QA Investigation Results

Pennsylvania Department of Health
MANHEIM PIKE DIALYSIS
Health Inspection Results
MANHEIM PIKE DIALYSIS
Health Inspection Results For:


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Initial Comments:


Based on the findings of an unannounced onsite Medicare recertification and addition of three (3) dialysis stations survey completed on April 19, 2021, Manheim Pike Dialysis was identified to be in compliance with the requirements of 42 CFR, Part 494.62, Subpart B, Conditions for Coverage for End-Stage Renal Disease (ESRD) Facilities-Emergency Preparedness.









Plan of Correction:




Initial Comments:


Based on the findings of an unannounced onsite Medicare recertification and addition of three (3) dialysis stations survey completed on April 19, 2021, Manheim Pike Dialysis was identified to have the following standard level deficiencies that were determined to be in substantial compliance with the requirements of 42 CFR, Part 494, Subparts A, B, C, and D: Conditions for Coverage for End-Stage Renal Disease Facilities.





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 review of facility policy/procedure, observations, and an interview with the facility Administrator, the facility failed to ensure the staff followed infection control protocols, included but not limited to, hand hygiene/don clean gloves, for two (2) of four (4) 'Discontinuation of Dialysis and Post Dialysis Access Care for AV Fistula or Graft' observations (Observation #1, Observation #4); two (2) of three (3) 'Cleaning and Disinfection of the Dialysis Station' observations (Observation #1, Observation #3); and two (2) of two (2) treatment area observations (Observation #1, Observation #2).

Findings include:

A review was conducted of facility policy/procedure on April 16, 2021, at approximately 11:00 a.m. Procedure: 1-03-12F 'Termination of Dialysis with all Single Use Dialyzer Types....." section #16 states "Disconnect venous blood line from venous access." Section #17 states "Discard gloves, perform hand hygiene and put on new gloves." Section #18 states "Perform post dialysis access care per procedure." Procedure: 1-04-01B 'Post Dialysis Vascular Access Care: Fistula/Graft Using Safety Needles' section #1 states "Perform hand hygiene. ......."

Observations conducted in patient treatment area on 04/13/21 between approximately 8:15 a.m. - 12:05 p.m. and on 04/14/21 at approximately 12:05 p.m. revealed the following:

Observation #1: During observation #1 of 'Discontinuation of Dialysis and Post Dialysis Access Care for AV Fistula or Graft' on 04/13/21 at approximately 9:15 a.m. of patient #16, station #3, EF (employee) #29 did not perform hand hygiene/don clean gloves after reinfusing the extracorporeal circuit/disconnecting bloodlines and before removing needles.

Observation #4: During observation #4 of 'Discontinuation of Dialysis and Post Dialysis Access Care for AV Fistula or Graft' on 04/13/21 at approximately 10:12 a.m. of patient #17, station #8, EF #29 did not perform hand hygiene/don clean gloves after reinfusing the extracorporeal circuit/disconnecting bloodlines and before removing needles.


Policy: 1-05-01 'Infection Control for Dialysis Facilities' 'Facility Hygiene' section #46 states "Equipment including the dialysis delivery system, the interior and exterior of the prime waste container, ....., will be wiped clean with a bleach solution .... after the completion of procedures, ......, and after each treatment." (Note: This Procedure does not follow CMS/CDC (Centers for Medicare and Medicaid Services/Centers for Disease Control and Prevention) recommended sequence which specifies "Remove all bloodlines and disposable equipment ...... Empty prime waste receptacle, if present on the machine. Remove gloves, hand hygiene, don clean gloves. Use disinfectant -soaked cloth to visibly wet all machine top, front, and side surfaces .....)"

Observation #1: During observation of 'Cleaning and Disinfection of the Dialysis Station' on 04/13/21 at approximately 9:40 a.m., of patient #16, Employee #29 at station #3 did not perform hand hygiene/don clean gloves after emptying the prime waste receptacle and before using a disinfectant soaked cloth to wipe down the dialysis machine. EF#29 emptied the prime waste receptacle after disinfecting the dialysis machine.

Observation #3: During observation of 'Cleaning and Disinfection of the Dialysis Station' on 04/13/21 at approximately 10:25 a.m., of patient #18, Employee #6 at station #10 did not perform hand hygiene/don clean gloves after emptying the prime waste receptacle and before using a disinfectant soaked cloth to wipe down the dialysis machine. EF#6 emptied the prime waste receptacle after starting to disinfect the dialysis machine.


