Substantial Allegation Survey Substantial Allegation OH00121044 An entrance conference was conducted with administrative staff on 04/05/21, an exit conference was conducted with administrative staff on 04/07/21. Alternate Solutions Homecare of Columbus was found not to be in compliance with the requirements of 42 CFR, Part 484 Subpart B,C for Home Health Agencies as a result of the substantial allegation survey completed on 04/07/21.
Every finding on record at Alternate Solutions Homecare of Columbus, LLC
Hilliard, Ohio · CCN 368227
5 findings across 1 survey, in the inspector's own words.
The inspector’s own words from form CMS-2567, unedited, including CMS’s own spacing. Names and some dates are redacted by CMS.
Survey of April 7, 2021
5 findingsComprehensive Assessment of Patients CFR(s): 484.55 Condition of participation: Comprehensive assessment of patients. Each patient must receive, and an HHA must provide, a patient-specific, comprehensive assessment. For Medicare beneficiaries, the HHA must verify the patient's eligibility for the Medicare home health benefit including homebound status, both at the time of the initial assessment visit and at the time of the comprehensive assessment. This CONDITION is not met as evidenced by: Based on medical record review, staff interview, and policy review, it was determined the agency failed to conduct the initial assessment of patient care and support needs within 48 hours of referral (G514). The systemic effect of this practice resulted in the agency's inability to ensure care and services are provided to patients timely. The agency census was 378.
RN performs assessment CFR(s): 484.55(a)(1) A registered nurse must conduct an initial assessment visit to determine the immediate care and support needs of the patient; and, for Medicare patients, to determine eligibility for the Medicare home health benefit, including homebound status. The initial assessment visit must be held either within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician or allowed practitioner - ordered start of care date. This ELEMENT is not met as evidenced by: Based on medical record review, staff interview, and policy review, it was determined the agency failed to conduct the initial assessment of patient care and support needs within 48 hours of referral for two (#1 and #3) of three patient medical records reviewed. The active census was 378. Findings include: Review of the agency policy titled "Initial and Comprehensive Assessment Policy and Procedure 04-001" noted an initial patient assessment will be performed and documented in the patient's clinical record by a registered nurse, physical therapist, or speech therapist within 48 hours of the referral. 1. Review of the medical record for Patient #1 revealed a diagnosis of multiple sclerosis. The patient had chronic urinary retention with a Foley catheter in place. The patient experienced increased fatigue and weakness after receiving the COVID-19 vaccine, resulting in a fall and hospitalization. Review of the hospital referral dated 03/21/21, indicated the need for home health care services to include: skilled nursing, home health aide, occupational therapy, and physical therapy. Review of the client coordination documentation confirmed the agency received the hospital referral on 03/21/21. Per the intake summary, the patient was status post a fall with paraplegia secondary to multiple sclerosis and had a urinary catheter in place. Disciplines ordered included: skilled nursing, occupational therapy, physical therapy, and home health aide services. Per the hospital referral services were to include cardiopulmonary assessment, disease management, medication reconciliation/instruction, activities of daily living assistance, safety and use of assistive devices, range of motion exercises, gait/mobility instruction, neuromuscular strengthening, and Foley catheter care. Review of the agency client coordination notes revealed the skilled nurse attempted to call the patient three times for a start of care on 03/22/21. The patient was unable to be reached and the visit was sent back to the office to schedule with another clinician. Review of the initial comprehensive assessment, completed by the physical therapist on 03/24/21, revealed on 03/24/21 a physical therapist began the start of care. Interview with Staff B revealed due to the COVID-19 emergency waivers a physical therapist conducted the initial comprehensive assessment on 03/24/21 instead of a skilled nurse. The medical record lacked evidence of any attempt to start care on 03/23/21 and/or physician notification of the delay in the start of care. Interview on 04/06/21 at 11:42 AM, Staff A confirmed this finding 2. Review of the medical record for Patient #3 included diagnoses of a malignant neoplasm of the right lung with pleural effusion. The patient had a PluerX (chest tube) drainage catheter placed on 12/16/20 to remove excess fluid from the pleural space. Review of the hospital referral noted the patient was to be discharged from the hospital on 12/18/20 with skilled nursing services requested to start on 12/19/20. Per the hospital documentation the son was also educated on proper procedures for drainage of the PluerX catheter system. Review of the client coordination documentation noted an attempt to reach the patient by phone on 12/18/20 to schedule the start of care. The patient was unable to be reached. On 12/21/20 the referring hospital staff reached out to the agency requesting the the start of care as soon as possible as the son drains the PluerX system daily and it's draining 500 cubic centimeters (cc) per day. On 12/21/20 the nurse called the patient to schedule the start of care and the patient was unable to be reached. On 12/22/20 the nurse spoke with the patient who declined the 12/22/20 visit and requested the start of care on 12/23/20. Review of the nursing documentation dated 12/23/20 noted the patient reported the son had not drained the PluerX for at least three days. The nurse documented 900 cc of amber colored fluid was removed from the lung. The nurse educated the patient on emergency procedures such as shortness of breath and when to seek further medical evaluation. Interview on 04/07/21 at 10:36 AM, Staff A confirmed there was no attempt to reach to patient until 12/21/20 and the physician was not notified of the delay in the start of care. This deficiency substantiates Substantial Allegation Number OH00121044.
