Based on the findings of an onsite unannounced Medicare recertification survey completed March 28, 2022, Amedisys Home Health was found to be in compliance with the requirements of 42 CFR, Part 484.22, Subpart B, Conditions of Participation: Home Health Agencies – Emergency Preparedness.
Every finding on record at Amedisys Pennsylvania, LLC D/B/A Amedisys Home Health
Butler, Pennsylvania · CCN 398146
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 March 28, 2022
5 findings800x600 Normal 0 false false false EN-US X-NONE X-NONE MicrosoftInternetExplorer4 st1\:*{behavior:url(#ieooui) } /* Style Definitions */ table.MsoNormalTable {mso-style-name:"Table Normal"; mso-tstyle-rowband-size:0; mso-tstyle-colband-size:0; mso-style-noshow:yes; mso-style-priority:99; mso-style-parent:""; mso-padding-alt:0in 5.4pt 0in 5.4pt; mso-para-margin:0in; mso-pagination:widow-orphan; font-size:10.0pt; font-family:"Times New Roman",serif;} Based on the findings of an onsite unannounced Medicare recertification survey completed March 28, 2022, Amedisys Home Health was found not to be in compliance with the following requirements of 42 CFR, Part 484, Subparts B and C, Conditions of Participation: Home Health Agencies.
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 review of agency policy, clinical records (CR), observation during home visits (HV), and interview with staff (EMP) and patients and their family members, the agency failed to ensure the patient's plan of care included all medications the patient was taking for five (5) of six (6) home visits when actual medications and medication lists were reviewed (HV2, HV3, & HV5-HV7). Findings include: Review of agency policy on March 25, 2022, at 11 a.m. showed, "Policy: AA-014 Plan of Care (POC)/Care Planning Process ... PROCEDURE: ... 6. The individualized plan of care must include the following: ... k. All medication and treatments." HV2 conducted with registered nurse (RN) (EMP6) at the residence of CR12 on March 24, 2022, at 10 a.m. The patient's medications were reviewed with the patient's wife, and she confirmed patient has been taking "Tylenol ... as needed for quite a while." Review of the patient's plan of care (medication list) at the time of home visit showed a start of care date of 2/17/2022 for an initial certification period ending 4/17/2022. The plan of care did not include the pain-relieving medication Tylenol. HV3 conducted with physical therapist (PT) (EMP7) at the residence of CR13 on March 24, 2022, at 11:10 a.m. The patient's plan of care was reviewed with the patient's wife. The patient started services on 12/30/2021 with a current certification period from 2/28 to 4/28/2022. The review showed the patient was taking the following medications, but the medications were not on the patient's plan of care: Tylenol 500 mg (milligrams) per day, "for a couple months;" Presser Vision (to help vision), "Just started September 2021;" MiraLAX (laxative), "takes in the morning ... couple years." The review also showed the plan of care contained the following medications, but the patient was not taking them: allopurinol 100 mg daily for gout; atorvastatin 80 mg 2 times a week for high cholesterol; and folic acid 1 mg tablet daily for vitamin deficiency. HV5 conducted with LPN (EMP9) at the residence of CR14 on March 24, 2022, at 1:30 p.m. The patient's medications were reviewed with the patient's family, and it was learned that the patient was currently taking the medication Tylenol since at least the beginning of the episode. Review of CR14's plan of care during the home visit showed a 2/15/2022 start of care for an initial certification period (episode) ending 4/15/2022. The review did not show Tylenol listed. However, the review did show that patient was taking the pain-relieving medication Percocet which also contains Tylenol-- duplicate drug therapy. HV6 conducted with PT (EMP10) at the residence of CR17 on March 25, 2022, at 9:15 a.m. The patient's medications were reviewed with the patient and his wife. The review showed patient has been taking two extra strength Tylenol every 4-5 hours since he was discharged from the hospital on 3/9/2022. Review of CR17's plan of care showed patient started services on 3/9/2022 for an initial certification period ending 5/9/2022. The review did not show Tylenol listed. However, the review did show that patient was taking the pain relieving medication Oxycodone which also contains Tylenol-- duplicate drug therapy. HV7 conducted with RN (EMP11) at the residence of CR18 on March 25, 2022, at 10:30 a.m. The patient's medications were reviewed with the patient's wife. The review showed the patient was taking 2000 international units of Vitamin D 2000 daily, "for quite a while." Review of the patient's plan of care during the visit did not show Vitamin D listed. The review also showed the allergy medication Claritin listed but the patient stopped taking it at the end of February 2022 according to the wife. Review of "Client Scheduling Calendar Report" on March 28, 2022, at 10 a.m. showed patient received several skilled service visits since the time when the Claritin was discontinued. An interview with EMP4 on March 25, 2022, at approximately 2 p.m. confirmed above medication discrepancies.
