Reliable Hospice

“It is required that the written Patient Bill of Rights includes the right to: Receive information about the services covered under the hospice benefit. This standard was not met as evidenced by clinical record review, document review and interview. In 6 of 6 (100%) clinical record review revealed that the agency did not ensure that the patients were notified verbally and in writing of their expected financial responsibility. CLINICAL RECORD 1: The patient was admitted on 10/15/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. CLINICAL RECORD 2: The patient was admitted on 10/14/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. CLINICAL RECORD 3: The patient was admitted on 01/07/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. CLINICAL RECORD 4: The patient was admitted on 10/09/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. CLINICAL RECORD 5: The patient was admitted on 10/06/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. CLINICAL RECORD 6: The patient was admitted on 09/03/2024. The financial responsibility form in the clinical record signed at admission, under payor source, listed Medicare (this was an initial site visit and these were nonbillable visits). Under the different levels of care listed, there were spaces to include the patient’s financial responsibility if there was any responsibility. The form was left blank and was signed at the bottom. In an interview with the Administrator on 02/19/2025 and 02/20/2025, the Administrator stated that Medicare is listed because that will be the patient’s payor source when they are able to bill and that it is implied that the patient has no financial responsibility.”

“It is required that the patient’s pain is assessed as part of a comprehensive assessment. The documented assessment of the patient’s pain includes history of pain and its treatment, both pharmacological and non-pharmacological, use of a standardized pain assessment tool appropriate to the patient’s developmental and cognitive status, characteristics of the pain, including the location, frequency, and intensity, how pain impacts the patient’s ability to engage in usual activities and function and the patient’s/family’s goals for pain management and their satisfaction with the current level of pain control. This standard was not met as evidenced by clinical record review and interview. In 3 of 3 (100%) clinical records reviewed, with pain as an active problem, the agency did not ensure the patient’s/family’s goals for pain management or their satisfaction with the current level of pain control were documented. CLINICAL RECORD 1: The comprehensive assessment dated 10/15/2024 included a pain assessment but did not include documentation of the patient’s/family’s goals for pain management or their satisfaction with the current level of pain control. CLINICAL RECORD 2: The comprehensive assessment dated 10/14/2024 included a pain assessment but did not include documentation of the patient’s/family’s goals for pain management or their satisfaction with the current level of pain control. CLINICAL RECORD 3: The comprehensive assessment dated 01/07/2024 included a pain assessment but did not include documentation of the patient’s/family’s goals for pain management or their satisfaction with the current level of pain control. In an interview with the Director of Nursing (DON) on 02/19/2025, the DON agreed with the finding that the patient/family’s goals were not included but did not offer a reason why they were not included.”

“It is required that the documented comprehensive assessment includes a drug profile that contains the patient’s current prescription and over-the-counter (OTC) drugs, supplements, herbal remedies, other alternative treatments that could affect drug therapy. The medication review process includes the identification of the effectiveness of drug therapy, drug side effects, actual or potential drug interactions, duplicate drug therapy, and drug therapy associated with laboratory monitoring. The assessment includes evidence that common side effects of medication in the hospice populations are anticipated, and, as appropriate, preventive measurements are implemented to manage the side effects. The drug profile is updated per the hospice policy and procedure, but, at minimum, at the time of each comprehensive assessment and/or when new medication is added or changes are made to existing medication. This standard was not met as evidenced by clinical record review, observation, and interview. In 1 of 6 (17%) clinical records reviewed, it was revealed that the agency did not ensure the drug profile contained the patient’s current prescription and over-the-counter (OTC) drugs, supplements, herbal remedies, other alternative treatments that could affect drug therapy. Agency policy PC.M55, Medication Profile (2022), stated in part, “A patient-specific medication profile is maintained for each patient and reviewed at a minimum, every fifteen days. When the patient is admitted to hospice, a medication profile is initiated to document all of the patient’s prescription and over-the-counter drugs, herbal remedies, and all alternative treatments that could affect drug therapy. The medication profile must include all current patient medications, date prescribed or taken, name of medication, dose, frequency, drug classification, date discontinued, and any drug and/or food allergies. The patient’s medication profile is reviewed by the IDG whenever there is a significant change and, at a minimum, every fifteen days.” CLINICAL RECORD 3/Home Visit 1: During a home visit to observe the Social Worker (Personnel Record 3), the patient’s medications and equipment were reviewed. A nebulizer was noted on the patient’s dresser. In an interview, the patient stated that she used the nebulizer one to two times a year as needed. In an interview with the group home manager who administered the medications, the manager stated that the patient is forgetful and that he administered the nebulizer treatment with albuterol as needed for wheezing. The patient had resided in the group home for the last two and one-half years and the manager stated the patient was on the medication when she was admitted to the home. The Director of Nursing (DON) in an interview on 02/19/2025, stated that the group home did not let her know that the patient was on nebulizer treatments with Albuterol and agreed that the medication was not on the medication profile.”

“It is required that each patient’s individualized written plan of care includes all services necessary for the palliation and management of the terminal illness, including the following: measurable outcomes anticipated from implementing and coordinating the plan of care. This standard was not met as evidenced by clinical record review and interview. In 4 of 6 (67%) clinical records reviewed, it was revealed that the agency did not ensure that measurable outcomes were anticipated from implementing and coordinating the plan of care. CLINICAL RECORD 1: The Plan of Care (POC) for the episode 10/15/2024 to 01/12/2025 identified pain as an active and potential problem. The goal was that pain would remain at a comfortable level until death/discharge. The patient’s comfort level was not defined thus the goal was not measurable. CLINICAL RECORD 2: The Plan of Care (POC) for the certification period of 10/14/2024 to 01/11/2025 included pain as an active problem, with interventions that included conducting a comprehensive pain assessment and identifying barriers to effective pain management. The goal was that pain would remain at a comfortable level until death/discharge. The patient’s comfort level was not defined thus the goal was not measurable. CLINICAL RECORD 3: The Plan of Care (POC) for the certification 01/07/2025 to 04/06/2025 included pain as an active problem. The documented interventions included assessment and monitoring pain and administration of pain medication per MD orders. The goal included, “Patient will remain comfortable during the entire care.” The patient’s comfort level was not defined thus the goal was not measurable. CLINICAL RECORD 4: The Plan of Care (POC) for the episode 10/09/2024 to 01/06/2025 identified anxiety/agitation and pain as problems with the goals of PCG will verbalize that anxiety and agitation are reduced to an acceptable level and PCG will verbalize understanding of non-verbal cues and patient’s pain will be managed throughout hospice care. The patient’s acceptable level was not defined thus the goal was not measurable. In an interview with the Director of Nursing (DON) on 02/19/2025, the DON agreed the goals were not measurable.”