QA Investigation Results

Pennsylvania Department of Health
CARING SENIOR SERVICE OF EASTERN MONTGOMERY COUNTY
Health Inspection Results
CARING SENIOR SERVICE OF EASTERN MONTGOMERY COUNTY
Health Inspection Results For:


There are  6 surveys for this facility. Please select a date to view the survey results.

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Initial Comments:


Based on the findings of an onsite unannounced state re-licensure survey conducted on February 26, 2020, Caring Senior Service of Eastern Montgomery County, was found to be in compliance with the requirements of 28 Pa. Code, Health Facilities, Part IV, Chapter 51, Subpart A.








Plan of Correction:




Initial Comments:


Based on the findings of an onsite unannounced state re-licensure survey conducted on February 26, 2020, Caring Senior Service of Eastern Montgomery County, was found not to be in compliance with the requirements of 28 Pa. Code, Health Facilities, Part IV, Chapter 611, Subpart H. Home Care Agencies and Home Care Registries.








Plan of Correction:




611.52(b) LICENSURE
State Police Criminal History Record

Name - Component - 00
If the individual required to submit or obtain a criminal history report has been a resident of this Commonwealth for 2 years preceding the date of the request for a criminal history report, the individual shall request a State Police criminal history record.

Observations:


Based on review of personnel files (PFs) and interview with the agency's administrator, the agency failed to ensure that a criminal background check was completed prior to employment for eight (8) of ten (10) PFs reviewed. (PF #3, 4, 5, 6, 7 , 8 , 9 and 10).

Findings include:

Act 169 of 1996 as amended by Act 13 of 1997 states: "If the applicant/employee has been a resident of the Commonwealth of Pennsylvania for 2 or more years prior to application for employment, the applicant will need to obtain a clearance from the Pennsylvania State Police. This clearance is obtained by doing the following: Request for Criminal Record Check Form (SP4-164)." "When the applicant/employee has not been a resident of the Commonwealth of Pennsylvania for the entire two years (without interruption) immediately preceding the date of application for employment or currently lives out of state, in addition to the Pennsylvania State Police Criminal History Check, the applicant/employee will also need to obtain an FBI Criminal History Check. Facilities are defined by the act to include: Domiciliary Care Homes, Home Health Care Agency, Nursing Facility (licensed by the Department of Aging), and Personal Care Home (licensed by the Department of Public Welfare). A Home Health Care Agency is further defined to include those agencies licensed by the Department of Health and any public or private organization which provides care to a care-dependent individual in their place of residence." "If entities run into special circumstances where they need to hire an employee before the results of their record checks are returned, there is a provision in CPSL that allows for a provisional hiring period. The period is to not exceed 30 days for in state residents and 90 for out of state residents."

Findings:

A review of the PFs was conducted on February 26, 2020 between approximately 10:30 AM- 2:00 PM revealed the following:


PF #3 Date of Hire (DOH): 8/27/2018 - File did not contain a Pennsylvania State Police Criminal Background Check.

PF #4 (DOH): 10/21/2017 - File did not contain a Pennsylvania State Police Criminal Background Check.

PF #5 (DOH): 6/15/2019 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 2/24/2020, which was eight (8) months after date of hire.

PF #6 (DOH): 8/20/2018 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 10/10/2018, which was two (2) months after date of hire.

PF #7 (DOH): 8/1/2019 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 11/7/2019, which was three (3) months after date of hire.

PF #8 (DOH): 3/6/2019 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 4/25/2019, which was one (1) month after date of hire.

PF #9 (DOH): 11/16/2017 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 2/24/2020, which was three (3) months after date of hire.

PF #10 (DOH): 8/9/2019 - There was documentation that a Pennsylvania State Police Criminal Background Check was conducted on 11/7/2019, which was three (3) months after date of hire.


Interview with the owner and adminstrator on February 26, 2020 at approximately 2:00 PM confirmed the above findings.

















Plan of Correction:

Caring Senior Service of Eastern Montgomery County (CSS of EMC) will correct the failure to ensure the criminal background check is completed and on time for all caregiver files and new hires as follows:

1. Produce and ensure a valid criminal background check is completed for two PFs from which it was missing.

2. CSS of EMC office staff will audit the remaining active caregiver files to ensure a valid criminal background check report is completed and if any deficiencies found will be corrected.

