Human Touch Home Health Inc.

“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 interview and record review the agency failed to encode and electronically transmit each completed OASIS assessment (a tool used by CMS to collect and report patient information for quality improvement and monitoring) to the CMS system within 30 days of completing the patient’s assessment for 47 OASIS patients’ assessments submitted from 01/01/2023 to 02/21/2025. This failure prevented CMS and the agency from analyzing patient’s data, outcomes of care, and the agency’s performance in comparison to other agencies, which potentially placed patients at risk for substandard care. The surveyor reviewed the OASIS (a set of assessment data used to measure patient outcomes over specified time periods) error report in IQIES (the CMS system to track patient care outcomes) on 2/21/2025 for period 01/01/2024 to 02/21/2025. The report revealed late submissions of OASIS assessment data greater than 30 days for 47 patient assessments. Record review of the agency QAPI manual and documents provided on 02/27/2025 at 3:00 PM revealed no identification and agency work on late OASIS transmissions. Validation reports (reports generated after submission of OASIS data with error information including late transmissions) were requested at entrance conference on 02/24/25 at 2:45 PM. None were provided by the end of the survey. An interview was conducted with the Administrator / DON during the entrance conference on 02/24/2025 at 2:45 PM. The surveyor reviewed the findings of the late OASIS patient assessment data transmissions to the Center for Medicare and Medicaid Services system via the IQIES system. The surveyor asked about the agency’s process for encoding and transmitting the OASIS. The Administrator/DON stated OASIS was submitted through the agency’s electronic medical record provider and “sometimes the software has issues, and the OASIS does not go through causing submission to be late.” The surveyor asked how long the nurse or therapist had to complete assessments. The Administrator / DON stated the nurse completes assessments within 48 hours. The surveyor asked who submitted the OASIS data. The Administrator/DON stated he submitted the assessments after he reviewed them. The surveyor asked for the reason for the late submissions. The Administrator / DON stated: “I don’t remember if it was software issues; I can’t remember the reason for all the late submissions.” Review of Agency’s policy “IM.6.I.M1 dated 2023” on 02/27/2024 at 2:30 PM read in part: “The organization encodes and electronically transmits each completed Outcome and Assessment Information Set (OASIS) assessment to the Centers for Medicare & Medicaid Services (CMS) system regarding each patient within 30 days of completing the assessment of the beneficiary. The encoded OASIS data accurately reflect the beneficiary’s status at the time of assessment. Data are encoded and transmitted using the software available from CMS or software that conforms to CMS standard electronic record layout, edit specifications, and data dictionary, and that includes the required OASIS data set…””

“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 observation, record review and interview the individualized plan of care for 1 (Patient #1) of 3 records reviewed with home visits made failed to include all medications. Patient #1 was receiving high risk medications including continuous intravenous medication to support his heart function and anticoagulants to prevent blood clots. The patient was at risk for unsafe and substandard care. Review of Patient #1 record on 02/25/2025 found a start of care of 11/27/2024 and a plan of care dated 11/27/2024 for care until 01/25/2025 which included high risk medications Milrinone Lactate (a drug that increases the strength of your heart muscles and widens your blood vessels) continuously via intravenous infusion, Xarelto (a drug used to treat or prevent blood clots) daily by mouth, and Heparin sodium (a drug used to prevent blood clots) intravenously (drug administered directly to into a vein) 3-5 milliliters through the PICC line (a long thin tube inserted into a vein in the body, usually the arm, used to deliver drugs) daily. Other medications listed on this plan of care included: Allopurinol (used to treat Gout or kidney stones), Amiodarone (treats heart rhythm problems), Torsemide (treats heart failure), Atorvastatin calcium (treats high cholesterol), Digoxin (treats heart failure and heart rhythm), Pantoprazole (treats high stomach acid), and Sodium Chloride (salt water used to flush intravenous lines) injection. Review of Patient #1 record on 02/25/2025 revealed the current plan of care for 01/26/2025 to 03/26/2025 with diagnoses of Systolic and Diastolic Congestive Heart Failure (a weak heart muscle that cannot contract properly resulting in a reduced ability to pump blood out, and a stiff heart muscle that cannot relax adequately hindering ability to fill with blood between beats), Ischemic Cardiomyopathy (the heart muscle is damaged and cant pump blood effectively), Adjustment and Management of Vascular Access Device (management of the central line), Kidney Failure (condition where the kidneys are no longer able to function properly), Cardiogenic shock (life-threatening emergency that occurs when the heart can’t pump enough oxygenated blood to the body’s vital organs), Atrial Fibrillation (a quivering or irregular heartbeat), and Long Term use of Anticoagulants (blood thinners that prevent blood clots). The Plan of Care did not include any medication in the area titled: “Medications: Dose/Frequency/Route (N)ew ( C )hange.” The POC ordered skilled nursing weekly for PICC care and dressing changes, lab draws, skilled assessment, and patient and caregiver education on heart failure and PICC line complications and adverse medication or ineffective IV response every visit. The Plan of care documented the patient remained on continuous Milrinone (a drug that increases the strength of your heart muscles and widens your blood vessels) continuously via intravenous infusion for heart failure. No other medications were listed on the Plan of care for 01/26/2025 to 03/26/2025. A home visit was made on 02/27/25 at 11 AM with Patient #1. The surveyor observed the patient was attached to an infusion pump. Patient #1 stated he had been on services with the agency for a couple of months and was receiving weekly visits by a skilled nurse who provided weekly dressing changes to the PICC. The surveyor reviewed the medications on the plan of care dated 11/27/2025 with the patient who stated they were still taking all the medications on the plan of care dated 11/27/2024 to 01/25/2025. An interview was conducted on 02/27/2025 at 10:26 AM with the Administrator/DON. The surveyor shared the findings of the record review and home visit with Patient #1. The surveyor asked why the current plan of care dated 01/26/2025 did not contain a list of the medications Patient #1 was taking. The Administrator/DON stated it was because the electronic medical record used by the agency sometimes deleted information. The Administrator/DON stated the medications were the same as the plan of care dated 11/27/2024 to 01/25/2025. The Administrator / DON stated the current Plan of care should also have all those medications listed as the patient was still taking the same medications. Record review of Agency’s policy on 02/27/25 found the agency policy “5.17 PLAN OF CARE REQUIREMENTS” dated 2023. The policy read in part: “Each patient must receive the home health services that are written in an individualized plan of care. The plan is developed, and evaluated, in partnership with the patient, representative (if any), and caregiver(s) and identifies patient-specific measurable outcomes and goals. The individualized plan of care includes the following:… 11. All medications and treatments;…””

