Accentcare Hospice & Palliative Care of Broward County

“Based on record review and interview, the Hospice failed to specify in its written agreement with 1 of 3 sampled hospitals or hospital systems (Hospital System C) that hospice patients inpatient clinical records are available to the Hospice upon their discharge. The findings included:The Hospice policy and procedure titled Admission for General Hospice Inpatient Services, last revised 12/12/25, documents, “the Hospice agency maintains a written agreement with the facility to provide short term inpatient care that is coordinated by the hospital agency. B. At a minimum, the written agreement shall specify that the contracted facility: … iv. Provides a copy of the discharge summary to the hospice agency at the time of discharge and provides a copy of the inpatient clinical record to the hospice agency at the time of discharge.”The Inpatient Hospice Agreement between the Hospice and Hospital System C, which includes 6 hospitals, documents under Certain Responsibilities of Hospital, “Hospital shall provide Hospice with a copy of the discharge summary at the time of a Hospice Patient’s discharge,” and under Records, “Hospital shall permit Hospice or its authorized representative, upon reasonable notice and presentment of written authorization by the appropriate Hospice Patient, to review and make photocopies of records maintained by Hospital relating to the provision of Hospital Services under this Agreement, including but not limited to medical records, Hospice Patient discharge summaries, and records relating to billing and payment.”This agreement creates an unnecessary barrier to the Hospice’s ability to obtain records for the care rendered under this Hospice agreement since it requires written authorization of the Hospice Patient, who may then be deceased or incapable of signing for release of records.During audio conferencing on 08/07/26 at 3:58 PM, the Regional Vice-President of Operations initially stated they use the same contract for all hospitals that is processed by legal department but, after hearing the noncompliance, stated some hospitals supply their own contracts.”

“Based on record review and interview, the Hospice failed to include in its written agreement with 2 of 3 sampled hospitals or hospital systems (Hospitals A and B) identification of an individual at the Hospital who is responsible for implementation of the provisions of the agreement. The findings included:The Hospice policy and procedure titled Admission for General Hospice Inpatient Services, last revised 12/12/25, documents, “the Hospice agency maintains a written agreement with the facility to provide short term inpatient care that is coordinated by the hospital agency. B. At a minimum, the written agreement shall specify that the contracted facility: …vi. Has identified an individual within the facility who is responsible for the implementation of the provisions of the agreement.”1) The Inpatient Hospice Services Agreement between the Hospice and Hospital A with effective date 06/02/22 and signatures for representatives of both parties dated 06/01/22 and 06/07/22 was provided by the Executive Director as the current agreement with Hospital A and documents, “Implementation of Agreement. Hospital shall designate an individual within Hospital who shall be responsible for the implementation of the provisions of this Agreement (“Responsible Hospital Representative”). The current Responsible Hospital Representative is identified at the end of this Agreement. Hospital shall notify Hospice if a new individual is designated as the Responsible Hospital Representative” and “Responsible Hospital Representative. Hospital has identified the following individual as the Responsible Hospital Representative: _________.” There is no name but a blank line and there is no Responsible Hospital Representative identified in the document. 2) The Hospice Agreement for Inpatient Services between the Hospice and Hospital B with effective date 03/31/25 and signatures for representatives of both parties dated 03/31/25 and 04/02/25 was provided by the Executive Director as the current agreement with Hospital B and documents, “Authorized Hospital Representatives. Hospital shall designate qualified individuals to serve in the following capacities and shall notify Hospice of the identity of each such designee: (a) A liaison authorized to represent Hospital for purposes of this Agreement; and (b) The individual responsible for the implementation of the provisions of this Agreement.” Further review of the contract as well as attached Appendices revealed no identification of an Authorized Hospital Representative responsible for the implementation of the provisions of the Agreement.During audio conferencing on 08/07/26 at 3:58 PM, the Regional Vice-President of Operations stated “we don’t always designate a person as a contact” and it is usually the CFO (Chief Financial Officer) or CEO (Chief Executive Officer) that they go to with contract issues; upon further explanation of the regulation she stated this has never been a barrier to them as they can call the CFO, CEO, or CNO (Chief Nursing Officer) depending on what their issue is that they’re wanting to address; and did not acknowledge the regulatory requirement.”

