Ie Community Hospice Inc.

“Upon observation, there was no evidence the hospice is in compliance with accepted professional standards and principles for all core services which includes nursing services, medical social services and counseling services. Patient 4: The medical record contained documentation from an outside wound care agency regarding weekly debridement of wounds as a current treatment. There was no documentation by the medical record regarding wounds being unrelated to the terminality of the patient. The CTIs listed wounds as secondary and related diagnoses. Upon interview with agency leadership, the wound care agency was billing Medicare Part B and hospice was not paying for the care. Payment verification was reflected in the contract between agencies. Patient 5: The medical record contained documentation from an outside wound care agency regarding weekly debridement of wounds through 7/25/24. There was no documentation by the medical record regarding wounds being unrelated to the terminality of the patient. Upon interview with agency leadership, the wound care agency was billing Medicare Part B and hospice was not paying for the care. Payment verification was reflected in the contract between agencies.”

“Upon patient record review, 2 of 14 (Patients #1,#2) did not have evidence in the patient record that the hospice has developed an individualized written plan of care for each patient. The plan of care must reflect patient/family goals and interventions based on the problems identified in the initial, comprehensive, and updated comprehensive assessments. The plan of care must include all services necessary for the palliation and management of the terminal illness and related conditions. Patient 1: The medication record identified patient is insulin dependent. There was no evidence of problems, goals, and interventions related to the need for insulin. Corrected on site. Patient 2: The medical record contained orders for social work and spiritual care visits. There was no evidence of problems, goals, and interventions related to psychosocial and spiritual needs.”

“Upon patient record review, 10 of 14 (Patients #1,#2,#3,#4,#5,#6,#7,#8,#9,#10) did not have evidence the plan of care must includes all services necessary for the palliation and management of the terminal illness and related conditions, including the following: • A detailed statement of the scope and frequency of services necessary to meet the specific patient and family needs • The IDG demonstrates a proactive approach in developing each patient’s plan of care by planning ahead for anticipated patient changes and needs. Decisions should reflect the patient/family preferences rather than be solely a response to a crisis. Patient 1: The medical record contained orders for skilled nursing once weekly and PRN; social work one time then PRN; and spiritual care one time then PRN. There was no quantity and timeframe for allowable as needed visits and anticipated scheduled needs for spiritual care and social work. Corrected on site. Patient 2: The medical record contained an order for RN visits once every 14 days and as needed. There was no quantity and timeframe for allowable as needed visits. Corrected on site. Patient 3: The medical record contained an order for social work one time then PRN; and spiritual care one time then PRN. There was no quantity and timeframe for allowable as needed visits and anticipated scheduled needs for spiritual care and social work. Corrected on site. Patients 4,5,6,7,8,9: The medical record contained orders for skilled nursing once weekly and as needed; aide visits twice weekly and as needed; social work one time then PRN; and spiritual care one time then PRN. There was no quantity and timeframe for allowable as needed visits and anticipated scheduled needs for spiritual care and social work. Corrected on site. Patient 10: The medical record contained an order for social work one time then 1 PRN; and spiritual care one time then 1 PRN. There was no anticipated scheduled needs ordered for spiritual care and social work. Corrected on site.”

“Upon patient record review, 3 of 14 (Patients #4,#9,#10) did not have evidence the plan of care must include all services necessary for the palliation and management of the terminal illness and related conditions, including medications and treatments. Patient 4: The medical record contained documentation by an outside wound care agency regarding weekly wound debridement completed. There was no evidence of orders for wound debridement. Patient 9: The medical record contained an order for glycolax oral powder with no instructions to mix with a diluent and an order for an indwelling catheter with no change frequency and maintenance instructions. Corrected on site. Patient 10: The medical record contained an order for nystatin topical powder with no area defined for administration. Corrected on site.”

“Upon client record review, 8 of 14 (Patients #1,#2,#3,#4,#6,#7,#8,#10) did not have evidence that the IDG ensures that the care and services are provided in accordance with the plan of care. Patient 1: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 8/4/24 and 8/11/24. There was also an order for social work frequency of one time then PRN. There was a scheduled social work visit completed 7/28/24 without an order. Patient 2: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 8/18/24 and 9/1/24. Patient 3: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 8/4/24, 8/18/24, and 9/1/24. Patient 4: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 8/4/24, 8/18/24, and 9/1/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of social work visits completed 7/1/24, 8/6/24, and 9/1/24; and spiritual care visits completed 4/30/24 and 5/28/24 without orders for anticipated scheduled needs. Patient 6: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 7/28/24, 8/11/24, and 8/25/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of a social work visit completed 7/14/24, and spiritual care visit completed 8/22/24 without orders for anticipated scheduled needs. Patient 7: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 8/4/24, 8/11/24, and 8/25/24. The record also contained an order for spiritual care visits one time then PRN. There was documentation of a spiritual care visit completed 8/28/24 without an order for anticipated scheduled needs. Patient 8: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 7/28/24, 8/11/24, and 8/25/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of a social work visit completed 8/8/24, and spiritual care visit completed 8/22/24 without orders for anticipated scheduled needs. Patient 10: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 7/28/24, 8/11/24, and 8/25/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of a social work visit completed 7/9/24 and 8/12/24; and spiritual care visits completed 7/26/24 and 8/22/24 without orders for anticipated scheduled needs.”

