Every finding on record at Hospice Advantage, LLC

It is required that the documented comprehensive assessment includes a drug profile that contains the patient's current prescription and over-the-counter (OTC) drugs. The medication review process includes the identification of the following the effectiveness of drug therapy, drug side effects, actual or potential drug interactions, and duplicate drug therapy; The assessment includes evidence that common side effects of medication in the hospice populations are anticipated, and, as appropriate, preventive measurements are implemented to manage the side effects. The drug profile is updated per the hospice policy and procedure, but, at minimum, at the time of each comprehensive assessment and/or when new medication is added or changes are made to existing medication. This standard was not met as evidenced by clinical record review and interview. 2 of 19 (11%) clinical records reviewed, the agency did not ensure that the comprehensive assessment included a medication profile that contained the patient's current prescription. Clinical Record 5: The patient elected hospice care on 5/18/23. The Skilled Nursing (SN) visit note dated 6/19/2023 documented, "Increased dyspnea, decreased lung sounds...Morphine ER and Morphine Concentrate sent to pharmacy. Patient and daughter educated in the use of morphine for air hunger." The medication profile was not updated to include Morphine ER and Morphine concentrate. Clinical Record 6: The patient elected hospice care on 5/8/23. The initial comprehensive assessment completed by the Registered Nurse (RN) on 5/8/2023 documented the patient had pancreatic cancer with a primary concern of pain and that hospital found "Fentanyl works best for patient's pain." The SN visit note dated 5/9/2023 documented, "There is at least a 7-day supply of medications on hand... no refills needed." Additionally, the visit note documented, "New orders for Ompremozole 20 mg BID." The SN visit note dated 5/14/2023 documented, "Oxycodone taken prior to my arrival...28 Roxicodone 20 mg and 5 Fentanyl patch 75mcg were in the home with no refills needed." The SN visit note dated 5/14/23 documented the patient was "using Lorazepam at night to sleep." The medication profile dated 5/9/2023 documented oxygen. No other medications were documented on the medication profile. There was no evidence that the medications were reviewed as part of the comprehensive assessment. During a joint review of the record and an interview on 8/1/2023, the Director of Quality Outcomes confirmed that the medications were not included on the medication profiles. 3 of 19 (21%) clinical records reviewed revealed that the agency did not ensure that the drug profile was updated to include all medications.

It is required that each patient’s individualized written plan of care includes drugs and treatment necessary to meet the needs of the patient. This standard was not met as evidenced by clinical record review and interview. In 2 of 19 (11%) clinical records reviewed, the agency did not ensure that drugs necessary for the patient's treatment were included in the plan of care. Clinical Record 6: The patient elected hospice care on 5/8/23. The initial comprehensive assessment completed by the Registered Nurse (RN) on 5/8/2023 documented the patient had pancreatic cancer with a primary concern of pain and that hospital found "Fentanyl works best for patient's pain." The SN visit note dated 5/9/2023 documented, "There is at least a 7-day supply of medications on hand... no refills needed." Additionally, the visit note documented, "New orders for Ompremozole 20 mg BID." The SN visit note dated 5/14/2023 documented, "Oxycodone taken prior to my arrival...28 Roxicodone 20 mg and 5 Fentanyl patch 75mcg were in the home with no refills needed." The SN visit note dated 5/14/23 documented the patient was "using Lorazepam at night to sleep," and a "Fentanyl Patch placed." The plan of care dated 5/8/2023 through 8/5/2023 did not document the medications, only the oxygen. During an interview on 8/1/2023, the Director of Clinical Services and Director of Quality Operations confirmed that Fentanyl, Oxycodone, and Lorazepam should have been included in the plan of care but were not. Clinical Record 14: The patient elected hospice care on 5/23/23 with the diagnoses of chronic obstructive pulmonary disease (COPD) and respiratory failure with Hypoxia. The initial comprehensive assessment completed by the Skilled Nurse (SN) documented that the patient was dependent on oxygen at 4 liters. The plan of care did not include documentation of oxygen. During an interview on 8/1/2023, the Director of Quality Outcomes confirmed that the medications and oxygen were not on the plans of care. 2 of 19 (11%) clinical records revealed that the agency did not ensure that drugs necessary for the patient treatment was included on the plan of care.

