Franklin County Public Health Services Chha

“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 the Home Health Agency (HHA) Error Summary by Agency Report for the period 01/01/2023 through 12/31/2023 and staff interview the agency failed to encode and electronically transmit each completed Outcome and Assessment Information Set (OASIS), regarding each beneficiary with respect to which information is required to be transmitted (as determined by the Secretary), within thirty days of completing the assessment of the beneficiary. Failure to encode and electronically transmit each complete OASIS assessment, regarding each beneficiary with respect to which information is required to be transmitted (as determined by the Secretary), within thirty days of completing the assessment of the beneficiary has the potential for incorrect and incomplete reporting data. On 10/04/2024 the surveyors reviewed the Certification and Survey Provider Enhanced Reports (CASPER), The “Home Health Agency Error Summary Report by Agency” for the report period 01/01/2023 - 12/31/2023. The report contains a warning code -3330 “Record Submitted Late”: The submission date is more than thirty days after M0090 “Date Assessment Completed” on this new record. The CASPER Report states 6 (0.63%) out of 950 assessments processed were submitted more than thirty days after M0090. The agency lacks documented evidence the agency submitted required documents timely for 6 out of 950, or for 0.63% of submissions. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“Home health aide assignments and duties CFR(s): 484.80(g)(1) Standard: Home health aide assignments and duties. Home health aides are assigned to a specific patient by a registered nurse or other appropriate skilled professional, with written patient care instructions for a home health aide prepared by that registered nurse or other appropriate skilled professional (that is, physical therapist, speech-language pathologist, or occupational therapist). This Standard is not met as evidenced by: Based on review of patients receiving paraprofessional aide services and staff interview the agency failed to ensure in one of one record reviewed (Patient # 1) the aide Plan of Care (POC) was complete to meet the individualized needs of the patient. Failure to ensure the development of a comprehensive aide POC that reflects the patient’s needs has the potential to result in inappropriate care, unmet patient needs and possible negative outcomes. Patient # 1 (start of care 07/26/2023) has diagnoses of Ventricular Fibrillation and Diabetes due to Underlying Conditions Without Complications. The record contains an aide POC dated 09/17/2024 that states the patient has allergies of plastic tape and a physician’s POC for certification period 09/18/2024 through 11/16/2024 that states the patient has allergies of penicillin, Advil, naproxen sodium, nitrofurantoin macrocrystalline and plastic tape. The aide POC was not revised to include all allergies noted on the physician’s POC. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“Participate in care CFR(s): 484.50(c)(4)(i,ii,iii,iv,v,vi,vii,viii) Participate in, be informed about, and consent or refuse care in advance of and during treatment, where appropriate, with respect to-- (i) Completion of all assessments; (ii) The care to be furnished, based on the comprehensive assessment; (iii) Establishing and revising the plan of care; (iv) The disciplines that will furnish the care; (v) The frequency of visits; (vi) Expected outcomes of care, including patient-identified goals, and anticipated risks and benefits; (vii) Any factors that could impact treatment effectiveness; and (viii) Any changes in the care to be furnished. This Element is not met as evidenced by: Based on clinical records review and staff interview the agency failed to ensure that patients are informed before care is initiated of the frequency of services to be provided in one out of ten records reviewed (Patient # 7). Failure to ensure that patients are informed before care is initiated of the frequency of services to be provided has the potential to result in the patient’s inability to exercise their rights. Patient # 7 (start of care 11/15/2017) has diagnoses of Multiple Sclerosis and Cramp and Spasm. The record contains the agency’s Home Health Consents and Agreements document dated 02/01/2022 that informs the patient they will be receiving Physical Therapy and Home Health Aide services. The form documents the frequency of Physical Therapy services only. The record lacks documented evidence the patient was informed of the frequency of home health aide services. