QA Investigation Results

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

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Initial Comments:

Based on the findings of an unannounced onsite complaint investigation conducted on May 4, 2021 and off-site on May 5, 2021 and May 10, 2021, ASO Home Health Agency, 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:

611.57(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.


Based on a review of agency documentation, consumer files, and an interview with the director and administrator, the agency failed to ensure services were provided according service agreement for one (1) of three (3) consumer files (CF) reviewed. (CF #2).

Findings include:

Review of consumer files (CF) was conducted on 5/4/2021 at approximately 12:53PM revealed:

CF2 - (Start of Care): 1/31/2020 - Consumer receives Personal Assistance Services (PAS) in her home Sunday through Saturday (8 hours/day x 7 days/week). Consumer Care Plan includes bathing, assist with ADL's, toileting, assist with transfers/ambulation (wheelchair), medication reminder, meal prep, light housekeeping, laundry, and grocery shopping.

Review of timesheets and daily activity reports on 5/4/2021 at approximately 11:43AM for the timeframe of 4/1/2021 - 4/30/2021, showed two (2) days when caregiver services were provided late for CF2. On 4/6/2021 and 4/13/2021, services were provided for 6.5 hours each day, instead of 8 hours each day as scheduled. Timesheets showed CF2 did not receive caregiver services for 1.5 hours on 4/6/2021 and 1.5 hours on 4/13/2021. Although agency has a back-up plan policy and procedure in place, documentation reviewed did not indicate whether the back-up plan was activated during these two (2) days. There was no documentation of communication between agency and CF2 when staff reported to work late.

Interview with director on 5/4/2021 at approximately 12:45PM, confirmed the above findings.

Plan of Correction:

ASO Home Health Agency

Deficiency Listing

Plan of Correction:

In Accordance with the Corrective Action Plan (CAP), ASO- Home Health Agency has developed action steps in addressing Consumer Rights. These action steps were effective on June 15, 2021, across all levels of the agency staff.

In compliance with the CAP, all administrative staff as well as caregivers, received a comprehensive re-education and updated policies training on June 16, 2021, to June 18, 2021. In addition to the training, all staff received hand-outs on all topics of the training.

Here's the following steps that has been taken after observation from assessor.

The following has been completed:

o Zero Tolerance Policy

 All employees must call the American Safety Options, Inc. on-call at 484-764-5738 when they are unable to fulfill a previously scheduled caregiver shift with our members. A minimum of 24 hours notice is required.

 If you have accepted a scheduled assignment, you are expected to be there on time, with your badge on and folder.

 If an emergency arises (which will need documentation), you must speak with your assigned supervisor or on-call contact ASAP. DO NOT LEAVE UNTIL COVERAGE IS ON SITE.

 Both the Member and ASO are depending on you to live up to your commitment.

American Safety Options has a ZERO TOLERANCE POLICY, when it comes to "No Call. No Show". This means that anyone who does not show up to a scheduled shift and has not called his/her supervisor of contact within 24 hours is subject to immediate termination.

o Documents & Record-Keeping (Timesheets)

Caregivers keep a weekly timesheet with hours worked for Medicaid billing. Timesheets are legal documents that track actual hours worked and services provided. Timesheets should reflect the task and hours of services provided. Also, timesheets should reflect the task and hours authorized on HHAeXchange and include:

Caregiver Timesheet Policy

 Caregiver must record all days of the week, dates, and times worked on their timesheet.
 Caregiver must electronically clock in and out (start and stop times) of service provided.
 Caregiver must document on notes of any change in Member's condition.
 Caregiver must provide on timesheet legal signature from supervisor/caregiver/Consumer/or PR with dates.
 All entries must be made in blue or black ink and be clearly legible.
 Correction can be made by drawing a single line through the mistake, entering the correct information nearby, and having both the caregiver and the Member/PR initial by the change.
 Performing work without recording your time is prohibited. An employee may never work "off the clock", regardless on or off American Safety Options premises.
 Caregivers may not leave work early before scheduled time without prior permission from supervisor and/or back-up coverage for remaining hours of their scheduled shift.

Timesheets should be given to the Member for signature every week. Timesheets must be sent by mail or faxed weekly to American Safety Options, Inc. main office located 5104 Township Line Road, Drexel Hill, Pa 19026 by midnight every Monday.

All Employees Timesheet Policy

 No supervisor or manager may require, encourage or even suggest that an employee perform any work "off the clock." If a supervisor or manager requires, encourage or even suggests that you work "off the clock", use the complaint procedure below immediately.

 Employees may not begin working before their scheduled starting time without prior permission from their supervisor. Non-exempt employees must log in immediately before doing any work.

 Employees may not work after their scheduled stop time without prior permission from their supervisor. Non-exempt employees must log out immediately after stopping work.

 Employees will be paid for all hours worked. If you do any work outside of your expected hours of work (before recording time started or after ending expected hours of work), please notify your supervisor immediately so that you can be properly paid.

 If you do any unauthorized work before your start time, during your meal break, after your stop time or at any other time, you will be paid for such time. However, you will be subject to corrective counseling for working such additional time without authorization.

American Safety Options prohibit documenting inaccurate recording hours on timesheets. This means if found that hours were falsely documented you will be automatically terminated. If our member refuses to sign the timesheet, you will need to contact the main office to receive further instruction. American Safety Options will not accept timesheets without member and scheduler signatures before being properly paid.

o Attendance Report Policy

Each employee is granted 6 lateness within a fiscal year. Employees will automatically start a new slate where lateness will not roll-over to the next fiscal year. If you expect to be late for work or are unable to report because of illness or other unavoidable cause, you personally must call your immediate supervisor. As call-in procedures may differ by home/group, you must follow the procedure established for your department or service provided home. Generally, caregiver must contact their supervisor 6 hours prior to the start of their scheduled shift if calling out. Caregiver must give notice as soon after the start of their workday as possible, but no later than one (1) hour prior to their scheduled shift. Allowances can be made for an unscheduled personal emergency at the discretion of your supervisor so that an absence may be considered as "Scheduled."

