Home Preferred Senior Care

“Plan Based on All Hazards Risk Assessment CFR(s): 484.102(a)(1)-(2) §403.748(a)(1)-(2), §416.54(a)(1)-(2), §418.113(a)(1)-(2), §441.184(a)(1)-(2), §460.84(a)(1)-(2), §482.15(a)(1)-(2), §483.73(a)(1)-(2), §483.475(a)(1)-(2), §484.102(a)(1)-(2), §485.68(a)(1)-(2), §485.542(a)(1)-(2), §485.625(a)(1)-(2), §485.727(a)(1)-(2), §485.920(a)(1)-(2), §486.360(a)(1)-(2), §491.12(a)(1)-(2), §494.62(a)(1)-(2) [(a) Emergency Plan. The [facility] must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:] (1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.* (2) Include strategies for addressing emergency events identified by the risk assessment. * [For Hospices at §418.113(a):] Emergency Plan. The Hospice must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following: (1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach. (2) Include strategies for addressing emergency events identified by the risk assessment, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice’s ability to provide care. *[For LTC facilities at §483.73(a):] Emergency Plan. The LTC facility must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must do the following: (1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing residents. (2) Include strategies for addressing emergency events identified by the risk assessment. *[For ICF/IIDs at §483.475(a):] Emergency Plan. The ICF/IID must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following: (1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing clients. (2) Include strategies for addressing emergency events identified by the risk assessment. This Standard is not met as evidenced by: Based on interview and record review, the agency failed to maintain an emergency plan that was based on and included a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach for 1 of 1 (January 2024 – September 2025) time-period reviewed. This failure could result in the agency being unprepared to address the highest risk hazards in the agency’s service area during an emergency or disaster and could result in harm to patients. The findings included: Record review of the agency’s emergency preparedness documentation, for the time-period of January 2024 – September 2025, did not include a documented, facility-based and community-based risk assessment, completed utilizing an all-hazards approach. The documentation included a blank (not completed) form titled, “Hazard Vulnerability Assessment,” not dated, which had no information from the agency documented to indicate the risk assessment had been completed. During an interview conducted on 09/23/25 at 8:35 a.m., with the Administrator/Supervising Nurse, the Alternate Administrator/Alternate Supervising Nurse, and Clinical Manager G, the Administrator/Supervising Nurse said she had never seen the Hazard Vulnerability Assessment form until the surveyor showed it to her on 09/22/25 (after the surveyor identified the blank form in the agency’s emergency preparedness documentation). The Administrator/Supervising Nurse said the Hazard Vulnerability Assessment form had not been discussed with her prior to the surveyor bringing it to her attention on 09/22/25. The Administrator/Supervising Nurse said if the facility-based and community-based risk assessment had been completed, Former Administrator I would have completed it and said if it was completed the documentation should have been included in the emergency preparedness plan binder with the other emergency preparedness plan documentation previously provided to the surveyor. The Administrator/Supervising Nurse said she did not know why it was not completed or documented and said she was not the Administrator and not responsible for the emergency preparedness plan during the year of 2024. The Administrator/Supervising Nurse said Former Administrator H and Former Administrator I would have been responsible for the emergency preparedness plan, including completion of the facility-based and community-based risk assessment, for the year of 2024. The Administrator/Supervising Nurse said she did not know the process for completing the facility-based and community-based risk assessment and was not sure when it should be completed or how often it should be reviewed/updated. The Administrator/Supervising Nurse said the facility-based and community-based risk assessment should be completed on the Hazard Vulnerability Assessment form. During an interview conducted on 09/23/25 at 10:08 a.m., Former Administrator H said she left employment with the agency at the end of April 2024 or beginning of May 2024 and said she was the Administrator and backup clinical manager while employed. Former Administrator H said she was employed with the agency from August of 2019 through the end of April 2024 or beginning of May 2024. Former Administrator H said she was responsible for the emergency preparedness plan for the year of 2024 until she left employment with the agency at the end of April of 2024 or beginning of May 2024. Former Administrator H said the facility-based and community-based risk assessment was completed and up to date when she left employment with the agency and said she spoke with the new owner and administrator prior to leaving to notify of what had been completed and where the documentation was located. Former Administrator H said the facility-based and community-based risk assessment was reviewed and updated after each implementation or test of the plan and documented in the emergency preparedness