It is required that each patient’s individualized written plan of care Includes all services necessary for the palliation and management of the terminal illness, including the following: medical supplies and appliances necessary to meet the needs of the patient. This standard was not met as evidenced by clinical record review and interview. In 2 of 19 (11%) clinical records reviewed, the agency did not ensure that all medical supplies were included in the plan of care. Clinical Record 1/Home Visit 1: The patient elected hospice care on 2/28/23. The Skilled Nurse (SN) visit note dated 6/30/2023 documented, "Patient uses CPAP at night." The plan of care did not include documentation of the continuous positive airway pressure machine (CPAP) with medical supplies and appliances necessary to meet the patient's needs. Clinical Record 14: The patient elected hospice care on 5/23/23. The initial comprehensive assessment completed by the Registered Nurse (RN) on 5/23/23 documented the patient's diagnoses as chronic obstructive pulmonary disease (COPD) and respiratory failure, and the patient was dependent on oxygen. A referral from the Pulmonologist on 5/23/23 documented that the patient was too weak to utilize inhalers and must take respiratory medications via nebulizers. Oxygen supplies and nebulizer supplies were not documented in the plan of care. The plan of care documented "None" under supplies. During an interview on 8/3/24, the Director of Clinical Services confirmed the supplies were not included in the POC. 2 of 19 (11%) of clinical records reviewed revealed that the agency did not ensure that all medical supplies were included on the plan of care.

It is required that if the care of a hospice patient is transferred to a Medicare/Medicaid certified facility, the hospice forwards to the receiving facility a copy of the hospice discharge summary described in HCDT 40.I; and the patient’s record, if requested. This standard was not met as evidenced by clinical record review and interview. 1 of 2 (50%) clinical records reviewed of patients transferred to a Medicare certified facility, the agency did not ensure the receiving facility was provided a discharge summary. Clinical Record 9: The patient elected hospice care on 5/27/23. The Skilled Nursing (SN) discharge summary note dated 7/17/23 documented the patient was transferred to another hospice as of 7/18/23. The communication note dated 7/17/2023 documented, "Caregiver called and stated that they have decided to move patient to an alternate hospice effective July 18, 2023." There was no evidence that a discharge summary was sent to the receiving facility, the hospice. During an interview on 8/1/2023, the Director of Quality Outcomes stated, "I do not see it either. There is some opportunity here around live discharges." 1 of 2 (50%) of clinical records reviewed with a transfer to a Medicare certified facility/service, the agency did not ensure that the receiving facility was provided a discharge summary.

It is required that if a patient revokes the election of hospice care or is discharged from hospice per hospice regulation §418.26 (i.e., no longer terminally ill), the hospice forwards to the patient’s attending physician a copy of the hospice discharge summary. This standard was not met as evidenced by clinical record review and interview. 1 of 2 (50%) clinical records reviewed of patients discharged from hospice care, the agency did not ensure that a discharge summary was provided to the physician. Clinical Record 8: The patient elected hospice care on 1/30/23 and revoked services on 2/27/2023. There is no evidence that a discharge summary was sent to the physician. During an interview on 8/1/2023, the Director of Quality confirmed that no discharge summary was sent to the physician. 1 of 2 (50%) of records reviewed with a discharge the agency did not ensure that a discharge summary was provided to the physician.

It is required that the hospice obtains a criminal background check on all hospice employees who have direct patient contact or access to patient records. Hospice contracts require that all contracted employees who have direct patient contact or access to patient records obtain criminal background checks. This standard was not met as evidenced by document review and interview. The agency did not ensure that all contracted employees with direct patient contact or access to patient records obtain criminal background checks. Contract 4: The Medical Director Agreement signed on 12/17/15 by the current Medical Director did not include contract language requiring a criminal background check. During a joint review of the document and an interview, the Director of Clinical Services confirmed the active contract did not include language requiring a criminal background check. The agency did not ensure that the Medical Director contract contained required language to obtain criminal background checks.