Procedure If Late for Scheduled Shift

 All employees are given a 7 minutes grace period from their scheduled shift start time. This time is allotted for the employee to put personal belongings away prior to shift start time. This time cannot be used for additional lateness.

 If you are going to be late by more than 7 minutes, you must call your supervisor and notify them of the expected length of delay.

 If you cannot reach the supervisor directly, follow the call out procedure for your assignment home. Continue to call your supervisor and On-Call Phone until you verbally talk to someone.

 It is not sufficient to leave a voice-mail message, to send an email, or text message or a message with the receptionist or a co-worker about lateness/call-out.

 Failure to speak to a live-person (supervisor/manager) or receive a verbal response back from them will result in disciplinary action.

 For unplanned absences, you are required to report the reason for your absence. If your absence continues for more than (1) day, you are required to contact your supervisor on a day-to-day basis until the probable duration of your absence is established.

 Your supervisor, at his or her discretion, may require documentation for any day of absence but if you are absent for three (3) or more consecutive workdays, when you return to work, you must present a doctor's note or other relevant documentation explaining the absence.

 Your supervisor is unable to allow paid leave benefits until such documentation is provided and approved.

 Your absence from work for a period of two (2) consecutively- scheduled working days without reporting constitutes an abandonment of your employment with us and is considered to be your voluntary resignation from our employer.

Medicaid Fraud

What is fraud?
What can happen to me if I commit fraud?
How do I report suspected fraud?

The money for Consumer's (a Member) services in the program comes from state and federal governments. Fraud or abuse of this Medicaid program is against the law. If a Consumer, caregiver or Consumer Direct is suspected of Medicaid fraud or abuse, it must be reported.

Examples of Consumer or caregiver fraud and abuse of Medicaid funds are:

 Writing down more time than actually worked on a timesheet

 Accepting pay for time you did not work

 "Padding" time sheets...such as showing up late or leaving early and writing down more time than actually worked, or taking a break time when you write down time

 Stating that task or procedure were completed when you did not do them

 Changing another person's timesheet or paperwork

 Forging other caregiver's or Consumer's signature

 Turning in a false claim for time worked or tasks completed when these were not done and you knew it

 Suggesting or helping a Consumer get services or supplies that are not required for the person's disability

 Not following all parts of the contract with Consumer Direct

 Not providing the quality of services for a Consumer that is expected

If you think a Consumer, caregiver or staff person is doing that is fraud, please call Consumer Direct right away. If you are worried that the Program Director is not dealing with the problem correctly, please call a Consumer Direct Vice President or President immediately.

Examples of fraud could be done by Consumer Direct are:

 Not keeping necessary records

 Not giving records to the Department that is investigating possible fraud

 Not providing the quality of services for a Consumer that is expected

 Turning in false application to become a provider

 Accepting a fee or getting money back in exchange for referring a Consumer

 Charging a Consumer more than Medicaid paid and keeping the difference

 Not meeting federal or state licensure or certification requirements but providing services anyway.

Read More: Federal False Claim Act
If you think Consumer Direct has done any of these things, please call the managed care agency or state agency. Penalties may be enforced against Consumer Direct if they do any of the things above.

If you give false information or know of false information and fail to report it, you could be convicted of a crime. You might have to pay large fines, go to jail for up to a year, and lose your job.

No-Call/No-Show Back Up Plan Policy

As of June 15, 2021, American Safety Options requires the On-Call Administrative Staff to create each member backup plan that is known as Emergency and Backup Plan. This will be placed in each member's home and in ASO database to respond to member's caregiver unplanned scheduled changes before the impacted shifts.

The Emergency & Backup Plan

 Is in writing and signed by both member and assigned caregiver.

 Must be completed prior to the start of service.

 Updated, at minimum every 60 days, at each home visit.
 Unapproved overtime is not a viable backup plan.

 Emergency numbers will be posted with who to call if a problem arises in member's home.

 It is the responsibility of American Safety Options agency to ensure that MCO are not wrongfully billed in a case of No-Call/No-Show scheduled shifts.

 We are responsible to ensure the process of No-Call/No-Show procedure is followed as:

No-Call/No Show Plan

 Inform the member/caregiver of missed visit as soon as you are aware of scheduled caregiver being absent.

 Use PRN staff list to search for the shift to be covered before calling the family.

 Call the family as soon as possible if no staff is available.

 Complete the agency "ASO Missed Visit Action Report" and submit a copy in the member's and caregiver's charts.

 Complete the next business day ASO Corrective Counseling Report & Action Steps form with supervisor/ manger and caregiver. This form must be documented and submitted to member's home to inform them with the solution to No-Call/ No-Show incident.

 Create a new schedule with appropriate caregiver to assist with quality of care and Proper Home Care training. This scheduled will be updated within 1 week of the incident and mailed to Member's home.

 Report shifts to the MCO within three (3) calendar days or as soon as the agency is aware.

 Report all missed shifts by faxing the Home Health Action Report (missed Visit form).

 Call MCO staff if there is a safety concern.

 Notify MCO Case Management and fax information to the MCO office if the services of ASO staff are declined for reasons other than quality of care, such as: discrimination/ prejudice based on race, age, gender, size, color of hair, national origin or staff will not do work that is not part of their job.

All staff that are currently working with our Members will be provided with updated Plans. Administrative staffs are trainedto follow the procedures for No-Call/ No-Show and ensure that our Consumers (Members ) are not left alone with no plan for quality care.