On 7/11/22, a complaint survey was conducted. This resulted in a standard survey at Interim Healthcare. The agency was found to have not met the requirements at 42 CFR. Part 484 for Home Health Agencies. H72813096C/71105 was unsubstantiated, however related deficiencies were issued at G550 as a result of the complaint investigation.
Every finding on record at Interim Healthcare
Duluth, Minnesota · CCN 247281
5 findings across 2 surveys, 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 July 11, 2022
2 findingsAt discharge CFR(s): 484.55(d)(3) At discharge. This ELEMENT is not met as evidenced by: Based on interview and document review, the agency failed to complete a comprehensive assessment at discharge to include a summary of the patient's progress in meeting the care plan goals for 1 of 3 patient (P1) who received non-skilled services reviewed for discharges. P1 was admitted to the agency on 8/21/21. P1 received weekly Aide services three time weekly for eight weeks beginning week of 6/5/22, through 7/30/22 according to the plan of care for the certification period 6/5/22 through 8/3/22. Record review revealed P1 was discharged on 6/20/22, however, there was no comprehensive assessment at discharge to include a summary of the patient's progress in meeting the care plan goals, and no explanation why the discharge assessment had not been completed for P1 in the clinical record. During review of the discharge summary dated 7/1/22, it was revealed registered nurse (RN)-A had documented "Summary: Client to be discharged from para services due to no available caregivers. A letter was sent out to client 10 days prior to discharge. No visit made." During interview on 7/11/22, at 12:58 p.m. RN-A stated she had been told to discharge P1 and it was supposed to be a "no visit discharge and did not need to go see her." RN-A stated she had not been the assigned case manager to P1 and is not familiar with discharge assessment. RN-A acknowledged she had found out later she was supposed to complete the assessment. RN-A also stated she had just completed the discharge summary on the computer and did not call P1 "I did not know I was supposed to go in and I thought because she was only getting para services, I did not need a visit nurse." RN-A then stated RN-B had educated her on the discharge requirements and RN-B had her she was supposed to have completed a home visit. RN-A further stated everything with the agency discharging multiple patients rather happened quickly and thought this would have been the other reason. During interview on 7/11/22, at 1:23 p.m. RN-B stated P1 received non-skilled services prior to her discharge from the agency. RN-B stated all patients had received a 10-day notice that the agency was closing including P1 who was admitted to the agency but did not have a current caregiver due to staffing issues which was the reason agency was closing. RN-B stated the agency had followed through the required communications with all parties involved including patients of the closure and was assisting patients to transfer to other agencies to continue with services. RN-B stated when she found out RN-A had completed a non-visit discharge she had educated her on the requirements. RN-B stated the policy was "for a patient with skilled services we would go in do a face-to-face visit and complete an Oasis assessment but she was not getting skilled services so it would have been a courtesy visit." The agency Discharge from Home Care dated 1/13/18, directed: "The designated employee completes the discharge assessment for any patient/client who has received more than one visit: During the last visit; or 1. Within 48 hours of discharge or knowledge of discharge. 2. The comprehensive assessment is completed to accurately reflect the patient's status at the time of discharge..."
Survey of January 28, 2022
3 findingsOn 1/27/22, through 1/28/22, an abbreviated on-site survey was conducted to investigate a complaint. The agency was found to have not met the requirements at 42 CFR. Part 484 for Home Health Agencies. The cumulative effects of these findings resulted in the the Home Health Agency's inability to ensure provision of quality of care.The following complaint was found to be unsubstantiated: H7281014C (61683, 61684, 61672, 61674) however an unrelated deficiency was cited at G687. The Condition of Participation: 484.70 Infection prevention and control was not met at G680. A partial extended survey was conducted and resulted in substandard quality of care. Hours of Operation: Monday through Friday 8:00 a.m. to 4:30 p.m.