“Upon patient record review, 5 of 14 (Patients #1, #3, #2,#5, 10) did not have evidence in the patient record that hospice aide assignments and duties are: • Assigned to a specific patient by a registered nurse that is a member of the interdisciplinary group • Written patient care instructions for a hospice aide must be prepared by a Registered Nurse who is responsible for the supervision of a hospice aide as specified under paragraph (h) of 418.76 • There is evidence in the patient record that the plan of care; indicate what tasks are to be done by the Aide and the frequency of these tasks. The use of “PRN” or “per patient choice”, for any task, whether personal care or non-personal care tasks, are not acceptable Patient 1,2,5: The aide care plan contained a task to obtain vital signs without parameters of when to notify the RN of findings. Corrected on site. Patient 3: The medical record contained an order for aide visits twice weekly and 1 PRN monthly. There was no quantity and timeframe for allowable as needed visits. Corrected on site. Patient 10: The medical record contained an order for aide visits twice weekly and 1 PRN monthly. There was no quantity and timeframe for allowable as needed visits. Corrected on site.”

“Upon patient record review 1 of 14 (Patient #1) did not have evidence documentation in the patient record that a hospice aide provides services that are: • Ordered by the interdisciplinary group • Included in the plan of care • Permitted to be performed under state law by such hospice aide • Consistent with the hospice aide training Patient 1: The medical record contained an order for aide visits twice weekly. There was no evidence of a second visit completed the week of 7/28/24. After agency investigation, there were two visits completed but only one visit documented. Corrected on site with late data entry.”

“Upon observation, there was no evidence the hospice is directed by a Board of Directors/governing body which assumes full legal authority and responsibility for the operation of the hospice. The governing body had evidence of a medical director contract that included an addendum with an agreement for referral payment. The Physician Self-Referral Law, commonly referred to as the Stark law, prohibits physicians from referring patients to receive “designated health services” payable by Medicare or Medicaid from entities with which the physician or an immediate family member has a financial relationship, unless an exception applies. In addition, the agency was not providing core services as evidenced by contracts with wound care companies providing wound care and billing Medicare Part B for the services and no evidence the patient wounds were unrelated to the patient’s terminal diagnosis.”

“Upon client record review, 2 of 14 (Patients #5,#9) did not have evidence that a written hospice plan of care is established and maintained in consultation with SNF/NF or ICF/IID representatives. All hospice care provided is in accordance with this hospice plan of care. Patient 5: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 7/28/24, 8/11/24, and 8/25/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of a social work visit completed 8/24/24, and spiritual care visits completed 7/26/24 and 8/14/24 without orders for anticipated scheduled needs. Patient 9: The medical record contained a nursing orders for skilled nursing once weekly and RN to go once every 14 days. There were two skilled nursing visits completed the weeks of 7/28/24, and three visits completed the week of 8/11/24. The record also contained orders for social work and spiritual care visits one time then PRN. There was documentation of social work visits completed 7/10/24 and 8/22/24; and spiritual care visits completed 6/10/24, 6/24/24, 7/10/24, 7/26/24 and 8/28/24 without orders for anticipated scheduled needs.”

“Upon observation, there was no evidence the hospice has the appropriate licenses/permits required by state or local rules and regulations. The medical director contract included an addendum with an agreement for referral payment. The addendum stated any patient referral coming from Doctor or Referring Doctor will be compensated $500 per patient. Then if the company needs a referring physician will compensate $300 per patient. The document was signed by both owners and the medical director. The Anti-Kickback Statute is a criminal law that prohibits the knowing and willful payment of “remuneration” to induce or reward patient referrals or the generation of business involving any item or service payable by the Federal health care programs (e.g., drugs, supplies, or health care services for Medicare or Medicaid patients). Remuneration includes anything of value and can take many forms besides cash, such as free rent, expensive hotel stays and meals, and excessive compensation for medical directorships or consultancies. In some industries, it is acceptable to reward those who refer business to you. However, in the Federal health care programs, paying for referrals is a crime. The statute covers the payers of kickbacks-those who offer or pay remuneration- as well as the recipients of kickbacks-those who solicit or receive remuneration.”