3. Going forward for new hires, a checklist will be created and followed by the office staff at the time of hiring/orientation to ensure a criminal background check is completed on time according to PA code 611.52(b).


611.55(a) LICENSURE
Compentency Requirements

Name - Component - 00
Prior to assigning or referring a direct care worker to provide services to a consumer, the home care agency or home care registry shall ensure that the direct care worker has done one of the following: (1) Obtained a valid nurse ' s license in this Commonwealth;
(2) Demonstrated competency by passing a competency examination developed by the home care agency or home care registry which meets the requirements of subsection (b)and (c).
(3) Has successfully completed one of the following:
(i) A training program developed by a home care agency, home care registry, or other entity which meets the requirements of subsection (b) and (c).
(ii) A home health aide training program meeting the requirements of 42 C.F.R. 484.36 (relating to the Conditions of Participation; Home Health Aide Services).
(iii) The nurse aid certification and training program sponsored by the Department of Education and located at www.pde.state.pa.us.
(iv) A training program meeting the training standards imposed on the agency or registry by virtue of the agency ' s or registry ' s participation as a provider in a Medicaid waiver or other publicly funded program providing home and community based services to qualifying consumers.
(v) Another program identified by the Department by subsequent publication in the Pennsylvania Bulletin or on the Department ' s website.

Observations:


Based on a review of personnel files (PF) and an interview with the administrator, the agency did not provide documentation of initial competency by obtaining one of the following: 1) Obtained a valid nurse's license in this Commonwealth;
(2) Demonstrated competency by passing a competency examination developed by the home care agency or home care registry which meets the requirements of subsection (b)and (c).
(3) Has successfully completed one of the following:
(i) A training program developed by a home care agency, home care registry, or other entity which meets the requirements of subsection (b) and (c).
(ii) A home health aide training program meeting the requirements of 42 C.F.R. 484.36 (relating to the Conditions of Participation; Home Health Aide Services).
(iii) The nurse aid certification and training program sponsored by the Department of Education and located at www.pde.state.pa.us.
(iv) A training program meeting the training standards imposed on the agency or registry by virtue of the agency 's or registry 's participation as a provider in a Medicaid waiver or other publicly funded program providing home and community based services to qualifying consumers.
(v) Another program identified by the Department by subsequent publication in the Pennsylvania Bulletin or on the Department ' s website.

One (1) of ten (10) PFs did not meet this requirement. PF #3.

Findings include:

A review of PFs was conducted on February 26, 2020 from approximately 10:30 AM - 2:00 PM revealed the following:

PF #3: Date of Hire: 8/27/2018 - File did not contain any documentation of initial competency.


An interview with the owner and administrator on February 26, 2020 at 2:00 PM confirmed the above finding.













Plan of Correction:

Caring Senior Service of Eastern Montgomery County will correct the deficiency of not providing documentation of initial competency by doing the following:

1. Produce copy of a valid professional license or a successful initial competency test for one of the ten PFs from which this document was missing.

2. CSS of EMC office staff will audit the remaining active caregiver files to ensure a valid competency or training certificate is conducted and included according to PA code 611.55(a) and if any deficiencies found will be corrected.

3.For new hires, our intake packet checklist will be followed strictly by the office staff at the time of hiring/orientation to ensure initial competency test is conducted and scored and report of a passing test is included in the caregiver file.




611.55(e) LICENSURE
Competency Requirements

Name - Component - 00
The competency review must occur at least once per year after initial competency is established, and more frequently when discipline or other sanction, including, for example, a verbal warning or suspension, is imposed because of a quality of care infraction.

Observations:


Based on a review of personnel files (PF) and an interview with the administrator, the agency did not provide documentation of an annual competency review for five (5) of ten (10) PFs. (PF #1, 3, 4, 6 and 9).

Findings include:

A review of PFs was conducted on February 26, 2020 from approximately 10:30 AM - 2:00 PM revealed the following:

PF #1 Date of Hire (DOH): 5/12/2018 - File did not contain documentation of an annual competency review for 2019.

PF #3 (DOH): 8/27/2018 - File did not contain documentation of an annual competency review for 2019.

