Every finding on record at Kaiser Foundation Hospitals

A standard recertification survey was conducted by the Office of Health Care Assurance (OHCA) on October 3, 2023 to October 6, 2023. The facility was found to be in compliance with §484.102, Condition for Participation for a Home Health Agency (HHA) of Appendix Z – Emergency Preparedness for All Provider and Certified Supplier Types, State Operations Manual.

A standard recertification survey was conducted by the Office of Health Care Assurance (OHCA), Medicare Section, on October 3, 2023 to October 6, 2023. The facility was found not to be in substantial compliance with 42 CFR 484 subparts A, B, and C. The facility’s unduplicated census was 2050 patients. Sample size was 17 which included 7 home visits with record review, 5 record reviews from the active patient list, and 5 closed record reviews.

Standard: Initial assessment visit. CFR(s): 484.55(a) Standard: Initial assessment visit. This STANDARD is not met as evidenced by: Based on record review and interview, the home health agency (HHA) failed to ensure that the initial assessment for 1 of 17 patients (P) was conducted within 48 hours of the referral for home health services. As a result of this deficient practice, P1 experienced a delay in the start of care. Findings include: Patient (P)1 is a 75-year-old female who was referred to the HHA with a diagnosis of “Speech Problem.” On 06/21/23, P1’s family medicine physician sent a referral for home health services, specifically speech therapy services, to the HHA. On 06/25/23, a physician for the HHA wrote the following order: “Home Health Start of Care Date Change Regarding referral dated: 6/21/2023 May do initial home health start of care visit on: 7/6/2023 Reason: ST [Speech Therapist] AVAILABLE” A review of P1’s electronic health record (EHR) confirmed that the initial assessment occurred on 07/06/23. Further review of the EHR noted that the delay was not at the request of the patient. On 10/06/23 at 11:37 AM, during an interview with Rehab Supervisor (RS)1 in the conference room, RS1 confirmed that the ST did have periods of unavailability in the last several months. Believes that at the end of June, ST was occupied onboarding/orienting an ST from a traveling agency.

Plan of care CFR(s): 484.60(a)(1) Each patient must receive the home health services that are written in an individualized plan of care that identifies patient-specific measurable outcomes and goals, and which is established, periodically reviewed, and signed by a doctor of medicine, osteopathy, or podiatry acting within the scope of his or her state license, certification, or registration. If a physician or allowed practitioner refers a patient under a plan of care that cannot be completed until after an evaluation visit, the physician or allowed practitioner is consulted to approve additions or modifications to the original plan. This STANDARD is not met as evidenced by: Based on record review and interview, the home health agency (HHA) failed to review and revise the plan of care in a timely manner, and/or implement the plan of care as ordered for 2 of 17 patients (P) in the sample (P3 and P2). As a result of this deficient practice, these patients were placed at risk of not having their needs met. 2) On 10/04/23, review of P2’s Electronic Health Record (EHR) was conducted. Start of care date for P2 was 09/18/23 with certification period of 09/18/23 to 11/16/23. P2 had a urinary catheter for urinary retention and had a history of urinary tract infections. Plan of care initiated on 09/18/23 documented interventions to be performed by the Home Care Aide (HCA) that included urinary catheter care. HCA was to, “. . . Empty bag and measure and record output. Observe urine and patient, record observations and report any observed or patient reported concerns to the RN (registered nurse).” Further review of the EHR was done and documentation on P2’s urine output from the HCA and RN home visit notes were not found. Concurrent interview and record review was conducted with the Clinical Supervisor (CS) on 10/04/23 at 03:12 PM in the conference room. Asked CS where the HCA would document P2’s urine output in the EHR. CS said, “It should be in the home visit notes, unless the caregiver emptied the bag.” CS reviewed the HCA and RN notes and was not able to locate documentation of P2’s urine output. Asked CS what the expectation was from the HCA if it was documented in the plan of care that she is to empty the bag. CS said HCA should document urine output in her home visit notes and reason why if the intervention was not done. On 10/05/23, observation of the home visits by the physical therapist and RN was conducted. During the RN visit, asked primary care giver if she ever emptied the urinary catheter bag. Care giver said P2 empties the bag herself in the bathroom and that she has never emptied the bag for her. Findings include: 1) Patient (P) 3 is a 59-year-old female referred to the home health agency (HHA) on 04/17/23. At the time of the start of care on 04/19/23, P3 was admitted for home health services with a percutaneous endoscopic gastrostomy (PEG) tube (a feeding tube), through which she received some nutrition and medications. During a review of P3’s electronic health record (EHR), it was noted that her PEG tube was surgically removed during an acute hospitalization, on 06/16/23. All nutrition and medications formerly administered through the PEG tube were to be given orally from then on. Further review of her EHR noted that P3 had two recertifications since the PEG tube was removed, one beginning on 06/18/23 and the second beginning on 08/17/23. A review of P3’s current Home Health Certification and Plan of Care noted the following two medication orders: Acetaminophen 500 mg (milligrams) “Take 500 mg via G-tube [gastric tube/feeding tube] as needed for fever or pain. take [sic] 2 tablets through G-tube every 6 hours as needed for pain or fever” Atorvastatin 40 mg “Take 1 tablet by G-tube every evening” On 10/05/23 at 02:46 PM, during an interview with the Clinical Supervisor (CS)1 in the conference room, CS1 confirmed that the Plan of Care should have been updated to reflect that P3 was taking all medications by mouth as soon as the PEG tube was removed, but at the latest, by the time of the next recertification [08/17/23]. A review of the HHA policy, Care Planning Process, last reviewed 06/2022, noted the following: “The frequency of the review of the plan of care will be based on changes in the patient’s health status, needs, and the environmental factors affecting care. The clinicians will be responsible to revise the plan of care or update the plan at least every 60 days.”