Ochsner Home Health of Covington

“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 and interviews, the agency failed to encode and electronically transmit each completed OASIS (Outcome and Assessment Information Set) as evidenced by failing to ensure the agency successfully completed and transmitted OASIS data within 30 days of completion (M0090 date). Findings: Review of the agency’s policy on 03/22/2024 titled “Encoding and Reporting Oasis Data” dated 02/01/2021, revealed, in part: Policy: Agency staff will capture and transmit OASIS data accurately to the appropriate State Agency. Procedure: 2. Transmittal of Oasis data: a. At least monthly, all Oasis assessments completed must be transmitted within thirty (30) days of M0090 date. Review of the agency’s OASIS Final Validation Reports with a submission date of 03/06/2024 revealed 54 out of 86 records were submitted greater than 30 days after the M0090 completion date. Further record review of the Final Validation Report dated 03/13/2024 revealed 28 out of 117 records were submitted greater than 30 days after the M0090 completion date, which was late. On 03/19/2024 at 10:45 a.m., an interview was conducted with S7BM. She confirmed she was responsible for reviewing all Final Validation Reports for OASIS submissions for this agency and recorded the accepted or rejected Oasis data status only. She stated the agency’s corporate office Quality Review team performed the Oasis quality review, locked the Oasis, and submitted all completed OASIS weekly. She stated corporate emailed the OASIS Final Validation Reports to her and she forwarded the reports to S1ED for review. The agency’s Final Validation Reports for 03/06/2024 and 03/13/2024 were reviewed. S7BM confirmed the Oasis assessments aforementioned on these dates were submitted after the 30 days of the M0090 completion date and were late. On 03/22/2024 at 4:00 p.m., an interview was conducted with S1ED. S1ED confirmed all Oasis assessments should be transmitted by the agency within 30 days of the M0090 date. The aforementioned validation reports were reviewed for the submission dates of 03/06/2024 and 03/13/2024. S1ED confirmed the OASIS assessments aforementioned on these dates were submitted after the 30 days of the M0090 completion date and were late.”

“A review of all current medications CFR(s): 484.55(c)(5) A review of all medications the patient is currently using in order to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy. This Element is not met as evidenced by: Based on observation, interviews, and record reviews, the agency failed to ensure the medication profile accurately reflected all medications patients were using and/or did not reflect medications the patients were no longer using for 4 (#1, #3, #4, and #7) of 7 (#1, #2, #3, #4, #5, #6 and #7) sampled patients reviewed who received home visits. Review of the agency’s policy on 03/22/2024 titled “Monitoring Medications”, with effective date of 12/01/2023, revealed the following: Purpose: To provide a process to ensure continuous monitoring of medication in the patient’s home Policy: A drug regimen review will be performed on all patients in conjunction with all comprehensive assessments. Additionally, all clinicians will participate in medication review and reconciliation throughout the episode. Procedure: 1. the discipline responsible for the drug regimen review will: a. Compare medication list obtained from the facility from which the patient was transferred and/or physician orders to actual medications patient is taking. b. Review all medications including over the counter (OTC) medications, vitamins, herbs, and herbal products, creams and topical ointments, and medical marijuana (in states where legalized), to identify issues such as: vii. Dosage Errors viii. Drug omissions c. Notify the physician the physician of any of the above identified issues/discrepancies. Findings: Patient #1 Review of the clinical record revealed a start of care date of 01/19/2024. The patient’s primary diagnosis was Type 2 Diabetes Mellitus with Other Specified Complication, Other Osteomyelitis, Ankle and Foot. A review of the Home Health Certification and Plan of Care/485 for the Certification Period of 01/19/2024 to 03/18/2024 revealed orders which included SN 1W1, 2W8 effective week of 01/19/2024. ROC orders dated 03/13/2024 were unavailable. A review of SN visit documentation revealed SN visits were conducted with Patient #1 on the following dates during the current Certification Period of 01/19/2024 since ROC (Resumption of Care) date 03/13/2024: 03/13/2024, 03/15/2024, and 03/18/2024. A current medication profile list was provided by S2PCM on 03/18/2024. On 03/18/2024 at 1:30 p.m., a home visit was conducted in the home of Patient #1. Review of the medications listed on the patient’s current