QA Investigation Results

Pennsylvania Department of Health
WEST PHILADELPHIA DIALYSIS
Health Inspection Results
WEST PHILADELPHIA DIALYSIS
Health Inspection Results For:


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Initial Comments:

Based on the findings of an onsite unannounced Medicare recertification survey conducted on February 6, 2023 through February 8, 2023 and offsite on February 10, 2023, West Philadelphia 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 conducted on February 6, 2023 through February 8, 2023 and offsite on February 10, 2023, West Philadelphia Dialysis, was identified to have the following standard level deficiencies that were 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(a)(1) STANDARD
IC-WEAR GLOVES/HAND HYGIENE

Name - Component - 00
Wear disposable gloves when caring for the patient or touching the patient's equipment at the dialysis station. Staff must remove gloves and wash hands between each patient or station.




Observations:



Based on observation of the clinical area, facility policy and an interview with the facility administrator, the facility did not follow its policy with regard to teammate fingernails. (Observations #3, 6, and 10).

Findings include:

Policy "Infection Control For Dialysis Facilities" was reviewed on February 9, 2023 at approximately 2:30 pm. Policy states: "Teammate Hygiene: 8. It is a requirement for all DaVita teammates whose primary location is working in a facility have only natural nails. Artificial fingernails, nail extenders or nail enhancements including but not limited to nail jewelry, sculptor, acrylic or resin overlays or bonding, gels, tips, wraps, hybrid gels are not permitted..."

Observation of the clinical area was conducted on February 6, 2023 from approximately 9:00 am to 11:00 am.

Observation #3. PCT #1 noted to have artificial fingernails.

Observation #6. PCT #2 noted to have artificial fingernails.

Observation #10. PCT #3 noted to have artificial fingernails.

An interview with the facility administrator on February 9, 2023 at 3:00 pm confirmed the above findings.









Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 02/22/23. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-05-01 "Infection Control for Dialysis Facilities" with the emphasis on but not limited to: 1) It is a requirement for all DaVita Teammates whose primary location is working in a facility have only natural nails. Artificial finger nails, nail extenders, sculptor, acrylic resin overlays or bonding, gels, tips, wraps, hybrid gels are not permitted. Verification of attendance is evidenced by teammate's signature on the in-service sheet.
The Facility Administrator or designee will conduct infection control audits to verify that teammates are compliant with infection control policy regarding artificial fingernails: daily for two (2) weeks, then weekly for two (2) weeks. Ongoing compliance will be monitored with the monthly infection control audits. Instances of non-compliance will be addressed immediately.
The Facility Administrator or designee will review the audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assessment and Performance Improvement meetings known as Facility Health Meetings, with supporting documentation 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/procedure and medical records, and based on interview with the facility administrator, the facility failed to document post treatment data collection/assessments for four (4) of ten (10) incenter hemodialysis MR's reviewed (MR #4, 5, 6, and 7).

Findings include:

A review of facility policy titled "Pre-Intra-Post Treatment Data Collection, Monitoring and Nursing Assessment" on February 8, 2023 at approximately 2:45 pm states, "Policy: Post Treatment Data Collection/Assessment: 15. The PCT or licensed nurse will obtain and document basic data on each patient post dialysis and compare to pre-dialysis findings. 16. If an abnormal finding(s) or concern is identified post treatment, this needs to be reported to the licensed nurse. The licensed nurse will assess the patient prior to discharge..."

A review of patient medical records (MR) was completed on February 7, 2023 from approximately 9:00 am to 2:30 pm and on February 8, 2023 from approximately 8:40 am to 11:00 am.

MR #4: Admission Date: 3/16/2020. Dialysis order date: 10/2/2022; Frequency: Monday, Wednesday, and Friday; Target Weight: 62.5 Kg; Dialyzer: Optiflux F160NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 135 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.
Review of Dialysis Treatment Details Reports revealed the the following:
On 2/3/2023, there was no documentation of a post treatment assessment.

