Initial Comments:
Based on the findings of an onsite unannounced State relicensure survey completed 8/10/2021, Aging In Place Services was found to be in compliance with the requirements of PA Code, Title 28, Health and Safety, Part IV, Health Facilities, Subpart A, Chapter 51.
Plan of Correction:
Initial Comments:
Based on the findings of an onsite unannounced state relicensure survey completed 8/10/2021, Aging In Place Services was found not to be in compliance with the following requirements of PA Code, Title 28, Health and Safety, Part IV, Health Facilities, Subpart H, Chapter 611, Home Care Agencies and Home Care Registries.
Plan of Correction:
611.4(c) LICENSURE
Requirements for HCA and HCR
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Home care agencies and home care registries licensed under this Chapter shall comply with applicable environmental, health, sanitation and professional licensure standards which are required by Federal, State, and local authorities.
Observations:
A review on 8/9/2021 at approximately 2:00 PM of Title 28. Health and Safety Part IV. Health Facilities Subpart H. Home Care Agencies and Home Care Registries. Chapter- 611. Home Care Agencies and Home Care Registries under 611.5 Definitions includes "Home Care Services- The term encompasses the following activities:
(i) Personal care.
(ii) Assistance with instrumental activities of daily living.
(iii) Companionship services.
(iv) Respite care.
(v) Specialized care."... Specialized care is further defined as "Nonskilled services unique to the consumer's care needs that facilitate the consumer's health, safety and welfare, and ability to live independently."
Based on review of the regulation's definition of home care services, agency policy, consumer records (CR), personnel files (PF) and staff (EMP) interviews, it was determined the agency did not follow the regulation or agency policy as the agecny accepted a consumer for skilled nursing services under a home care license which is outside the scope of the definition for home care agency services for one (1) of nine (9) CR reviewed (CR2).
Findings include:
Review of the agency policy on 8/9/2021 at approximately 3:00 PM revealed, "SUBJECT: CONSUMER ASSISTANCE WITH SELF-ADMINISTERED MEDICATIONS ...POLICY: *(Agency), A Home Care Provider...will provide consumers with services related to assistance with self-administered medications. During the intake procedures for (agency) Services and when assistance with self-administered medications is requested by the consumer/family/caregiver will be referred to an appropriate skilled agency for medication management..."
Review of the agency policy on 8/9/2021 at approximately 3:00 PM revealed "SUBJECT: RN or LPN MEDICATION ADMINISTRATION...PROCEDURE: Medication orders include the following information: ordering physician's name, address and telephone number, consumer name, medical record number, medication name, dose, route, and frequency of administration. Medication orders should be documented in understandable language and legible writing. Medication order changes should be documented on a consumer's care plan and on medication profile on consumer record. The nurse discusses any unresolved, significant concerns about the medication with the prescribing physician, licensed independent practitioner, and/or (Agency) staff involved in the consumer's care, treatment, and/or services ...Prior to administer the medication, the nurse verifies the following information based on the medication order and product label: Correct Medication and strength, correct dose, correct time, correct route, correct frequency, correct patient..."
A review of CR #2 on 8/4/2021 at approximately 10:02 AM revealed, "HCA/R Survey Form for Consumers Receiving Specialized Care" The surveyor asked EMP1 and EMP3 if any consumers were receiving any of the following specialized services. The surveyor pointed out the six (6) items on the form to confirm. "1. Specialized services provided: Bowel/Bladder Routines, Ostomy Care, Assistance with Skin Care, Assistance with Medications, Intermittent Urinary Catheterization (clean) and Wound Care..." EMP1 confirmed no consumers were receiving specialized services.
A review of CR #2 on 8/4/2021 at approximately 1:25 PM revealed start of services 5/20/2019. Per review of CR#2 County "Service Order" dated 6/1/21 the following was requested "Services: PPS-Skilled Nursing LPN...Start Date: 07/01/2020...Subservices: Special Instructions: Please provide LPN services 1x daily Administer insulin, Monitor overall health, Liaison with physicians as needed Medication Management***Medical appointment management, transport and escort when additional nurses are available...Please provide in home assistance for 27/7. Hours to be shared with spouse for billing purposes. Meal Prep, Grocery shopping, Errands, Housekeeping, Laundry, Transportation, Personal Care assistance as requested..."
