Every finding on record at Right Choice Home Health Care, LLC

Substantial Allegation Survey Substantial Allegations 102488 and 102699 An entrance conference was conducted on 12/18/23 at10:00 AM with administrative staff, and an exit conference was completed on 12/18/23 at 5:20 PM with administrative staff. Right Choice Home Health Care, 368391, was not in compliance with the requirements at 42 CFR Part 484 Subpart B, C for Home Health Agencies in regard to the allegations contained in substantial allegations 102488 and 102699 completed on 12/18/23.

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 medical record review, policy review and staff interview, the agency failed to ensure patients received home health services as written in the plan of care and failed to notify the physician and case manager of the missed visits for two of four medical records reviewed (Patient #2 and #3). The agency census was 24. 1. The medical record for the Patient #2 was reviewed on 12/18/23. Patient #2 had a start of care (SOC) of 04/29/23 with a primary diagnosis of chronic obstructive pulmonary disease (COPD). The certification period reviewed was from 10/26/23-12/24/23. Skilled nurse (SN) visits were ordered for one time per week and home health aide (HHA) for 15 hours per week . Home health aide visits were completed for the ordered 15 hours per week. Skilled visits were completed weekly with the last visit completed on 11/17/23. No visits were documented after this date. Interview with Staff C revealed they were not aware these visits were not completed, further stating no documentation was found regarding physician notification for the missed visits. Review of the facility policy titled "Management of Missed Visits/Services" instructs agency staff to notify the physician of missed visits or deficiencies in service hours provided that do not coincide with the 485/Plan of care orders. This notification may be sent as soon as possible but no later than the Monday of the following week. Documentation of MD notification must be placed in the patient chart and may be in the form of a communication note. The findings of not completing skilled visits as ordered on the 485 and not notifying the physician as policy instructs was verified with Staff C on 12/18/23 at 2:20 PM. 2. The medical record for Patient #3 was reviewed on 12/18/23. Patient #3 had a SOC date of 07/16/22 with a primary diagnosis of type II diabetes. The certification period reviewed was for 09/11/23-11/07/23 and 11/08/23-01/06/24. Physician orders were on the plan of care to complete 35 hours per week of HHA services. Review of the visits revealed 35 hours of HHA visits were completed weekly until the week of 10/22/23-10/28/23 and 10/29/23-11/04/23, when only 15 hours were provided each week. A communication note to the case manager (CM), dated 11/16/23, revealed notification of the missed visits of 10/23/23 through 10/26/23 and 10/30/23 through 11/02/23. Interview with Staff C revealed Patient #3's HHA went on vacation and did not return. The agency has been struggling to meet the 35 hours per week. Staff A provided a letter which was sent to the physician on 11/10/23 regarding the missed visits. Review of the facility policy titled "Management of Missed Visits/Services and Calling Off" revealed a missed visit will be reported to the CM and physician in the event the agency is unable to cover the shift. Staff C further stated this notification should occur once the agency realizes no visit was completed. The findings of not following the facility policies for missed visits and notification to the physician and the CM was verified with Staff C and Staff B on 12/18/23 at 5:00 PM.

EMERGENCY PREPAREDNESS SURVEY The following deficiency is based on the emergency preparedness survey completed on 09/24/21.