“Reviewed, revised by physician every 60 days CFR(s): 484.60(c)(1) The individualized plan of care must be reviewed and revised by the physician or allowed practitioner who is responsible for the home health plan of care and the HHA as frequently as the patient’s condition or needs require, but no less frequently than once every 60 days, beginning with the start of care date. This Element is not met as evidenced by: Based on observation, record review and interview for 1(Patient #1) of 3 patient records reviewed with home visits, the agency failed to ensure the home health plan of care was reviewed by the physician or allowed practitioner who was responsible no less frequently than once every 60 days, beginning with the start of care date. Patient’s care was potentially negatively impacted without a complete plan of care reviewed by the physician. Review of Patient #1 record on 02/25/2025 revealed a start of care of 11/27/2024 with diagnoses of Systolic and Diastolic Congestive Heart Failure (a weak heart muscle that cannot contract properly resulting in a reduced ability to pump blood out, and a stiff heart muscle that cannot relax adequately hindering ability to fill with blood between beats), Ischemic Cardiomyopathy (the heart muscle is damaged and can’t pump blood effectively), Adjustment and Management of Vascular Access Device (management of the central line), Kidney Failure (condition where the kidneys are no longer able to function properly), Cardiogenic shock (life-threatening emergency that occurs when the heart cant pump enough oxygenated blood to the body’s vital organs), Atrial Fibrillation (a quivering or irregular heartbeat), and Long Term use of Anticoagulants (blood thinners that prevent blood clots). The POC was dated 11/27/2024 to 01/25/2025 and ordered skilled nursing weekly for PICC (a long thin tube inserted into a vein in the body, usually the arm, used to deliver drugs) care and dressing changes, lab draws, skilled assessment, and patient and caregiver education on heart failure and PICC line complications and adverse medication or ineffective IV response every visit. The Plan of Care included high risk medications Milrinone Lactate (a drug that increases the strength of your heart muscles and widens your blood vessels) continuously via intravenous infusion, Xarelto (a drug used to treat or prevent blood clots) daily by mouth, Heparin sodium (a drug used to prevent blood clots) intravenously (drug administered directly to into a vein) 3-5 milliliters through the PICC line daily. (CMS defined high risk medications as those with greater potential for harm to the elderly in the OASIS E new rules published in 2023 for high-risk medications.) The Plan of care for 11/27/24 to 01/25/2025 was not signed by the physician and the record contained no evidence the physician had reviewed the plan of care. A home visit was made on 02/27/25 at 11 AM with Patient #1. The surveyor observed the patient was attached to an infusion pump. Patient #1 stated he had been on services with the agency for a couple of months and was receiving weekly visits by a skilled nurse who provided weekly dressing changes to the PICC. An interview was conducted on 02/27/2025 at 10:26 AM with the Administrator/DON. The surveyor shared the findings of the record review and home visit with Patient #1. The surveyor asked for the signed plan of care for 11/27/24 to 01/25/2025. The Administrator / DON stated he didn’t “have it.” The surveyor asked why. The Administrator / DON stated Patient #1 sees a cardiologist and he doesn’t sign the plan of care. The Administrator / DON stated Patient #1 didn’t have a primary care doctor and he only sees the cardiologist and the agency was “just doing the PICC line care” weekly. The surveyor asked if the physician signature was used to ensure the physician had reviewed the plan of care. The Administrator / DON stated yes and the POC was emailed to his cardiologist and a signed POC has not been received from the cardiologist. The Administrator / DON stated: “they (the physician) don’t send them (signed plans of care) back.” Record review of Agency’s policy on 02/27/25 found the agency policy numbered “5.17 (titled) PLAN OF CARE REQUIREMENTS” dated “2023.” The policy read in part: “Each patient must receive the home health services that are written in an individualized plan of care. The plan is developed, and evaluated, in partnership with the patient, representative (if any), and caregiver(s) and identifies patient-specific measurable outcomes and goals. The individualized plan of care includes the following:... 20. Any additional items the organization, or physician or allowed practitioner, may choose to include. …The patient’s individualized care plan is established, periodically reviewed, and signed by a Doctor of Medicine, osteopathy, or podiatry, acting within the scope of his/her state license, certification, or registration…The individualized plan of care is reviewed and revised by the physician or allowed practitioner who is responsible for the home health plan of care and the home health organization as frequently as the patient’s condition or needs require, but no less frequently than once every 60 days, beginning with the start‐of‐care date…””