Pathways Healthcare

“Infection control CFR(s): 484.70(b)(1)(2) Standard: Control. The HHA must maintain a coordinated agency-wide program for the surveillance, identification, prevention, control, and investigation of infectious and communicable diseases that is an integral part of the HHA’s quality assessment and performance improvement (QAPI) program. The infection control program must include: (1) A method for identifying infectious and communicable disease problems; and (2) A plan for the appropriate actions that are expected to result in improvement and disease prevention. This Standard is not met as evidenced by: Based on review of agency policies/procedures, initial tuberculosis (TB) screening guidance from the Centers for Disease Control (CDC) and Pennsylvania Department of Health (PA DOH), clinical records and personnel files and based administrative staff interview, the agency failed to ensure initial TB screening was conducted in accordance with agency policies/procedures and CDC and PA DOH recommendations for seven (7) of seven (7) active employees whose date of hire was after January 21, 2022. (Employees #1, #3, #6, #7, #8, #9 and #10) Finding include: On January 30, 2025 at approximately 2:34 PM, review of agency policy 1-005, titled “Categories/Qualifications of Personnel”, revealed the following under “Health Requirements”: 1. Personnel with Patient Contact: All new personnel who will be in contact with patients...must undergo a physical screening before they are employed...In addition, personnel must have a Mantoux (TB skin test-TST) text or show evidence that there is no active TB in the past 12 months by providing a copy of a negative Mantoux/TB test within the past 12 months prior to providing care. On January 30, 2025 at approximately 2:39 PM, review of agency policy 6-028, titled “Tuberculosis Exposure Control Plan”, revealed the following: Purpose: To provide guidelines to reduce the risk of occupational exposure to TB. Procedure...2. Where required by state...regulations, a two (2) step TST will be given for all personnel upon hire if no TST has been performed within 12 months of hire date... On January 30, 2025 at approximately 3:35 PM, review of CDC recommendations for initial TB screening for health care personnel revealed the following as documented on the CDC website: https://www.cdc.gov/tb-healthcare-settings/hcp/screening-testing/index.html The TB screening process for health care personnel includes: -A baseline individual TB risk assessment; -TB symptom evaluation; and -A TB test (TB blood test or a TB skin test (2-Step)). On January 30, 2025 at approximately 3:50 PM, review the PA DOH webpage ( https://www.pa.gov/agencies/health/diseases-conditions/infectious-disease/tuberculosis/tb-testing-health-care-workers.html ) revealed the following: Tuberculosis Testing Health Care Workers...On May 17, 2019 the Centers for Disease Control and Prevention (CDC) issued updated recommendations for TB testing of health care personnel. Key points include: On May 17, 2019 the Centers for Disease Control and Prevention (CDC) issued updated recommendations for TB testing of health care personnel. Key points include: \r\n \r\n\r\nThe updated recommendations call for health care personnel to be screened for TB upon hire with an individual risk assessment, a symptom evaluation, and a TB test (either the interferon gamma-release assay, or IGRA, blood test or the tuberculin skin test). Thereafter, annual TB testing is not recommended unless there is a known exposure to a case of infectious TB disease or there is ongoing transmission in the health care setting where the individual works.\r\nA positive TB test indicates that a person has been infected with TB bacteria. It does not specify whether the person has latent TB infection (LTBI) or has progressed to TB disease. Anyone with a newly positive TB test should receive a symptom evaluation and chest x-ray to rule out TB disease. Additional workup may be needed based on these results.\r\nTreatment for latent TB infection is strongly encouraged for health care personnel diagnosed with LTBI. Shorter treatment regimens, such as once-weekly isoniazid and rifapentine for 3 months or daily rifampin for 4 months, should be used as they are more likely to be completed when compared to the traditional regimens of 6 or 9 months of isoniazid.\r\nHealth care personnel that have been diagnosed with LTBI and declined treatment should receive an annual TB symptom screen to detect early evidence of TB disease and to reevaluate the risks and benefits of LTBI treatment. If the benefit of treatment is expected to exceed the risk, the health care worker should continue to be strongly encouraged to complete LTBI treatment.\r\nThe CDC recommends that all health care personnel receive TB education annually. The PA TB program has prepared a presentation for health care personnel that reviews TB risk factors, the signs and symptoms of TB disease, and TB infection control policies and procedures. Consistent with CDC guidance, the presentation also emphasizes that health care personnel diagnosed with LTBI are strongly encouraged to complete preventive treatment..\r\nLastly, the above information updates the recommendations for TB screening and testing of health care personnel from the 2005 CDC Guidelines on Preventing the Transmission of Mycobacterium tuberculosis in Health Care Settings. All other aspects of the 2005 guidelines, including infection control practices and facility risk assessments, remain in effect.  \r\n\r\nFor additional resources from the CDC, visit the TB Screening and Testing of Health Care Personnel page on the CDC website. \r\nIf you have any questions about TB testing call the PA TB program at 717-787-6267. \r\n \r\n \r\n \r\n \r\n”}}”> The updated recommendations call for health care personnel to be screened for TB upon hire with an individual risk assessment(opens in a new tab), a symptom evaluation, and a TB test(opens in a new tab) (either the interferon gamma-release assay, or IGRA, blood test or the tuberculin skin test). On January 30, 2025 at approximately 3:55 PM, review of the PA DOH TB manual ( https://www.pa.gov/content/dam/copapwp-pagov/en/health/documents/topics/documents/diseases-and-conditions/tb/CMHD%20TB%20Manual%202023.pdf ) revealed the following: LAWS PERTAINING TO TB CONTROL...Pennsylvania laws on TB can be found in the Administrative Code of 1929 and the Disease Prevention and Control Law of 1955, 35 P.S. Sec. 521.1 . Under the provisions of the Pennsylvania Administrative Code of 1929 and the Disease Prevention and Control Law of 1955, DOH has the authority to “protect the health of the people of this Commonwealth, and to determine and employ the most efficient and practical means for the prevention and suppression of disease.” Patient #1 (Discharge): On January 28, 2025 at approximately 10:14 AM, review of the clinical record revealed the registered nurse (RN-Employee #6) provided skilled nursing (SN) services in September 2024. Patient #2: On January 28, 2025 at approximately 11:22 AM, review of the clinical record revealed the RN (Employee #1) provided SN services in January 2025. Patient #4: On January 28, 2025 at approximately 12:28 PM, review of the clinical record revealed the occupational therapist (OT-Employee #7) provided services in December 2024 and January 2025. Patient #5: On January 28, 2025 at approximately 1:46 PM, review of the clinical record revealed the PT (Employee #3) provided PT services in December 2024 and January 2025. Patient #6 (Discharge): On January 30, 2025 at approximately 10:56 AM, review of the clinical record revealed the certified occupational therapy assistant (COTA-Employee #8), the physical therapy assistant (PTA-Employee #9) and the social worker (SW-Employee #10) provided services in September 2024. Between January 29, 2025 at approximately 1;44 PM and January 30, 2025 at approximately 1:36 PM, review of personnel file documentation revealed the following: Employee #1: The date of hire of the RN was 07/17/2023, that the first date of assignment to provide SN services was 07/19/2023 and that a single step TST was completed on 10/10/2023. There was no documentation in the personnel file which provided evidence the first step of the TST was completed prior to the assignment to provide SN service nor was documentation present which provided evidence the second step TST had been completed. Employee #3: The date of hire of the PT was 08/14/2023, that the first date of assignment to provide PT services was 08/23/2023 and that a single step TST was completed on 08/23/2023. There was no documentation in the personnel file which provided evidence the second step TST had been completed. Employee #6: The date of hire of the RN was 08/01/2024, that the first date of assignment to provide SN services was 08/15/2024 and that a single step TST was completed on 01/27/2025. There was no documentation in the personnel file which provided evidence the first step TST was completed prior to the assignment to provide SN services nor was documentation present which provided evidence a second step TST had been completed. Employee #7: The date of hire of the OT was 08/07/2023, that the first date of assignment to provide OT services was 08/23/2023 and that a single step TST was completed on 08/07/2023. There was no documentation in the personnel file which provided evidence the second step TST had been completed. Employee #8: The date of hire of the COTA was 08/19/2024, that the first date of assignment to provide OT services was 08/29/2024 and that a single step TST was completed on 08/19/2024. There was no documentation in the personnel file which provided evidence the second step TST had been completed. Employee #9: The date of hire of the PTA was 02/13/2023, that the first date of assignment to provide PT services was 02/21/2023 and that a single step TST was completed on 01/27/2025. There was no documentation in the personnel file which provided evidence that the TST screening process was initiated prior to the assignment to provide services on 02/21/2023. Employee #10: The date of hire of the SW was 02/06/2023, that the first date of assignment to provide SW services was 02/13/2023 and that the SW reported a TST test was completed on 09/01/2023 as documented on the TB questionnaire dated 09/12/2024. There was no documentation in the personnel file which provided evidence a two (2) step TST had been completed. During interview conducted on January 30, 2025 at approximately 2:45 PM, the Administrator (Employee #11), COO (Employee #12) and the Vice President of Clinical Operations (Employee #13) confirmed initial TB screening was not conducted in accordance with agency policy/procedure nor CDC and PA DOH recommendations for the above referenced employees.”