MR #5: Admission Date: 8/24/2022. Dialysis order date: 10/2/2022; Frequency: Tuesday, Thursday, and Saturday; Target Weight: 54.5 Kg; Dialyzer: Gambro Revaclear 300; Dialysate: 2 K; 2.5 CA; 30 HCO3; 136 NA; Treatment Duration: 195 minutes; BFR: 400; DFR: 600.
Review of Dialysis Treatment Details Reports revealed the the following:
On 1/26/2023 and 1/28/2023, there was no documentation of a post treatment assessment.

MR #6: Admission Date: 8/25/2022. Dialysis order date: 1/27/2023; Frequency: Tuesday, Thursday, and Saturday; Target Weight: 69.5 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 137 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.
Review of Dialysis Treatment Details Reports revealed the the following:
On 1/31/2023, there was no documentation of a post treatment assessment.

MR#7: Admission Date: 10/7/2015. Dialysis order date: 12/23/2022; Frequency: Tuesday, Thursday, and Saturday; Target Weight: 101 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 136 NA; Treatment Duration: 240 minutes; BFR: 450; DFR: 500.
Review of Dialysis Treatment Details Reports revealed the the following:
On 1/28/2023, there was no documentation of a post treatment assessment.

During an interview on February 8, 2023 at approximately 2:30 PM, the facility administrator confirmed the above findings.
















Plan of Correction:

The Facility Administrator or designee held mandatory in-service for all clinical teammates starting on 02/08/23. 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) Patient data will be obtained and documented by the patient care technician (PCT) or a licensed nurse. Data collection includes but is not necessarily limited to: i. Measurement of patient temperature; ii. Measurement of Blood Pressure (BP):
1. Sitting and standing BP measurement required pre and post treatment (if patient unable to stand, document reason in the patient electronic record or flow sheet) and 2. Intradialytic BP in the sitting/reclined or supine position; iii. Heart or pulse rate, noting also if the beat is regular or irregular; iv. Patient weight; v. Respiration rate; vi. Patient's report of well-being, level of pain or discomfort, complaints, hospitalization; vii. Vascular access status. 2) The PCT or Licensed nurse will obtain and document basic data on each patient post dialysis and compare to pre-dialysis findings. 3) If an abnormal finding or concern is identified post treatment, this needs to be communicated to the nurse. The licensed nurse will assess the patient prior to discharge. 4) Licensed nurse will use his/her clinical judgment based on individual patient needs to determine if any clinical interventions or notification of physician (or NPP as applicable) is necessary prior to discharge of the patient from the facility. Verification of attendance at in-service will be evidenced by teammates signature on in-service sheet.
The Facility Administrator or designee will conduct audits to verify treatment documentation reflects any abnormal findings or concern identified post treatment is reported to the nurse, with nurse assessing patient prior to discharge:
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. Instances of non-compliance will be addressed immediately.
The Facility Administrator or designee will review the audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assessment and Performance Improvement meetings known as Facility Health Meetings, with supporting documentation included in the meeting minutes. The Facility Administrator is responsible for compliance with this plan of correction.



494.90(a)(1) STANDARD
POC-ACHIEVE ADEQUATE CLEARANCE

Name - Component - 00
Achieve and sustain the prescribed dose of dialysis to meet a hemodialysis Kt/V of at least 1.2 and a peritoneal dialysis weekly Kt/V of at least 1.7 or meet an alternative equivalent professionally-accepted clinical practice standard for adequacy of dialysis.


Observations:


Based on review of facility policies/procedure, medical records (MR), and an interview with the facility administrator, the facility failed to ensure the blood flow rate (BFR) and/or the dialysate flow rate (DFR) was administered per physician order for seven (7) of ten (10) incenter hemodialysis patient medical records (MR) reviewed. (MR #1, 2, 3, 5, 6, 7, and 8); and the facility failed to provide documentation that a patient requested early treatment termination for four (4) of ten (10) incenter hemodialysis patient medical records (MR) reviewed, (MR #1, 2, 4, and 5).


