated she did not see a NOMNC done for the patient. On 01/08/24 at 2:01 PM, during the interview, the DON stated that Skilled Nurse was out of the country and not available for an interview. During the review and interview, on 01/08/24 at 2:01 PM, the DON stated that when a patient was ready for discharge, the field nurse calls the doctor, lets the provider know that the patient has been discharged, then the nurse completes a “Discharge Assessment, and fills out the NOMNC form; the DON stated that every discharged patient need a NONMC and added that it’s been “a thorn in her side” trying to get them (NOMNC Forms) in and the NOMNC is done 2-3 days before discharge.”