Infection prevention and control CFR(s): 484.70 Condition of Participation: Infection prevention and control. The HHA must maintain and document an infection control program which has as its goal the prevention and control of infections and communicable diseases. This CONDITION is not met as evidenced by: Based on interview and document review, the home health agency (HHA) failed to meet the Condition of Participation at 484.70 Infection Prevention and Control. The agency failed to ensure they developed and implemented policies and procedures for COVID-19 Vaccination of Home Health Agency Staff. Refer to G687: Based on interview and document review the agency failed to ensure a 100% vaccination rate for COVID-19 as required, 4 of 98 (HHA-A, HMK-A, HHA-B and RN-A) staff did not have proof of vaccination or proof of an exemption from vaccination. In addition, the agency failed to develop a process for tracking and documenting vaccination status, booster doses, or exemptions.
COVID-19 Vaccination of Home Health Agency staff CFR(s): 484.70 (d)-(d)(3)(i-x) § 484.70 Condition of Participation: Infection Prevention and Control. (d) Standard: COVID-19 Vaccination of Home Health Agency staff. The home health agency (HHA) must develop and implement policies and procedures to ensure that all staff are fully vaccinated for COVID-19. For purposes of this section, staff are considered fully vaccinated if it has been 2 weeks or more since they completed a primary vaccination series for COVID-19. The completion of a primary vaccination series for COVID-19 is defined here as the administration of a single-dose vaccine, or the administration of all required doses of a multi-dose vaccine. (1) Regardless of clinical responsibility or patient contact, the policies and procedures must apply to the following HHA staff, who provide any care, treatment, or other services for the HHA and/or its patients: (i) HHA employees; (ii) Licensed practitioners; (iii) Students, trainees, and volunteers; and (iv) Individuals who provide care, treatment, or other services for the HHA and/or its patients, under contract or by other arrangement. (2) The policies and procedures of this section do not apply to the following HHA staff: (i) Staff who exclusively provide telehealth or telemedicine services outside of the settings where home health services are directly provided to patients and who do not have any direct contact with patients, families, and caregivers, and other staff specified in paragraph (d)(1) of this section; and (ii) Staff who provide support services for the HHA that are performed exclusively outside of the settings where home health services are directly provided to patients and who do not have any direct contact with patients, families, and caregivers, and other staff specified in paragraph (d)(1) of this section. (3) The policies and procedures must include, at a minimum, the following components: (i) A process for ensuring all staff specified in paragraph (d)(1) of this section (except for those staff who have pending requests for, or who have been granted, exemptions to the vaccination requirements of this section, or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations) have received, at a minimum, a single-dose COVID-19 vaccine, or the first dose of the primary vaccination series for a multi-dose COVID-19 vaccine prior to staff providing any care, treatment, or other services for the HHA and/or its patients; (ii) A process for ensuring that all staff specified in paragraph (d)(1) of this section are fully vaccinated for COVID-19, except for those staff who have been granted exemptions to the vaccination requirements of this section, or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations; (iii) A process for ensuring the implementation of additional precautions, intended to mitigate the transmission and spread of COVID-19, for all staff who are not fully vaccinated for COVID-19; (iv) A process for tracking and securely documenting the COVID-19 vaccination status of all staff specified in paragraph (d)(1) of this section; (v) A process for tracking and securely documenting the COVID-19 vaccination status of any staff who have obtained any booster doses as recommended by the CDC; (vi) A process by which staff may request an exemption from the staff COVID-19 vaccination requirements based on an applicable Federal law; (vii) A process for tracking and securely documenting information provided by those staff who have requested, and for whom the HHA has granted, an exemption from the staff COVID-19 vaccination requirements; (viii) A process for ensuring that all documentation, which confirms recognized clinical contraindications to COVID-19 vaccines and which supports staff requests for medical exemptions from vaccination, has been signed and dated by a licensed practitioner, who is not the individual requesting the exemption, and who is acting within their respective scope of practice as defined by, and in accordance with, all applicable State and local laws, and for further ensuring that such documentation contains (A) All information specifying which of the authorized COVID-19 vaccines are clinically contraindicated for the staff member to receive and the recognized clinical reasons for the contraindications; and (B) A statement by the authenticating practitioner recommending that the staff member be exempted from the HHA's COVID-19 vaccination requirements for staff based on the recognized clinical contraindications; (ix) A process for ensuring the tracking and secure documentation of the vaccination status of staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations, including, but not limited to, individuals with acute illness secondary to COVID-19, and individuals who received monoclonal antibodies or convalescent plasma for COVID-19 treatment; and (x) Contingency plans for staff who are not fully vaccinated for COVID-19. This STANDARD is not met as evidenced by: Based on interview and document review the agency failed to ensure a 100% vaccination rate for COVID-19 as required, 4 of 98 (HHA-A, HMK-A, HHA-B and RN-A) staff did not have proof of vaccination or proof of an exemption from vaccination. In addition, the agency failed to develop a process for tracking and documenting vaccination status, booster doses, or exemptions. On review of the agency's employee vaccination records on 1/27/22 and 1/28/22, indicated the agency had a 95% vaccination rate for COVID-19, which included vaccinated staff and staff with approved exemptions. The agency did not have any pending requests for exemption from the COVID-19 vaccination filed at the time of review. During interview on 1/27/22, at 12:44 human resources manger (HR)-A provided a list of the agency's current employees. She indicated the agency had 98 staff. The employees with dates next to their name on the list had received vaccinations for COVID-19. The other employees on the list were either unvaccinated or had received approved exemptions. She would have to look up their exemption and declination forms to see which employees had approved exemptions as the employee list did not indicate that information. The list did not include whether the vaccination series was complete or identify employees who had received vaccination boosters as recommended by the CDC. The employee list lacked identification of approved exempt employees, exemption requests with results pending or employees refusing vaccine. HR-A stated she was working on trying to get the information organized and had just received an email that day, from the director of nursing (DON) of a template to use to track this information. All the agency unvaccinated employees continued to work and were required to put on an N95 mask and cover that with a surgical mask when providing patient care. She had located and provided exemption forms for three of the five exempt employees, however could not locate the exemption forms for two of the agency's unvaccinated employees. HR-A identified two additional agency staff had not filed an exemption form and continued to refuse to obtain the COVID-19 vaccine. When interviewed on 1/27/22, at 10:16 a.m. the DON indicated unvaccinated staff were allowed to continue to provide direct patient care, regardless of whether they had approved exemptions or had not requested exemption. Unvaccinated staff were to wear an N95 mask and a surgical mask and goggles. The agency did not require any testing for COVID-19 unless employees were symptomatic for COVID-19. She had talked to the unvaccinated staff on numerous occasions and they continued to refuse the COVID-19 vaccine. Other than that, she did not know what else she could do. During interview on 1/28/22, at 10:16 a.m. the director of nursing (DON) stated home health aide (HHA)-A and homemaker (HMK)-A refused the COVID-19 vaccination and did not have exemption requests. She had thought HHA-B and registered nurse (RN)-A had filed for exemptions to the COVID-19 vaccine, however, was unable to find the exemption forms. The agency's CMS COVID-19 Vaccination Mandate policy dated 12/3/21, indicated the administrator or designee would be responsible for identifying all eligible agency staff and would verify and track COVID-19 vaccination status. Vaccination categories would be determined to include the unvaccinated, recipients of first dose of the primary vaccination series, completion of a primary vaccination series, fully vaccinated staff and fully vaccinated staff with booster dose. A tracking log would be completed to include agency staff name, date and name of vaccine and booster doses, date in which staff requested a vaccination delay and/or exemption and the date the request was granted or denies, and the date in which staff had declined both the COVID-19 vaccination and request for exemption. Any staff that did not submit proof of vaccination and did not request an exemption are considered unvaccinated without an exemption. All new and current agency staff who are currently unvaccinated will not be able to provide care, treatment or other services for the agency or its patients after December 6, 2021, unless the staff have a pending request or have been granted an exemption to the vaccination requirements or provided evidence their vaccination must be temporarily delayed, as recommended by the CDC. Agency staff who have ben granted exemptions are eligible to provide care, treatment, or other services for the agency and its patients and must follow the agency's contingency plan.
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