Findings include:

A review of facility policy titled "Pre-Intra-Post Treatment Data Collection, Monitoring and Nursing Assessment" on February 8, 2023 at approximately 2:45 pm states, "Policy: 3. Patient identity, prescription and machine settings are verified by teammate prior to initiation of treatment with the exception of blood flow rate which is verified and documented when the ordered rate is obtained after onset of treatment...Prescription components include but are not necessarily limited to: f. Blood flow rate (BFR) g. Dialysate flow rate (DFR)...Intradialytic Date Collection/Assessment: 10. If the dialysis prescription is not being met (including DFR or change to/inability to obtain prescribed BFR) the reason will be documented and the licensed nurse informed..."

A review of facility policy titled "CWOW-Prescribed Treatment Time Not Met" on February 10, 2023 at approximately 9:00 am states, "Policy: A. Completion of the Early Termination of Treatment Against Medical Advice Form: 1. The RN will verify that a patient signs the Early Termination of Treatment Against Medical Advice form any time the patient requests to terminate their treatment earlier than the prescribed run time...3. The RN will obtain the patient ' s signature on the Early Termination of Treatment Against Medical Advice form prior to the patient being rinsed back from their treatment. If unable to obtain the patient ' s signature prior to rinse-back, the RN will obtain the patient ' s signature on the form prior to the patient ' s departure from the facility. 4. A RN must countersign all Early Termination of Treatment Against Medical Advice forms. A witness signature is required only if the patient refuses to sign the form. 5. If a patient refuses to sign the Early Termination of Treatment Against Medical Advice form, the RN will document the patient ' s refusal with the words " patient refused " in the patient signature box along with the date. Under such circumstances, the RN will sign the form and will also obtain a witness ' signature on the form... B. Prescribed Treatment Time Not Met: 1. If shortened/early termination of treatment time exceeds 30 or more minutes, the RN will notify the patient ' s attending nephrologist to discuss the appropriate intervention (if any), including what additional medical orders may be necessary to address the patient ' s specific needs..."

A review of patient medical records (MR) was completed on February 7, 2023 from approximately 9:00 am to 2:30 pm and on February 8, 2023 from approximately 8:40 am to 11:00 am.

MR #1: Admission Date: 12/19/2022. Dialysis order date: 1/4/2023. Frequency: Monday, Wednesday, and Friday; Target Weight: 111 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 37 HCO3, 137 NA; Treatment Duration: 210 minutes; BFR: 400; DFR: 600.

Review of Dialysis Treatment Details Reports revealed the BFR/DFR was not administered at prescribed rates on the following dates:
1/25/2023 between 1:46 pm and 4:33 pm, BFR was administered at 350 ml/hr and at 5:01 pm, BFR 300 ml/min; entire treatment DFR was administered at 500 ml/min.
1/27/2023 between 2:36 pm and 4:32 pm, BFR 345 ml/min and at 5:01 pm, BFR 300 ml/min; entire treatment DFR was administered at 500 ml/min.
1/30/2023 entire treatment DFR 500 ml/min.
2/1/2023 entire treatment DFR 500 ml/min.
2/3/2023 between 2:03 pm and 4:05 pm, BFR 200 ml/min and between 4:06 pm and 5:04 pm, BFR 350 ml/min; entire treatment DFR 500 ml/min.

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR/DFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the BFR/DFR was administered at a rate different from the prescribed amount for any of the above dates.

Review of Dialysis Treatment Details Reports revealed the patient requested early termination of treatment on the following dates:
1/27/2023 Treatment time 171 minutes, 39 minutes short
1/30/2023 Treatment time 170 minutes, 40 minutes short
There is no documentation of an Early Termination of Treatment Against Medical Advice form in the MR for either date.

