A Recertification Survey entrance conference was initiated on 08/18/2022. Census: Licensed and Certified- 0 Licensed Home Health- 2 Personal Assistance Services- 45 Agency operated in substantial compliance with the Medicare Conditions of Participation for Emergency Preparedness.
Every finding on record at Citizens Healthcare Services LLC
Richardson, Texas · CCN 747808
3 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 August 26, 2022
3 findingsA Recertification Survey entrance conference was initiated on 08/18/2022. Census: Licensed and Certified- 0 Licensed Home Health- 2 Personal Assistance Services- 45 Abbreviations/Definitions: QIO- Quality Improvement Organization COP's- Conditions of Participation KEPRO- Keystone Peer Review Organization, Inc. NOMNC- Notice of Medicare Non-Coverage CMS- Center for Medicare and Medicaid services BFCC- Beneficiary and Family Centered Care POC- Plan of Care SOC- Start of Care D/C- Discharge HHABN- Home Health Advance Beneficiary Notice- provided to original Medicare beneficiaries receiving home health care benefits to notify of plan of care changes. Form does not include QIO appeal information.
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 provide the contact information of the current QIO for 4 (Patient’s #4, 5, 6 and 7) of 5 patients whose goals were met and discharge records reviewed. Specifically, the current QIO contact information was not listed in the agency's NOMNC information. This failure prevented the patients from exercising their right to appeal the discharge decision. FINDINGS INCLUDE: A QIO is a CMS patient advocacy agency that deals with discharge, appeals, complaints, and advocates for CMS patients. Effective June 8, 2019, CMS restructured the BFCC/QIO coverage. Texas is now in region 6. The current QIO, KEPRO toll-free phone number is xxx-xxx-0636 and contact information is located on the website: www.keproqio.com. HHABN- provided to original Medicare beneficiaries receiving home health care benefits to notify of a plan of care change. Form does not include QIO appeal information. An agency list of discharged patients from 07/31/2021-08/01/2022 was provided to the surveyor on 08/18/2022. The list included the following discharge dates: Patient 4: 11/12/2021; Patient 5: 11/22/2021; Patient 6: 09/22/2021 and Patient 7 03/20/2022: Patient #4: Review of the record revealed a POC with a certification period of 09/24/2021 to 11/12/2021. The POC included the following diagnoses: Age-related osteoporosis without current pathological fracture; Low back pain and Essential (primary) Hypertension. A discharge summary dated 12/03/2021 included, “… Reason for Discharge- Goals Met….” An agency form titled; “Notice of Medicare Non-Coverage” included 11/12/2021 as the effective date home health services would end. Patient #4 signed the form 11/05/2021. The form included, “… How to Ask for an Immediate Appeal… Your request for an immediate appeal should be made as soon as possible, but no later than noon of the day before the effective date indicated above…. Call your QIO at: {insert QIO name and toll-free number of QIO} to appeal, or if you have questions….” The form did not include the name or contact phone number of the region 6 QIO. Review of the entire record did not reveal any discharge information with the contact information of the QIO for the patient to appeal the discharge. Patient #5: Review of the record revealed a POC with a certification period of 09/24/2021 to 11/22/2021. The POC included the following diagnoses: Bilateral primary osteoarthritis of knee; Essential (primary) hypertension and Type 2 diabetes mellitus with other circulatory complications. A discharge summary dated 12/03/2021 included, “… Reason for Discharge- Goals Met….” An agency form titled; “Notice of Medicare Non-Coverage” included 11/22/2021 as the effective date home health services would end. Patient #5 signed the form 11/18/2021. The form included, “… How to Ask for an Immediate Appeal… Your request for an immediate appeal should be made as soon as possible, but no later than noon of the day before the effective date indicated above…. Call your QIO at: {insert QIO name and toll-free number of QIO} to appeal, or if you have questions….” The form did not include the name or contact phone number of the region 6 QIO. Review of the entire record did not reveal any discharge information with the contact information of the QIO for the patient to appeal the discharge. Patient #6: Review of the record revealed a POC with a certification period of 07/25/2021 to 09/22/2021. The POC included the following diagnoses: Primary generalized (osteo)arthritis; Essential (primary) hypertension and Other idiopathic peripheral autonomic neuropathy. A discharge summary dated 09/28/2021 included, “… Reason for Discharge- Goals Met….” An agency form titled; “Notice of Medicare Non-Coverage” included 09/22/2021 as the effective date home health services would end. Patient #6 signed the form 09/16/2021. The form included, “… How to Ask for an Immediate Appeal… Your request for an immediate appeal should be made as soon as possible, but no later than noon of the day before the effective date indicated above…. Call your QIO at: {insert QIO name and toll-free number of QIO} to appeal, or if you have questions….” The form did not include the name or contact phone number of the region 6 QIO. Review of the entire record did not reveal any discharge information with the contact information of the QIO for the patient to appeal the discharge. Patient #7: Review of the record revealed a POC with a certification period of 01/20/22 to 03/30/2022. The POC included the following diagnoses: Type 2 diabetes mellitus with diabetic neuropathy; Essential (primary) hypertension and Atherosclerotic heart disease. A discharge summary dated 05/13/2022 included, “… Reason for Discharge- Goals Met….” An agency for titled, “Notice of Medicare Non-Coverage” included 03/30/2022 as the effective date home health services would end. Patient #7 signed the form 03/23/2022. The form included, “… How to Ask for an Immediate Appeal… Your request for an immediate appeal should be made as soon as possible, but no later than noon of the day before the effective date indicated above…. Call your QIO at: {insert QIO name and toll-free number of QIO} to appeal, or if you have questions….” The form did not include the name or contact phone number of the region 6 QIO. Review of the entire record did not reveal any discharge information with the contact information of the QIO for the patient to appeal the discharge. During an interview with the Administrator and Office Manager on 08/26/2022 at approximately 3:00 PM, the surveyor presented the findings. The Administrator stated, “the patient has the phone number to the agency to tell us wat they need if they wat to appeal the discharge, the agency provided the HHABN.” The surveyor and Administrator reviewed the agency policy and the NOMNC form. The surveyor asked how this could have impacted the patient. The Administrator did not provide a response. Agency policy, quoted in part, “4.6 PATIENT DISCHARGE… The Agency will provide appropriate discharge planning and notification, per regulations…. The Agency will provide notice to eligible patients of their right to expedited determinations when their period of covered care ends. … The agency will deliver the Notice of Medicare Non-Coverage (an OMB-approved Medicare form) to the patient (or authorized representative), at least 2 calendar days before Medicare covered services end or the second to last day of service if care is not provided daily.…”
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