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“Payment from federally funded programs CFR(s): 484.50(c)(7)(i, ii, iii, iv) Be advised, orally and in writing, of- (i) The extent to which payment for HHA services may be expected from Medicare, Medicaid, or any other federally-funded or federal aid program known to the HHA, (ii) The charges for services that may not be covered by Medicare, Medicaid, or any other federally-funded or federal aid program known to the HHA, (iii) The charges the individual may have to pay before care is initiated; and (iv) Any changes in the information provided in accordance with paragraph (c)(7) of this section when they occur. The HHA must advise the patient and representative (if any), of these changes as soon as possible, in advance of the next home health visit. The HHA must comply with the patient notice requirements at 42 CFR 411.408(d)(2) and 42 CFR 411.408(f). This Element is not met as evidenced by: Based on clinical record review and staff interview the agency failed to ensure that patients are informed of their financial liability in one out of ten records reviewed (Patient # 7). Failure to ensure that patients are informed their financial liability has the potential to result in the patient’s inability to exercise their rights. Patient # 7 (start of care 11/15/2017) has diagnoses of Multiple Sclerosis and Cramp and Spasm. The record contains the agency’s Home Health Consents and Agreements document dated 02/01/2022 that informs the patient they will be receiving Physical Therapy and Home Health Aide services. The form includes financial liability for the Physical Therapy services only. The record lacks documented evidence the patient was informed of financial liability for home health aide services. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“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 clinical record review and staff interview evidence is lacking in three out of ten records (Patient # 1, 3 and 5) the initial assessment visit was conducted within 48 hours of receiving the referral for services, within 48 hours of the patient’s return home or on the physician ordered start of care date. Failure to conduct the initial assessment within the required time frame has the potential to result in unmet patient needs and negative patient outcomes. Patient # 1 (start of care 07/26/2023) has diagnoses of Ventricular Fibrillation and Diabetes Mellitus due to Underlying Condition without Complications. The record contains an initial assessment conducted on 07/26/2023 stating the initial community referral was received on 07/19/2023 without a physician’s specified start of care date. The record also contains a physician’s order (dated 07/25/2023) for a start of care date of 07/26/2023. The record is lacking documentation of any communication between the physician and the agency between 07/19/2023 and 07/25/2023. The initial assessment was conducted on 07/26/2023, seven days after the agency received the initial referral. Patient # 3 (start of care 09/11/2024) has diagnoses of Fracture of Unspecified Part of Right Clavicle and Other Fracture of Shaft of Right Ulna. The record contains a referral faxed to the agency on 09/06/2024 without a specified physician’s ordered start of care date and a physician’s order dated 09/10/2024 for a start of care date of 09/11/2024. The record lacks documented evidence of any communication between the agency and the physician between 09/06/2024 and 09/10/2024. The initial assessment was conducted on 09/11/2024, five days after the agency received the initial referral. Patient # 5 (start of care 09/20/2024) has diagnoses of Unspecified Open Wound of Left Forearm and Hydronephrosis with Ureteral Stricture. The record contains a referral dated 09/16/2024 with a physician expected start of care date of within “48 hours (Urgent)”. The initial assessment conducted on 09/20/2024 states the referral was received on 09/17/2024. The initial assessment was conducted three days after the agency received the referral. The findings were confirmed on 10/08/2024 at 3:15 PM with the Director of Patient Services and Supervising Community Health Nurse and on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“5 calendar days after start of care CFR(s): 484.55(b)(1) The comprehensive assessment must be completed in a timely manner, consistent with the patient’s immediate needs, but no later than 5 calendar days after the start of care. This Element is not met as evidenced by: Based on clinical record review and staff interview evidence is lacking in two out of ten records (Patient # 5 and 9) the comprehensive assessment was completed in a timely manner, but no later than 5 calendar days after the start of care. Failure to complete the comprehensive assessment within the required time frame has the potential to result in unmet patient needs and negative patient outcomes. Patient # 5 (start of care 09/20/2024) has diagnoses of Unspecified Open Wound of Left Forearm and Hydronephrosis with Ureteral Stricture. The record contains an initial comprehensive assessment conducted on 09/20/2024 and signed as complete on 09/30/2024. The comprehensive assessment was completed 11 days after the start of care. Patient # 9 (start of care 01/19/2024, discharged 02/29/2024) has diagnoses of Encounter for Adjustment and Management of Ventricular Assist Device (VAD) and Sepsis due to Methicillin Susceptible Staphylococcus Aureus. The record contains an initial comprehensive assessment conducted on 01/19/2024 and signed as complete on 01/28/2024. The initial comprehensive assessment was completed 10 days after the start of care. Also, the record contains a resumption of care assessment completed 02/09/2024 and signed as complete on 02/14/2024. The assessment was completed 6 days after the resumption of care. The findings were confirmed on 10/09/2024 at 3:45 PM and 10/10/2024 at 11:30 AM with the Director of Patient Services; no additional evidence was provided.”