MR #2: Admission Date: 2/15/2019. Dialysis order date: 1/24/2023. Frequency: Tuesday, Thursday, and Saturday; Target Weight: 76 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 136 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the BFR/DFR was not administered at prescribed rates on the following dates:
1/17/2023 between 3:41 pm and 4:32 pm, BFR 350 ml/min
1/28/2023 between 2:07 pm and 3:10 pm, DFR 800 ml/min

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR/DFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the BFR/DFR was administered at a rate different from the prescribed amount for any of the above dates.

MR #4: Admission Date: 3/16/2020. Dialysis order date: 10/2/2022. Frequency: Monday, Wednesday, and Friday; Target Weight: 79 Kg; Dialyzer: Optiflux F160NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 135 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the DFR was not administered at prescribed rates on the following dates:
1/27/2023 entire treatment, DFR 600 ml/min

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the DFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the DFR was administered at a rate different from the prescribed amount for any of the above dates.

Review of Dialysis Treatment Details Reports revealed the patient requested early termination of treatment on the following dates:
1/27/2023 Treatment time 135 minutes, short 45 minutes
2/1/2023 Treatment time 150 minutes, short 30 minutes
There is no documentation of an Early Termination of Treatment Against Medical Advice form in the MR for either date.

MR#5: Admission Date: 3/16/2020. Dialysis order date: 10/2/2022. Frequency: Monday, Wednesday, and Friday; Target Weight: 79 Kg; Dialyzer: Optiflux F160NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 135 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the BFR was not administered at prescribed rates on the following dates:
1/24/2023 between 3:33 pm and 4:03 pm, BFR 350 ml/min and between 4:33 pm and 5:03 pm, BFR 300 ml/min
1/26/2023 entire treatment, DFR 500 ml/min
2/2/2023 between 2:02 pm and 3:02 pm, BFR 350 ml/min; at 4:02 pm, BFR 335 ml/min; between 4:04 pm and 5:02 pm, BFR 350 ml/min
2/4/2023 1:24 pm BFR 200 ml/min; 1:30 pm BFR 0 ml/min; between 2:00 pm and 2:30 pm, BFR 250 ml/min; between 3:00 pm and 3:30 pm, BFR 0 ml/min; at 4:00 pm, BFR 200 ml/min; at 4:30 pm, BFR 0 ml/min.

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR/DFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the DFR was administered at a rate different from the prescribed amount for any of the above dates.

Review of Dialysis Treatment Details Reports revealed the patient requested early termination of treatment on the following dates:
1/24/2023 Treatment time 133 minutes, short 62 minutes
1/26/2023 Treatment time 164 minutes, short 31 minutes
2/4/2023 Treatment time 165 minutes, short 30 minutes
There is no documentation of an Early Termination of Treatment Against Medical Advice form in the MR for the above dates.

MR #6: Admission Date: 8/25/2022. Dialysis order date: 1/27/2023. Frequency: Tuesday, Thursday, and Saturday; Target Weight: 69.5 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 137 NA; Treatment Duration: 180 minutes; BFR: 400; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the BFR was not administered at prescribed rates on the following dates:
1/28/2023 entire treatment, BFR 300 ml/min
1/26/2023 at 10:32 am, BFR 310 ml/min and between 11:02 am and 12:32 pm, BFR 300 ml/min

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the BFR was administered at a rate different from the prescribed amount for any of the above dates.


MR#7: Admission Date: 10/7/2015. Dialysis order date: 12/23/2022. Frequency: Tuesday, Thursday, and Saturday; Target Weight: 69.5 Kg; Dialyzer: Optiflux F180NR; Dialysate: 2 K, 2.5 CA, 35 HCO3, 136 NA; Treatment Duration: 240 minutes; BFR: 450; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the BFR/DFR was not administered at prescribed rates on the following dates:
1/28/2023 between 11:30 am and 2:36 pm, DFR 700 ml/min
2/4/2023 between 11:02 am and 2:02 pm, BFR 400 ml/min and between 11:32 am and 2:22 pm, DFR 500 ml/min

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR/DFR to be administered at a rate different from the prescribed amount for any of the above dates and there was no documentation of a reason why the BFR/DFR was administered at a rate different from the prescribed amount for any of the above dates.

