Observed in Record Review. In 1 of 2 live discharge records reviewed, the Notice of Medicare Non Coverage was signed the day before the patient discharged. The Medicare Conditions of Participation required that this be done two days prior to discharge. This RFI was reviewed with the Executive Director and Director of Clinical Operations.
Every finding on record at Seasons Hospice & Palliative Care of Pennsylvania, LLC
King of Prussia, Pennsylvania · CCN 391709
14 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 October 11, 2024
7 findingsObserved in Record Review. In 14 of 14 active patient records reviewed, the organization did not assess the patient's need for volunteer services because there were no patient volunteers available. And in records RRHV#2, RRNHV#8, and RRNHV#10 spiritual care was not assessed as part of the initial comprehensive assessment. This RFI was reviewed with the Executive Director and Director of Clinical Operations.
Observed in Record Review. In 13 of 14 active patient records reviewed, the organization did not ensure that the plan of care identified time frames for goal completion. Target dates were not documented. This RFI was reviewed with the Executive Director and Director of Clinical Operations.
Observed in Record Review. In 2 of 14 active patient records reviewed, the organization did not ensure that the plan of care specified medications and treatments necessary to meet the patient’s needs. In record RRHV#1 an order for oxygen was not found in the initial or revised plans of care since the patient’s admission eight months ago, despite the patient having a tracheostomy and requiring continuous oxygen. Additionally, there was medication duplication for the treatment of constipation with orders for Maalox, Gavilax, Dulcolax suppository and Fleet enema. Also, Tylenol and Tramadol were both ordered twice and did not indicate when to use which drug to manage pain. And in RRHV#3 the record in the assisted living facility contained a hand-written order for a comfort kit. However, that same order was not found in the hospice plan of care. This RFI was reviewed with the Executive Director and Director of Clinical Operations.
Observed in Record Review. In 2 of 14 active patient records reviewed, the organization did not ensure that services were provided according to the plan of care. In records RRNHV#4 and RRNHV#5 multiple scheduled visits for the spiritual counselor and social worker were not completed as ordered. This RFI was reviewed with the Executive Director and Director of Clinical Operations.
Observed in Tracer Activities. Upon interview, the patient experience director confirmed that the volunteers had not provided at least 5% of the total patient care hours of all paid hospice employees and contract staff. From 9/2023 to 8/2024, volunteers contributed 3% of total patient care hours.
Observed in HR File Review. In 1 of 11 HR files reviewed, the music therapist had not had a competency performed in the last three years. This observation was confirmed with the business operations leader.
Survey of October 22, 2021
7 findingsObserved in Record Review. In 15 of 15 patient records reviewed, the surveyor noted that the Plan of Care goals did not include time frames for achieving goals. This was confirmed with the national executive director present.
Observed in Patient Home. During home visit HV#1 the surveyor noted that the care giver had not received education on the storage of medications. For example, the patient requires liquid Ativan doses and the care giver reviewed her system with the skilled nurse; the caregiver removes the medications from the refrigerator, draws up doses of both Morphine and Ativan into syringes every morning and then places the unlabeled syringes in a cup(orange syringe for Ativan and clear syringe for Morphine) on a table. She then uses them throughout the day. When questioned about any left at the end of day the caregiver reported that they remain and are included the following day. The label on the Ativan stated that the medication is to remain at a refrigerated temperature. The skilled nurse at the visit did not educate the caregiver to the refrigeration of the medication and the surveyor was unable to identify education in the record.
Observed in Record Review. In 2 of 3 patient records reviewed, that included wound care, the Plan of Care included wound care interventions, but the wound care was incomplete. For example, in record review RR#5 and RR#9 there was no frequency at which to complete the wound care included. This was confirmed with the ED present.
Observed in Record Review. In 3 of 15 patient records reviewed, it was noted that care was not provided according to hospice plan of care. For example, in record review HV#3 the plan of care included music therapy once every 4 weeks and no music therapy visit was documented in July or a coordination of care/missed visit note. RR#9 and #10 the plan of care included music therapy 1 time visit and no music therapy visit was documented. This was confirmed with the ED present.
Observed in Patient Home. In 3 of 4 home visits conducted, the surveyor noted that the organization had not followed standard practice to prevent transmission of infections. For example, during HV#1 and #2 the nurse did not follow contact time(wet time) as specified by the disinfectant manufacturer’s IFUs for the wipes the nurse stated were purple top Sani Cloths. Also, during HV#2 the nurse used an alcohol wipe to disinfect the tape measure after use. During HV#1 and HV#2 the nurse used her tablet, placed in on the floor with no barrier and then picked it up and used it again and again placed in on the floor multiple times during the visit. At the end of the visit the nurse handed the tablet to the caregiver or patient for signature. No disinfection took place. The organization's Equipment Maintenance policy Electronic Devices section stated that the device was to be cleaned after each use with a germicidal disposable cloth. During HV#3 the hospice aide disinfected the equipment with purple top Sani cloths and then stated I know it's 2 minutes. However, the 2 minute wet/contact time was not overserved. Observed in Patient Home. In 2 of 4 home visits conducted, the hospice surveyor noted that the nurse did not follow the organization's bag technique policy. The nursing bag was placed on the patient's floor without a barrier throughout the visit. The organization's policy included that the bag should not be placed on the patient's floor, Policy Bag Technique 4004 #4 The bag may also hang from a doorknob or other suitable location to avoid contact with the floor or other unsuitable surfaces. Observed in Patient Home. During home visit HV#3 the surveyor noted that the hospice aide failed to perform hand hygiene consistent with the organization's policy. For example, the HHA ran out of gloves and continued the visit with 1 glove and attempting to perform 1 handed hand hygiene using the hand sanitizer. The organization's Hand Hygiene policy included direction on procedure for hand hygiene and it required 2 hands.
Observed in Patient Home. During home visit HV#1 the surveyor noted that the medication list was inaccurate. For example, oral Roflumilast on the medication list and plan of care stated daily, but caregiver in the home reported that they have only ever used it as needed for cough only. Also, Theophylline 0.5mg-1mg oral on the home medication list had a hand written change to 0.5mg twice a day dated 4/7/21, however there had been no change on the plan of care list in the record and no order documented.
Observed in Patient Home. In 3 of 3 home visits conducted, the surveyor noted that there was no education documented for the patient's individualized disaster/emergency management plan. The example admission packet in the office included a form for this education however this form was not in the binders in the patient homes.
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