Policy: 1-05-01 'Infection Control for Dialysis Facilities' 'Teammate Hygiene' section #1 states "Hand hygiene is to be performed upon entering the patient treatment area, ....., and on exiting the patient treatment area."

Observation #1: During observations in the treatment area on 04/13/21 at approximately 10:15 a.m., Employee #4 did not perform hand hygiene after removing her gown and before exiting the treatment area into the front receptionist office area.

Observation #2: During observations in the treatment area on 04/13/21 at approximately 10:20 a.m., Employee #5 did not perform hand hygiene after removing her gown and before exiting the treatment area into the front receptionist office area.


An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.

















Plan of Correction:

V 0113
The Facility Administrator (FA) or designee will educate all clinical teammates on: 1) policy 1-03-12F Termination of Dialysis with Single Use Dialyzer Types specifically steps 16-18 focusing on changing of gloves and hand hygiene between disconnection of patient post treatment and prior to removing needles. 2) Policy 1-05-01 Infection Control for Dialysis Facilities with emphasis on equipment including the dialysis delivery system, the interior and exterior of the prime waste container will be wiped clean with a bleach solution after the completion of procedures and after each treatment. TMs were instructed to empty the prime waste container, return it on the machine, remove gloves, perform hand hygiene, don clean gloves and proceed to disinfect the equipment within the patient station. In addition, hand hygiene is to be performed upon entering the patient treatment area and on exiting the patient treatment area. Verification of attendance will be evidenced by teammate signature on in-service sheet. The FA or designee is audit daily for five (5) days then weekly for four (4) weeks then monthly during internal infection control audits to verify compliance. The results of the audits will be reviewed with the teammates during homeroom meeting and with the Medical Director at Facility Health Meetings (FHM-QAPI) with the supporting documentation included in the meeting minutes. The Fa is responsible for compliance with this plan of correction.



494.30(a)(1)(i) STANDARD
IC-IF TO STATION=DISP/DEDICATE OR DISINFECT

Name - Component - 00
Items taken into the dialysis station should either be disposed of, dedicated for use only on a single patient, or cleaned and disinfected before being taken to a common clean area or used on another patient.
-- Nondisposable items that cannot be cleaned and disinfected (e.g., adhesive tape, cloth covered blood pressure cuffs) should be dedicated for use only on a single patient.
-- Unused medications (including multiple dose vials containing diluents) or supplies (syringes, alcohol swabs, etc.) taken to the patient's station should be used only for that patient and should not be returned to a common clean area or used on other patients.



Observations:


Based on review of facility policy/procedure, observations, and an interview with the facility Administrator, the facility failed to ensure the staff followed infection control protocols, included but not limited to, disinfecting non-disposable items before being used on another patient, for one (1) of one (1) treatment area observations (Observation #1).

Findings include:

A review was conducted of facility policy/procedure on April 16, 2021, at approximately 11:00 a.m. Policy: 1-05-01 'Infection Control for Dialysis Facilities' 'Teammate Patient/ Safety' section #25 states "Non-disposable items are to be disinfected between patients."

Observations conducted in patient treatment area on 04/13/21 between approximately 8:15 a.m. - 12:05 p.m. and on 04/14/21 at approximately 12:05 p.m. revealed the following:

Observation #1: During treatment area observations on 04/13/21 at approximately 10:20 a.m., station #7, patient #23, employee #4 was observed leaving station #7 and walking to station #11 where patient #20 was being treated. Employee #7 obtained a blood pressure cuff from station #11 and returned to station #7. Employee #4 did not disinfect the blood pressure cuff prior to using on patient #23.


An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.













Plan of Correction:

V 0116
The FA or designee will educate all clinical teammates on policy 1-05-01 Infection Control for Dialysis Facilities specifically steps 46 all work surfaces and non-disposable equipment including blood pressure cuffs will be wiped clean with a bleach solution of the appropriate strength before being used on another patient. Verification of attendance will be evidenced by teammate signature on in-service sheet. The FA or designee will audit daily for five (5) days then weekly for four (4) weeks then monthly during internal infection control audits to verify compliance. The results of the audits will be reviewed with the teammates during homeroom meeting and with the Medical Director at FHM-QAPI with the supporting documentation included in the meeting minutes. The Fa is responsible for compliance with this plan of correction.