“Based on record review and interview, the Hospice failed to include in its written agreement with 1 of 3 sampled hospitals or hospital systems (Hospital A) that the Hospice retains responsibility to ensure and document training of Hospital staff providing care to the hospice’s patients, including a description of the training and names of trainers. The findings included:The Hospice policy and procedure titled Admission for General Hospice Inpatient Services, last revised 12/12/25, documents, “the Hospice agency maintains a written agreement with the facility to provide short term inpatient care that is coordinated by the hospital agency. A. At a minimum, the written agreement shall specify that the hospice agency: … v. Ensures that the training of personnel who will be providing the patient’s care in the inpatient facility has been provided and documented. vi. Documentation will consist of: a. A description of the training, b. Names of those giving the training, and c. Names of personnel trained.”The Inpatient Hospice Services Agreement between the Hospice and Hospital A with effective date 06/02/22 and signatures for representatives of both parties dated 06/01/22 and 06/07/22 was provided by the Executive Director as the current agreement with Hospital A and documents under Responsibilities of Hospice, “Hospice shall provide orientation and ongoing hospice care training to Hospital’s personnel as necessary to facilitate the provision of safe and effective care to Hospice Patient.” Further review of the contract reveals it does not document the Hospice retains responsibility to ensure training to Hospital staff who provide care to the hospice’s patients but only “as necessary” or that the Hospice will document descriptions of the training and names of persons giving the training.During interview on 08/06/26 at 1:25 PM, the Executive Director stated the Hospice does not train hospital staff who take care of the Hospice’s patients but trains only the Hospice’s own nurses that go into the hospitals to visit their patients in contract beds; that they do not do orientation to the hospice philosophy or training with hospital staff.During interview on 08/06/26 at 1:27 PM, the Director of Business Development reported they have “Clinical Liaisons” stationed at hospitals where they have contracts and showed an entry on a patient’s Plan of Care for the Intervention, “SN (Staff Nurse) will reinforce with family/CG(caregiver)/facility staff that Hospice provides 24 hr. (hour) availability and what symptoms or events should be reported” as evidence of teaching to the facility staff, although this is an assigned intervention and not evidence of teaching performed. During further interview on 08/06/26 at 1:33 PM, the Director of Business Development showed an expense report for food provided to hospital staff but could not provide evidence of training to hospital staff who provide care to the hospice’s patients.”

“Based on record review and interview, the Hospice failed to include in its written agreement with 3 of 3 sampled hospitals or hospital systems (Hospitals A and B, and Hospital System C) a method to verify the requirements for inpatient care arrangements are met. The findings included:1) The Inpatient Hospice Services Agreement between the Hospice and Hospital A with effective date 06/02/22 and signatures for representatives of both parties dated 06/01/22 and 06/07/22 was provided by the Executive Director as the current agreement with Hospital A and documents, “Verification of Regulatory Requirements. In accordance with the requirements established by the Medicare Conditions of Participation for Hospice Care, Hospice shall periodically meet with the Responsible Hospital Representative to verify: (a) that Hospice supplied Hospital with a copy of the Hospice Patient’s Plan of Care; (b) that Hospital established patient care policies consistent with those of Hospice and agreed to abide by the palliative care protocols and Plans of Care established by Hospice for Hospice Patient; (c) that the Hospice Patient’s inpatient clinical records include records of all Inpatient Services furnished and events regarding care that occurred at Hospital; (d) that a copy of the discharge summary is provided to Hospice at the time of discharge and that a copy of the inpatient clinical record is available to Hospice at all times, including after discharge; (e) that Hospital has identified the Responsible Hospital Representative; and (f) that Hospice retains responsibility for ensuring that the training of personnel who will be providing Hospice Patient’s care has been provided and that a description of the training and the names of those giving the training are documented.” However, this Agreement also documents, “Responsible Hospital Representative. Hospital has identified the following individual as the Responsible Hospital Representative: ____________.” There is no name but a blank line and there is no Responsible Hospital Representative identified in the document. Without a designated Responsible Hospital Representative with whom to meet and verify the requirements listed above, there is no mechanism to ensure those requirements are met.2) Review of the Hospice Agreement for Inpatient Services between the Hospice and Hospital B with effective date 03/31/25 that was provided by the Executive Director as the current agreement with Hospital B reveals it does not contain any provision to verify the following requirements for inpatient care arrangements are met: (1) that the Hospice provides patients’ plans of care and specifies inpatient services to be provided; (2) that the Hospital’s patient care policies are consistent with those of the hospice and Hospital agrees to abide by the palliative care protocols and plan of care established by the Hospice for its patients; (3) that the hospice patient’s inpatient clinical record includes a record of all inpatient services furnished and events regarding care that occurred at the facility; that a copy of the discharge summary is provided to the hospice at the time of discharge; and that a copy of the inpatient clinical record is available to the Hospice at the time of discharge; (4) that the Hospital has identified an individual within the facility who is responsible for the implementation of the provisions of the agreement; and (5) that the Hospice retains responsibility for ensuring that the training of personnel who will be providing the patient’s care in the Hospital has been provided and that a description of the training and the names of those giving the training is documented. 3) The Inpatient Hospice Agreement between the Hospice and Hospital System C, which includes 6 hospitals named therein, executed on 03/20/15 with signatures for representatives of both parties was provided by the Hospice Executive Director as the current agreement with Hospital System C and documents, “Hospice shall verify compliance with the following requirements established by the Medicare Conditions of Participation for Hospice Care, by periodically reviewing records to verify that these requirements are met: (a) Hospice shall document in the Hospice Patient’s record that the Plan of Care has been provided to Hospital and specify the Hospital Services that Hospital will furnish [document compliance instead of ensuring the Plan of Care was provided to the Hospital and that it specifies the inpatient services to be furnished, as required]; … and (d) Hospice shall document in the Hospice Patient’s record that Hospital provided a copy of the discharge summary at the time of discharge [document compliance rather than ensuring the Hospice received the discharge summary, as required].During audio conferencing on 08/07/26 at 3:58 PM, the Regional Vice-President of Operations initially stated they use the same contract for all hospitals that is processed by their legal department which she reported is well-versed in the regulations but, after hearing the noncompliance, stated some hospitals supply their own contracts.”