A current service order was reviewed: County "Service Order" dated 7/1/2021 the following was requested "Services: PPS-Skilled Nursing LPN...Start Date: 07/01/2021...Subservices: Special Instructions: Please provide LPN services X1 daily Administer insulin, Monitor overall health, Liaison with physicians as needed Medication Management***Medical appointment management, transport and escort when additional nurses are available...Services: PPS-inHome Services...Special Instructions: Please provide in home assistance for 27/7. Hours to be shared with spouse for billing purposes. Meal Prep, Grocery shopping, Errands, Housekeeping, Laundry, Transportation, Personal Care assistance as requested..."
A review of the CR2 revealed a document labeled: "PATIENT CHOICE OF HOME HEALTH AND HOME CARE PROVIDERS To provide my home health care needs (skilled care), I have chosen: (name of agency home health branch). To provide my home care needs (supportive services), I have chosen: (agency)...dated 5/20/2019."
A doctor's order was located in the CR and reviewed on 8/9/2021 at approximately 3:00 PM which revealed, "...REQUESTED STUDIES Custom Order (please administer pt's (patients) Lantus after her dialysis appt (appointment)..." dated 10/10/2019.
A document was within CR2 labeled "MEDICATION PROFILE (AGENCY) A Home Care Provider Prescribed Medications (Including Over-the -Counter and Herbals)..." One of the medication "lantus 18 U @ 9 am (route) Subq (Frequency) qd" was listed on the medication profile. There was not a date on the document to confirm when the medication list was provided to the agency.
A "MEDICATION LIST" from the consumers primary care provider was reviewed which listed "...LANTUS 100/ML SUBCUTANEOUS SOLUTION, 20 UNITS QAM..." (print date 7/12/2021).
Agency notes for the period of 5/1/2021 to 8/1/2021 were reviewed which confirmed skilled nursing services for medication administration via injection was provide to the consumer. The surveyor was not able to confirm from documentation the correct dosage of medication skilled nursing was to administer from the custom order date of 10/10/2019 to 7/12/2021.
An exit interview was conducted with the administrator, director and agency director on 8/5/2021 at approximately 3:45 PM which confirmed the findings.
Plan of Correction:Clarification on order obtained by PCP office r/t insulin injection. Consumer is now opened under home health services for daily insulin injection.
Director will field all referrals to ensure that consumers are appropriate for home care.
Monthly chart audits were implemented 7/2021. Audits include monitoring care provided to consumers and meeting necessary requirements related to scheduling, LPN pill planners, monitoring/updating care plans, etc. A monthly audit sheet has been placed in consumer's charts for designated areas to be audited and signed off. Support specialist and LPN case managers will be continuing chart audits and reporting any issues/concerns to Director.
Director will be monitoring continued implementation of the plan of correction.
611.52(d) LICENSURE
Proof of Residency
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The home care agency or home care registry may request an individual required to submit or obtain a criminal history record to furnish proof of residency through submission of any one of the following documents:
(1) Motor vehicle records, such as a valid driver ' s license or a State-issued identification.
(2) Housing records, such as mortgage records or rent receipts.
(3) Public utility records and receipts, such as electric bills.
(4) Local tax records.
(5) A completed and signed, Federal, State or local income tax return with the applicant ' s name and address preprinted on it.
(6) Employment records, including records of unemployment compensation
Observations:
Based on a review of policy, personnel files (PFs) and staff (EMP) interview it was determined the agency failed to verify proof of residency in this Commonwealth for the 2 years preceding the date of hire (DOH) for one (1) of seven (7) PFs reviewed (PF1).
