Elara Caring

“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 interview, the agency failed to ensure each OASIS (Outcome and Assessment Information Set) was successfully transmitted to the CMS system within 30 days of completion. Review of the agency’s policy titled, “Encoding and Reporting Oasis Data” dated 09/09/2020 revealed the following, in part: Policy Overview: The agency will electronically report all OASIS data collected in accordance with federal regulations. Procedure: 1. The agency will submit individual client assessment data within 30 days of completing the comprehensive assessment. This will be done within 30 days of the day the OASIS was completed. Review of the agency’s OASIS Final Validation Report with a submission date of 06/07/2024 revealed 9 records were processed with 1 record receiving a message in which the record was submitted late due to a submission date of more than 30 days after date on the record. Review of the agency’s OASIS Final Validation Report with a submission date of 06/11/2024 revealed 12 records were processed with 1 record receiving a message in which the record was submitted late due to a submission date of more than 30 days after date on the record. Review of the agency’s OASIS Final Validation Report with a submission date of 06/27/2024 revealed 5 records were processed with 1 record receiving a message in which the record was submitted late due to a submission date of more than 30 days after date on the record. Review of the agency’s OASIS Final Validation Report with a submission date of 08/28/2024 revealed 11 records were processed with 1 record receiving a message in which the record was submitted late due to a submission date of more than 30 days after date on the record. An interview was conducted with S1ADM on 11/13/2024 at 3:00 p.m. She reviewed the agency’s OASIS validation reports and verified the above records were submitted late. She confirmed the OASIS records should have been submitted within 30 days of completion.”

“Accuracy of encoded OASIS data CFR(s): 484.45(b) Standard: The encoded OASIS data must accurately reflect the patient’s status at the time of assessment. This Standard is not met as evidenced by: Based on record review and interviews, the agency failed to ensure the OASIS data accurately reflected the patient’s status at the time of assessment. The agency inaccurately documented a patient’s discharge status for 1 (#12) of 4 (#10, #11, #12, and #13) patient discharge records reviewed. Findings: Review of Patient #12’s Clinical Record revealed he began receiving services from the Home Health Agency on 07/27/2023, had a Certification Period of 07/27/2023 to 09/24/2023 and was discharged from the agency on 09/21/2023. Review of Patient #12’s Coordination Notes dated 09/18/2023 revealed the following, in part: Patient currently at a local hospital Room 4258. Review of the Discharge OASIS dated 09/21/2023 for Patient #12 and completed by S2RN revealed the following, in part: Discharge/Inpatient Admission: To which inpatient facility has the patient been admitted to? NA-No Inpatient Facility Admission Discharge Disposition: Where is the patient after discharge from your agency? 1-Patient remained in the community (without formal assistance services) An interview was conducted with S2RN on 11/13/2024 at 8:40 a.m. She stated Patient #12 was admitted to the hospital at the end of his certification period. She confirmed Patient #12’s Discharge OASIS dated 09/21/2023 was not accurately coded and should have been. An interview was conducted with S1ADM on 11/12/2024 at 2:00 p.m. She reviewed Patient #12’s coordination notes and Discharge OASIS dated 09/21/2023. She confirmed the last coordination note in the clinical record dated 09/18/2023 stated the patient was at the hospital. She confirmed the Discharge OASIS was not accurately coded and should have been.”