494.40(a) STANDARD
DIALYS PROPORT-MONITOR PH/CONDUCTIVITY

Name - Component - 00
5.6 Dialysate proportioning: monitor pH/conductivity
It is necessary for the operator to follow the manufacturer's instructions regarding dialysate conductivity and to measure approximate pH with an independent method before starting the treatment of the next patient.




Observations:


Based on reviews of facility policy, manufacturer recommendations, observations, and an interview with the facility Administrator, the facility failed to ensure the staff followed infection control protocols which include, but not limited to, following the manufacturers recommendations for use of the phoenix meter for four (4) of four (4) observations of the 'Preparation of the Hemodialysis Machine/Extracorporeal Circuit' (Observation #1-4).


Findings include:

A review was conducted of facility policy on 04/19/21 at approximately 1:30 p.m. Procedure: 2-08-01G 'Measuring Conductivity, Temperature and/or pH Using the Phoenix Conductivity Meter' 'Procedure' section #6 states "Rinse the cell and syringe interior by drawing dialysis quality water throught the cell filling the syringe. Expel and discard the water (The Phoenix meter should be rinsed free of dialysate between uses)." Section #8 states "When you are finished with the Phoenix Meter, RINSE interior thoroughly with dialysate quality water."

A review of manufacturer's recommendations for use of the phoenix meter was conducted on 04/19/21 at approximately 4:00 p.m. Section 'Taking Measurements' step #(4) states "Rinse the cell, syringe interior, and sampling cup/tube thoroughly with RO (reverse osmosis) water after use."

Observations conducted in patient treatment area on 04/13/21 between approximately 8:15 a.m. - 12:05 p.m. and on 04/14/21 at approximately 12:05 p.m. revealed the following:

Observation #1: On 04/13/21 at approximately 8:15 a.m., employee #6 was observed using the phoenix meter to check for conductivity and pH for station #9, for the dialysis treatment of patient #19. After using the phoenix meter, employee #6 failed to rinse the meter with treated (RO) water.

Observation #2: On 04/13/21 at approximately 8:20 a.m., employee #6 was observed using the phoenix meter to check for conductivity and pH for station #11, for the dialysis treatment of patient #20. After using the phoenix meter, employee #6 failed to rinse the meter with treated (RO) water.

Observation #3: On 04/13/21 at approximately 10:37 a.m., employee #4 was observed using the phoenix meter to check for conductivity and pH for station #7, for the dialysis treatment of patient #21. After using the phoenix meter, employee #4 failed to rinse the meter with treated (RO) water.

Observation #4: On 04/13/21 at approximately 10:45 a.m., employee #5 was observed using the phoenix meter to check for conductivity and pH for station #2, for the dialysis treatment of patient #22. After using the phoenix meter, employee #5 failed to rinse the meter with treated (RO) water.

An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.














Plan of Correction:

V0250
The FA or designee will educate all clinical teammates on policy 2-08-01G Measuring conductivity, Temperature and/or pH using the Phoenix Conductivity meter specifically step 8, when finished with the Phoenix meter, Rinse interior thoroughly with dialysis quality water and clean exterior of meter with 1:100 bleach solution before taking to a common clean area or used in another station. Verification of attendance will be evidence by teammate signature on in-service sheet. The FA or designee will audit daily for five (5) days then weekly for four (4) weeks then monthly during internal infection control audits to verify compliance. The results of the audits will be reviewed with the teammates during homeroom meeting and with the Medical Director at FHM-QAPI with the supporting documentation included in the meeting minutes. The Fa is responsible for compliance with this plan of correction.



494.100(b)(2),(3) STANDARD
H-FAC RECEIVE/REVIEW PT RECORDS Q 2 MONTHS

Name - Component - 00
The dialysis facility must -
(2) Retrieve and review complete self-monitoring data and other information from self-care patients or their designated caregiver(s) at least every 2 months; and
(3) Maintain this information in the patient ' s medical record.


Observations:


Based on review of facility policy, review of medical records, and an interview with facility Administrator, the facility failed to ensure, during treatment record patient flow sheet reviews, that patients are following their treatment plans and/or having problems with their dialysis at home for three (3) of five (5) peritoneal dialysis (PD) patient medical records (MRs) reviewed (MR#12, MR#14, MR#15).