binder. Former Administrator H said the information might have been placed on the agency’s shared drive. Former Administrator H said the Administrator was responsible for ensuring the facility-based and community-based risk assessment was completed, reviewed, updated, and documented and said she used the Hazard Vulnerability Assessment form from the emergency preparedness binder to document the assessment. Former Administrator H said that was the form they were given to use to document the facility-based and community-based risk assessment. During an interview conducted on 09/23/25 at 11:44 a.m., Former Administrator I said her former position/title with the agency was Administrator/Clinical Manager/ADON. Former Administrator I said she was employed by the agency from June 2021 through the beginning of March of 2025 and was designated as the Administrator of the agency in May of 2024. When asked if she was responsible for the agency’s emergency preparedness program when she was designated as Administrator during the year of 2024, Former Administrator I said, yes. Former Administrator I said the agency had a checkoff form, a “grid” which was completed for the facility-based and community-based risk assessment and said if she had completed a facility-based and community-based risk assessment while designated as Administrator of the agency she would have documented it on the Hazard Vulnerability Assessment form and included it in the emergency preparedness binder. Former Administrator I said if she had completed the Hazard Vulnerability Assessment it would have occurred after the agency implemented the emergency preparedness plan for winter weather. Former Administrator I said she did not recall the exact date, but it was possibly in January of 2024. Former Administrator I said the Administrator was responsible for completion of the facility-based and community-based risk assessment and said the process was to complete the facility-based and community-based risk assessment using the agency’s Hazard Vulnerability Assessment form. Former Administrator I said she just did what had been done when it was completed previously and completed the form and included it in the emergency preparedness binder. Former Administrator I said the Hazard Vulnerability Risk Assessment was usually updated after each implementation of the plan and said she thought she had only completed it once after the implementation for the winter freeze (possibly in January 2024). Former Administrator I said she used the Hazard Vulnerability Assessment form when she completed it. During an interview conducted on 09/23/25 at 12:30 p.m., the Administrator/Supervising Nurse said the agency had searched the agency’s shared drive and the agency’s stored records but were unable to locate any documentation regarding a completed facility-based and community-based risk assessment completed utilizing an all-hazards approach for the agency’s emergency preparedness plan. During an interview conducted on 09/26/25 at 9:11 a.m., the Administrator/Supervising Nurse said the agency did not locate any documentation to indicate the facility-based and community-based risk assessment was completed and documented by the agency. The Administrator/Supervising Nurse said the facility-based and community-based risk assessment had not been completed since she had become administrator of the agency. The Administrator/Supervising Nurse said there was a potential adverse outcome to clients in that the agency might not be prepared to address the highest risk issues. Record review of an agency policy titled, “Emergency Preparedness: External & Internal Disasters,” dated 01/01/22, indicated. “Risks shall be prioritized based on frequency and regional vulnerability … An all Hazard approach will be taken when evaluating risks; refer to the Hazard Vulnerability Form … The agency director or designee is responsible for ensuring that all provisions of this plan are carried out and initiating each phase … The Administrator/DON/ADON shall … Ensure that the plan is kept up to date …””

“Only as ordered by a physician CFR(s): 484.60(b)(1) Drugs, services, and treatments are administered only as ordered by a physician or allowed practitioner. This Element is not met as evidenced by: Based on interview and record review, the agency failed to ensure treatments were administered only as ordered by a physician for 1 of 7 (Patient #3) patients reviewed. This failure could have resulted in the provision of care which did not meet the patient’s needs and in deterioration of the patient’s wound. The findings included: Record review of the clinical record for Patient #3 included a plan of care, for the certification period of 08/06/25 – 10/04/25, which indicated the patient had a start of care date of 02/07/25 and diagnoses of transient synovitis (a temporary inflammation of the lining of a joint) of the right wrist and Type 2 Diabetes Mellitus (a medical condition in which the body cannot effectively regulate the amount of glucose or sugar in the blood and which can result in delayed healing of wounds). The plan of care indicated that the patient was to receive skilled nurse visits once a week for one week, twice a week for four weeks, and then once a week for four weeks. Record review of a skilled nurse’s note, dated 08/26/25, signed by RN L, indicated, “Abrasion [a superficial injury where the top layer of skin is scraped or rubbed off] noted left lower ABD [stomach area]- cleansed with Vashe [a type of wound