Every finding on record at Oasis Healthcare, Inc.

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: measurable outcomes anticipated from implementing and coordinating the plan of care. This standard was not met as evidenced by clinical record review and interview. In 8 of 19 (42%) clinical records reviewed, the agency did not ensure that the patient’s plan of care included measurable outcomes anticipated from implementing and coordinating the plan of care. Clinical Record 10: The patient elected the hospice benefit on 12/07/2023 with a terminal diagnosis of cerebral vascular accident (CVA). The plan of care (POC) dated 12/07/2023 identified the patient’s problem: “Altered comfort.” The POC documented the patient’s goal: “(Patient/Caregiver) Pt/Cg understands the pain scale, how to manage pain, and report changes to hospice.” The goal did not include a measurable outcome for managing and reporting the patient’s pain. Clinical Record 11: The patient elected the hospice benefit on 9/09/2023 with a terminal diagnosis of chronic obstructive pulmonary disease (COPD). The POC dated 09/09/20/23 identified the patient’s problem: “Altered Respiratory Status.” The POC documented the patient’s goal: “(Patient’s) Pt’s respiratory symptoms will be managed.” The goal did not include a measurable outcome for managing the patient’s respiratory symptoms. Clinical Record 12: The patient elected the hospice benefit on 09/29/2023 with a terminal diagnosis of amyotrophic lateral sclerosis (ALS). The POC dated 09/29/2023 identified the patient’s problem: “Altered Respiratory Status.” The POC documented the patient’s goal: “Pt’s respiratory symptoms [sic] is stabilized.” The goal did not include a measurable outcome for stabilizing the patient’s respiratory symptoms. Clinical Record 13: The patient elected the hospice benefit on 02/27/2024 with a terminal diagnosis of hypertensive chronic kidney disease. The POC dated 02/27/2023 identified the patient’s problem: “Altered Genitourinary Status.” The POC documented the patient’s goal: “Pt’s genitourinary symptoms will be managed.” The goal did not include a measurable outcome for managing the patient’s genitourinary symptoms. Clinical Record 14: The patient elected the hospice benefit on 03/01/2023 with a terminal diagnosis of acute respiratory failure. The POC dated 03/01/2023 identified the patient’s problem: “Altered Respiratory Status.” The POC documented the patient’s goal: “Pt’s respiratory symptoms [sic] is stabilized.” The goal did not include a measurable outcome for stabilizing the patient’s respiratory symptoms. Clinical Record 17: The patient elected the hospice benefit on 02/06/2023 with a terminal diagnosis of Parkinson’s Disease. The POC dated 02/06/2023 identified the patient’s problem: “Alteration Respiratory Status.” The POC documented the patient’s goal: “Pt’s respiratory symptoms will be managed.” The goal did not include a measurable outcome for managing the patient’s respiratory symptoms. Clinical Record 18: The patient elected the hospice benefit on 07/31/2023 with a terminal diagnosis of Alzheimer’s Disease. The POC dated 07/31/2023 identified the patient’s problem: “Alteration in comfort pain.” The POC documented the patient’s goal: “Pt’s pain will be managed.” The goal did not include a measurable outcome for managing the patient’s pain. Clinical Record 19: The patient elected the hospice benefit on 02/19/2024 with a terminal diagnosis of COPD. The POC dated 02/19/2024 identified the patient’s problem: “Alteration Respiratory Status.” The POC documented the patient’s goal: “Pt’s respiratory symptoms will be managed.” The goal did not include a measurable outcome for managing the patient’s respiratory symptoms. During a joint record review and interviews on 09/10/2024, the Executive Director confirmed that the written plans of care were not individualized to include measurable outcomes.

It is required that a hospice aide provides services: included in the plan of care. This standard was not met as evidenced by clinical record review and interview. In 1 of 17 (6%) clinical records reviewed with Hospice Aide (HA) services provided, the agency did not ensure the HA provided services included in the care plan. Clinical Record 1: The patient elected the hospice benefit on 11/29/2022. The HA care plan dated 09/01/2024 assigned the HA the relevant task of shampooing the patient's hair weekly. The HA visit notes dated 09/04/2024 and 09/06/2024 documented that the HA shampooed the patient's hair. There was no evidence that the HA care plan was changed. During a joint record review and interview on 09/10/2024, the Executive Director confirmed that the HA did not follow the care plan.