Findings:

A review was conducted of facility policy on 04/19/21 at approximately 1:30 p.m.
PD Policy: 5-01-29 'Daily Home Treatment Record' 'Purpose' states "To provide guidance for proper documentation of home peritoneal dialysis treatments and to collect data needed to assess the patients response to peritoneal dialysis treatments".
Section #1 states "Each peritoneal dialysis patient will be instructed to complete documentation of each treatment procedure on the Daily Home Treatment Record , also referred to as a flowsheet."
Section #3 states "Each patient and /or home care partner will complete training regarding treatment data collection. As clinically appropriate, all treatment data outlined on the Daily Home Treatment Record sheet must be collected."
Section #4 states "Electronic data cards are not a replacement for Daily Home Treatment Records as these do not allow for comprehensive entry of all treatment related data and do not allow for patients to view treatment data trends."
Section #7 states "Home training teammate will review completed Daily Home Treatment Records to assist in evaluating the patients progress and self care decision making progress."


Review of medical records conducted on 04/13/21 between approximately 9:00 a.m. - 3:00 p.m. revealed the following:

MR#12 Date of admission 04/23/18: Patient Peritoneal Dialysis Treatment orders dated 05/05/19 with 'Schedule' "Su-Mo-Tu-We-Th-Fr-Sa". Daily Home Treatment Records reviewed from 12/28/20-03/10/21. Last documented registered nurse review of patient self monitoring data was dated 02/17/21 and 03/10/21.
On 01/20/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 02/05/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Pulse' and 'Blood Pressure' sections left blank with no entries.
On 03/01/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' 'Pulse' and 'Blood Pressure' sections left blank with no entries.
On 03/06/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' 'Pulse' and 'Blood Pressure' sections left blank with no entries.

No documentation provided of registered nurse providing education to reinforce previously instructed information.

MR#14 Date of admission 02/09/15: Patient Peritoneal Dialysis Treatment orders dated 11/15/19 with 'Schedule' "Su-Mo-Tu-We-Th-Fr-Sa". Daily Home Treatment Records reviewed from 01/01/21-04/14/21. Last documented registered nurse review of patient self monitoring data was dated 01/15/21, 02/01/21, 03/25/21, and 04/14/21.
On 01/10/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 03/15/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Pulse' and 'Blood Pressure' sections left blank with no entries.
On 03/21/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 04/05/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 04/21/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 04/14/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.

No documentation provided of registered nurse providing education to reinforce previously instructed information.

MR#15 Date of admission 06/26/19: Patient Peritoneal Dialysis Treatment orders dated 03/08/21 with 'Schedule' "Su-Mo-Tu-We-Th-Fr-Sa". Daily Home Treatment Records reviewed from 01/09/21-04/07/21. Last documented registered nurse review of patient self monitoring data was dated 02/17/21, 03/08/21, and 04/13/21.
On 01/16/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' section left blank with no entries.
On 02/06/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' section left blank with no entries.
On 02/10/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Blood Pressure' section left blank with no entries.
On 02/18/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' section left blank with no entries.
On 02/21/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' section left blank with no entries.
On 03/05/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' section left blank with no entries.
On 03/07/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 03/25/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Dextrose Concentration' section left blank with no entries.
On 03/26/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' and 'Dextrose Concentration' section left blank with no entries.
On 04/02/21 the Daily Treatment Home Record shows incomplete patient entries with the 'Weight' and 'Dextrose Concentration' section left blank with no entries.

No documentation provided of registered nurse providing education to reinforce previously instructed information.

An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.

















Plan of Correction:

V 0587
The FA or designee will educate all Peritoneal Dialysis (PD) clinical teammates on policy 5-01-29 Daily Home Treatment Record with emphasis on steps 1, 3, 4, and 7 concentrating on completeness of documentation for all treatments performed, nurse review of flowsheet documentation, and follow-up documentation in the medical record to include education provided to reinforce previously instructed information. Verification of attendance will be evidenced by teammate signature on in-service sheet. The FA or designee will audit ten percent (10%) of medical records monthly to verify compliance. The audit results will be reviewed with the PD teammates and with the Medical Director at FHM-QAPI with supporting documentation included in the meeting minutes. The FA is responsible for compliance with the plan of correction.



