Every finding on record at American Home Health Care, LLC

On 4/18/22 through 4/21/22, the Michigan Department of Licensing and Regulatory Affairs conducted a recertification survey at American Home Health Care. This was a standard survey. The requirements for participation in Medicare at 42 CFR 484.102 Emergency Preparedness were not reviewed.

The following standard level deficiencies were identified at a Medicare authorized recertification survey, concurrent with a Covid-19 vaccine mandate review, conducted by the Michigan Department of Licensing and Regulatory Affairs on 4/18/22 through 4/21/22 at: American Home Health Care 2075 Fort Street, Suite 201 Lincoln Park, MI 48146 At the time of the survey, the Agency did not operate any branch offices or subunits. The services provided include, Skilled Nursing (SN), Physical Therapy (PT), Occupational Therapy (OT), Medical Social Worker (MSW) and Home Health Aide (HHa). The Agency was in compliance with staff COVID-19 vaccine mandates. Clinical records reviewed for this survey: 2 records with home visits and 5 records without home visits for a total of 7 records reviewed. At the conclusion of the survey, the Agency was found to not be in substantial compliance for the conditions of participation for home health agencies at: 42 CFR Part 484.

HHA administrator contact information CFR(s): 484.50(a)(1)(ii) (ii) Contact information for the HHA administrator, including the administrator's name, business address, and business phone number in order to receive complaints. This ELEMENT is not met as evidenced by: Based on record review and interview, the agency failed to ensure patients were informed of the name and contact information for the agency's administrator for 7 of 7 records reviewed (MR# 1, 2, 3, 4, 5, 6, 7), resulting in the potential for patient complaints or concerns to go unaddressed which could affect the 14 patients the agency cared for in the past year. Findings include: The agency provides their patients with a folder that contains many papers and forms including a consent for care, medication profile, emergency plan, patient rights, and responsibilities. On 4/18/22, the contents of the agency's admission folder were reviewed. There was no documentation of the administrator's name and contact information to enable patients to express their concerns or complaints. The findings were reviewed with and confirmed by the Administrator (Adm#1) during an interview on 4/21/22 at 12:30 pm.

Participate in care CFR(s): 484.50(c)(4)(i,ii,iii,iv,v,vi,vii,viii) Participate in, be informed about, and consent or refuse care in advance of and during treatment, where appropriate, with respect to-- (i) Completion of all assessments; (ii) The care to be furnished, based on the comprehensive assessment; (iii) Establishing and revising the plan of care; (iv) The disciplines that will furnish the care; (v) The frequency of visits; (vi) Expected outcomes of care, including patient-identified goals, and anticipated risks and benefits; (vii) Any factors that could impact treatment effectiveness; and (viii) Any changes in the care to be furnished. This ELEMENT is not met as evidenced by: Based on record review and interview, the agency failed to inform the patient in advance of the disciplines that will furnish care in 1 records reviewed (MR# 5) from a total sample of 7 records reviewed, resulting in the patient not having knowledge of the plan for treatment and potential unmet care needs. Findings include: MR#5: The Start of Care (SOC) was dated 1/27/22. The Plan of Care (POC) identified diagnoses of Osteoarthritis, Unsteady Gait and Hypertension. During record review on 4/20/22, it was noted that the referral dated 1/24/22 documented, “I certify that, based on my findings, the following services are medically necessary home health services: Physical Therapy (PT), Skilled Nursing (SN) and Home Health Aide (HHA).” The comprehensive assessment completed on 1/27/22 documented, “Orders for Discipline and Treatments. SN: 1w1 (1 time a week for 1 week). PT: 1w1, 2w5, 1w1. HHA: Blank.” There was no documentation that the patient declined HHA services. The agency failed to provide HHA services as referred. The finding was reviewed with and confirmed by the Administrator (Adm#1) during an interview on 4/21/22 at 12:30 pm.

Written notice for non-covered care CFR(s): 484.50(c)(8) Receive proper written notice, in advance of a specific service being furnished, if the HHA believes that the service may be non-covered care; or in advance of the HHA reducing or terminating on-going care. The HHA must also comply with the requirements of 42 CFR 405.1200 through 405.1204. This ELEMENT is not met as evidenced by: Based on record review and interview, the Agency failed to ensure the patient received proper written notice (Notice of Medicare Provider Non-Coverage) in advance of the agency terminating on-going care for 4 (MR# 1, 2, 6, 7) of 5 discharged records, resulting in the patient being denied the right to appeal the decision to end Medicare covered services. Findings include: MR#1: The Start of Care (SOC) was dated 6/10/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Multiple Falls and Muscle Weakness. During record review on 4/18/22, it was noted the "Notice of Medicare Non-Coverage" was signed on 8/7/21, the date of the patients discharge from services. The Agency failed to ensure the patient received proper written Notice of Medicare Provider Non-Coverage in advance of the agency terminating on-going care. MR#2: The Start of Care (SOC) was dated 10/19/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Osteoarthritis and Muscle Weakness. During record review on 4/18/22, it was noted the "Notice of Medicare Non-Coverage" was blank under the section "The effective Date Coverage of Your Current Home Health Care Services Will End." The Agency failed to ensure the patient received proper written Notice of Medicare Provider Non-Coverage in advance of the agency terminating on-going care. MR#6: The Start of Care (SOC) was dated 9/22/21. The Plan of Care (POC) identified diagnoses of Osteoarthritis, Right Leg Pain and Falls. During record review on 4/20/22, it was noted the "Notice of Medicare Non-Coverage" was signed on 9/22/21, the date of the SOC. The form was also blank under the section "The effective Date Coverage of Your Current Home Health Care Services Will End." The Agency failed to ensure the patient received proper written Notice of Medicare Provider Non-Coverage in advance of the agency terminating on-going care. MR#7: The Start of Care (SOC) was dated 9/22/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Osteoarthritis and Chronic Obstructive Pulmonary Disease (COPD). During record review on 4/21/22, it was noted the "Notice of Medicare Non-Coverage" was signed on 9/22/21, the date of the SOC. The form was also blank under the section "The effective Date Coverage of Your Current Home Health Care Services Will End." The Agency failed to ensure the patient received proper written Notice of Medicare Provider Non-Coverage in advance of the agency terminating on-going care. These findings were reviewed with and confirmed by the Administrator (Adm#1) during an interview on 4/21/22 at 12:45 pm.