cleanser] and applied TAO [a medication applied to the skin to treat or prevent infection] and secured with a bandaid.” There was no documentation to indicate a physician’s order was received to provide the documented wound care to this wound. Record review of a skilled nurse’s note, dated 08/28/25, signed by RN M, indicated, “Pt has superficial wound on ABD LLQ [left lower area of the stomach area] … Cleansed area with wound cleanser applied skin protectant [a cream or ointment used to create a barrier between the skin and moisture to prevent deterioration of the skin] periwound [around the wound] … applied TAO and foam border [a type of absorbent wound dressing] …” There was no documentation to indicate a physician’s order was received to provide the documented wound care to this wound. Record review of the clinical record for Patient #3, for the certification period of 08/06/25 – 10/04/25, did not include a physician’s order for the wound care provided to Patient #3’s abdominal wound on 08/26/25 or 08/28/25. During an interview conducted on 09/25/25 at 4:04 p.m., with RN L, when asked if she had notified Patient #3’s physician/practitioner of the new wound to the stomach area on 08/26/25, RN L said, yes, and said she notified the physician while in the home and the physician’s office gave a verbal order to provide wound care to the area per the agency’s protocol. When asked if the agency had a wound care protocol (a written set of guidelines with detailed steps for care to be provided based on the type of wound which are established prior to development of a wound) in place, RN L said she did not know and said if the agency did have a wound care protocol, she was not aware of it. RN L said she asked another nurse if the agency had a wound care protocol and the other nurse said no so she used her nursing judgement and experience and assessment of the wound to determine the type of wound care to provide to the area. RN L said the wound was a scratch on the patient’s skin. RN L said she could not recall if she had documented notifying the physician of the new wound and said usually, she would document when she contacted a physician in the narrative section of the nurse’s note. RN L said she did not document the physician’s order for the verbal order received for the wound care provided on 08/26/25. When asked the reason the verbal order was not documented RN L said she thought because the wound was an abrasion and not a previously documented wound that she did not need to document the order. RN L confirmed she provided the wound care documented on the skilled nurse’s note for 08/26/25. When asked the agency’s process for when a change in condition such as when a new wound was identified or if a need to alter the plan of care, such as the need to provide wound care not previously ordered, was identified, RN L said the nurse who made the visit was responsible for notifying the physician and receiving an order and documenting the new order and the contact with the physician. During an interview conducted on 09/25/25 at 4:07 p.m., RN M said RN L had identified the wound to Patient #3’s stomach area on the previous visit on 08/26/25 and therefore she did not notify the physician during the visit on 08/28/25 as she did not feel the wound required more intervention than continued monitoring. RN M said she did perform the wound care documented in her nurse’s note to the wound on 08/28/25 and said she did not contact the physician or receive an order for the wound care provided. RN M said she was not aware of any wound care protocols or standing orders (physician’s orders established prior to care being needed to allow for quick response which are detailed for specific situations) for the agency for wound care. RN M said RN L had advised her the patient had irritation to the area from the bandage previously placed and advised her to add skin protectant to the peri-wound area for the irritation. RN M said she provided wound care similar to that of RN L on 08/26/25, with an addition of skin protectant for the irritation and change in dressing due to the irritation. RN M said the agency’s process for what to do if a new wound was identified or new wound care was needed was to contact the patient’s physician and document the order and the coordination with the physician. RN M said the nurse who made the visit and noted the change in condition or need to change the plan of care would be responsible for notifying the physician and receiving the order for any changes to the plan of care. During an interview conducted on 09/25/25 at 4:38 p.m., with the Administrator/Supervising Nurse, when asked the agency’s process regarding notifying physicians/practitioners of changes in a patient’s condition, such as a new wound, or a need to alter the plan of care, such as for a need for new wound care, the Administrator/Supervising Nurse said the nurse who conducted the visit and identified the issue was to contact the physician’s office and document the notification in either a coordination note or in the narrative section of the skilled nurse’s note. The Administrator/Supervising Nurse said the nurse should document who they spoke with, what was said, when the contact was made and should then notify the clinical manager assigned to that patient so that the clinical manager was aware of the issue and contact with the practitioner and could follow-up as needed to ensure continuity of care. The Administrator/Supervising Nurse said the patients were