Promptly alert relevant physician of changes CFR(s): 484.60(c)(1) The HHA must promptly alert the relevant physician(s) or allowed practitioner(s) to any changes in the patient's condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered. This ELEMENT is not met as evidenced by: Based on review of agency policy and procedure, clinical records (CR), and staff (EMP) interview, the agency failed to promptly notify the physician to any changes in the patient's condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered for three (3) of three (3) clinical records who reported moderate to severe pain (CR3, CR6, & CR13). Review of agency policy on March 28, 2022, at 10:25 a.m. showed: "Policy: MSC-001 Pain assessment and Management ... PROCEDURE: ... 10. The physician should be notified when there are new complaints of pain or when prescribed interventions do not result in adequate pain relief. Policy: AA-003 Patient Assessment/Reassessment ... 20. The patient's primary physician will be notified of changes/updates in the patient's condition: a. Any changes in the patient's condition or needs indicating outcomes are not being achieved and/or that the plan of care should be altered." Review of CR3 on March 22, 2022, at 1:35 p.m. showed a physician ordered plan of care for an initial certification period from 7/6/2021 to 9/3/2021. Orders included pain management. The initial skilled nursing start of care assessment on 7/6/2021 showed patient reported pain of 3/10 (3 out of 10 on a 0-10 scale with 10 being severe pain) that occurred daily but not constantly. Subsequent visit on 7/8/2021 by physical therapist (PT) showed patient reported pain at 7/10 but with activity only. An occupational therapy (OT) visit the same day showed patient reported pain at 7/10 that occurred daily but not constantly. A PT visit on 7/13/2021 showed patient reported pain was 7/10 that occurred daily but not constantly and was 9/10 at worse in the last 24 hours. A PT visit on 7/20/2021 showed patient reported pain at 7/10 that occurred with activity only and constantly and was 8/10 at worse within the last 24 hours. A skilled nursing visit on 7/22/2021 showed patient's pain was now constant "all the time," was 7/10, and 8/10 at worse in the last 24 hours. Patient continued to experience moderate to severe pain for the remainder of the episode until discharged from the agency on 8/10/2021. Interview with EMP4 (administrator) on March 25, 2022, at 1:58 p.m. confirmed above findings and that skilled professional services did not notify the physician concerning the patient's moderate to severe pain. Review of CR6 on March 22, 2022, at 3 p.m. showed a physician ordered plan of care for an initial certification period from 2/14/2022 to 4/14/2022. Patient's admitting diagnoses were pressure ulcers to right ankle, and both sides of buttocks. The initial skilled nursing start of care assessment was completed on 2/14/2022 but the patient was admitted for sepsis and did not return to the agency until 2/22/2022 when the resumption of care visit showed patient reported pain of 10/10. The "pharmacological intervention" was listed as "Tylenol." The "Narrative" portion of the skilled nursing note showed the nurse contacted the physician for wound care orders, but there was nothing to show physician was informed or that orders were obtained for patient's 10/10 pain. An OT visit on 3/1/2022 showed patient reported pain at 10/10 that was all the time in both lower extremities and was aching, burning, and shooting in nature. A skilled nursing visit on 3/4/2022 showed patient reported pain at 5/10 but was 10/10 at worse in the last 24 hours-- pharmacological intervention was Tylenol. An OT visit on 3/9/2022 showed patient reported pain at 10/10. A skilled nursing visit on 3/11/2022 showed patient reported pain at 6/10 but was 10/10 at worse in the last 24 hours-- pharmacological intervention was Tylenol. An OT visit on 3/16/2022 showed patient reported pain at 10/10. A skilled nursing visit on 3/17/2022 showed patient reported pain at 7/10 but was 10/10 at worse in the last 24 hours-- pharmacological intervention was Tylenol as needed. Interview with EMP4 on March 25, 2022, at 2 p.m., and EMP12 (area VP of clinical) on March 28, 2022, at 9:30 a.m. confirmed above findings and that skilled professional services did not notify the physician concerning the patient's moderate to severe pain. Review of CR13 on March 23, 2022, at 12:25 p.m. showed a physician ordered plan of care beginning 12/30/2021 and a recertification period 2/28/2022 to 4/28/2022. Admitting diagnoses were venous insufficiency, an ulcer to right leg, diabetic foot ulcer and diabetic neuropathy. Orders included pain management. A skilled nursing visit from 2/28/2022 showed patient reported pain 8/10 and 10/10 at worse in the last 24 hours. Pharmalogical intervention was listed as Tylenol. A skilled nursing visit on 3/2/2022 showed patient reported pain 8/10 with 10/10 being the worse in last 24 hours that constant and aching/burning in nature. A skilled nursing visit on 3/4/2022 showed patient reported pain 8/10 with 10/10 being the worse in last 24 hours that constant and aching/burning in nature. An OT visit on 3/4/2022 showed patient reported pain 7/10 with 9/10 being the worse in last 24 hours that constant and aching/burning in nature. The pharmalogical intervention was listed as gabapentin (to treat neurogenic pain) and that "It takes the edge off a little." The patient continued to report severe pain and a skilled nurse visit on 3/18/2022 showed patient reported pain 10/10. Pharmalogical intervention was listed as gabapentin. There was no change in the plan of care until 3/18/2022 when patient's gabapentin was increased from 300 mg daily to 400 mg three times daily. A skilled nurse visit on 3/21/2022 showed patient continued to report severe pain at 8/10 and 10/10 at worse in the last 24 hours. A skilled nurse visit on 3/25/2022 showed patient reported pain at 8/10 and 10/10 at worse in the last 24 hours. No other interventions made until 3/18/2022 to help decrease the patient's pain. Interview with EMP4 (administrator) on March 25, 2022, at 2:05 p.m.