MR #8: Admission Date: 8/23/2022. Dialysis order date: 2/1/2023. Frequency: Tuesday, Thursday, and Saturday; Target Weight: 49 Kg; Dialyzer: Gambro Revaclear 300; Dialysate: 2 K, 2.5 CA, 35 HCO3, 136 NA; Treatment Duration: 195 minutes; BFR: 350; DFR: 500.

Review of Dialysis Treatment Details Reports revealed the BFR was not administered at prescribed rates on the following date:
2/2/2023 entire treatment, BFR 400 ml/min

There was no documentation in the medical record that the hemodialysis staff had obtained a physician order to allow the BFR to be administered at a rate different from the prescribed amount for the above date and there was no documentation of a reason why the BFR was administered at a rate different from the prescribed amount for any of the above date.

During an interview on February 8, 2023 at approximately 2:30 PM, the facility administrator confirmed the above findings.













Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 02/08023. 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" and Policy 1-01-09 "Prescribed Treatment Time Not Met" with emphasis on but not limited to: 1. Policy 1-03-08: 1) Patient identity, prescription and machine settings are verified by teammates prior to initiation of treatment. Prescription components include but are not necessarily limited to: ... Blood Flow rate and Dialysate flow rate ... 2) If the dialysis prescription is not being met [including dialysis flow rate or change to/inability to obtain prescribed blood flow rate] the reason will be documented and the licensed nurse informed.
2. Policy 1-01-09: 1) The Registered Nurse (RN) will verify that a patient signs the Early Termination of Treatment Against Medical Advice form any time the patient requests to terminate their treatment earlier than the prescribed run time. 2) The RN will obtain the patient's signature on the Early Termination of Treatment against Medical Advice form prior to the patient being rinsed back from their treatment. If unable to obtain the patient's signature prior to rinse-back, the RN will obtain the patient's signature on the form prior to the patient's departure from the facility. 3) A RN must countersign all Early Termination of Treatment against Medical Advice forms. A witness signature is required only if the patient refuses to sign the form. If a patient refuses to sign the Early Termination of Treatment against Medical Advice form, the RN will document the patient's refusal with the words "patient refused" in the patient signature box along with the date. Under such circumstances, the RN will sign the form and will also obtain a witness' signature on the form. 4) If shortened/early termination of treatment time exceeds 30 or more minutes, the RN will notify the patient's attending nephrologist to discuss the appropriate intervention (if any), including what additional medical orders may be necessary to address the patient's specific needs. 5) If a patient's treatment is shortened/early terminated, the RN will document the event in the patient's medical record... Verification of attendance at in-service will be evidenced by teammate's signature on in-service sheet.
The Facility Administrator or designee will conduct audits to verify teammate documentation of abnormal findings to the licensed nurse, and the appropriate response by the nurse to the findings: on twenty five percent (25%) of the flow sheets daily for two (2) weeks then weekly for two (2) weeks.
The Facility Administrator or designee will perform a one hundred percent (100%) daily review of run time report and compare with submitted AMA's by RNs, prior to filing in patient charts: daily for two (2) weeks, weekly for two (2) weeks. Ongoing compliance for both audits will be monitored with the monthly ten percent (10%) medical records audits. Instances of non-compliance will be addressed immediately.
The Facility Administrator or designee will review the audit results with teammates during homeroom meetings, and with the Medical Director during monthly Quality Assessment and Performance Improvement meetings known as Facility Health Meetings, with supporting documentation included in the meeting minutes. The Facility Administrator is responsible for compliance with this plan of correction.