EP Training Program CFR(s): 484.102(d)(1) *[For RNCHIs at §403.748, ASCs at §416.54, Hospitals at §482.15, ICF/IIDs at §483.475, HHAs at §484.102, "Organizations" under §485.727, OPOs at §486.360, RHC/FQHCs at §491.12:] (1) Training program. The [facility] must do all of the following: (i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles. (ii) Provide emergency preparedness training at least every 2 years. (iii) Maintain documentation of all emergency preparedness training. (iv) Demonstrate staff knowledge of emergency procedures. (v) If the emergency preparedness policies and procedures are significantly updated, the [facility] must conduct training on the updated policies and procedures. *[For Hospices at §418.113(d):] (1) Training. The hospice must do all of the following: (i) Initial training in emergency preparedness policies and procedures to all new and existing hospice employees, and individuals providing services under arrangement, consistent with their expected roles. (ii) Demonstrate staff knowledge of emergency procedures. (iii) Provide emergency preparedness training at least every 2 years. (iv) Periodically review and rehearse its emergency preparedness plan with hospice employees (including nonemployee staff), with special emphasis placed on carrying out the procedures necessary to protect patients and others. (v) Maintain documentation of all emergency preparedness training. (vi) If the emergency preparedness policies and procedures are significantly updated, the hospice must conduct training on the updated policies and procedures. *[For PRTFs at §441.184(d):] (1) Training program. The PRTF must do all of the following: (i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles. (ii) After initial training, provide emergency preparedness training every 2 years. (iii) Demonstrate staff knowledge of emergency procedures. (iv) Maintain documentation of all emergency preparedness training. (v) If the emergency preparedness policies and procedures are significantly updated, the PRTF must conduct training on the updated policies and procedures. *[For LTC Facilities at §483.73(d):] (1) Training Program. The LTC facility must do all of the following: (i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected role. (ii) Provide emergency preparedness training at least annually. (iii) Maintain documentation of all emergency preparedness training. (iv) Demonstrate staff knowledge of emergency procedures. *[For CORFs at §485.68(d):](1) Training. The CORF must do all of the following: (i) Provide initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles. (ii) Provide emergency preparedness training at least every 2 years. (iii) Maintain documentation of the training. (iv) Demonstrate staff knowledge of emergency procedures. All new personnel must be oriented and assigned specific responsibilities regarding the CORF's emergency plan within 2 weeks of their first workday. The training program must include instruction in the location and use of alarm systems and signals and firefighting equipment. (v) If the emergency preparedness policies and procedures are significantly updated, the CORF must conduct training on the updated policies and procedures. *[For CAHs at §485.625(d):] (1) Training program. The CAH must do all of the following: (i) Initial training in emergency preparedness policies and procedures, including prompt reporting and extinguishing of fires, protection, and where necessary, evacuation of patients, personnel, and guests, fire prevention, and cooperation with firefighting and disaster authorities, to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles. (ii) Provide emergency preparedness training at least every 2 years. (iii) Maintain documentation of the training. (iv) Demonstrate staff knowledge of emergency procedures. (v) If the emergency preparedness policies and procedures are significantly updated, the CAH must conduct training on the updated policies and procedures. *[For CMHCs at §485.920(d):] (1) Training. The CMHC must provide initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles, and maintain documentation of the training. The CMHC must demonstrate staff knowledge of emergency procedures. Thereafter, the CMHC must provide emergency preparedness training at least every 2 years. This STANDARD is not met as evidenced by: Based on document review and staff interview, the agency failed to provide training and to maintain documentation of training on the emergency preparedness plan at least every two years for 11 of 30 staff (Staff B, C, D, F, G, I, K, L, M, N and O). This could affect all patients receiving services from the agncy. The census was 35 patients. Findings include: Review of the emergency preparedness education revealed 11 of 30 employees lacked documentation of education on emergency preparedness in the last two years. Staff L's most recent emergency preparedness education was dated 10/17/17. Staff K's most recent emergency preparedness education was dated 02/10/18. Staff F's most recent emergency preparedness education was dated 07/10/18. Staff N's most recent emergency preparedness education was dated 03/29/19. Staff B, C, D, G, I, and O's most recent emergency preparedness education was dated 04/17/19. Staff M's most recent emergency preparedness education was dated 04/18/19. The findings were verified in an interview with Staff A on 09/24/21 at 11:29 AM.

Partial Extended Recertification Survey An entrance conference was conducted on 09/21/21 at 10:00 AM with administrative personnel, and an exit conference was completed on 09/24/21 at 12:45 PM with administrative personnel. The following deficiencies are based on the Partial Extended Recertification survey completed on 09/24/21. Right Choice Home Health Care, LLC 368391, is not in compliance with the requirements found at 42 CFR Part 484 Subpart B, C for Home Health Agencies.