medication profile list provided by the agency revealed the following discrepancies when compared with medications in the home: Hydrocodone 7.5mg-Acetaminophen 325mg one tablet every 6 hours as needed for pain. This medication was not in the home. Insulin Lispro (Humalog) 100 units/ml Subcutaneous Pen 3 units two times daily with breakfast and lunch. Patient taking differently. Insulin Lispro (Humalog) 100 units/ml Subcutaneous Pen- 5 units every PM with Supper. Patient taking differently. Humalog 100 units/ml Sliding Scale as follows: 160-230= add 1 unit; 231-280= add 2 units; 281-330= add 3 units; 331-380= add 4 units; >380= add 5 units. Correction max total/day= 60 units. Sliding scale not on 485 orders, patient taking. The patient was alert and oriented times three and stated he was familiar with all his current medications. Patient #1 verified he did not have any Hydrocodone available in the home and was no longer taking Hydrocodone. Patient #1 verified he was taking 12 units of Insulin Lispro + Sliding scale Humalog (Insulin Lispro) before meals. An interview was conducted with S3RN during the home visit. She stated she was not aware the patient was taking his Insulin Lispro differently since returning from a hospital stay on 03/13/2024 and had just taken over his care. She stated all medications should be updated every visit, and the patient’s medication list should accurately reflect what the patient is taking. Patient #3 Review of the clinical record revealed a start of care date of 02/27/2024. The patient’s primary diagnosis was Benign Prostatic Hyperplasia with Lower Urinary Tract Symptoms, Other Retention of Urine, and Neuromuscular Dysfunction of Bladder. A review of the Home Health Certification and Plan of Care/485 for the Certification Period of 02/27/2024 to 04/26/2024 revealed orders which included SN 6W1, 1W8 effective week of 01/19/2024, PT 2W4, 1W3 and ST 1W1. A review of SN visit documentation revealed SN visits were conducted with Patient #3 on the following dates during the current Certification Period of 02/27/2024 to present: 02/27/2024, 03/012024, 03/07/2024, 03/12/2024, and 03/19/2024. A current medication profile list was provided by S2PCM on 03/18/2024. On 03/19/2024 at 9:00 a.m., a home visit was conducted in the home of Patient #3, with the patient’s daughter in law present during the visit. She verified she was familiar with the patient’s medications and stated Patient #3’s son prepared his medications using a 2-week medication planner. Review of the medications listed on the patient’s current medication profile list provided by the agency revealed the following discrepancies when compared with medications in the home: Azelastine 137mcg nasal spray- patient not taking, not in home. Hibiclens 4% topical liquid- patient not taking. Lactulose 20 grams- patient not taking. Hemorrhoidal suppository 0.25%- patient not taking. Polyethylene Glycol 17gram daily as needed- patient not taking. Sucralfate 100mg/ml 10ml 4 times a day- patient not taking. Systane Hydration PF 0.4%-0.3%- take 2 drops in each eye two times daily- not in home- patient not taking. Cefalexin 500mg twice a day x 7 days, filled 03/12/2024- script RX # 4884626-03990- not on med list. An interview with S4LPN was conducted during the home visit. She verified Patient #3’s medication list did not reflect current medications in the home the patient was taking and should have. She stated all staff should review home medications every visit and make updates in the electronic health record accordingly. Patient #4 Review of the clinical record revealed a start of care date of 03/10/2024. The patient’s primary diagnosis was Alcohol Use, Unspecified with Intoxication, Unspecified, and Chronic Kidney Disease, and Chronic Diastolic Congestive Heart Failure. A review of the Home Health Certification and Plan of Care/485 for the Certification Period of 03/10/2024 to 05/08/2024 revealed orders which included SN 2W1, 1W8, PT 2W2, 1W6, OT 1W1, MSW 1W1, 1Every2WK2, and HHA 1W3. A review of SN visit documentation revealed SN visits were conducted with Patient #4 on the following dates during the current Certification Period of 03/10/2024 to present: 03/10/2024; 03/13/2024-phone visit, and 03/20/2024. A current medication profile list was provided by S2PCM on 03/18/2024. On 03/19/2024 at 10:15 a.m., a home visit was conducted in the home of Patient #4 with S5HHA present. Review of the medications listed on the patient’s current medication profile list provided by the agency revealed the following discrepancies when compared with medications in the home: Hydrochlorothiazide 12.5mg one tablet daily with fill date of 03/15/2024, present in the home, not on current agency medication list. Cetirizine 10mg one tablet daily with fill date of 03/12/2024, present in the home, not on current