EMERGENCY PREPAREDNESS At the time of the emergency preparedness survey completed on 09/15/22, Reliable and Holistic Homecare Services 369163 is in compliance with the provisions of 42 CFR Part 484.102, Conditions of Participation for Home Health Agencies.
Every finding on record at Reliable and Holistic Homecare Services LLC
Westerville, Ohio · CCN 369163
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 September 15, 2022
4 findingsExtended Recertification Survey An entrance conference was conducted on 09/13/22 with the Director of Nursing (DON), an exit conference was conducted with administrative staff on 09/15/22. The following deficiencies are based on the extended recertification survey completed 09/15/22. Reliable and Holistic Home Care Services, 369163, is not in compliance with the requirements found at Home Health Agency 42 CFR Part 484, Subpart B, C. Reliable and Holistic Home Care Services is precluded from providing its own home health training and competency testing or competency evaluation program for a period of two years form the date of the receipt of the deficiency report (2567) for this survey.
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 review of QSO memo 22-09-ALL Attachment G, review of staff covid-19 vaccination status, and staff interview, the agency failed to ensure all staff were vaccinated against Covid-19 and failled to ensure policies were in place for Covid-19 vaccination of staff at G680. The cumulative effect of this systemic practice resulted in the agency's inability to ensure the patients were safe from communicable disease.
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 review of QSO memo 22-09-ALL Attachment G, staff covid-19 vaccination status, and staff interview, the agency failed have policies for staff Covid-19 vaccination and mitigation strategies in place for unvaccinated staff and failed to ensure all staff were vaccinated for Covid-19 or had a qualifying religious or medical exemption. Three (Staff Q, Staff R, and Staff S) of 16 staff members were unvaccinated and the agency had a staff vaccination rate of 81.3%. This affected three patients (Patient #6, Patient #7, Patient #9). The agency census was 13. Review of QSO memo 22-09-ALL Attachment G, dated 01/14/22, revealed within 90 days of issuance of this memorandum, 100% of staff have received the necessary doses to complete the vaccine series (i.e., one dose of a single-dose vaccine or all doses of a multiple vaccine series) or have been granted a qualifying exemption, or are identified as having a temporary delay as recommended by the Centers for Disease Control and Prevention (CDC). The memo also stated the home health agency (HHA) must develop and implement policies and procedures and the policies and procedures must include, at a minimum, 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; and 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. Review of the facility COVID-19 vaccination information revealed three out of sixteen staff members, Staff Q, Staff R, and Staff S, did not receive a COVID-19 vaccination and did not have a medical or relieous exemption on file. The facility staff vaccination rate wa 81.3%. Review of agency forms titled "Covid Vaccine/Waiver Form," and signed by Staff Q, Staff R and Staff S revealed these staff members acknowledged their risk for occupational exposure to Covid-19. Interview on 09/14/22 at 3:39 PM, the Director of Nursing (DON) stated the did not have policies in place for Covid-19 staff vaccination or for the mitigation to be followed for unvaccinated staff. The DON confirmed Staff Q, Staff R and Staff S were unvaccinated.
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