Observed in Record Review. In 2 of 2 live discharge records reviewed, the patient discharged from service without the completion of a Notice of Medicare Non Coverage (NOMNC) or contact with the Medicare Administrative Contractor prior to discharging patient from service. On review of RRDC #1, the agency was discharging for cause for not allowing care and there was no NOMNC was completed prior to discharging or notification to the the Medicare administrative contractor of the discharge. On RRDC #2, the agency did not get a signed NOMNC prior to discharging a patient for an extended diagnosis. This finding was reviewed with the Administrator.
Every finding on record at Apreva Corporation
San Diego, California · CCN 551557
16 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 May 9, 2025
10 findingsObserved in Record Review. In 14 of 14 active patient records reviewed, the nurse surveyor noted that plan of care goals were not measurable and/or time specific for achieving goals. For example, RRHV #1-#4 and RRNHV #1-#10, the plan of cares did not have timeframes for achieving goals. Examples include: dyspnea will be managed at acceptable level to patient, pain is managed at acceptable rating, and most all goals had no timeframe or a timeframe as “while on hospice”. This finding was reviewed with the organization leadership.
Observed in Record Review. In 6 out of 14 active patient records reviewed, the organization failed to update the patient’s plan of care. On RRHV#3, the Hospice Nurse Surveyor observed the plan of care had not been updated to include goals or interventions for added medication therapies one due to a new lesion and one for a new topical medication. On RRHV #4, it was noted that patient was started on a topical agitation cream and the plan of care had not been updated to include goals or interventions for this new treatment. On RRNHV #1 and RRNHV #3, teaching goals from admissions have been on the care plan since admission and not updated to reflect the current condition. RRNHV #2, patient started Lidocaine patches after admission, but the Plan of care was not updated to reflect those changes. On RRNHV #4, it was noted that patient was started on antibiotic for UTI prevention and no goal developed for this. This was discussed and reviewed with the Hospice Leadership Team.
Observed in Record Review. In 14 of 14 active patient records reviewed, the hospice nurse surveyor noted medication orders were not clear and accurate. On RRHV # 1 the physician's orders in the plan of care documented Morphine 15 mg immediate release tab Q6prn for mod pain and Morphine concentrate 10mg Q 2 PRN mod pain; however, there was no indication how to handle the duplicate therapy. On RRHV #2 and RRHV #3, the physician order in the plan of care documented MiraLAX and Bisacodyl PRN for constipation, with no indication for how to handle the duplicate therapy. On RRHV #4, there were multiple duplicate PRN medications for the same indication, one example includes senna PRN for constipation and Bisacodyl Suppository PRN for constipation and not indication how to handle the duplicate therapies. On review of RRNHV #1-10, these records further demonstrate duplicate PRN medication therapy with the same examples. This was discussed with the leadership team.
Observed in Record Review. On 1 of 2 live discharge records reviewed., the organization failed to coordinate the discharge with family prior to discharge. On RRDC #1, the organization discharged the patient from service without coordination with the attending physician and the family. This finding was reviewed with agency leadership.
Observed in Data Session. During the data management session with the organization, it was noted that the organization had been collecting event data. However, the data for Medication Error and Medication Adverse Events were all gathered under other events and not broken into each area to analyze and identify and trend over time. In addition, the hand hygiene data had not been collected so it could not be analyzed or trended as well. This finding was reviewed with agency leaders.
Observed in Data Session. During the data management session with the organization, it was noted that the organization had not improved compliance with hand hygiene because there was no data had not been aggregated to evaluate hand hygiene compliance. This finding was reviewed with agency leaders.
Observed in Tracer Activities. The organization failed to provide services that meet the patient needs. During tracer activities for volunteer services, the Hospice Nurse Surveyor observed the volunteer percentage for 2025 was between 3-4% each month. The organization is in the process of an active performance improvement project around volunteers. They also have a new volunteer coordinator who started 1 week ago as part of the plan to address the issue. This finding was discussed and reviewed with the Hospice Leadership Team.