In accordance with current clinical practice CFR(s): 484.105(f)(2) All HHA services must be provided in accordance with current clinical practice guidelines and accepted professional standards of practice. This ELEMENT is not met as evidenced by: Based on review of agency policy, manufacturer directions for use, observations during home visits (HV), and staff (EMP) interviews, the agency failed to ensure staff followed accepted standards of practice for six (6) of seven (7) home visits conducted (HV1-HV5, & HV7). Findings include: Review of agency policy on March 24, 2022, at 2 p.m., "PCP-002 ... Bag Technique ... PURPOSE: To provide guidelines for the adherence of the principles of infection prevention in relationship to practitioner equipment and supply bag usage ... APPLICABLE DISCIPLINES: All Staff ... GUIDELINES: ... Nothing inside the bag should ever be 'dirty' or soiled. Staff should not re-enter the bag with used gloves. Always perform hand hygiene before entering the bag. ... PROCEDURE: ... 3. The field staff member cleanses hands prior to accessing materials from the supply bag. ... 4. Equipment and supplies to be used, such as blood pressure cuff and thermometer, are removed and placed on a clean field. Keep the supply bag closed when not in use. 5. Wash hands again if you need to re-enter the bag for additional supplies during patient care. Do not go back into the bag without removing gloves and performing hand hygiene. ... 8. Hands are cleansed prior to returning clean equipment to the bag." HV1 conducted with occupational therapist (OT) (EMP5) on March 24, 2022, at 9:20 a.m. During the visit, the OT unzipped his/her supply bag, removed supplies, and assessed the patient. Supply bag remained unzipped for entire visit. Interview with EMP5 at 9:49 a.m. confirmed findings. HV2 conducted with registered nurse (RN) (EMP6) on March 24, 2022, at 10 a.m. EMP6 donned gloves and finished ostomy care. Cat jumped up onto supply bag. EMP6 removed gloves and with no hand hygiene went into supply bag and retrieved stethoscope. EMP6 donned new gloves and proceeded with assessment of patient but left supply bag unzipped. Interview with EMP6 at approximately 10:30 a.m. confirmed findings. HV3 conducted with physical therapist (PT) (EMP7) on March 24, 2022, at 11:10 a.m. EMP7 unzipped his/her supply bag, folded its side compartment down and donned gloves for assessment. The compartment contained other supplies intended to remain clean. Once assessment was competed, EMP7 wiped equipment with alcohol and placed the equipment back inside the bag while wearing the same gloves. EMP7 then proceeded with patient treatment wearing the same gloves and with supply bag unzipped. Interview with EMP7 at 11:40 a.m. confirmed findings. HV4 conducted with licensed practical nurse (LPN) (EMP8) on March 24, 2022, at 12:24 p.m. EMP8 placed barrier on kitchen table and talked to patient. At this time, patient's cat jumped on table and walked on barrier. EMP8 removed equipment from supply bag and used it for patient assessment. Once finished, EMP8 placed equipment onto contaminated barrier. EMP8 then wiped equipment with gloved hands and while wearing gloves and before items were dry, placed back into bag one by one. Review of disinfectant wipe used by EMP8 showed, "Sani-Cloth ... TO DISINFECT ... Unfold a clean wipe and thoroughly wet surface. Allow treated surface to remain wet for a full two (2) minutes." Interview with EMP8 at 12:35 p.m. confirmed findings. HV5 conducted on March 24, 2022, at 1:30 p.m. with LPN (EMP9). EMP9 opened bag and removed supplies from bag and placed on folded down portion of bag (clean portion of bag per EMP9). EMP9 placed equipment onto the inside portion of the folded down compartment. This same compartment also contained supplies intended to remain clean such as alcohol wipes, thermometer, and thermometer probe covers. EMP9 proceeded with patient assessment. During the assessment and with gloved hands, EMP9 retrieved blood pressure cuff from folded down part of bag. EMP9 continued to touch patient with gloved hands during assessment and then reached into bag while wearing gloves for thermometer and probe cover. EMP9 then prepared supplies for patient and provided wound care. The supply bag remained unzipped in this manner for the entire visit. Interview with EMP9 at 2 p.m. confirmed findings. HV7 conducted with RN (EMP11) on March 25, 2022, at 10:30 a.m. EMP11 used equipment on patient for assessment. Once assessment was completed, EMP11 used alcohol wipes on each piece of equipment with ungloved hands and placed directly back into bag one at a time without letting equipment dry or performing hand hygiene. Interview with EMP11 at 11:15 a.m. confirmed findings.
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