QA Investigation Results

Pennsylvania Department of Health
WESTTOWN DIALYSIS
Health Inspection Results
WESTTOWN DIALYSIS
Health Inspection Results For:


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Initial Comments:


Based on the findings of an onsite unannounced Medicare recertification survey completed on September 19, 2024, Westtown Dialysis, was found to be in compliance with the requirements of 42 CFR, Part 494.62, Subpart B, Conditions for Coverage of Suppliers of End-Stage Renal Disease (ESRD) Services-Emergency Preparedness.




Plan of Correction:




Initial Comments:

Based on the findings of an onsite unannounced Medicare recertification survey completed on September 19, 2024, Westtown Dialysis located at 105 Westown Rd. West Chester Pa, 19382 and a home hemodialysis location at: Skilled Nursing & Rehab Pottstown, 724 N Charlotte St, Pottstown, PA 19464, (skilled nursing facility #1), were identified to have the following standard level deficiencies that was determined to be in substantial compliance with the following requirements of 42 CFR, Part 494, Subparts A, B, C, and D, Conditions for Coverage of Suppliers of End-Stage Renal Disease (ESRD) Services






Plan of Correction:




494.30(c)(2) STANDARD
IC-CATHETERS:GENERAL

Name - Component - 00
(2) The "Guidelines for the Prevention of Intravascular Catheter-Related Infections" entitled "Recommendations for Placement of Intravascular Catheters in Adults and Children" parts I - IV; and "Central Venous Catheters, Including PICCs, Hemodialysis, and Pulmonary Artery Catheters in Adult and Pediatric Patients," Morbidity and Mortality Weekly Report, volume 51 number RR-10, pages 16 through 18, August 9, 2002. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR Part 51. This publication is available for inspection as the CMS Information Resource Center, 7500 Security Boulevard, Central Building, Baltimore, MD or at the National Archives and Records Administration (NARA). Copies may be obtained at the CMS Information Resource Center. For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_regulations/ibr_locations.html




Observations:


Based on observations, policy and procedure review, and an interview with the ESRD administrator, it was determined the ESRD failed to ensure the Patient Care Technician (PCT #1) to change gloves and perform hand hygiene during for Central Venous Catheter (CVC) exit site care for one (1) of two (2) central venous catheter exit site care observations observed. ( Observation #1).


Findings include:

Review of policy Central Venous Catheter (CVC) Care Procedure on September 19 at approximately 11:00 am states " 4. remove old dressing and discard...7. remove gloves and discard. Perform hand hygiene per procedure and re-glove...8...clean exit site...10. Remove gloves and discard, perform hand hygiene per procedure and re-glove....."

Observation #1, on 9/17/2024 at approximately 11:00 AM, PCT #1 was observed at Station #17, removing the old CVC dressing, without changing gloves and performing hand hygiene after performing the task, then cleansing CVC exit site, again without changing gloves and performing hand hygiene after performing the task, and placing a new dressing on the CVC exit site.

An interview with the facility administrator on 9/19/2024 at approximately12:00 pm confirmed the above findings.






Plan of Correction:

V 0146
The Facility Administrator or designee held mandatory in-service(s) for all clinical teammates starting on 10/3/24. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-05-01 "Infection Control for Dialysis Facilities", Policy 1-12-17 "DSD Infection Control for Dialysis Facilities" Procedure 1-04-02B (ICHD), and Procedure 12-06-02B (HHD) "Central Venous Catheter (CVC) with Clear guard HD Antimicrobial End Caps Procedure" with emphasis on but not limited to A. Infection control – Hand Hygiene: 1) All teammates, Physicians, and Non-Physician (NPP) will perform hand hygiene before gloving and immediately after removal of gloves B. CVC care: 1) Step 4: Remove and discard gloves, conduct hand hygiene, and don new gloves. Place sterile gauze over the catheter and exit site leaving catheter limbs accessible. 2) Step 7: Remove gloves and discard. Perform hand hygiene per procedure and re-glove. Rationale: alcohol-based hand rubs may be used unless hands are visibly contaminated. Hand washing will be performed if hands are visibly contaminated with blood or bodily fluids. 3) Step 8: ...using an aseptic technique, clean the exit site... 4) Step 10: Remove gloves and discard, perform hand hygiene per procedure, and re-glove. Verification of attendance at in-service will be evidenced by teammates' signatures on the in-service sheet.
The Facility Administrator or designee will conduct observational audits for CVC care to verify hand hygiene with glove wearing and changing is performed per policy: daily for two (2) weeks then weekly for two (2) weeks then ongoing monthly during internal infection control audits to verify compliance. Instances of non-adherence will be corrected immediately.
The Facility Administrator or designee will review audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assurance and Performance Improvement meetings known as Facility Health Meetings. The Facility Administrator will report progress and any barriers to maintaining compliance. Action plans will be evaluated for effectiveness and new plans developed when needed until sustained compliance is achieved. Supporting documentation will be included in the meeting minutes. The Facility Administrator is responsible for compliance with this plan of correction.