PF #4 (DOH): 10/21/2017 - File did not contain documentation of an annual competency review for 2018 and 2019.

PF #6 (DOH): 8/20/2018 - File did not contain documentation of an annual competency review for 2019.

PF #9 (DOH): 11/16/2017 - File did not contain documentation of an annual competency review for 2018 and 2019.


An interview with the owner and administrator on February 26, 2020 at 2:00 PM confirmed the above findings.













Plan of Correction:

CSS of EMC will correct the deficiency to ensure annual competency review is completed for all active caregivers as follows:

1. The office staff will assign an online training course in our Caring University (it is our online training platform for all employee and staff training) catalog to the caregiver and conduct a test afterward for proving his/her annual competency for five of the ten PFs reviewed.

2. The office staff will audit the remaining active caregiver files to ensure an annual competency documentation that satisfies PA code 611.55(e) is included in the chart and if any deficiencies found will be corrected as described in step 1 above.

3. Going forward, the due date for annual competency training will be tracked for all active caregivers in Tendio (our client management software system). A report will be generated on a regular basis to show the list of caregivers approaching annual competency training due to be conducted. Then these caregivers will be given the training and test as explained in step 1 above. The result of test will be added to their caregiver chart.


611.56(a) LICENSURE
Health Screening

Name - Component - 00
(a) A home care agency or home care registry shall insure that each direct care worker and other office staff or contractors with direct consumer contact, prior to consumer contact, provide documentation that the individual has been screened for and is free from active mycobacterium tuberculosis.

Observations:



Based on review of personnel files (PF), Centers for Disease Control guidelines, and administrator interview, it was determined the agency failed to ensure that direct care workers were screened for and were free from active mycobacterium tuberculosis prior to assignment with clients. Review of personnel files revealed that six (6) of ten (10) direct care workers were not screened for mycobacterium tuberculosis per CDC guidelines. (PF #1, 3, 4, 5, 6 and 9).

Findings include:

The CDC guidelines state that all Health Care Workers (HCW) should receive baseline tuberculosis screening upon hire, using a two-step tuberculin skin test (TST) of a single blood assay for tuberculosis (TB) to test for infection with tuberculosis. After baseline testing for infection with tuberculosis, HCWs should receive TB screen annually. HCWs with a baseline positive test for tuberculosis infections should receive one chest radiograph result to exclude tuberculosis disease. CDC Guidelines for preventing the transmission of Mycobacterium tuberculosis in health care settings, 2005. Morbidity and Mortality World Report 2005;(RR-17) http://www.cdc.gov/mmwr/pdf/rr/rr5417.pdf.

A review of PFs was conducted on February 26, 2020 from approximately 10:30 AM - 2:00 PM revealed the following:

PF #1 Date of Hire (DOH): 5/12/2018 - There was no documentation of annual TB screening for 2019.

PF #3 (DOH): 8/27/2018: There was no documentation of initial two step TST, Quantiferon or chest x-ray, or an annual TB screening for 2019.

PF #4 (DOH): 10/21/2017: There was no documentation of initial two step TST, Quantiferon or chest x-ray, or an annual TB screening for 2018 and 2019.

PF #5 (DOH): 6/15/2019: There was no documentation of a second step TST for 2019.

PF #6 (DOH): 8/20/2018: There was no documentation of an annual TB screening for 2019.

PF #9 (DOH): 11/16/2017: There was no documentation of an annual TB screening for 2018.


An interview with the owner and administrator on February 26, 2020 at 2:00 PM confirmed the above findings.













Plan of Correction:

Caring Senior Service of Eastern Montgomery County understands that upon hire, a symptom checklist is also required in addition to a 2-step PPD. An annual symptom checklist or a 1-step PPD is required thereafter. This is in accordance with CDC Guidelines for preventing the transmission of Mycobacterium tuberculosis in health care settings, 2005.

CSS of EMC will correct the deficiency of not having documentation proving that the caregiver has been screened for and is free from active mycobacterium tuberculosis by doing the following:

1. Produce documentation of annual TB screening for five of the ten PFs from which annual TB screening was missing; produce documentation of initial 2-step TST or chest X-ray for one of ten PFs reviewed and produce documentation of a 2nd step TST for one of ten PFs who was found deficient of a 2nd step TST in 2019.