494.100(c)(1)(i) STANDARD
H-MONITOR HOME ADAPT;HOME VISIT=POC

Name - Component - 00
Services include, but are not limited to, the following:
(i) Periodic monitoring of the patient's home adaptation, including visits to the patient's home by facility personnel in accordance with the patient's plan of care.





Observations:


Based on review of facility policy, review of medical records, and an interview with the facility Administrator, the facility failed to ensure a home visit was conducted at the skilled nursing home facility upon patient admit for two (2) of two (2) medical records reviews (MR#14, MR#15).

Findings include:

A review was conducted of facility policy/procedure on April 16, 2021, at approximately 11:00 a.m. Policy: 5-16-01 'Peritoneal Dialysis (PD) Services Rendered in Skilled Nursing Facilities' 'Purpose' states "To provide compliance guidance in administering peritoneal dialysis (PD) to patients residing in Skilled Nursing Home Facilities (SNFs)."'Policy' section (9) states "As with all Home patients, CMS guidelines require a preliminary "Home Visit" to occur upon a patient being admitted to the SNF. A PD RN (registered nurse) must visit SNF and complete home visit for each patient admitted."

Review of medical records conducted on 04/13/21 between approximately 9:00 a.m. - 3:00 p.m. revealed the following:

MR#14, Date of admission 02/09/15: No documentation provided of Davita staff conducting a home visit (at the SNF) upon admission.

MR#15, Date of admission 06/26/19: No documentation provided of Davita staff conducting a home visit (at the SNF) upon admission.


An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.







Plan of Correction:

V 0589
The FA or designee will educate all PD clinical teammates on policy 5-16-01 Peritoneal Dialysis Services in Skilled Nursing Facilities (SNF) specifically step 9, a Peritoneal Dialysis Registered Nurse must visit the SNF to complete a preliminary home visit upon patient being admitted to a SNF. Verification of attendance will be evidenced by teammate signature on in-service sheet. The FA or designee will audit the next five (5) SNF patient admissions for compliance then ten percent (10%) of the medical records during monthly medical records audits. The audit results will be reviewed with the PD teammates and with the Medical Director at FHM-QAPI with supporting documentation included in the meeting minutes. The FA is responsible for compliance with the plan of correction.




494.150(c)(2)(i) STANDARD
MD RESP-ENSURE ALL ADHERE TO P&P

Name - Component - 00
The medical director must-
(2) Ensure that-
(i) All policies and procedures relative to patient admissions, patient care, infection control, and safety are adhered to by all individuals who treat patients in the facility, including attending physicians and nonphysician providers;



Observations:


Based on review of facility policy, review of medical records, and an interview with the facility Administrator, the facility failed to ensure newly admitted peritoneal dialysis (PD) patients had a minimal evaluation completed by a registered nurse (RN), prior to initiating treatment for immediate needs, which contained the minimal elements of nursing standards of care for new dialysis patients for four (4) of four (4) medical records reviewed (MR#2, MR#5, MR#11, MR#15); failed to ensure long term care facility (LTC) staff were trained initially and ongoing by Davita staff for two (2) of two (2) LTC facility training documentation reviewed (Review #1-#2).


Findings include:

A review was conducted of facility policy/procedure on April 16, 2021, at approximately 11:00 a.m. and on April 19, 2021 at approximately 1:30 p.m. Policy 1-03-07 'New Patient pre-Treatment Evaluation' 'Policy' section 1 states : "A registered nurse (RN) as required by federal regulation will perform an initial pre-treatment evaluation of all new patients prior to the initiation of their first treatment at the facility". Section 4 states "This pre-treatment evaluation will be documented on the 1-03-07A New Patient Pre-Treatment Initial Nurse Assessment 0910 rev0418."

Policy: 5-02-28 'New Patient Pre-Treatment Evaluation' 'Policy' section #1 states "A registered nurse (RN) as required by federal regulation will perform an initial pre-treatment evaluation of all new peritoneal dialysis (PD) patients prior to the initiation of their first treatment/training at the facility."

Review of medical records conducted on 04/13/21 between approximately 9:00 a.m. - 3:00 p.m. revealed the following:

MR#2 Date of admission 12/31/20: Patient flow sheet dated 12/31/20 reveals patients initial dialysis treatment. Patient treatment began at 4:16 p.m. Documentation provided of registered nurse performing initial assessment at 7:00 p.m. (2 hours forty-four minutes after dialysis initiation).

