An unannounced Home Health Agency Medicare Medicaid recertification survey was conducted March 14-17, 2022 by one (1) Medical Facilities Inspector from The Office of Licensure and Certification, Virginia Department of Health. In conjunction with this survey, the agency's emergency preparedness plan was reviewed. The agency was found to be in compliance with 42 CFR 484.102 Conditions of Participation Emergency Preparedness for Home Health Agencies.
Every finding on record at National Home Health Care Inc
Herndon, Virginia · CCN 497587
4 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 17, 2022
4 findingsAn unannounced Medicare Medicaid Home Health Agency recertification survey was conducted March 14-17, 2022 at the above captioned agency by one (1) Medical Facilities Inspector from The Office of Licensure and Certification, Virginia Department of Health. The agency reported 1736 unduplicated admissions in the last twelve (12) months with an active census of 247 patients. The following were completed/reviewed in conjunction with the survey: Seven (7) home visits, seventeen (17) clinical records, ten (10) personnel files, review of selected policies and procedures, the agency's complaint log, emergency preparedness plan, and Covid vaccination records. Interviews were also conducted. Deficiencies were identified and are cited in this report. The agency was found not to be out of compliance with 42 CFR 484, Conditions of Participation for Home Health Agencies (HHAs).
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 clinical record review and staff interview, it was determined the agency failed to provide a Home Health Change of Care Notice (HHCCN) or a Notice of Medicare Non-Coverage (NOMNIC) to Medicare patients in advance of reducing/discontinuing services for three (3) of five (5) clinical records in the survey sample for which a HHCCN/NOMNIC was applicable (clinical record: #1, 4, and 9). The findings were: Seventeen (17) electronic clinical records were reviewed in read only mode March 14, 2022 through March 17, 2022 with the following findings: 1. Clinical record #1 was reviewed for the certification of 11/14/2021 to 01/12/2022. The plan of care contained a physician's order for Occupational therapy (OT) visits one (1) to two (2) times a week for nine (9) weeks. The clinical record contained documentation that the OT discontinued services after four (4) weeks. The clinical record failed to contain evidence the agency provided the patient an advance notice/Home Health Change of Care Notice (HHCCN) prior to terminating OT services from the agency. On 3/16/2022 at 12:49 PM an interview was conducted with the Director Of Nursing (staff member #2) regarding the patient's advance notice of the OT early discharge. Staff member #2 stated "there was none". 2. Clinical record #4 was reviewed for the certification of 02/20/2022 to 04/20/2022. The plan of care contained a physician's order for Physical Therapy (PT) visits one (1) to two (2) times per week for eight (8) weeks. The PT discharged the patient on week four (4). The clinical record failed to contain evidence a NOMNIC was provided to the patient prior to discontinuing service. On 3/16/2022 at 12:49 PM an interview was conducted with the Director Of Nursing (staff member #2) regarding the patient's advance notice of the PT early discharge. Staff member #2 stated "there was none". 3. Clinical record #9 was reviewed for the certification of 01/07/2022 to 03/07/2022. The plan of care contained a physician's order for Occupational therapy (OT) visits one (1) time a week for four (4) weeks. The clinical record contained documentation that the OT discontinued services after three (3) weeks. The clinical record failed to contain evidence the agency provided the patient an advanced notice/Home Health Change of Care Notice (HHCCN) prior to terminating OT services. The care plan also contained orders for Speech Therapy (ST) one (1) to two (2) times per week for five (5) weeks. The ST discharged the patient after three (3) weeks. The clinical record failed to contain evidence the agency provided the patient an advanced notice/Home Health Change of Care Notice (HHCCN) prior to terminating ST services On 3/16/2022 at 12:49 PM an interview was conducted with the Director Of Nursing (staff member #2) regarding the patient's advance notice of the OT and ST early discharge. Staff member #2 stated "there was none". The findings were reviewed with the Director of Operations and the Director of Nursing during the exit conference on 3/17/2022 at 8:45 am.
Infection Prevention CFR(s): 484.70(a) Standard: Infection Prevention. The HHA must follow accepted standards of practice, including the use of standard precautions, to prevent the transmission of infections and communicable diseases. This STANDARD is not met as evidenced by: Based on observations and interviews it was determined agency staff failed to follow infection control guidelines for two (2) of three (3) patients that were observed during home visits and receiving wound care (patient #15 and 17). The findings were: Observations of care during a home visit to patient #17 on 3/16/2022 at 8:30 am revealed the Registered nurse (employee #7) failed to follow infection control guidelines when performing a wound vacuum dressing change. Employee #7 set up the clean field with the clean dressing supplies and donned clean gloves. The skilled nurse removed the old dressing and cleaned the wound. The nurse proceeded to the clean supplies with soiled gloves and without changing gloves or performing hand hygiene, the nurse picked up the clean foam dressing, cut out the needed size and placed it into the patients wound. Employee #4 contaminated the clean wound by touching the clean dressing with dirty gloves and placing the contaminated dressing onto the wound. An interview was conducted at approximately 9 am with the Director of Nursing (employee #2) who was present at the visit. Employee #2 stated not being able to see well but acknowledged thinking the nurse did not remove the dirty gloves and perform hand hygiene when moving from cleaning the wound to applying the clean dressing. Observations of care during a home visit to patient #15 on 3/16/2022 at 11:15 am revealed the Registered nurse (employee #9) failed to follow infection control guidelines when performing a wound care dressing change. Employee #9 set up a clean field with the clean dressing supplies and donned clean gloves. The skilled nurse removed the old dressing and cleaned the wound. The nurse proceeded to the clean supplies with soiled gloves and without changing gloves or performing hand hygiene, the nurse picked up the clean Xeroform dressing and placed it onto the patients wound. Employee #9 contaminated the clean wound by touching the clean dressing with dirty gloves and placing the contaminated dressing onto the wound. An interview was conducted at approximately 11:40 am with the Director of Nursing (employee #2) who was present at the visit. Employee #2 stated having also observed the nurse fail to remove the dirty gloves and perform hand hygiene prior to picking up the clean dressing and applying it to the wound. Fundamentals of Nursing Mosby, Potter and Perry, 7th Edition St. Louis Missouri, page 645 states in part: modes of transmission for infection are indirect contact-personal contact of susceptible host with contaminated inanimate object (e.g.,needles or sharp objects, dressings, environment). In both of these cases, the gloves would have been contaminated after touching the dirty dressing and wounds and glove removal and hand hygiene should have occurred before proceeding. Page #655 goes on to discuss medical asepsis or clean technique procedures are used to reduce the number of organisms present and prevent the transfer of organisms. According to the Centers for Disease Control and Prevention (CDC), hand hygiene should be performed after contact with nonintact skin, after contact with wound dressings, and after removing gloves. (Guideline for Hand Hygiene in Health-Care Settings. Retrieved from https://www.cdc.gov/mmwr/PDF/rr/rr5116.pdf). The nurse placed the patient at risk for infection by not following standards of practice to prevent infection transmission and failing to perform hand hygiene at the required times. The findings were reviewed with the Director of Operations and the Director of Nursing during the exit conference on 3/17/2022 at 8:45 am.
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