agency medication list. Patient #4’s niece and brother were present in the home. Patient #4’s niece and brother both verified Patient #4 had been on the Hydrochlorothiazide and Cetirizine since last week. Patient #7 Review of the clinical record revealed a start of care date of 03/10/2024. The patient’s primary diagnosis was Acute Kidney Failure, Unspecified, and Chronic Kidney Disease Requiring Chronic Dialysis. A review of the Home Health Certification and Plan of Care/485 for the Certification Period of 03/10/2024 to 05/08/2024 revealed orders which included SN 5W1, 2W7, 1W1; PT 2W4, 1W5, OT 2W3, 1W1. A review of SN visit documentation revealed SN visits were conducted with Patient #7 on the following dates during the current Certification Period of 03/10/2024 to present: 03/10/2024, Missed Visit 03/15/2024 and 03/16/2024. A current medication profile list was provided by S2PCM on 03/18/2024. On 03/21/2024 at 9:00 a.m., a home visit was conducted in the home of Patient #7. Review of the medications listed on the patient’s current medication profile list provided by the agency revealed the following discrepancies when compared with medications in the home: Furosemide 40mg tablet daily was in the home included with current medication bottles. Further record review revealed Patient #7’s After visit summary medication orders, dated 03/14/2024 from his physician’ office, revealed no orders for Furosemide 40mg daily. The patient was alert and oriented times three. He stated his daughter helped prepare his medications, and he was aware of his current medications. He stated no one had instructed him he should not take Furosemide. An interview with S6PT was conducted during the home visit. She stated all staff should review the patient’s home medications every visit. S6PT verified Patient #7’s medication list was not up to date and did not reflect the current medications he should be taking. She stated Patient #7 and his caregiver should have been instructed to discontinue the Furosemide as of 03/14/2024 and were not. On 03/22/2024 at 4:00 p.m., S1ED verified all staff should reconcile all medications in the home on every visit. Patients #1, #3, #4, and #7’s Medication lists provided by the agency were reviewed with S1ED. S1ED confirmed the medication lists for Patients #1, #3, #4 and #7 were inaccurate, and should have been updated to reflect all current medications present and in use in the home and were not.”

“Last 5 days of every 60 days unless: CFR(s): 484.55(d)(1)(i,ii,iii) The last 5 days of every 60 days beginning with the start-of-care date, unless there is a- (i) Beneficiary elected transfer; (ii) Significant change in condition; or (iii) Discharge and return to the same HHA during the 60-day episode. This Element is not met as evidenced by: Based on record review and interviews, the agency failed to ensure a comprehensive assessment was completed in the last 5 days of every 60-day certification period for 1 (Patient #11) of 17 (Patients #1-#17) clinical records reviewed. Findings: Patient #11 Review of the clinical record revealed a start of care date of 12/09/2023. The patient’s primary diagnosis was Displaced Fracture of 1st Metatarsal Bone, Left Foot, Subsequent Encounter and Chronic Venous Insufficiency. A review of the Home Health Certification and Plan of Care/485 for the Certification Period of 02/07/2024 to 04/06/2024 revealed orders for Skilled Nurse: 3W1, 2W3, 1W4 + 2 PRN for wound complications effective week of 02/11/2024. Further record review revealed no documented evidence a skilled nurse visit had been completed during the last 5 days of the Certification period dated 12/09/2023-02/06/2024. A review of the skilled nurse (SN) visit documentation, provided by S12PCM on 03/22/2024, revealed Patient #11’s Recertification visit, completed 02/08/2024 by S8RN, was not completed within the last 5 days of the prior Certification period ending 02/06/2024. On 03/22/2024 at 1:02 p.m., an interview was conducted with S12PCM. S12PCM confirmed Patient #11’s recertification OASIS assessment was completed late and should have been performed within the last 5 days of the prior certification period ending 02/06/2024. S12PCM stated the patient’s physician had not clarified wound care orders timely and her recertification was late and should not have been. On 03/22/2024 at 4:00 p.m., an interview was conducted with S1ED. S1ED stated all recertification OASIS assessments should be completed timely within the last 5 days of the 60-day certification period. S1ED confirmed Patient #11’s Oasis Recertification assessment, dated 02/08/2024, revealed no documented evidence of why the assessment was late. S1ED confirmed Patient #11’s Recertification OASIS should have been performed in the last 5 days of Patient #11’s 60-day certification period and was not.”