Ortonville Area Health Services Home Health Agency

“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 document review and interview, the agency failed to timely encode and submit Outcome and Assessment Information Set (OASIS) in accordance with the Center for Medicare (CMS) requirements. Based on document review and interview, the agency failed to timely encode and submit Outcome and Assessment Information Set (OASIS) in accordance with Center for Medicare (CMS) requirement. On the HHA Error Summary by Agency report, with run date of 2/4/25, the agency had an error code of -3330: record submitted late. The description included was the submission date was more than 30 days after M0090 on the new record. The report identified the number of assessments with this error code was 30 assessments, with 30 assessments completed and submitted. During interview on 2/25/25, at 11:00 a.m. 2/25/25 11:30 a.m., registered nurse, clinical care coordinator, (RN/CCC)-A stated with the current process, there was not an assistant who reviewed the OASIS documents for her prior to submission. RN/CCC-A stated if there were corrections to be made, or errors which needed to be corrected, there was a delay in the process. RN/CCC-A stated with her current responsibilities; the OASIS submission was not always completed in a timely process. A policy was requested for submission of the OASIS assessment; however, RN/CCC-A stated the process was completed by use of CMS guidance on their website, and a separate agency policy was not available for viewing.”

“RN performs assessment CFR(s): 484.55(a)(1) A registered nurse must conduct an initial assessment visit to determine the immediate care and support needs of the patient; and, for Medicare patients, to determine eligibility for the Medicare home health benefit, including homebound status. The initial assessment visit must be held either within 48 hours of referral, or within 48 hours of the patient’s return home, or on the physician or allowed practitioner - ordered start of care date. This Element is not met as evidenced by: Based on interview and document review, the agency failed to ensure each patient had an initial assessment visit within 48 hours of their referral date for 1 of 3 active patients (P3), selected for record review only. P3’s Home Health Certification Start of Care/ Recertification Plan of Care (POC), effective from 1/5/25 to 3/5/25 indicated P3’s start of care date was 3/11/24. P3’s medical diagnoses included the following: chronic diastolic (congestive) heart failure, hypertension, chronic kidney disease, chronic atrial fibrillation, type 2 diabetes mellitus, atherosclerotic heart disease without angina pectoris, hypertrophic cardiomyopathy, long term use of anticoagulants, presence of heart valve and cardiac pacemaker, and history of nicotine dependence. P3’s plan of care identified the plan of service to include a weekly nursing visit to assess general and mental health status, weight, mobility, safety, diabetic management/teach to deficits, set up medications and assess compliance, and to assess with chronic disease management. On 2/27/24, a Clinic Home Health Referral was sent from P3’s primary provider to the agency, however, record review indicated his start of care (SOC) was 3/11/24. P3 was initially referred for home care by his primary care provider following a hospitalization from 2/23/25-2/27/24. P3’s initial request for services from the home health agency were to assist with medication management and education. P3 was identified as having shortness of breath at rest, and/or with daily activities. A review of the narrative notes lacked any indication as to why the start of care was delayed. On 2/25/25, at 1:30 p.m., director of nursing (DON) stated upon receipt of the referral on 2/27/25, outreach was made to the Veterans Administration (VA) to determine if perhaps P3 was eligible for this service through his VA benefits. CCC-A stated she was unable to find documentation to reflect this was the reason for delay, or to demonstrate the agency obtained a deferred admission date until funding resources could be verified. A facility policy, Provision of Services and Development of Written Materials for Communication with Clients-Ortonville, dated 10/31/24, indicated acceptance for admission to home health is based on reasonable expectations that the patient’s needs can be adequately met by services provided by OAHS (Ortonville Area Health Services) professional home health staff and services must be ordered by a physician. The policy identified the patient would be informed of the agency’s decision to accept or not accept patient for admission. All patients will be admitted only if OAHS Home Health has the ability to provide safe, professional, and competent care at the level or intensity needed. The policy lacked definition as to the time frame for admission to be anticipated upon acceptance of admission/referral for services.”

“Duties of a HH aide CFR(s): 484.80(g)(3) The duties of a home health aide include: (i) The provision of hands-on personal care; (ii) The performance of simple procedures as an extension of therapy or nursing services; (iii) Assistance in ambulation or exercises; and (iv) Assistance in administering medications ordinarily self-administered. This Element is not met as evidenced by: Based on interview and document, the facility failed to assure the home health aides provided only a passive role in medication administration and application of prescription topical medications for 2 of 2 patients (P9 and P10) reviewed for administration of topical skin medication. P9’s Home Health SOC (Start of Care)/Recert (Recertification) Plan of Care, effective from 1/11/25 to 3/11/25 indicated P9’s start of care was on 7/26/22. P9’s medical diagnoses included the following: rheumatoid arthritis (chronic inflammatory disorder that can affect more than just your joints), erythema intertrigo (inflammation of skinfolds caused by skin-on-skin friction), localized edema (swelling), diabetes type 2 (a chronic disease characterized by high levels of sugar in the blood), and chronic pain. P9’s Medication Profile listed orders for P9 to receive nystatin ointment topically two times a day, as well as an order for nystatin powder to be used up to two times a day as needed. P9’s Plan of Care identified P9 was to receive a home health aide visit weekly to assist with personal cares, in addition to a skilled nurse visit one to three times per month. During the skilled nurse visit, the skilled nurse was to assess general and mental health, diabetes management, medication and pain management, skin integrity, diet, safety and mobility. P10’s Home Health SOC (Start of Care)/Recert (Recertification) Plan of Care, effective from 1/24/25 to 3/24/25 indicated P10’s start of care was on 9/19/14. P10’s medical diagnoses included the following: hemiplegia and hemiparesis (weakness or complete loss of strength in one leg, arm, or side of face) on left non-dominant side, other sites of candidiasis (a fungal infection caused by overgrowth of yeast), localized edema, and essential primary hypertension (high blood pressure). P10’s Medication Profile listed orders for P10 to receive miconazole 2% powder to times as needed for yeast infection. P10’s Plan of Care identified P10 was to receive a home health aide visit weekly to assist with shower and personal cares, in addition to a skilled nurse visit (SNV) one time a week. There was no delegated task listed under frequency order for SNV. On 2/25/25, at 12:52 p.m. during review of policies and procedures, the director of nursing (DON) stated there were two clients who received assistance with application of prescription topical skin medication. A facility document, titled Instructions/Competency for Administration of Topical Skin Medication, was signed by director of nursing and home health aide (HHA)-A on 3/18/24. This document was reviewed with DON. The policy outlined the appropriate infection control techniques for hand washing. The policy went on with the process of informing the client of the task to be performed and instructed home health aide to ensure privacy. The policy went on to describe the appropriate process for review of the six rights to medication administration (the right: client, medication, dosage, time, route, and documentation). The policy completed with directing the staff to check affected skin area, as needed, and concluded the process with appropriate hand hygiene and documentation. DON stated she was unaware that home health aides were only to “take only a passive role in this activity” A review of the regulation was completed, informing the prescription ointment could be provided to resident, however, the home health aide may only provide assistance with applying a topical product, such as a non-prescription cream, to intact skin per home health aide instructions on how to apply it.”