“Services by skilled professionals CFR(s): 484.75(a) Standard: Provision of services by skilled professionals. Skilled professional services are authorized, delivered, and supervised only by health care professionals who meet the appropriate qualifications specified under §484.115 and who practice according to the HHA’s policies and procedures. This Standard is not met as evidenced by: Based on interview and record review, the home health agency failed to ensure the RN provided home health agency services in accordance with current clinical practice guidelines and accepted professional standards for 2 (#9 and #12) of 4 (#1, #9, #12 and #13) patients reviewed for pressure ulcers. The agency failed to ensure the RN assessed and staged Patient #9 and #12’s pressure wounds on a weekly basis. Review of the Louisiana State Board of Nursing, Declaratory Statement Scope of Practice for Registered Nurses - Wound Care Management revealed, in part, the following: Registered nurses render care that is directed towards the prevention and the treatment of wounds. Scope of Practice - The Louisiana State Board of Nursing recognizes that assessment, planning, intervention, teaching, evaluation, and supervision are the major responsibilities of the registered nurse in the practice setting. The Registered nurse initiates appropriate wound prevention measures, stages wounds and collaborates with the wound care team in the implementation and evaluation of nursing interventions as prescribed by the authorized prescriber. Review of the National Pressure Ulcer Advisory Panel Prevention and Treatment of Pressure Ulcers: Quick Reference Guide revealed, in part, the following: Pressure Ulcer Assessment 1. Assess the pressure ulcer initially and re-assess it at least weekly. 1.1. Document the results of all wound assessments. Assess and document physical characteristics including: location, Category/Stage, size, tissue type(s), color, peri-wound condition, wound edges, sinus tracts, undermining, tunneling, exudate, and odor. Review of the agency’s policy titled “Wound Measurement” dated 12/04/2019, revealed the following, in part: Procedures: g. Documentation of wound measurements is a part of the required documentation for all wound care procedures. Review of the agency’s policy titled “Assessment/Staging of Pressure Ulcers” dated 12/04/2019, revealed the following, in part: Pressure Ulcer Assessment Guide 1. In assessing the pressure ulcer, the following parameters should be addressed consistently. Site, stage of ulcer and size of ulcer. ( include length, width and depth) Patient #9 Review of the Clinical Record for Patient #9 revealed she began receiving services from the Home Health Agency on 03/29/2023 and had a current Certification Period of 09/19/2024 to 11/17/2024. Patient #9 had diagnoses, which included Pressure Ulcer of Sacral Region, Stage 3. Review of the current Physician’s Orders for Patient #9 revealed the following, in part: Cleanse the wound with wound cleanser and gauze. Pat dry with gauze, apply moistened collagen to wound bed. Apply 2x2 hydrocolloid with foam boarder dressing to prevent saturation from urine and feces. Change 2 times a week excluding wound care days and prn if soiled or dislodged. Review of the Skilled Nursing Visit notes conducted for Patient #9 for Certification Period 09/19/2024 to 11/17/2024 revealed Patient #9’s Sacral Pressure Ulcer, Stage 3 was not assessed to include measurements of the Pressure Ulcer the weeks of 10/07/2024 and 10/14/2024. Patient #12 Review of the Clinical Record for Patient #12 revealed he began receiving services from the Home Health Agency on 07/27/2023, had a Certification Period of 07/27/2023 to 09/24/2023, and was discharged from the agency on 09/21/2023. Patient #12 had diagnoses, which included Hemiplegia Following Cerebral Infarction Affecting Right Dominant Side. Review of the Skilled Nursing Visit notes conducted for Patient #12 for Certification Period 07/27/2023 to 09/24/2023 revealed Patient #12’s Right Buttock Pressure Ulcer, Stage 2 with an onset date of 09/06/2023 was not assessed to include measurements by an RN the weeks of 09/06/2023 and 09/10/2023. An interview was conducted on 11/13/2024 at 3:00 p.m. with S1ADM. She verified pressure wounds should be assessed and measured by a Registered Nurse at least weekly. She confirmed a Registered Nurse had not assessed or measured Patient #9 and #12’s wounds listed above weekly.”

“Provide services in the plan of care CFR(s): 484.75(b)(3) Providing services that are ordered by the physician or allowed practitioner as indicated in the plan of care; This Element is not met as evidenced by: Based on record reviews and interview, the agency failed to ensure services ordered by the Physician were provided as indicated in the Plan of Care as evidenced by: 1. Home Health Aide (HHA) visits were not conducted as ordered for 1 (#11) of 4 (#5, #7, #8 and #11) patient records reviewed with orders for Home Health Aide services; and 2. Home Health Therapy visits were not conducted as ordered for 1 (#12) of 9 (#2, #3, #4, #7, #8, #10, #11, #12, and #13) patient records reviewed with orders for Home Health Therapy services. Findings: Patient #11 Review of Patient #11’s Clinical Record revealed she began receiving services from the Home Health Agency on 08/02/2023, had a Certification Period of 08/02/2023 to 09/30/2023, and was discharged from the agency on 09/29/2023. Patient #11 had diagnoses, which included Hypertensive Heart Disease with Heart Failure, Acute on Chronic Diastolic Congestive Heart Failure, Acute Respiratory Failure with Hypoxia, and Unspecified Obesity. Further review revealed a physician’s order dated 08/01/2023 for admit to home health, Aide to provide assistance with personal care, ADLs, and vital signs. Review of Patient #11’s Client Calendar Report revealed no documentation of HHA visits for the Certification Period 08/02/2023 to 09/30/2023. Patient #12 Review of Patient #12’s Clinical Record revealed he began receiving services from the Home Health Agency on 07/27/2023, had a Certification Period of 07/27/2023 to 09/24/2023, and was discharged from the agency on 09/21/2023. Patient #12 had diagnoses, which included Hemiplegia Following Cerebral Infarction Affecting Right Dominant Side and Personal History of Malignant Neoplasm of Large Intestine. Further review revealed a physician’s order dated 07/25/2023 for admit to home health, Home Health Therapy to be continued upon discharge. Review of Patient #12’s Client Calendar Report revealed no documentation of Home Health Therapy visits for the Certification Period 07/27/2023 to 09/24/2023. An interview was conducted with S1ADM on 11/12/2024 at 2:00 p.m. She reviewed Patient #11’s clinical record and physician orders dated 08/01/2023. She confirmed the physician ordered Home Health Aide services. She further confirmed there was no documentation as to why the HHA services were not provided or the physician being notified Aide services were not provided and there should have been. She reviewed Patient #12’s clinical record and physician orders dated 07/25/2023. She confirmed the physician ordered Home Health Therapy services. She further confirmed there was no documentation as to why the Therapy services were not provided or the physician being notified Therapy services were not provided and there should have been.”