Findings included:
A review of the agency policies on 8/4/2021 at approximately 10:40 a.m. revealed that policy entitled : "SUBJECT: PROVISIONAL HIRING: DIRECT CARE WORKER reference #103AP ...POLICY: (Agency) will use consistent hiring processes, including provisional hiring for all applicants in accordance with the licensing requirements at section 611 for home care agencies and registries..."
A review of the agency consumer admission packet on 8/4/2021 at approximately 11:10 a.m. revealed, "CONSUMER RIGHTS AND RESPONSIBILITIES...Be advised that all direct care workers of (agency) criminal background checks have been completed and cleared..."
A review of PF #1 was conducted on 8/5/2021 at approximately 2:40 p.m., the employee's date of hire (DOH) was 11/19/2019. Documentation within the file confirmed a Pennsylvania driver's license with an issue date of 9/6/2018 was provided. Also, within PF1 was a " PENNSYLVANIA LICENSE TO CARRY FIREARMS " with an issue date of 11/7/2014. There was no additional documentation in PF to confirm the agency verified proof of residency from the list of required documents in the Commonwealth for two (2) years immediately preceding the date of hire.
An exit interview was conducted with the administrator, director and agency director on 8/5/2021 at approximately 3:45 p.m. which confirmed the findings.
Plan of Correction:HR staff re-educated on appropriate verification methods for proof of residency and what is not appropriate for home care.
Upon hire, HR will put appropriate employee file in place with valid proof of residency. A second HR employee with check completed employee file. Chart will then be re-audited at 90 days by Human Resources Director.
Human Resources Director will monitor implementation of plan of correction.
611.52(g) LICENSURE
Confidentiality
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The home care agency or home care registry shall keep the information obtained from State Police criminal history records and Department of Aging letters of determination regarding Federal criminal history records confidential and use it solely to determine an applicant ' s eligibility to be hired, rostered or retained.
Observations:
Based on review of agency's policy, consumer records (CR), observation (OBV) and staff (EMP) interview, the agency failed to maintain consumer files in a confidential manner in accordance with agency policy for seven (7) of nine (9) PF reviewed (PF1-PF7).
Findings included:
Review of agency's policy and procedure manual on 8/5/2021, at approximately 3:30 PM revealed, "SUBJECT AND CONFIDENTIALITY OF INFORMATION (HIPAA) ...POLICY...All client's personal and health information and billing data is considered confidential and will be disclosed at the direction (Agency) of Community Services only when authorized to do so by the client or his/her legal representative, when required by law or on a "need to know" basis as necessary to carry out the day to day business activities ...PROCEDURE...Operational and professional AIP Services' personnel who require access to client day-to-day tasks, are permitted access to needed records...Safeguarding of Records: *Original paper or computer client medical records, personnel files, payroll records and billing records shall be filed and shall not be removed from the site of origin except by court order or for transfer to and from storage facilities or other authorized sites as needed to accomplish the day-to-day business of the organization upon direction of the (Agency) of Community Services...Records should not be left un unattended areas accessible to unauthorized individuals..."
Direct observation of agency's office space on 8/4/2021 at approximately 12:55 p.m. revealed active consumer records in an open shelving unit with no locking mechanism or means to be locked and secured. Additional cardboard boxes with inactive consumer records were stacked at the back wall of the office space. The surveyor asked whom had access to the office space and EMP1 confirmed staff only. The surveyor asked if cleaning services were provided by the facility personnel. EMP1 confirmed cleaning services were not performed by agency staff, and were performed by facility personnel. EMP1 confirmed the boxes stacked at the back wall were inactive files waiting to be taken to a secure location.
An exit interview was conducted with the administrator, director and agency director on 8/5/2021 at approximately 3:45 p.m. which confirmed the findings.
Plan of Correction:All consumer files will be centralized in a designated room. Desks removed, making the room a locked medical records area with no unauthorized entrance. Door will remain closed and locked, if entrance is needed by staff, director/administrator will supervise and grant access.
Initial Comments:
Based on the findings of an onsite unannounced State relicensure survey completed 8/10/2021, Aging In Place Services was found to be in compliance with the requirements of 35 P.S. 448.809 (b).
Plan of Correction:
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