Health, psychosocial, functional, cognition CFR(s): 484.55(c)(1) The patient's current health, psychosocial, functional, and cognitive status; This ELEMENT is not met as evidenced by: Based on medical record review and staff interview, the agency failed to ensure the comprehensive assessment included the patient's current health status including vital signs for five of seven medical records reviewed (Patient #1, #2, #5, #6, and #7). The agency census was 35. Findings include: 1. Review of the medical record for Patient #1 revealed a comprehensive assessment for recertification on 08/27/21 which lacked documentation of vital signs. 2. Review of the medical record for Patient #2 revealed a comprehensive assessment for recertification on 08/23/21 which lacked documentation of vital signs. 3. Review of the medical record for Patient #5 revealed a comprehensive assessment for recertification on 08/03/21 which lacked documentation of vital signs. 4. Review of the medical record for Patient #6 revealed a comprehensive assessment for recertification on 06/15/21 which lacked documentation of vital signs. 5. Review of the medical record for Patient #7 revealed a comprehensive assessment for recertification on 03/16/21 which lacked documentation of vital signs. The findings were verified in an interview with Staff A on 09/23/21 at 1:30 PM.

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 medical record review and staff interview, the agency failed to ensure patients received home health services as written in the plan of care for six of seven medical records reviewed (Patient #1, #3, #4, #5, #6, and #7). The agency census was 35. Findings include: 1. Review of the medical record for Patient #1 revealed orders for home health aide services 20 hours per week. The medical record contained documentation that 10 hours to 19 and a half hours of home health aide services were provided per week from 07/18/21 to 08/14/21. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. 2. Review of the medical record for Patient #3 revealed a plan of care dated 07/14/21 to 09/11/21 with orders for skilled nursing three times per day. The medical record lacked documentation of any skilled nursing visits on 08/08/21, 08/09/21, and 08/10/21. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. 3. Review of the medical record for Patient #4 revealed plans of care dated 06/06/21 to 08/04/21 and 08/05/21 to 10/03/21 with orders for home health aide services 28 hours per week. The medical record contained documentation that the weeks of 8/01/21, 08/15/21, 08/22/21 and 08/29/21 showed only 23 hours and 46 minutes to 27 hours and 25 minutes of home health aide services per week were provided. The medical record contained documentation that the weeks of 07/18/21, 07/25/21, and 08/08/21 showed that 28 hours and 30 minutes to 29 hours and 34 minutes of hours of home health aide services per week were provided. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. 4. Review of the medical record for Patient #5 revealed orders for skilled nursing twice a day and home health aide services 14 hours per week. The medical record contained documentation of only one skilled nursing visit per day on 07/23/21, 07/24/21 and 08/14/21. The medical record lacked documentation of any home health aide visits the week of 07/18/21, and contained documentation of only nine to 12 hours of home health aide services provided the weeks of 07/25/21, 08/01/21, and 08/08/21. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. 5. Review of the medical record for Patient #6 revealed orders for skilled nursing twice a week. The medical record contained documentation of only one skilled nursing visit the week of 06/13/21. The medical record lacked documentation of any skilled nursing visits the weeks of 06/20/21 and 06/27/21. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. 6. Review of the medical record for Patient #7 revealed a plan of care dated 03/17/21 to 05/15/21 with orders for home health aide services four hours per week. The medical record lacked documentation of any home health aide visits from 03/17/21 to 04/20/21. The medical record lacked documentation of additional orders or physician notification that services were not provided as ordered. The findings were verified in an interview with Staff A on 09/23/21 at 3:38 PM.