2. Our office staff will audit the remaining active caregiver files to ensure an initial 2-step TST or chest X-ray is included and an annual TB symptom checklist or a 1-step PPD is included for those who requires annual TB screening.

3.For new hires, our intake packet checklist will be followed closely by the office staff at the time of hiring/orientation to ensure proof of documentation for initial 2-step TST, Quantiferon or chest X-ray is obtained before allowing caregiver to work with a client.




611.57(a) LICENSURE
Consumer Rights

Name - Component - 00
(a) The consumer of home care services provided by a home care agency or through a home care registry shall have the following rights: (1) To be involved in the service planning process and to receive services with reasonable accommodation of individual needs and preferences, except where the health and safety of the direct care worker is at risk. (2) To receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services. Less than 10 days advance written notice may be provided in the event the consumer has failed to pay for services, despite notice, and the consumer is more than 14 days in arrears, or if the health and welfare of the direct care worker is at risk.

Observations:


Based on review of consumer records (CRs) and interview with the agency's administrator, it was determined that the home care agency failed to ensure that the consumer rights included the following, "To receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services. Less than 10 days advance written notice maybe provided in the event the consumer has failed to pay for services, despite notice, and the consumer is more than 14 days in arrears, or if the health and welfare of the direct care worker is at risk," for eight (8) of ten (10) Consumer Records (CR) reviewed (CR # 1, 2, 5, 6, 7, 8, 9 and 10).

Findings include:

A document containing the "10 day notice" was listed on the service agreement. An interview was conducted with the administrator on February 26, 2020 at approximately 9:15 AM. The administrator stated the "10 day notice" which is included in the welcome packet was currently only given to private pay clients.

The following consumer records were reviewed on February 26, 2020 between approximately 9:15 AM - 10:30 AM revealed the following:

CR# 1: Start of Service (SOS): 6/28/2018 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 2: (SOS): 12/13/2019 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 5: (SOS): 9/17/2018 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 6: (SOS): 5/18/2019 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 7: (SOS): 5/11/2018 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 8: (SOS): 4/18/2018 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 9: (SOS): 2/4/2019 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.

CR# 10: (SOS): 2/10/2020 - Revealed that there was no documentation to show that the consumer had received the following consumer rights information, to receive at least 10 calendar days advance written notice of the intent of the home care agency or home care registry to terminate services.


An interview with the owner and administrator was conducted on February 26, 2020, at approximately 2:00 PM confirmed the above findings.










Plan of Correction:

Caring Senior Service of Eastern Montgomery County understands that Client Intake must be performed for all clients when admitted regardless of whether they are private or otherwise. During the intake process the CSS will present the client with consumer rights information and have them sign documents in the intake packet which will contain information related to consumer rights including power of attorney or guardianship under PA code 611.57(b) Consumer protection/prohibitions.

CSS of EMC will correct the deficiency of certain active clients not having received the consumer rights information from our agency at the time of admission. This is true for many of our non-private clients. The Application For Services Agreement form, which will contain the guardianship or power of attorney clause, will be updated with the new phone number (1-800-254-51640 for the Department of Health's Complaint Hotline. The steps to accomplish the correction will be as follows:

1. Our office staff will visit eight of ten CRs reveiwed, who are found not having received the consumer rights regarding guardianship or power of attorney, and have the consumer sign the Application For Services Agreement.

2. Our office staff will audit the remaining active client files to determine if Application For Services Agreement have been signed and included in the client chart. If deficiency found, then the client record will be corrected by following the procedure outlined in step 1 above.

3.For new client admissions, an intake will be conducted in the home of the consumer, private and non-private, and have this consumer sign the documents in the intake packet including the Application For Services Agreement which covers consumer rights regarding power of attorney and guardianship clause.



611.57(b) LICENSURE
Prohibitions

Name - Component - 00
(b) No individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry. The home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

Observations:



Based on review of the consumer records (CR) and interview with the administrator, the agency failed to provide documentation that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry for eight (8) of ten (10) CRs reviewed. (CR #1, 2, 5, 6, 7, 8, 9 and 10).

Findings include:

A document containing no check endorsement or assuming power of attorney was listed on the service agreement. An interview was conducted with the administrator on February 26, 2020 at approximately 9:15 AM. The administrator indicated that the above clause which is included in the welcome packet, was currently only given to private pay clients.