divided alphabetically between herself, the Alternate Administrator/Alternate Supervising Nurse, and Clinical Manager G and the notification should be made by the nurse who made the visit to the appropriate clinical manager. The Administrator/Supervising Nurse said the agency did not have a wound care protocol or standing orders for wound care in place and said the agency required a specific physician’s order for the wound care to be provided to be received by the nurse prior to the nurse providing wound care. The Administrator/Supervising Nurse said RN L should have written the verbal order received by the physician’s office and if she had done so and notified the clinical manager the clinical manager would have reviewed the order and identified the issues and clarified the order to ensure the agency had a specific order for the wound care to be provided. The Administrator/Supervising Nurse said the nurse who made the visit and identified the change in condition or need to alter the plan of care was responsible for notifying the physician/practitioner, obtaining orders for care, documenting the orders and coordination of care, and notifying the appropriate clinical manager. The Administrator/Supervising Nurse said the clinical manager assigned to that patient would then be responsible for following up with any concerns or issues and ensuring continuity of care. The Administrator/Supervising Nurse said the agency’s standard was the contact with the physician/practitioner should be made while the nurse was still present in the patient’s home. The Administrator/Supervising Nurse said the nurse should not complete wound care until a physician’s order was received and if no order was received while the nurse was present in the home the agency would advise the patient to monitor the area and the nurse would do a PRN (as needed) visit the next day when the order was received to follow up and provide the ordered wound care. The Administrator/Supervising Nurse said verbal orders would be documented by the nurse who received the order in the orders section of the patient’s clinical record. When asked how the agency monitored for compliance, the Administrator/Supervising Nurse said the staff were required to notify the clinical manager and said all new orders were reviewed by the assigned clinical manager who was responsible for following up on any issues with orders. The Administrator/Supervising Nurse said verbal orders should all be documented in the patient’s clinical record to allow for review of all staff assigned to provide care to the patient. The Administrator/Supervising Nurse said if the contact with the physician and the order received were not documented other staff providing care after the visit might not be aware of the wound and know to assess and follow up. The Administrator/Supervising Nurse said the failure to obtain orders prior to providing wound care could result in the nurse using something the patient was allergic to or that was not adequate for the wound, or which could make the wound worse. The Administrator/Supervising Nurse said the failure of RN L to document the verbal order resulted in the clinical manager being unaware of the order and the need to follow up to ensure the order was specific. The Administrator/Supervising Nurse said the agency did conduct patient clinical record reviews to audit for issues, but it was unlikely they would identify the issue in real time due to the large census of the agency especially as the visit was not labeled as a wound care visit. The Administrator/Supervising Nurse said the potential outcome for failing to clarify the order to ensure it was complete, specific, and acceptable to the agency was that the order received might not be adequate to achieve wound healing. Record review of an agency policy titled, “Physician Orders,” dated 01/01/22, indicated, “An order from a qualified physician or designee is required prior to administration of … treatments … or any other therapeutic service … Verbal or telephone orders are documented in the software system to include the date the verbal order was received, ordering physician, name of physician designee when applicable … and the clinician accepting the order … If there are questions regarding an order … it is the responsibility of the licensed clinician to seek clarification from the physician …””

“Verbal orders CFR(s): 484.60(b)(3)(4) (3) Verbal orders must be accepted only by personnel authorized to do so by applicable state laws and regulations and by the HHA’s internal policies. (4) When services are provided on the basis of a physician or allowed practitioner’s verbal orders, a nurse acting in accordance with state licensure requirements, or other qualified practitioner responsible for furnishing or supervising the ordered services, in accordance with state law and the HHA’s policies, must document the orders in the patient’s clinical record, and sign, date, and time the orders. Verbal orders must be authenticated and dated by the physician or allowed pracitioner in accordance with applicable state laws and regulations, as well as the HHA’s internal policies. This Element is not met as evidenced by: Based on interview and record review, the agency failed to ensure that the nurse documented physician verbal orders in accordance with state law and the agency’s policies in the patient’s clinical record for 1 of 7 (Patient #3) patients reviewed. This failure resulted in the agency’s clinical manager being unaware of an order