It is required that hospice aides must report changes in the patient’s medical, nursing, rehabilitative, and/or social needs to a registered nurse as the changes relate to the plan of care and any quality assessment and improvement activities. The hospice aide must also complete appropriate records of service, including the report of changes in the patient’s needs. Hospice aide documentation complies with hospice policies and procedures. This standard was not met as evidenced by clinical record review and interview. In 3 of 17 (18%) clinical records reviewed with Hospice Aide (HA) services provided, the agency did not ensure the Hospice Aide reported changes in the patient’s care needs to the Registered Nurse (RN). Clinical Record 1: The patient elected the hospice benefit on 11/29/2022. The HA care plan dated 09/01/2024 assigned the HA to shampoo the patient’s hair weekly. The HA visit notes dated 09/04/2024 and 09/06/2024 documented that the HA shampooed the patient’s hair. A clinical record review revealed no evidence that the HA notified the Registered Nurse (RN) of the change in the patient’s needs related to the HA care plan. Clinical Record 2: The patient elected the hospice benefit on 08/30/2024. The HA care plan dated 09/01/2024 assigned the HA the relevant tasks: bed bath, hair care, skin care, and oral care. On 09/4/2024, the HA visit note documented that no tasks were completed. A clinical record review revealed no evidence that the HA notified the RN of the change in the patient’s needs related to the HA care plan. Clinical Record 3: The patient elected the hospice benefit on 08/1/2024. The HA care plan dated 08/01/2024 assigned the HA the relevant tasks: tub bath, shampoo, skincare, and perineal care every visit. On 08/4/2024, the HA visit note documented that the patient refused care. A clinical record review revealed no evidence that the HA notified the RN of the change in the patient’s needs related to the HA care plan. During a joint clinical record review and interview on 09/10/2024, the Executive Director confirmed the Hospice Aide did not report changes in the patient’s care needs to the RN.

It is required that the hospice Interdisciplinary Group, in consultation with the individual's attending physician (if any), completes an initial comprehensive assessment no later than five (5) calendar days after the election of hospice care, in accordance with CMS §418.24–the elements of the hospice care election statement. This standard was not met as evidenced by agency policy review, clinical record review, and interview. 1 of 13 (8%) records reviewed, the agency failed to ensure that the initial comprehensive assessment was completed no later than 5 calendar days after the hospice election. Record #40189: The patient's Start of Care was 8/11/2021. An Initial Social Worker Assessment was performed on 8/17/2021 (6 days post start of care). There was no documented reason for the late assessment. Agency policy 1-014.1 Comprehensive Assessment (Revised October 2019) states, "the hospice interdisciplinary group, in consultation with the individual's attending physician (if any) will complete the comprehensive assessment no later than 5 calendar days after the election of hospice care." In an interview with the Director of Clinical Operations, it was confirmed that the Initial Social Worker Assessment was performed later than the required 5 days from the hospice election.

It is required that the comprehensive assessment identifies the physical, psychosocial, emotional, and spiritual needs related to the patient's terminal illness that are addressed to promote the patient's well-being, comfort, dignity throughout the dying process. This standard was not met as evidenced by agency policy review, clinical record review, and interview. 1 of 13 (8%) records reviewed, the agency failed to ensure that the comprehensive assessment included all required elements. Record #81394: The patient's Start of Care was 3/10/2021, and the Initial Comprehensive Assessment did not include a psychosocial assessment as required. The record did not include an initial assessment by the social worker, and there was no documentation that a social worker was offered and declined. Additionally, the initial RN assessment performed on 3/10/2021 stated, "Social Support - Was social/spiritual status assessed?" The RN's response was "No." The documentation further stated, "Indicate reason social/spiritual status not assessed." The RN's response was "NA." Agency Policy No. 1-014.1 Comprehensive Assessment (Revised October 2019) states, "the hospice will conduct and document in writing a patient-specific assessment that identifies the patient's need for hospice care and services, and the patient's need for physical, psychosocial, emotional and spiritual care." In an interview with the Director of Clinical Operations, it was confirmed that an initial psychosocial assessment was not performed as required.

