Beyond Hospice & Palliative Care, LLC

“It is required that the hospice medical director, physician employees, and contracted physician(s), in conjunction with the patient’s attending physician, are responsible for the palliation and management of the terminal illness as well as conditions related to the terminal illness. THIS IS A CMS CONDITION LEVEL FINDING This CONDITION was not met as evidenced by a review of clinical records, interviews, document review and interviews which revealed the hospice: Failed to ensure that the hospice medical director or physician designee provided written certification of terminal illness, including the primary terminal diagnosis, related diagnosis(es), if any, current subjective and objective medical findings, current medication and treatment orders, and information about the medical management of any of the patient’s conditions unrelated to the terminal illness{HCPC.4. I/L667}; and Failed to ensure that the hospice medical director or physician-designee provided written and signed recertification of the terminal illness (CTI) to meet the hospice care benefit requirement {HCPC. 6. IL668}. The cumulative effect of these deficiencies has resulted in the hospice organization’s inability to ensure the provision of quality of care for the Condition of Participation CFR 418.102: Medical Director. The collective deficient practice illustrated systemic process failures that had the potential to affect all patients receiving hospice care and services from the agency.”

“It is required that hospice aides are supervised by a registered nurse who makes an on-site visit to the patient’s home no less frequently than every 14 days to: assess the quality of care and services provided by the hospice aide; ensure that services ordered by the hospice Interdisciplinary Group (IDG) meet the patient’s need. The hospice aide does not need to be present. This standard was not met as evidenced by clinical record review and interview. In 2 of 6 (33%) clinical records reviewed for patients that elected hospice aide services revealed the agency did not ensure that hospice aide services were supervised by a registered nurse no less frequently than every 14 days. Clinical Record 1: The election of the hospice benefit was 06/14/2024. The clinical record was reviewed for benefit period 06/14/2024 to 09/11/2024. The plan of care included an order for aide services for 2 times per week. The patient received aide services as ordered, starting on 06/18/2024. The first aide supervisory visit was completed on 07/06/2024 18 days after the first aide visit. Clinical Record 7: The election of hospice benefit was 04/05/2024. The clinical record review for benefit period 06/04/2024 to 08/02/2024 revealed an order for hospice aide services for 2 times per week. The patient received aide services as ordered starting on 06/05/2024. The first aide supervisory visit was completed on 06/10/2024. The next aide supervisory visit was dated 06/24/2024, which is 14 days, then on 07/11/2024 which is 17 days. There were no additional documented aide supervisory visits completed between 07/11/2024 and the end of the benefit period 08/02/2024. In an interview with the Director of Nurses on 09/25/24 while reviewing the clinical record stated I don’t know why those were missed but we are constantly educating and encouraging that aide supervisory visits be done at each visit, so they are not missed.”

“It is required that the hospice medical director or physician designee reviews the clinical information for each patient being evaluated for admission and provides written certification that it is anticipated that the patient’s life expectancy is six months or less if the illness runs its normal course. This standard was not met as evidenced by clinical record review and interview. In 2 of 14 (14%) clinical records reviewed revealed the entries were not complete. Clinical Record 3: The patient elected hospice services on 05/03/2024. Clinical record review revealed that an initial Certification of Terminal Illness for periods 05/03/2024 to 07/01/2024 did not include a physician signature. There was no documented evidence that the physician reviewed the initial CTI. Clinical Record 4: The patient elected hospice services on 02/26/2024. Clinical record review revealed that an initial Certification of Terminal Illness for periods 02/26/2024 to 05/25/2024 did not include a physician signature. There was no documented evidence that the physician reviewed the initial CTI. The Administrator stated in an interview on 09/26/2024 during a joint review of the clinical records that she had previously seen a missing signature on a Certification of Terminal Illness. Still, she thought it was an isolated incident. Also, she stated she did not look any deeper and did not realize it was a problem in multiple charts.”

“It is required that the hospice medical director or physician-designee provides written and signed recertification of the terminal illness to meet the hospice care benefit requirement. Recertification for the hospice care benefit is informed by the medical director or physician designee’s review of the patient’s clinical information. This standard was not met as evidenced by clinical record review and interview. In 3 of 11 (27%) clinical records reviewed for patients requiring a physician’s recertification of terminal illness revealed that the agency did not ensure that the hospice medical director completed and signed the recertification of terminal illness. Clinical Record 3: The patient elected hospice services on 05/03/2024. Clinical record review revealed that a recertification of Terminal Illness for periods 07/02/2024 to 08/30/2024, and 08/31/2024 to 10/29/2024 included all required narrative, yet lacked evidence of a physician signature. Clinical Record 4: The patient elected hospice services on 02/26/2024. Clinical record review revealed that a recertification of Terminal Illness for periods 05/26/2024 to 08/23/2024, and 08/24/2024 to 10/22/2024 included all required narrative, yet lacked evidence of a physician signature. Clinical Record 5: The patient elected hospice services on 09/07/2023. Clinical record review revealed that a recertification of Terminal Illness for periods 01/05/2024 to 03/04/2024, 03/05/2024 to 05/03/2024, 05/04/2024 to 07/02/2024, 07/03/2024 to 08/31/2024, and 09/01/2024 to 10/30/2024 included all required narrative, yet lacked evidence of a physician signature. The Administrator stated in an interview on 09/26/2024 during a joint review of the clinical records that she had previously seen a missing signature on a Certification of Terminal Illness. Still, she thought it was an isolated incident. Also, she stated she did not look any deeper and did not realize it was a problem in multiple charts.”

“It is required that if a patient revokes the election of hospice care or is discharged from hospice per hospice regulation §418.26 (i.e., no longer terminally ill), the hospice forwards to the patient’s attending physician a copy of the hospice discharge summary and the patient’s record, if requested. This standard was not met as evidenced by clinical record review and interview. In 5 of 6 (83%) clinical records reviewed for patients discharged revealed that the agency did not ensure a discharge summary was provided to the attending physician. Clinical Record 10: The patient was discharged on 03/04/2024. The clinical record contained no evidence of a documented discharge summary, or a discharge summary sent to the attending physician. Clinical Record 11: The patient was discharged on 12/05/2023. The clinical record contained no evidence of a documented discharge summary, or a discharge summary sent to the attending physician. Clinical Record 12: The patient was discharged on 12/11/2023. The clinical record contained no evidence of a documented discharge summary or a discharge summary sent to the attending physician. Clinical Record 13: The patient was discharged on 10/24/2023. The clinical record contained no evidence of a documented discharge summary or a discharge summary sent to the attending physician. Clinical Record 14: The patient was discharged on 09/30/202. The clinical record contained no evidence of a documented discharge summary or a discharge summary sent to the attending physician. The Registered Nurse/Clinical Manager in an interview during a joint review of the clinical record on 09/26/2024, stated she is new to hospice and was not aware a discharge summary was to be sent to the attending physician.”