“Communication with physicians CFR(s): 484.75(b)(7) Communication with all physicians involved in the plan of care and other health care practitioners (as appropriate) related to the current plan of care; This Element is not met as evidenced by: Based on record reviews and interviews, the agency failed to ensure a Physician was notified regarding a change in patient’s status as evidenced by the agency failing to: 1. Ensure pain was communicated to the Physician for 1 (#10) of 13 (#1-#13) patients record reviewed; and 2. Ensure a low Potassium level was communicated to the Physician for 1 (#12) of 13 (#1-#13) patients records reviewed; Patient #10 Review of Patient #10’s Clinical Record revealed she began receiving services with the agency on 08/13/2024 and had a certification period of 08/13/2024 to 10/11/2024. Patient #10 had diagnoses, which included Interstitial Pulmonary Disease. Further review revealed Patient #10 received Physical Therapy services two times a week for three weeks and one time a week for one week. Review of Patient #10’s Coordination Notes for certification period 08/13/2024 to 10/11/2024 revealed no notification to the Physician of Patient #10’s leg pain. Review of Patient #10’s Physical Therapy Assistant’s notes revealed the following, in part: 09/17/2024 -Patient continues to have leg pain with standing/walking. Signed S3PTA. 09/19/2024-Patient participation in therapy continues to be limited by pain. Patient has not been compliant with home exercise program and spends most of the day in bed due to pain at legs/low back. Signed S3PTA. An interview was conducted on 11/13/2024 at 8:00 a.m. with S3PTA. She said she was unsure if she notified Patient #10’s Physician regarding her continued leg pain. She said if she would have notified the Physician, it would have been documented in Patient #10’s Clinical Record. An interview was conducted on 11/13/2024 at 11:15 a.m. with S1ADM. She reviewed Patient #10’s visit notes dated 09/17/2024 and 09/19/2024 and confirmed S3PTA should have informed Patient #10’s Physician of her pain and decreased participation in physical therapy and did not. Patient #12 Review of Patient #12’s Clinical Record revealed he began receiving services from the Home Health Agency on 07/27/2023, had a Certification Period of 07/27/2023 to 09/24/2023 and was discharged from the agency on 09/21/2023. Patient #12 had diagnoses, which included Hemiplegia Following Cerebral Infarction Affecting Right Dominant Side, Type 2 Diabetes Mellitus, Essential Hypertension, and Personal History of Malignant Neoplasm of Large Intestine. Further review revealed Patient #12 received Skilled Nursing Visits once weekly for nine weeks for the Certification period of 07/27/2023 to 09/24/2023. Review of Patient #12’s Plan of Care dated 07/27/2023 revealed the following, in part: Skilled Nurse to obtain blood specimen via venipuncture for labs as ordered CBC, Chem 7 in 1 week. Obtain lab results and report to physician. Review of Patient #12’s Laboratory Results dated 08/10/2023 revealed the following, in part: Potassium 3.0 mmol/L Low, Reference Interval (3.5-5.2) Review of Patient #12’s Nurses’ Notes dated August 2023 revealed no documented evidence the physician was notified or the agency followed up regarding Patient #12’s low Potassium results on 08/10/2023. An interview was conducted with S1ADM on 11/12/2024 at 2:00 p.m. She reviewed Patient #12’s clinical record and laboratory results dated 08/10/2023 and confirmed the patient had a low Potassium level of 3.0. She stated Patient #12’s laboratory results were faxed to the physician on 08/11/2023. She confirmed there was no documentation the agency staff communicated or followed up with Patient #12’s physician regarding the Potassium level of 3.0. She stated a patient with a low Potassium level would warrant a follow up phone call from the agency to the physician. She confirmed a Potassium level outside of therapeutic range could have affected Patient #12’s health.”