“Based on record review, observation, and interview, the Hospice provider failed to adhere to the patient’s Plan of Care for 2 of 15 sampled patients (Patient #1 and 2). The findings included: 1. Review of the record reveals Patient #1 was admitted for hospice services on 07/28/23. Patient #1s Hospice IDG (InterDisciplinary Group) Comprehensive Assessment and Plan of Care Update Report for the meeting date of 11/07/23 includes the following discipline frequencies ordered on 10/29/23: MSW (Medical Social Worker) eff (effective) 11/13/23: 1w1 (1 visit the first week), 1every4wk8 (one visit every 4 weeks for the next 8 weeks), 3 PRN (“;as needed” visits) for coping, crisis mgt (management) and MU (Music therapy) eff 11/13/23: 1wk1, 1every2wk6 ( 1 visit every 2 weeks for the next 6 weeks), 1wk1, 3 PRN crisis mgt. Review of Patient #1s record reveals a Social Work visit was made on 11/15/23 but there was no visit documented for the 4 weeks of 11/19/23 to 12/16/23), and the next Social Work visit occurred on 01/11/24. Review of Patient #1s electronic record reveals a Music Therapy visit was made on 11/17/23, no Music Therapy visit was made during the 2 weeks of 11/19/23-12/2/23, Music Therapy visits were made 12/05/23 and 12/15/23 (2 music visits for 12/3/23 to 12/16/23 instead of 1 as ordered), no Music Therapy visit was made during the 2 weeks of 12/17/23 to 12/30/23, and then a Music Therapy visit occurred on 1/3/24. Review of Patient #1s “Aide Care Plan Report,” effective 08/03/23 documents the services to be provided as bed bath, dressing, hair care, oral care, change linens but does not specify frequencies for any of these tasks and the services do not include shampoos. Patient #1s “Aide Care Plan Report,” effective 01/08/24 documents the services to be provided as bed bath, dressing, hair care, oral care, change linens to be performed with each visit, but does not include shampoos. During a Home Visit on 01/09/24, at 8:05 AM, during an interview, the Hospice Aide, Staff A explained that she visits Patient #1 5 days a week, during which she bathes the patient, provides hair (care), gets the patient dressed, and that she also shampoos Patient #1s hair every Monday and Friday; Staff A stated she does not take Patient #1s vital signs because that is not on the “Care Plan” but did not mention that shampoos were also not on the “Care Plan.” 2. Review of the record reveals Patient #2 was admitted for hospice services on 11/30/23. Patient #2s Physician’s Order, dated 12/11/23 at 4:04 PM documents MU (Music Therapy) effective 12/10/23 1wk1 (1 visit the first week), 1every 2wk10 (then 1 visit every 2 weeks for 10 weeks). Review of Patient #1s electronic record reveals Music Therapy visits were made on 12/11/23 and 01/08/23 and no documented evidence of a Music Therapy visit for the 2 weeks of 12/17/23 to 12/30/23. Further review of Patient #2s record reveals a “Plan Of Care Update” order dated 12/05/23 for the Hospice Nurse to perform wound care to a Stage II (open wound with partial skin damage) pressure wound on the upper R(right)-inner buttock utilizing clean technique – cleanse with Normal Saline, cover with clean dressing and change every day and PRN (as needed). During a home visit with Patient #2 on 01/09/24, accompanied by the Hospice’s Executive Director, the Registered Nurse, Staff B was observed at 9:44 AM to remove the dressing, cleanse the wound, and to apply Hydrogel (type of wound gel) and Medihoney (type of wound gel) to a border dressing (absorptive dressing) before applying it to the wound. As Staff B was doing this, Staff B stated that she has been using Hydrogel and Medihoney mixed together and that is why the wound has healed so fast. Further review of the record reveals a physician’s order dated 01/09/24 at 9:14 PM, after the observation of wound care, for “;Hospice nurse to perform wound care to Stage II pressure wound on upper R-inner buttock utilizing clean technique – cleanse with Normal Saline. Pat dry and apply Hydrogel and cover with clean dressing and change every day and PRN. Instruct caregiver in wound care.” During interview with the Executive Director on 01/10/24 at 11:35 AM, she acknowledged observing Staff Bs use of Hydrogel and Medihoney during the home visit and hearing Staff Bs statement that she had been applying these two products on the wound, although this did not match the order in place at the time of the visit, and that the new physician’s order obtained later that day still did not include Medihoney.”