494.60(b) STANDARD
PE-EQUIPMENT MAINTENANCE-MANUFACTURER'S DFU

Name - Component - 00
The dialysis facility must implement and maintain a program to ensure that all equipment (including emergency equipment, dialysis machines and equipment, and the water treatment system) are maintained and operated in accordance with the manufacturer's recommendations.



Observations:


Based on observation and interview with Registered Nurse #1, it was determined the clinic failed to ensure documentation of preventative maintenance for ancillary equipment for 2023 for eleven (11) out of eleven (11) pieces of Ancillary Equipment used in the dialysis den located within Skilled Nursing facility (SNF#1) (Ancillary Equipment #1-Ancillary Equipment #11).

Findings include:

Observations were conducted at the following skilled nursing facility (SNF) dialysis treatment den on 9/18/2024:
SNF #1, Skilled Nursing & Rehab Pottstown, 724 N Charlotte St, Pottstown, PA 19464

Ancillary Equipment Observations of Dialysis Den #1 were conducted on 9/18/2024 from 11:00 AM-11:30 AM, revealing the following:
Ancillary Equipment #1, a Laboratory Centrifuge, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #2, a Scale, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #3, a Hoyer Lift, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #4, a Automated External Defibrillator, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #5, a Suction Machine, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #6, a Medication Fridge, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #7, a Biohazard Waste Fridge, contained a sticker reading " Maintenance Due October 2023".
Ancillary Equipment #8-Ancillary Equipment #11, Oxygen Concentrators, all contained a sticker reading " Maintenance Due October 2023".

There was no available documentation present in the Dialysis Den to show Ancillary Equipment #1-Ancillary Equipment #11 received preventative maintenance for 2023.

An interview on 9/18/2024 with Registered Nurse #1 at approximately 12:00 PM confirmed the above findings.












Plan of Correction:

V403
The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 10/03/24. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 8-04-01 "Physical Environment" with emphasis on but not limited to 1) The dialysis facility will implement and maintain a program to verify that all equipment, including emergency equipment, dialysis delivery systems, and water treatment systems are maintained and operated according to the manufacturer's recommendations. Verification of attendance at in-service will be evidenced by the teammate's signature on the in-service sheet.

Preventive Maintenance for all identified ancillary equipment due October 2023 will be completed by Skilled Nursing Facility at Pottstown and DaVita Teammate with supervision from the Regional Operations Manager (ROM) on 11/15/24.
- Laboratory centrifuge
- Scale
- Hoyer Lift
- Automated External Defibrillator
- Suction Machine
- Medication Fridge
- Biohazard Fridge
- Oxygen Concentrators
The Facility Administrator or designee will conduct physical plant observational audits to verify preventive maintenance has been completed as evidenced by a new sticker with a future due date attached to each piece of equipment: daily for two (2) weeks, then weekly for two (2) weeks. Ongoing compliance will be audited with the Monthly OSHA Safety audits. Instances of non-adherence will be corrected immediately.
The Facility Administrator or designee will review audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assurance and Performance Improvement meetings known as Facility Health Meetings. The Facility Administrator will report progress and any barriers to maintaining compliance. Action plans will be evaluated for effectiveness and new plans developed when needed until sustained compliance is achieved. Supporting documentation will be included in the meeting minutes. The Facility Administrator is responsible for compliance with this plan of correction.




494.90(a)(1) STANDARD
POC-MANAGE VOLUME STATUS

Name - Component - 00
The plan of care must address, but not be limited to, the following:
(1) Dose of dialysis. The interdisciplinary team must provide the necessary care and services to manage the patient's volume status;


Observations:


Based on review of facility policies, clinical records (CR), and interview with facility staff, the facility failed to assess and manage patient's blood pressure needs according to facility policy for four (4) of six (6) in-center hemodialysis CR reviewed (CR #1, 6, 7, and 9).

Findings Included:

Review of facility policy #1-03-08 titled "Pre-Intra-Post Treatment Data Collection, Monitoring and Nursing Assessment" on September 17, 2024, at approximately 3:30 P.M. stated, "Intradialytic Data Collection/Assessment... 11. Abnormal findings or findings outside any patient specific physician ordered parameters will be reported to the licensed nurse immediately... The licensed nurse will use his/her clinical judgement based on individual patient needs to be determined if any clinical interventions are necessary..."
"Abnormal Findings: Blood Pressure- Intradialytic: Systolic greater than 180 mm/Hg or less than 90 mm/Hg. Diastolic greater than or equal to 100 mm/Hg or less than 50 mm/Hg."

