Brighton Hospice Michigan, LLC

“It is required that the hospice designates a registered nurse member of the IDG to: ensure the implementation of the interdisciplinary plan of care. Hospice care and services provided to patients and families follow the individualized plan of care established by: the hospice IDG in collaboration with the attending physician (if any). This standard was not met as evidenced by clinical record review and interview. In 1 of 2 (50%) clinical records reviewed of patients with a catheter, the agency did not ensure that the care provided followed the individualized plan of care. Clinical Record 5: The patient elected hospice care on 12/12/2023. The patient was admitted with a Foley catheter. The skilled nursing (SN) visit note dated 01/29/2024 documented that the patient’s son complained that the Foley catheter leaked. In addition, the visit note documented the SN evaluated the Foley catheter, irrigated the catheter with 60cc of sterile water, and reconnected the catheter to the large drainage bag. The plan of care and updated plans of care did not include an intervention for the catheter irrigation. During an interview, the Senior Director of Education and Compliance stated that there was no documentation for the intervention to irrigate the catheter, only to change the catheter as of discharge 02/09/2024.”

“It is required that each patient’s individualized written plan of care: each patient’s individualized written plan of care: identifies planned interventions based on problems identified in the initial and updated comprehensive assessments. This standard was not met as evidenced by clinical record review and interview. In 1 of 8 (12%) clinical records reviewed of patients receiving wound care, the agency did not ensure that the plan of care identified planned interventions based on problems identified in the initial and updated comprehensive assessments. Clinical Record 2: The patient elected hospice care on 01/25/2024. The initial comprehensive assessment completed by the Skilled Nurse (SN) documented that the patient had an allevyn dressing (a border dressing) in place on the coccyx. On 01/29/2024, the updated comprehensive assessment completed by the Skilled Nurse (SN) documented a change in the patient’s skin integrity and the need to treat with a dressing. On 02/01/2024, the assessment documented the continued decline of the skin, that barrier cream with a border dressing was started, and that the bilateral heels were” boggy” and now required to be floated on a pillow. The updated plans of care did not include documentation of interventions for skin care as of the patient’s death on 02/05/2024. During an interview, the Senior Director of Education and Compliance stated that the interventions were not documented.”

“It is required that the hospice follows accepted standards of practice to prevent the transmission of infections and communicable diseases, including the use of standard precautions, such as: hand hygiene. This standard was not met as evidenced by document review, interview, and observation. Agency policy “Hand Hygiene” (Revision date 04/272022) stated in part, “All personnel will use the hand-hygiene techniques, as set forth in the following procedure: Decontaminate hands after coming in contact with patient’s intact skin, i.e. taking a patient’s blood pressure, pulse, lifting/moving the patient.” In 1 of 4 (25%) home visits observed, the agency did not ensure that hand hygiene was performed per the agency’s policy. Home Visit 1: During the home visit with the Registered Nurse (RN) [Personnel Record 11] on 06/12/2024, the RN sanitized their hands, entered the bag and removed the equipment, assessed the patient’s vital signs, which included a skin assessment, and moved to the table and entered information into their device without hand sanitization. The RN returned to the patient to assess the patient’s feet and measure previously open areas. Following the assessment, the RN sanitized their hands. During an interview, the RN [Personnel Record 11] agreed that they had not sanitized prior to entering information in the device and had returned to patient care.”