Plan of care must include the following CFR(s): 484.60(a)(2)(i-xvi) The individualized plan of care must include the following: (i) All pertinent diagnoses; (ii) The patient's mental, psychosocial, and cognitive status; (iii) The types of services, supplies, and equipment required; (iv) The frequency and duration of visits to be made; (v) Prognosis; (vi) Rehabilitation potential; (vii) Functional limitations; (viii) Activities permitted; (ix) Nutritional requirements; (x) All medications and treatments; (xi) Safety measures to protect against injury; (xii) A description of the patient's risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors. (xiii) Patient and caregiver education and training to facilitate timely discharge; (xiv) Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient; (xv) Information related to any advanced directives; and (xvi) Any additional items the HHA or physician or allowed practitioner may choose to include. This ELEMENT is not met as evidenced by: Based on medical record review and staff interview, the agency failed to ensure the plans of care included the frequency and duration of visits to be made; patient specific interventions, education, measurable outcomes and goals; rehabilitation potential; and discharge planning for seven of seven medical records reviewed (Patient #1, #2, #3, #4, #5, #6, and #7). The agency census was 35. Findings include: 1. Review of the medical record for Patient #1 revealed plans of care dated 06/29/21 to 08/27/21 and 08/28/21 to 10/26/21 with orders for home health aide services 10 hours per week for 60 days. The orders lacked the frequency of the home health aide hours to be provided. The medical record contained documentation from 07/18/21 to 9/11/21 of ten to 20 hours of home health aide services per week. The home health aide services were provided in one or two visits per day, three to five days per week. The plan of care dated 08/28/21 to 10/26/21 also lacked documentation of rehabilitation potential and discharge planning. 2. Review of the medical record for Patient #2 revealed a plan of care dated 08/24/21 to 10/22/21. The plan of care lacked documentation of patient specific interventions and education by nursing. The plans of care dated 06/25/21 to 08/23/21 and 08/24/21 to 10/22/21 lacked documentation of rehabilitation potential and discharge planning. 3. Review of the medical record for Patient #3 revealed plans of care dated 07/14/21 to 09/11/21 and 09/12/21 to 11/10/21 with orders for home health aide services 42 hours per week. The orders lacked the frequency of the home health aide hours to be provided. The medical record contained documentation from 07/18/21 to 09/11/21 of home health aide services daily for six hours each visit. 4. Review of the medical record for Patient #4 revealed plans of care dated 06/06/21 to 08/04/21 and 08/05/21 to 10/03/21 with orders for home health aide services 28 hours per week for 60 days. The orders lacked the frequency of the home health aide hours to be provided. The medical record contained documentation from 07/18/21 to 9/11/21 that 23 hours and 46 minutes to 29 hours and 24 minutes of home health aide services were provided per week. The home health aide services were provided six to seven days per week in one to two visits per day from one hour to five hours and 40 minutes each visit. The plans of care lacked documentation of rehabilitation potential and discharge planning. 5. Review of the medical record for Patient #5 revealed plans of care dated 06/05/21 to 08/03/21 and 08/04/21 to 10/02/21 with orders for home health aide services 14 hours per week for 60 days. The orders lacked the frequency of the home health aide hours to be provided. The medical record contained documentation from 07/25/21 to 08/14/21 that nine to 12 hours of home health aide services were provided per week. The home health aide services were provided in three hour visits, three to four days per week. The plans of care lacked documentation of rehabilitation potential and discharge planning. 6. Review of the medical record for Patient #6 revealed a plan of care dated 06/17/21 to 08/15/21. The plan of care lacked documentation of patient specific interventions and education by nursing and measurable outcomes and goals. The plans of care dated 04/18/21 to 06/16/21 and 06/17/21 to 08/15/21 lacked documentation of rehabilitation potential and discharge planning. 7. Review of the medical record for Patient #7 revealed a plan of care dated 03/17/21 to 05/15/21 with orders for home health aide services four hours per week for nine weeks. The orders lacked the frequency of the home health aide hours to be provided. The plans of care dated 01/16/21 to 03/16/21 and 03/17/21 to 05/15/21 lacked documentation of rehabilitation potential and discharge planning. The findings were verified in an interview with Staff A on 09/23/21 at 3:38 PM.