The following consumer records reviewed on February 26, 2020 between approximately 9:15 AM - 10:30 AM revealed the following:


CR #1: Start of Service (SOS): 6/28/2018 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #2: (SOS): 12/13/2019 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #5: (SOS): 9/17/2018 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #6: (SOS): 5/18/2019 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #7: (SOS): 5/11/2018 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #8: (SOS): 4/18/2018 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #9: (SOS): 2/4/2019 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.

CR #10: (SOS): 2/10/2020 - Revealed that there was no documentation that the consumer was informed that no individual as a result of the individual's affiliation with a home care agency or home care registry may assume power of attorney or guardianship over a consumer utilizing the services of that home care agency or home care registry and that the home care agency or home care registry may not require a consumer to endorse checks over to the home care agency or home care registry.


An interview with the agency's owner and administrator on February 26, 2020, at approximately 2:00 PM confirmed the above findings.












Plan of Correction:

Please Note: This correction plan should address citation number 5. The POC provided for citation 5 (last page) should apply to citation 6. (This is due to being unable to edit the last submitted correction plan)


Caring Senior Service of Eastern Montgomery County understands that Client Intake must be performed for all clients when admitted regardless of whether they are private or otherwise. During the intake process the CSS will present the client with consumer rights information and have them sign documents in the intake packet which will contain information related to consumer rights including terminating service with 10-day notice under PA code 611.57(a) Consumer protection/prohibitions.

CSS of EMC will correct the deficiency of certain active clients not having received the consumer rights information from our agency at the time of admission. The Application For Services Agreement form, which will contain rights regarding terminating service with 10-day notice, termination due to failure of payment, or if the health and welfare of the direct care worker is at risk, will be presented to the client during intake. The steps to accomplish the correction will be as follows:

1. Our office staff will visit eight of ten CRs reveiwed, who are found not having received the consumer rights regarding termination of service and have the consumer sign the Application For Services Agreement.

2. Our office staff will audit the remaining active client files to determine if Application For Services Agreement have been signed and included in the client chart. If deficiency found, then the client record will be corrected by following the procedure outlined in step 1 above.

3.For new client admissions, an intake will be conducted in the home of the consumer, private and non-private, and have this consumer sign the documents in the intake packet including the Application For Services Agreement which covers consumer rights regarding terminating service with 10-day notice, termination due to failure of payment, or if the health and welfare of the direct care worker is at risk.



611.57(c) LICENSURE
Information to be Provided

Name - Component - 00
(c) Prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

Observations:


Based on review of the consumer records (CR) and interview with the administrator, the agency failed to provide documentation to the consumer, the consumer's legal representative or responsible family member an information packet stating, prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.
for eight (8) of ten (10) CRs reviewed. (CR #1, 2, 5, 6, 7, 8, 9 and 10).


Findings include:


An interview was conducted with the adminstrator on February 26, 2020 at approximately 9:15 AM. The administrator indicated that the welcome packets were only given to private pay clients.

Consumer records (CR) reviewed on February 26, 2020 between approximately 9:15 AM - 10:30 AM revealed the following:


CR #1: Start of Service (SOS): 6/28/2018 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #2: (SOS): 12/13/2019 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #5: (SOS): 9/17/2018 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #6: (SOS): 5/18/2019 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #7: (SOS): 5/11/2018 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #8: (SOS): 4/18/2018 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #9: (SOS): 2/4/2019 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.

CR #10: (SOS): 2/10/2020 - Revealed that there was no documentation that prior to the commencement of services, the home care agency or home care registry shall provide to the consumer, the consumer's legal representative or responsible family member an information packet containing the following information in a form that is easily read and understood: (1) A listing of the available home care services that will be provided to the consumer by the direct care worker and the identity of the direct care worker who will provide the services. (2) The hours when those services will be provided. (3) Fees and total costs for those services on an hourly or weekly basis. (4) Who to contact at the Department for information about licensure requirements for a home care agency or home care registry and for compliance information about a particular home care agency or home care registry. (5) The Department's complaint Hot Line (1-800-254-5164) and the telephone number of the Ombudsman Program located with the local Area Agency on Aging (AAA). (6) The hiring and competency requirements applicable to direct care workers employed by the home care agency or referred by the home care registry. (7) A disclosure, in a format to be published by the Department in the Pennsylvania Bulletin by February 10, 2010, addressing the employee or independent contractor status of the direct care worker providing services to the consumer, and the resultant respective tax and insurance obligations and other responsibilities of the consumer and the home care agency or home care registry.