“Visit schedule CFR(s): 484.60(e)(1) Visit schedule, including frequency of visits by HHA personnel and personnel acting on behalf of the HHA. This Element is not met as evidenced by: Based on review of agency policy/procedure, documentation and clinical records, and based on administrative staff interview, the agency failed to ensure written instructions regarding the revised skilled nursing (SN) visit frequency were provided to three (3) of four (4) patients for whom a home visit was conducted. (Patients #2, #3 and #5) Findings include: On January 30, 2025 at approximately 2:41 PM, review of agency policy 2-004, titled “Admission Documents”, revealed the following under “Procedure”: 3. The admission information, including the...calendar with visit frequency will be left in the patient’s home. 4. Any updates to the...visit frequency will be documented by the clinician in the patient’s home prior to being printed. Patient #2: On January 28, 2025 at approximately 11:22 AM, review of the clinical record revealed the projected SN visit frequency was two (2) times a week for nine (9) weeks as documented on the admission form titled “Estimated Frequency/Duration” dated 01/16/2025. Review of the “Home Health Certification and Plan of Care” for the initial certification period of 01/16/2025 through 03/16/2025 revealed the SN visit frequency is one (1) time a week for one (1) week, two (2) times a week for two (2) weeks followed by one (1) time a week for six (6) weeks. During a home visit conducted on January 29, 2025 at approximately 8:30 AM, review of the agency’s admission booklet failed to reveal that the agency had provided the patient with written instructions regarding the updated SN visit frequency which was ordered on the “Home Health Certification and Plan of Care”. Patient #3: On January 28, 2025 at approximately 11:55 AM, review of the clinical record revealed the projected SN visit frequency was two (2) times a week for four (4) weeks as documented on the admission form titled “Estimated Frequency/Duration” form dated 10/25/2024 Review of the “Home Health Certification and Plan of Care” for the recertification period of 12/24/2024 through 02/21/2025 revealed the SN visit frequency is two (2) times a week for five (5) weeks followed by one (1) time a week for four (4) weeks. During a home visit conducted on January 29, 2025 at approximately 9:20 AM, review of the agency’s admission booklet failed to reveal that the agency had provided the patient with written instructions regarding the updated SN visit frequency which was ordered on the “Home Health Certification and Plan of Care”. Patient #5: On January 28, 2025 at approximately 1:46 PM, review of the clinical record revealed the projected SN visit frequency was two (2) times a week for two (2) weeks as documented on the admission form titled “Estimated Frequency/Duration” form dated 12/12/2024. Review of the “Home Health Certification and Plan of Care” for the initial certification period of 12/12/2024 through 02/09//2025 revealed the SN visit frequency is one (1) time a week for one (1) week, two (2) times a week for two (2) weeks followed by one (1) time a week for six (6) weeks. During a home visit conducted on January 29, 2025 at approximately 11:30 AM, review of the agency’s admission booklet failed to reveal that the agency had provided the patient with written instructions regarding the updated SN visit frequency which was ordered on the “Home Health Certification and Plan of Care”. During interview conducted on January 30, 2025 at approximately 2:45 PM, the Administrator (Employee #11), the Chief Operating Officer (Employee #12) and the Vice President of Clinical Operations (Employee #13) confirmed there was no documentation which provided evidence that the agency had provided the above identified patients with written instructions regarding the updated SN visit frequency which was ordered on the “Home Health Certification and Plan of Care”.”

“Patient medication schedule/instructions CFR(s): 484.60(e)(2) Patient medication schedule/instructions, including: medication name, dosage and frequency and which medications will be administered by HHA personnel and personnel acting on behalf of the HHA. This Element is not met as evidenced by: Based on review of agency policy/procedure, documentation and clinical records, and based on administrative staff interview, the agency failed to ensure written instructions regarding the medication schedule/instructions had been provided to two (2) of four (4) patients for whom a home visit was conducted. (Patients #2 and #5) Findings include: On January 30, 2025 at approximately 2:41 PM, review of agency policy 2-004, titled “Admission Documents”, revealed the following under “Procedure”: 3. The admission information, including the reconciled medication sheet...will be left in the patient’s home. 4. Any updates to the medication list...will be documented by the clinician in the patient’s home prior to being printed. Patient #2: On January 28, 2025 at approximately 11:22 AM, review of the clinical record revealed a total of nine (9) medications, including heparin and normal saline intravenous flushes and meclizine (medication to treat dizziness), were ordered on the “Home Health Certification and Plan of Care” for the initial certification period of 01/16/2025 through 03/16/2025. During a home visit conducted on January 29, 2025 at approximately 8:30 AM, review of healthcare provider documentation provided by the patient revealed a partial list of the patient medications were included on the form titled “Patient Discharge Instructions”. The “Patient Discharge Instructions” form was dated 01/24/2025 and did not include instructions regarding heparin and saline flushes nor meclizine. Review of the agency’s admission folder revealed there was no documentation which provided evidence the agency had provided the patient with written instructions regarding the heparin and saline intravenous flushes and meclizine which were ordered on the “Home Health Certification and Plan of Care”. Patient #5: On January 28, 2025 at approximately 1:46 PM, review of the clinical record revealed a total of six (6) medications were ordered on the “Home Health Certification and Plan of Care” for the initial certification period of 12/12/2024 through 02/09/2025. During a home visit conducted on January 29, 2025 at approximately 11:30 AM, review of the agency’s admission folder revealed there was no documentation which provided evidence the agency had provided the patient with written instructions regarding the medication schedule/instructions which were ordered on the “Home Health Certification and Plan of Care”. During interview conducted on January 30, 2025 at approximately 2:45 PM, the Administrator (Employee #11), the Chief Operating Officer (Employee #12) and the Vice President of Clinical Operations (Employee #13) confirmed there was no documentation which provided evidence that the agency had provided the above identified patients with written instructions regarding the aforementioned medication schedule/instructions which were ordered on the “Home Health Certification and Plan of Care”.”