It is required that the hospice designates a Registered Nurse member of the IDG to ensure the implementation of the interdisciplinary plan of care. Hospice care and services provided to patients and families follow the individualized plan of care established by the hospice IDG in collaboration with the attending physician (if any), the patient or patient representative, and the primary caregiver in accordance with the patient's needs. This standard was not met as evidenced by agency policy review, clinical record review, and interview. 2 of 13 (15%) records reviewed, the agency failed to ensure that care was provided following the ordered frequencies on the interdisciplinary plan of care. Record #96545: The patient's Start of Care was 7/23/2021. The initial plan of care dated 7/23/2021 included a Skilled Nursing (SN) frequency of 2x/week. The week of 9/12/2021, one SN visit was performed 9/13/2021. There was no documentation for the missed visit. Record #39759: The patient's Start of Care was 10/4/2021. The initial plan of care dated 10/4/2021 included a skilled nursing frequency, 3w1, 2w11, and five prn. The week of 10/31/2021, one SN visit was performed 11/5/2021. An order was entered on 11/5/2021 "omit duplicate SN visit," and there was no documented missed visit or order to change the visit frequency. Agency policy 1-035.1 Interdisciplinary Group Coordination of Care (Revised October 2019) states, "the Case Manager will be responsible for the coordination of services with the interdisciplinary group from referral to discharge. The Case Manager will be qualified through education, training and/or experience and will know the scope of care which can be provided by various interdisciplinary group members." In an interview with the Director of Clinical Operations, it was confirmed that the RN did not follow the frequency for Record #96545 and that the order to "omit the duplicate SN visit" for Record #39759 was entered in error, and the correct frequency of 2x/week was not followed.

It is required that if the care of a hospice patient is transferred to a Medicare/Medicaid/MediCal-certified facility, the hospice forwards to the receiving facility a copy of the hospice discharge summary described in HCDT 41.I. This standard was not met as evidenced by agency policy review, clinical record review, and interview. 2 of 2 (100%) applicable records for patients transferred to a Medicare/Medicaid/MediCal-certified facility, the agency failed to ensure that a copy of the discharge summary was sent as required. Record #20988: The patient's Start of Care was 8/27/2021, and discharged/transferred to a hospital on 10/16/2021 to seek aggressive treatment. There was no documentation that a copy of the discharge summary was sent to transferring facility. Record #96545: The patient's Start of Care was 6/28/2021, and discharged/transferred to a hospital on 9/27/2021. There was no documentation that a copy of the discharge summary was sent to transferring facility. Agency Policy 1-025.1 Discharge from Hospice Program [State] (Revised October 2019) states, "a copy of the discharge summary will be sent to the attending physician." The policy did not state that a copy of the discharge summary should be sent to the receiving facility. In an interview with the Director of Clinical Operations, it was confirmed that the agency was not aware that a copy of the Discharge Summary was required to be sent to the receiving facility.

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 agency policy review, clinical record review, and interview. 2 of 2 (100%) applicable records for patients who revoked/discharged from the agency, the agency failed to ensure that a copy of the discharge summary was sent to the attending physician as required. Record #20988: The patient's Start of Care was 8/27/2021 and revoked/discharged from hospice on 10/16/2021. There was no documentation that a copy of the discharge summary was sent to the attending physician. Record #96545: The patient's Start of Care was 6/28/2021 and revoked/discharged from hospice on 9/27/2021. There was no documentation that a copy of the discharge summary was sent to the attending physician. Agency Policy 1-025.1 Discharge from Hospice Program [State] (Revised October 2019) states, "a copy of the discharge summary will be sent to the attending physician." In an interview with the Director of Clinical Operations, it was confirmed that a copy of the discharge summary was not sent to the patients' attending physicians.