for wound care which was non-specific and incomplete and therefore being unable to implement interventions to address the concern and could have resulted in provision of care which did not meet the patient’s needs and in deterioration of the wound. The findings included: Record review of the clinical record for Patient #3 included a plan of care, for the certification period of 08/06/25 – 10/04/25, which indicated the patient had a start of care date of 02/07/25 and diagnoses of transient synovitis (a temporary inflammation of the lining of a joint) of the right wrist and Type 2 Diabetes Mellitus (a medical condition in which the body cannot effectively regulate the amount of glucose or sugar in the blood and which can result in delayed healing of wounds). The plan of care indicated that the patient was to receive skilled nurse visits once a week for one week, twice a week for four weeks, and then once a week for four weeks. Record review of a skilled nurse’s note, dated 08/26/25, signed by RN L, indicated, “Abrasion [a superficial injury where the top layer of skin is scraped or rubbed off] noted left lower ABD [stomach area]- cleansed with Vashe [a type of wound cleanser] and applied TAO [a medication applied to the skin to treat or prevent infection] and secured with a bandaid.” There was no documentation to indicate a physician’s order was received to provide wound care to this wound. Record review of a skilled nurse’s note, dated 08/28/25, signed by RN M, indicated, “Pt has superficial wound on ABD LLQ [left lower area of the stomach area] … Cleansed area with wound cleanser applied skin protectant [a cream or ointment used to create a barrier between the skin and moisture to prevent deterioration of the skin] periwound [around the wound] … applied TAO and foam border [a type of absorbent wound dressing] …” There was no documentation to indicate a physician’s order was received to provide wound care to this wound. Record review of the clinical record for Patient #3, for the certification period of 08/06/25 – 10/04/25, did not include a physician’s order for the wound care provided to Patient #3’s abdominal wound on 08/26/25 or 08/28/25. During an interview conducted on 09/25/25 at 4:04 p.m., with RN L, when asked if she had notified Patient #3’s physician/practitioner of the new wound to the stomach area on 08/26/25, RN L said, yes, and said she notified the physician while in the home and the physician’s office gave a verbal order to provide wound care to the area per the agency’s protocol. When asked if the agency had a wound care protocol (a written set of guidelines with detailed steps for care to be provided based on the type of wound which are established prior to development of a wound) in place, RN L said she did not know and said if the agency did have a wound care protocol, she was not aware of it. RN L said she asked another nurse if the agency had a wound care protocol and the other nurse said no so she used her nursing judgement and experience and assessment of the wound to determine the type of wound care to provide to the area. RN L said the wound was a scratch on the patient’s skin. RN L said she could not recall if she had documented notifying the physician of the new wound and said usually, she would document when she contacted a physician in the narrative section of the nurse’s note. RN L said she did not document the physician’s order for the verbal order received for the wound care provided on 08/26/25. When asked the reason the verbal order was not documented RN L said she thought because the wound was an abrasion and not a previously documented wound that she did not need to document the order. RN L confirmed she provided the wound care documented on the skilled nurse’s note for 08/26/25. When asked the agency’s process for when a change in condition such as when a new wound was identified or if a need to alter the plan of care, such as the need to provide wound care not previously ordered, was identified, RN L said the nurse who made the visit was responsible for notifying the physician and receiving an order and documenting the new order and the contact with the physician. During an interview conducted on 09/25/25 at 4:07 p.m., RN M said RN L had identified the wound to Patient #3’s stomach area on the previous visit on 08/26/25 and therefore she did not notify the physician during the visit on 08/28/25 as she did not feel the wound required more intervention than continued monitoring. RN M said she did perform the wound care documented in her nurse’s note to the wound on 08/28/25 and said she did not contact the physician or receive an order for the wound care provided. RN M said she was not aware of any wound care protocols or standing orders (physician’s orders established prior to care being needed to allow for quick response which are detailed for specific situations) for the agency for wound care. RN M said RN L had advised her the patient had irritation to the area from the bandage previously placed and advised her to add skin protectant to the peri-wound area for the irritation. RN M said she provided wound care similar to that of RN L on 08/26/25, with an addition of skin protectant for the irritation and change in dressing due to the irritation. RN M said the agency’s process for what to do if a new wound was identified or new wound care was needed was to contact the patient’s physician and document the order and the coordination with the physician. RN M said the nurse who made the