“It is required that hospice aides are assigned to a specific patient by a registered nurse who is a member of the Interdisciplinary Group. Written patient care instructions for a hospice aide are prepared by an RN who is responsible for the supervision of the hospice aide. This standard was not met as evidenced by clinical record review and interview. In 6 of 19 (32%) clinical records reviewed of patients that received Hospice Aide (HA) services, the agency did not ensure that the HA received specific written patient care instructions for bathing and the safety equipment required for the patient care. Clinical Record 1: The patient elected hospice care on 03/25/2024 and resided at a skilled nursing facility (SNF). The patient’s transfer documented on admission that the patient was a “2-person transfer.” The plan of care ordered HA services five (5) visits a week. During March and April, the patient’s condition declined. The Skilled Nursing (SN) assessments documented that the patient required a “Hoyer lift transfer only.” The Hospice Aide (HA) care plan documented a “2-person transfer” until the patient’s death on 05/29/2024. The HA care plan was not updated to reflect the “Hoyer lift transfer only.” During an interview, the HA stated that the caregivers did all the transfers, and they did not transfer the patient. The transfer task was documented as completed by facility staff. Clinical Record 3: The patient elected hospice care on 06/23/2023 with a history of falls documented. The HA care plan was documented on 06/23/2023 and updated to a “2-person transfer.” The plan of care ordered HA services five (5) visits a week. On 08/09/2023, the SN documented that the patient required a “Hoyer transfer” due to the patient’s condition decline. The CTI (certificate of terminal illness) dated 09/19/2023 documented that a “Hoyer transfer” was required. The HA care plan was not updated to reflect the “Hoyer transfer” until 10/23/2023. During an interview, the HA stated that the caregivers did all the transfers, and they did not transfer the patient. Clinical Record 6: The patient elected hospice care on 02/05/2024. The plan of care ordered HA services five (5) visits a week. The HA care plan effective 02/15/2024 assigned the HA the relevant task: shower on Monday and Thursday. On 04/29/2024, the SN assessment documented a change in the patient’s skin integrity, requiring a foam dressing on the coccyx with Calmoseptine cream. The HA care plan was not updated to provide the HA with instructions on what to do with the dressing during the shower if the dressing became saturated or fell off. Clinical Record 8: The patient elected hospice care on 03/04/2024. The plan of care ordered HA services five (5) visits a week. The HA care plan effective 04/09/2024 assigned the HA the relevant task: shower on Monday and Thursday. On 05/28/2024, the SN assessment documented that the patient had a fall and a new skin tear on the right arm that required a dressing change daily: “cleaning with Normal Saline, applying Xeroform, and a kerlix dressing.” The skin tear was resolved on 06/07/2024. The HA care plan was not updated from 05/28/2024 through 06/07/2024 to provide the HA with instructions on what to do with the dressing during the shower if the dressing became saturated or fell off. Clinical Record 9: The patient elected hospice care on 03/22/2024. The plan of care ordered HA services five (5) visits a week. The HA care plan effective 03/24/2024 assigned the HA the relevant task: shower on Monday and Thursday. On 06/06/2024, the SN assessment documented a change in the patient’s skin integrity, requiring a dressing on the right inner knee with a Xeroform and border gauze dressing. The HA care plan was not updated to provide the HA with instructions on protecting the gauze dressing during the shower or what to do if the dressing became saturated or fell off. Clinical Record 19: The patient elected hospice care on 11/30/2023. The HA care plan updated on 05/17/2024 assigned the HA the relevant task: shower on Tuesday and Friday. On 05/20/2024, the SN documented that the patient continued with bilateral ace wraps on lower extremities that were re-wrapped twice a day. Additionally, the SN assessment documented a change in the patient’s skin integrity, a skin tear on the right lower extremity, and a border dressing on the coccyx for a pressure area. The HA care plan was not updated to provide the HA with instructions on protecting the gauze dressing and the ace wraps during the shower or what to do if the dressing became saturated or fell off. During an interview, the Senior Director of Education and Compliance stated that the HA care plans were self-identified, and a process improvement plan was in place for record review audits and education.”

“It is required that volunteers be used in day-to-day administrative and/or direct patient care roles. Volunteer services provided to patients/families are in a defined role and under the supervision of a designated hospice employee. Volunteer services are: noted in the plan of care. This standard was not met as evidenced by clinical record review and interview. In 3 of 3 (100%) clinical records of patients that received volunteer services, the agency did not ensure that the volunteer provided the frequency of care ordered and desired by the patient. Clinical Record 8: The patient elected hospice care on 03/04/2024. On 04/04/2024, the physician ordered volunteer services for companion care: “1-2 times a month.” Companion visits were documented two (2) times a month in April 2024. No companion visits were documented in May 2024 and to date for June 2024. A clinical record review revealed no documented reason volunteer services were not provided as ordered. Clinical Record 14: The patient elected hospice care on 02/14/2024. On 03/27/2024, the physician ordered volunteer services for companion care: “1 month 1, 3-4 times a month 1, and then 1-2 times a month.” No companion visits were documented in March 2024, May 2024, and to date for June 2024. A clinical record review revealed no documented reason volunteer services were not provided as ordered. Clinical Record 18: The patient elected hospice care on 08/18/2023. On 03/01/2024, the physician ordered volunteer services for companion care: “3-4 times a month.” Companion visits were documented two (2) times a month in April 2024. In March 2024 and May 2024, no companion visits were documented. A clinical record review revealed no documented reason volunteer services were not provided the minimum of three (3) times as ordered in April 2024 and in March and May. During an interview, the Volunteer Coordinator (VC) and the Senior Director of Education and Compliance stated that the VC had spoken with the volunteer and the volunteer was unable to provide the visit. The volunteer stated that the patient and family had been communicated with and agreed to the changed frequency but that this was not documented.”

“It is required that a patient clinical record containing past and current findings is maintained for each hospice patient. Each patient’s record includes, at a minimum: physician orders. This standard was not met as evidenced by clinical record review and interview. In 1 of 2 (50%) clinical records reviewed of patients with a catheter, the agency did not ensure that the patient’s clinical record contained a physician ‘s order for the care provided. Clinical Record 5: The patient elected hospice care on 12/12/2023. The patient was admitted with a Foley catheter. The skilled nursing (SN) visit note dated 01/29/2024 documented that the patient’s son complained that the Foley catheter leaked. In addition, the visit note documented the SN evaluated the Foley catheter, irrigated the catheter with 60cc of sterile water, and reconnected the catheter to the large drainage bag. A review of the clinical record revealed no physician’s order for the catheter irrigation. During an interview, the Senior Director of Education and Compliance stated that there was no documentation for the intervention to irrigate the catheter, only to change the catheter as of discharge 02/09/2024.”