“Health, psychosocial, functional, cognition CFR(s): 484.55(c)(1) Standard: Content of the comprehensive assessment. The comprehensive assessment must accurately reflect the patient’s status, and must include, at a minimum, the following information: (1) The patient’s current health, psychosocial, functional, and cognitive status; This Element is not met as evidenced by: Based on clinical record review and staff interview the agency failed to ensure in one out of ten records (Patient # 6) the comprehensive assessment included a complete picture of the patient’s status to assist the agency in developing the patient’s plan of care. Failure to ensure comprehensive assessments include a complete picture of the patient’s status to assist the agency in developing the patient’s plan of care has the potential to result in unmet patient needs and negative patient outcomes. Patient # 6 (start of care 04/23/2024) has diagnoses of Type 2 Diabetes Mellitus and Developmental Disorder of Scholastic Skills. The comprehensive assessment conducted on 08/30/2024 states: “Patient will check blood sugar twice a day (BID) and as needed (PRN)”. The assessment lacks documentation of any durable medical equipment or device the patient would be using the check the blood sugar. The assessment lacked a complete picture of the patient’s status to assist the agency in developing the patient’s plan of care. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“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 clinical record review and staff interview evidence is lacking in one out of ten records (Patient # 7) the comprehensive assessment was conducted the last 5 days of every 60 days beginning with the start-of-care date, unless there is a beneficiary elected transfer, significant change in condition; or discharge and return to the same HHA during the 60-day episode. Failure to conduct the comprehensive assessment the last 5 days of every 60 days beginning with the start-of-care date, unless there is a beneficiary elected transfer, significant change in condition; or discharge and return to the same HHA during the 60-day episode has the potential to result in unmet patient needs and negative patient outcomes. Patient # 7 (start of care 11/15/2017) has diagnoses of Multiple Sclerosis and Cramp and Spasm. The record contains a recertification assessment conducted on 06/06/2024 and physician’s recertification plan of care for the certification period 06/11/2024 through 08/09/2024. The comprehensive assessment was completed 6 days prior to the end of the 60-day episode. Also, the record contains comprehensive assessments completed on 06/06/2024 and 08/08/2024. The assessment completed on 08/08/2024 was completed 62 days from the previous assessment without documented evidence of a beneficiary elected transfer, significant change in condition or discharge and return to the same home health agency. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“Plan of care must include the following CFR(s): 484.60(a)(2)(i-xvi) The individualized plan of care must include the following: (i) All pertinent diagnoses; (ii) The patient’s mental, psychosocial, and cognitive status; (iii) The types of services, supplies, and equipment required; (iv) The frequency and duration of visits to be made; (v) Prognosis; (vi) Rehabilitation potential; (vii) Functional limitations; (viii) Activities permitted; (ix) Nutritional requirements; (x) All medications and treatments; (xi) Safety measures to protect against injury; (xii) A description of the patient’s risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors. (xiii) Patient and caregiver education and training to facilitate timely discharge; (xiv) Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient; (xv) Information related to any advanced directives; and (xvi) Any additional items the HHA or physician or allowed practitioner may choose to include. This Element is not met as evidenced by: Based on clinical record review and staff interview the agency failed to ensure a complete Plan of Care (POC) was developed to meet the individualized needs of the patient in one of ten patient records reviewed (Patient # 10). Failure to develop a comprehensive POC has the potential for unmet patient needs and places patients at risk for receiving incorrect and/or inappropriate care. Patient # 10 (start of care 07/14/2023, discharged 08/02/2023) has diagnoses of Fracture of Unspecified Part of Neck of Left Femur and Unspecified Bacterial Pneumonia. The physician’s POC for certification period 07/14/2023 through 09/11/2023 contains an order for: Acetaminophen-hydrocodone (Norco 5 milligrams (mg)-325 mg) tablet 325 mg-5mg 1 tablet every day (QD) at noon and may take another throughout the day if needed for pain 6-7 on pain scale of 0-10, maximum daily dosage (MDD) of acetaminophen 3000 mg in combination with other meds with acetaminophen, oral, pain. The order is incomplete as it is lacking a time interval between the first dose and the potential second dose. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”

“Promptly alert relevant physician of changes CFR(s): 484.60(c)(1) The HHA must promptly alert the relevant physician(s) or allowed practitioner(s) to any changes in the patient’s condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered. This Element is not met as evidenced by: Based on clinical record review and staff interview evidence is lacking in one of ten patient records (Patient # 5) the physician was contacted regarding changes that alter or suggest the need to alter the Plan of Care (POC). Failure to consult with the physician when changes occur in the patient’s condition has the potential for unmet patient needs and/or negative patient outcomes. Patient # 5 (start of care 09/20/2024) has diagnoses of Unspecified Open Wound of Left Forearm and Hydronephrosis with Ureteral Stricture. The record contains an initial skilled nurse assessment stating the patient reports having left arm wound pain that is at a level of 6/10 (out of a 1-10 pain scale), is dull and occurs during wound care. The physician’s POC for certification period 09/20/2024 through 11/18/2024 does not contain any pain control measures ordered. The record lacks documented evidence the physician was notified of the level of the patients pain and the lack of pain control measures ordered. The finding was confirmed on 10/09/2024 at 3:45 PM with the Director of Patient Services; no additional evidence was provided.”