visit and noted the change in condition or need to change the plan of care would be responsible for notifying the physician and receiving the order for any changes to the plan of care. During an interview conducted on 09/25/25 at 4:38 p.m., with the Administrator/Supervising Nurse, when asked the agency’s process regarding notifying physicians/practitioners of changes in a patient’s condition, such as a new wound, or a need to alter the plan of care, such as for a need for new wound care, the Administrator/Supervising Nurse said the nurse who conducted the visit and identified the issue was to contact the physician’s office and document the notification in either a coordination note or in the narrative section of the skilled nurse’s note. The Administrator/Supervising Nurse said the nurse should document who they spoke with, what was said, when the contact was made and should then notify the clinical manager assigned to that patient so that the clinical manager was aware of the issue and contact with the practitioner and could follow-up as needed to ensure continuity of care. The Administrator/Supervising Nurse said the patients were divided alphabetically between herself, the Alternate Administrator/Alternate Supervising Nurse, and Clinical Manager G and the notification should be made by the nurse who made the visit to the appropriate clinical manager. The Administrator/Supervising Nurse said the agency did not have a wound care protocol or standing orders for wound care in place and said the agency required a specific physician’s order for the wound care to be provided to be received by the nurse prior to the nurse providing wound care. The Administrator/Supervising Nurse said RN L should have written the verbal order received by the physician’s office and if she had done so and notified the clinical manager the clinical manager would have reviewed the order and identified the issues and clarified the order to ensure the agency had a specific order for the wound care to be provided. The Administrator/Supervising Nurse said the nurse who made the visit and identified the change in condition or need to alter the plan of care was responsible for notifying the physician/practitioner, obtaining orders for care, documenting the orders and coordination of care, and notifying the appropriate clinical manager. The Administrator/Supervising Nurse said the clinical manager assigned to that patient would then be responsible for following up with any concerns or issues and ensuring continuity of care. The Administrator/Supervising Nurse said the agency’s standard was the contact with the physician/practitioner should be made while the nurse was still present in the patient’s home. The Administrator/Supervising Nurse said the nurse should not complete wound care until a physician’s order was received and if no order was received while the nurse was present in the home the agency would advise the patient to monitor the area and the nurse would do a PRN (as needed) visit the next day when the order was received to follow up and provide the ordered wound care. The Administrator/Supervising Nurse said verbal orders would be documented by the nurse who received the order in the orders section of the patient’s clinical record. When asked how the agency monitored for compliance, the Administrator/Supervising Nurse said the staff were required to notify the clinical manager and said all new orders were reviewed by the assigned clinical manager who was responsible for following up on any issues with orders. The Administrator/Supervising Nurse said verbal orders should all be documented in the patient’s clinical record to allow for review of all staff assigned to provide care to the patient. The Administrator/Supervising Nurse said if the contact with the physician and the order received were not documented other staff providing care after the visit might not be aware of the wound and know to assess and follow up. The Administrator/Supervising Nurse said the failure to obtain orders prior to providing wound care could result in the nurse using something the patient was allergic to or that was not adequate for the wound, or which could make the wound worse. The Administrator/Supervising Nurse said the failure of RN L to document the verbal order resulted in the clinical manager being unaware of the order and the need to follow up to ensure the order was specific. The Administrator/Supervising Nurse said the agency did conduct patient clinical record reviews to audit for issues, but it was unlikely they would identify the issue in real time due to the large census of the agency especially as the visit was not labeled as a wound care visit. The Administrator/Supervising Nurse said the potential outcome for failing to clarify the order to ensure it was complete, specific, and acceptable to the agency was that the order received might not be adequate to achieve wound healing. Record review of an agency policy titled, “Physician Orders,” dated 01/01/22, indicated, “An order from a qualified physician or designee is required prior to administration of … treatments … or any other therapeutic service … Verbal or telephone orders are documented in the software system to include the date the verbal order was received, ordering physician, name of physician designee when applicable … and the clinician accepting the order … If there are questions regarding an order … it is the responsibility of the licensed clinician to seek clarification from the physician …””