Contact info Federal/State-funded entities CFR(s): 484.50(c)(10)(i,ii,iii,iv,v) Be advised of the names, addresses, and telephone numbers of the following Federally-funded and state-funded entities that serve the area where the patient resides: (i) Agency on Aging (ii) Center for Independent Living (iii) Protection and Advocacy Agency, (iv) Aging and Disability Resource Center; and (v) Quality Improvement Organization. This ELEMENT is not met as evidenced by: Based on record review and interview, the Agency failed to advise their patients of the names, addresses and telephone numbers of federally funded and state-funded entities that serve the area where the patient resides, resulting in the potential for unmet patient care needs. Findings include: During review of the Agency's patient admission packet on 4/18/21, it was noted that the information for the Federally and State funded patient resource entities (Agency on Aging, Center for Independent Living, Protection and Advocacy Agency, Aging and Disability Resource Center and Quality Improvement Organization) had not been included. The finding was reviewed with and confirmed by the Administrator (Adm#1) during the exit interview on 4/21/22.

Skilled services furnished CFR(s): 484.105(f) Standard: Services furnished. Skilled nursing services and at least one other therapeutic service (physical therapy, speech-language pathology, or occupational therapy; medical social services; or home health aide services) are made available on a visiting basis, in a place of residence used as a patient's home. An HHA must provide at least one of the services described in this subsection directly, but may provide the second service and additional services under arrangement with another agency or organization. This STANDARD is not met as evidenced by: Based on interview and record review, the administrator failed to ensure that at least one qualifying service was provided directly by agency employees, resulting in the potential for all services to be provided by contracted staff. Findings include: During the entrance conference on 4/18/22, the administrator (Adm#1) was asked what services were currently provided by the agency. The response was, "We offer Skilled Nursing (SN), Physical Therapy (PT), Occupational Therapy (OT), Medical Social Work (MSW) and Home Health aide (HHa)." When asked what service was provided directly by the agency, Adm#1 stated, "PTA (Physical Therapy Assistant) and Nursing services are provided directly by the agency." Adm#1 was then questioned regarding the PTA and Nursing staff receiving W-2’s or 1099’s and stated, “The PTA receives a W-2 and the nurses receive 1099’s.” All services have the potential to be provided by contracted staff.

Discharge and transfer summaries CFR(s): 484.110(a)(6)(i-iii) (i) A completed discharge summary that is sent to the primary care practitioner or other health care professional who will be responsible for providing care and services to the patient after discharge from the HHA (if any) within 5 business days of the patient's discharge; or (ii) A completed transfer summary that is sent within 2 business days of a planned transfer, if the patient's care will be immediately continued in a health care facility; or (iii) A completed transfer summary that is sent within 2 business days of becoming aware of an unplanned transfer, if the patient is still receiving care in a health care facility at the time when the HHA becomes aware of the transfer. This ELEMENT is not met as evidenced by: Based on record review and interview, the Agency failed to ensure a discharge summary was forwarded to the physician within 5 days of discharge in 5 (MR# 1, 2, 5, 6, 7), of 5 closed records, from a total of 7 records reviewed, resulting in the potential for unidentified continuing health care concerns and unmet care needs. Findings include: MR#1: The Start of Care (SOC) was dated 6/10/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Multiple Falls and Muscle Weakness. The Skilled Nurse (SN) completed a discharge OASIS (outcome and assessment information set) on 8/7/21. During record review on 4/18/22, it was noted that there was no documented evidence a discharge summary was sent to the physician within 5 business days of the patient's discharge. MR#2: The Start of Care (SOC) was dated 10/19/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Osteoarthritis and Muscle Weakness. The SN completed a discharge OASIS on 2/8/22. During record review on 4/18/22, it was noted that there was no documented evidence a discharge summary was sent to the physician within 5 business days of the patient's discharge. MR#5: The Start of Care (SOC) was dated 1/27/22. The Plan of Care (POC) identified diagnoses of Osteoarthritis, Unsteady Gait and Hypertension. The SN completed a discharge OASIS on 3/18/22. During record review on 4/20/22, it was noted that there was no documented evidence a discharge summary was sent to the physician within 5 business days of the patient's discharge. MR#6: The Start of Care (SOC) was dated 9/22/21. The Plan of Care (POC) identified diagnoses of Osteoarthritis, Right Leg Pain and Falls. The SN completed a discharge OASIS on 1/18/22. During record review on 4/20/22, it was noted that there was no documented evidence a discharge summary was sent to the physician within 5 business days of the patient's discharge. MR#7: The Start of Care (SOC) was dated 9/22/21. The Plan of Care (POC) identified diagnoses of Disc Degeneration, Osteoarthritis and Chronic Obstructive Pulmonary Disease (COPD). The SN completed a discharge OASIS on 1/18/22. During record review on 4/21/22, it was noted that there was no documented evidence a discharge summary was sent to the physician within 5 business days of the patient's discharge. These findings were reviewed with and confirmed by the Administrator (Adm#1) during an interview on 4/21/22 at 12:50 pm.