An interview with the agency's owner and administrator on February 26, 2020, at approximately 2:00 PM confirmed the above findings.











Plan of Correction:

Caring Senior Service of Eastern Montgomery County understands that Client Intake must be performed for all clients when admitted regardless of whether they are private or otherwise. During the intake process the CSS will present the client with consumer rights information and have them sign documents in the intake packet which will contain information related to consumer rights including the identity and status of the direct care worker, listing of home care service provided, hours and fees associated with the service, important hotline numbers for consumers under PA code 611.57(c) Consumer protections/information to be provided.

CSS of EMC will correct the deficiency of certain active clients not having received the consumer rights information from our agency at the time of admission. The Application For Services Agreement form and Consumer Notice of Direct Care Worker Status form will be presented to the client during intake. Both these forms combined will provide the necessary information that satisfies the requirement under section 611.57(c) of the PA code Consumer protections/information to be provided.

The steps to accomplish the correction will be as follows:

1. Our office staff will visit eight of ten CRs reveiwed, who are found not having received the consumer rights regarding Consumer Notice of Direct Care Worker Status and the Application For Services Agreement, and present them with the intake packet and have them sign the aforementioned forms.

2. Our office staff will audit the remaining active client files to determine if Application For Services Agreement and Consumer Notice of Direct Care Worker Status have been signed and included in the client chart. If deficiency found, then the client record will be corrected by following the procedure outlined in step 1 above.

3.For new client admissions, an intake will be conducted in the home of the consumer, private and non-private, and have this consumer sign the documents in the intake packet including the Application For Services Agreement and Consumer Notice of Direct Care Worker Status.



Initial Comments:


Based on the findings of an onsite unannounced state re-licensure survey conducted on February 26, 2020, Caring Senior Service of Eastern Montgomery County, was found not to be in compliance with the requirements of 35 P.S. 448.809 (b).






Plan of Correction:




35 P. S. 448.809b LICENSURE
Photo Id Reg

Name - Component - 00
(1) The photo identification tag shall include a recent photograph of the employee, the employee's FIRST name, the employee's title and the name of the health care facility or employment agency.

(2) The title of the employee shall be as large as possible in block type and shall occupy a one-half inch tall strip as close as practicable to the bottom edge of the badge.

(3) Titles shall be as follows:
(i) A Medical Doctor shall have the title " Physician. "
(ii) A Doctor of Osteopathy shall have the title " Physician. "
(iii) A Registered Nurse shall have the title " Registered Nurse. "
(iv) A Licensed Practical Nurse shall have the title " Licensed Practical Nurse. "
(v) Abbreviated titles may be used when the title indicates licensure or certification by a Commonwealth agency.

(4)A notation, marker or indicator included on an identification badge that differentiates employees with the same first name is considered acceptable in lieu of displaying an employee's last name.



Observations:


Based on observation of photo identification (ID) badge and an interview with the agency's owner, it was determined that the agency failed to ensure a (ID) badge that would include the individual's full name, title, and recent photograph of the employee for all direct care workers and office staff with direct care of consumers.

Findings include:

During onsite relicensure survey conducted on February 26, 2020 with the agency's owner and administrator between approximately 10:30 AM - 2:00 PM, an ID badge copy was observed.

The ID badge did not contain the full name and recent photograph for employees.

An interview with the agency's owner and administrator was conducted at appproxminatley 2:00 PM and it was confirmed that the above information was missing.












Plan of Correction:

Caring Senior Service of Eastern Montgomery County will correct the deficiency of ID badges for caregivers and staff that did not conform to the Photo ID Reg of 35 P.S. 448.809b. The following steps will be taken to correct this problem:

The office administrator will issue new ID badges to all active caregivers and staff members with direct care of consumers. The new id badge will display recent photograph of the employee, his/her name and title, and name of our agency.