Review of CR conducted on September 16, 2024, from approximately 11:15 A.M. to 3:00 P.M. and September 17, 2024, from approximately 9:00 A.M. to 3:00 P.M. revealed the following:

CR #1, admission date July 16, 2024. The hemodialysis flow sheet dated September 3, 2024, contained documentation of a blood pressure reading of 161/11 at 12:32 P.M., 160/102 at 1:02 P.M., and 183/150 at 2:32 P.M. The hemodialysis flow sheet dated September 10, 2024, contained documentation of a blood pressure reading of 158/101 at 11:24 A.M. The hemodialysis flow sheet dated September 12, 2024, contained documentation of a blood pressure reading of 178/122 at 2:01 P.M. There was no documentation that the Registered Nurse (RN) was notified of the elevated blood pressure readings.

CR #6, admission date December 7, 2021. The hemodialysis flow sheet dated September 10, 2024, contained documentation of a blood pressure reading of 156/105 at 10:22 A.M., 192/171 at 10:21 A.M. and 131/103 at 1:31 P.M. There was no documentation that the RN was notified of the elevated blood pressure readings.

CR #7, admission date November 18, 2023. The hemodialysis flow sheet dated September 3, 2024, contained documentation of a blood pressure reading of 178/157 at 6:46 A.M., 176/104 at 7:02 A.M., 166/101 at 8:02 A.M., and 174/100 at 10:32 A.M. The hemodialysis flow sheet dated September 5, 2024, contained documentation of a blood pressure reading of 172/103 at 7:32 A.M. The hemodialysis flow sheet dated September 10, 2024, contained documentation of a blood pressure reading of 178/102 at 6:44 A.M., 169/102 at 7:01 A.M., and 175/131 at 9:31 A.M. There was no documentation that the RN was notified of the elevated blood pressure readings.

CR #9, admission date July 1, 2024. The hemodialysis flow sheet dated September 4, 2024, contained documentation of a blood pressure reading of 183/110 at 7:18 A.M., 183/116 at 7:31 A.M., 176/109 at 8:01 A.M., and 175/103 at 8:31 A.M. The hemodialysis flow sheet dated September 9, 2024, contained documentation of a blood pressure reading of 178/111 at 6:20 A.M., 183/113 at 6:21 A.M., and 189/110 at 6:51 A.M. The hemodialysis flow sheet dated September 11, 2024, contained documentation of a blood pressure reading of 175/109 at 6:36 A.M., 182/108 at 6:41 A.M., 175/108 at 7:01 A.M., 171/105 at 7:31 A.M. and 160/107 at 8:03 A.M. The hemodialysis flow sheet dated September 13, 2024, contained documentation of a blood pressure reading of 179/103 at 6:55 A.M., 217/121 at 7:01 A.M., 185/115 at 7:02 A.M., 181/112 at 7:31 A.M., 171/106 at 8:01 A.M., 165/105 at 8:31 A.M., 186/107 at 9:01 A.M., 154/102 at 10:01 A.M., 171/107 at 10:31 A.M., and 152/101 at 11:14 A.M. There was no documentation that the RN was notified of the elevated blood pressure readings.

An interview with the Facility Administrator on September 17, 2024, at approximately 3:45 P.M. confirmed the above findings.











Plan of Correction:

V543
The Facility Administrator or designee held mandatory in-service(s) for all clinical teammates starting on 10/03/24. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-03-08 "Pre- Intra- Post Treatment Data Collection Monitoring and Nursing Assessment" with emphasis on but not limited to 1) Abnormal findings or findings outside of any patient-specific physician parameters will be reported to the licensed nurse immediately (refer to "Abnormal Findings" section in this policy). The licensed nurse will use his/her clinical judgment based on individual patient needs to determine if any clinical interventions are necessary. 2) The licensed nurse notifies the physician (or NPP if applicable) as needed of changes in patient status. 3) All findings, interventions, and patient response will be documented in the patient's medical record. 4) The following are abnormal findings and should be reported to the licensed nurse and documented in the patient's medical record. Blood pressure: Intradialytic: Systolic greater than 180 mm/Hg or less than 90 mm/Hg; Diastolic greater than or equal to 100 mm/Hg or less than 50 mm/Hg. Verification of attendance at in-service will be evidenced by teammates' signatures on the in-service sheet.
The Facility Administrator or designee will complete flow sheet audits to verify that any documentation of abnormal findings is also documented as reported to the licensed nurse, and that nurse response is documented, including but not limited to communication with the physician as needed, per policy:
Conduct audits on twenty-five percent (25%) of the flow sheets daily for two (2) weeks, then weekly for two (2) weeks. Ongoing compliance will be monitored with the monthly ten percent (10%) medical records audits to verify compliance. Instances of non-compliance will be addressed immediately.
The Facility Administrator or designee will review audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assurance and Performance Improvement meetings known as Facility Health Meetings. The Facility Administrator will report progress and any barriers to maintaining compliance. Action plans will be evaluated for effectiveness and new plans developed when needed until sustained compliance is achieved. Supporting documentation will be included in the meeting minutes. The Facility Administrator is responsible for compliance with this plan of correction.