Plan of care must include the following CFR(s): 484.60(a)(2)(i-xvi) The individualized plan of care must include the following: (i) All pertinent diagnoses; (ii) The patient's mental, psychosocial, and cognitive status; (iii) The types of services, supplies, and equipment required; (iv) The frequency and duration of visits to be made; (v) Prognosis; (vi) Rehabilitation potential; (vii) Functional limitations; (viii) Activities permitted; (ix) Nutritional requirements; (x) All medications and treatments; (xi) Safety measures to protect against injury; (xii) A description of the patient's risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors. (xiii) Patient and caregiver education and training to facilitate timely discharge; (xiv) Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient; (xv) Information related to any advanced directives; and (xvi) Any additional items the HHA or physician or allowed practitioner may choose to include. This ELEMENT is not met as evidenced by: Based on medical record review and staff interview it was determined the plan of care failed to include wound care/dressing change orders for a patient with a PlueurX drainage catheter. This affected one (#3) of three patient records reviewed. The active census was 378. Findings include: Review of the medical record for Patient #3 included diagnoses of a malignant neoplasm of the right lung with pleural effusion. The patient had a PluerX (chest tube) drainage catheter placed on 12/16/20 to remove excess fluid from the pleural space. Review of the plan of care dated 12/23/20 noted the skilled nurse was to observe/assess the PleurX tube and tube drainage system to identify and intervene to minimize complications and provide care to the PleurX tube site located in the right thoracic region as directed. The plan of care failed to include any wound care or dressing change orders for the catheter insertion site to prevent infection. Interview on 04/07/21 at 12:01 PM with Staff A confirmed the lack of wound care on the plan of care.
Preparing clinical notes CFR(s): 484.75(b)(6) Preparing clinical notes; This ELEMENT is not met as evidenced by: Based on medical record review, staff interview, and policy review, it was determined the skilled nurse failed to complete clinical notes according to policy and procedure. This affected two #1 and #3) of three patient medical records reviewed. The active census was 378. Findings include: Review of the agency policy titled "Policy and Procedure for Documentation of Clinical Services 12-002," noted home care personnel providing patient care and supervisory / quality staff have authority to make entries into the clinical/service record. Documentation in the clinical/service record will be timely, detailed, accurate, and reflect the care or services provided. Late entries will be documented stating "late entry for visit." 1. Review of the medical record for Patient #1 revealed a skilled nursing visit was conducted on 03/25/21 at 11:09 AM. Documentation of the visit was not completed until 03/29/21 at 7:57 AM. The medical record lacked documentation of a late entry as per policy. This finding was confirmed during an interview with Staff A on 04/07/21 at 10:36 AM. 2. Review of the hospital referral dated 03/21/21 for Patient #1 noted a physician request for home health aide services. An interview was conducted with Staff E on 04/06/21 at 8:46 AM who reported the patient was offered a bath aide and the service was declined due to having a private caregiver. Staff E confirmed he/she did not document the refusal of the aide service.
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