Observed in Record Review. On 1 of 2 live discharge records reviewed., the organization failed to contact the attending physician to plan the patient needs prior to discharge. On RRDC #1, the organization discharged the patient from service without planning care treatment and services with the attending physician prior to discharge. This finding was reviewed with agency leadership.
Observed in Patient Home. In 3 of 4 home visits conducted, the patient's individualized emergency management plan was not completed and in the home. On RRHV #1, RRHV #3 and RRHV #4, it was noted that patients did not have an emergency plan completed. This finding was discussed with agency leadership.
Survey of March 25, 2022
6 findingsObserved in Record Review. In 16 of 16 patient records reviewed, the nurse surveyor noted that the plan of care goals did not have time frames for achieving goals. For example, HV#1 through HV#4 and RR#1through RR#12 goals on the plan of care did not include time frames. This was discussed with the Administrator present.
Observed in Record Review. In 16 of 16 patient records reviewed, the nurse surveyor noted that the frequency of services were not specific to meet the patient and family needs. For example; the statement for the 12 patient's who received music therapy was identical and included the same number of visits, 1 per month and 2 as needed, with no description of when an as needed visit would be provided. The as needed visits for skilled nurse all stated for skilled nurse needs. The as needed visits for spiritual counselor all stated for spiritual needs and the MSW all stated for psychosocial needs. This was confirmed with the DPCS and Administrator present.
Observed in Record Review. In 1 of 16 patient records reviewed, the nurse surveyor noted that care was not provided according to hospice plan of care. For example, in RR#8 the plan of care/physician order stated that the patient was to use oxygen at 7 liters per nasal cannula. 4 medical record notes over a 3 week period all recorded that the patient was using 4 liters of oxygen and there was no documentation of change in dose or attempts to contact the provider. This was confirmed with the Executive Director present.
Observed in Patient Home. In 1 of 4 home visits conducted, the nurse surveyor noted that the staff did not follow accepted standards of practice to prevent the transmission of infections. For example, HV#1 the nurse did not follow contact time (wet time) as specified by disinfectant manufacturer’s IFUs. The nurse used a Sani Cloth wipe to wipe the equipment and then allowed a dry time. The packaging stated that disinfection required a 2 minute wet time, this was not observed. Also during this home visit, the nurse placed a piece of wax paper on the table and then reached into her nursing bag individually for each piece of equipment as she needed to use them and after use placed them on the wax paper. When disinfecting the equipment she wiped them and then placed them back on the same barrier (the dirty barrier) to dry. Also during this visit, during wound care the nurse moved the bottle of wound cleanser from a barrier on to the floor and did not disinfect the bottle prior to use or prior to returning it to the wound care supplies. This was discussed with the DCPS present. Observed in Patient Home. In 1 of 4 home visits conducted, the nurse surveyor noted that the staff failed to perform hand hygiene consistent with policy. For example; the organization's Hand Hygiene policy stated that hand hygiene was to be performed before donning gloves and after removing gloves. On greater than 2 occasions during the patient visit the nurse did not perform hand hygiene before donning gloves. The organization's Bag Technique policy stated that hand hygiene was to be performed before returning equipment to bag. The nurse did not perform hand hygiene prior to returning the equipment to the nursing bag. This was discussed with the DCPS present.
Observed in HR File Review. In 1 of 9 HR files reviewed, the nurse surveyor noted that the organization had not assessed the skills and competence of the staff. For example, during review of the MSW record the competence document was in the record however only part of it had been completed. Areas such as psychosocial assessment, grief assessment and counseling were not completed. The MSW had been providing psychosocial assessments and grief assessments and counseling with the patient's and families. This was confirmed with the human resource staff and DPCS present.
Observed in Record Review. In 1 of 16 patient records reviewed, the surveyor noted that the staff did not follow the organization's policy that required corrections be made by drawing a line through the error and adding the authors initials, date and time of correction. For example, in RR#5 four volunteer notes had been corrected by using black marker to completely cover between 5 and 40 lines of text. This was confirmed with the Administrator and Executive Director present.
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Federal survey findings only. State licensure findings for hospices are not shown.
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