MR#5 Date of admission 03/18/21: Patient flow sheet dated 03/18/21 reveals patients initial dialysis treatment. Patient treatment began at 4:18 p.m. Documentation provided of registered nurse performing initial assessment at 7:30 p.m. (3 hours twelve minutes after dialysis initiation).

MR#11, Date of admission 12/10/18: Documentation provided of nursing pre-treatment evaluation completed on 12/10/18 at 7:30 a.m. by a registered nurse. Documentation provided of a training date form dated 12/10/18. There was no time stamp on this form to show that the treatment began after the RN pre-treatment evaluation.

MR#15, Date of admission 06/26/19: Documentation provided of nursing pre-treatment evaluation completed on 06/26/19 at 8:00 a.m. by a registered nurse. No documentation provided of when treatment began to show that the treatment began after the RN pre-treatment evaluation.


Policy: 5-16-01 'Peritoneal Dialysis Services Rendered in Skilled Nursing Facilities' 'Purpose' states "To provide compliance guidance in administering peritoneal dialysis (PD) to patients residing in Skilled Nursing Home Facilities (SNFs)."'Policy' Section (10) states "Davita will provide initial and ongoing training to SNF licensed nurses (RNs or LPNs (licensed practical nurse) ....) who are designated as Davita Trained Caregiver or Care Partners for the purpose of dialysis treatment oversight. Only Davita Trained Caregivers or Care Partners who have completed Davitas training program may be involved in the dialysis care of patients."

Review #1: A review of LTC facility #1 documentation was conducted 04/16/21 at approximately 9:00 a.m.
The 'PD Coordination Agreement' signed on 08/28/17 section (L) states "Company (Davita) will provide training to PD patient and to the designated Licensed caregivers (defined below) concerning the PD treatment methodology. ..... The training will be consistent with the training the company provides to home dialysis patients and/or caregivers of home dialysis patients who reside in non-institutional settings. .....If there are changes to the persons designated as the Licensed Caregivers, Company will provide training before such replacement Licensed Caregivers begin providing services as the PD patients caregiver."

A list was requested of LTC facility staff who have/or are currently providing dialysis treatments MR#15. The list contained eighteen (18) licensed nurses. Documentation provided of in-services being conducted by Davita staff on 01/29/20 and 03/18/21. Ten (10) nurses from the list are included in these two in-services. No documentation provided of the other eight (8) LTC facility staff nurses being trained initially nor ongoing by Davita, per Davita policy and/or the written coordination agreement between Davita and the LTC facility.


Review #2: A review of LTC facility #2 documentation was conducted 04/16/21 at approximately 9:00 a.m.
The 'PD Coordination Agreement' signed on 08/26/13 section (K) states "Company (Davita) will provide training to PD patient and to the designated Licensed caregivers (defined below) concerning the PD treatment methodology. ..... The training will be consistent with the training the company provides to home dialysis patients and/or caregivers of home dialysis patients who reside in non-institutional settings. .....If there are changes to the persons designated as the Licensed Caregivers, Company will provide training before such replacement Licensed Caregivers begin providing services as the PD patients caregiver."

A list was requested of LTC facility staff who have/or are currently providing dialysis treatments MR#14. The list contained ten (10) licensed nurses. Documentation provided of in-services being conducted by Davita staff on 10/29/20. Five (5) nurses from the list are included in this in-service. No documentation provided of the other five (5) LTC facility staff nurses being trained initially nor ongoing by Davita, per Davita policy and/or the written coordination agreement between Davita and the LTC facility.


An interview with the facility Administrator on April 16, 2021 at approximately 3:45 p.m. confirmed the above findings.























Plan of Correction:

V 0715
The FA or designee will educate all PD clinical teammates on: 1) policy 5-02-28 New Patient Pre-Treatment Evaluation 5-02-28A New PD Patient Pre-Treatment Initial Nurse Assessment with emphasis on steps 1 and 4, initial pre-treatment evaluation of all new patients must be completed prior to initiation of first treatment/training in the facility and documented on the New PD Patient Pre-Treatment Initial Nurse Assessment form. 2) Policy 5-16-01 Peritoneal Dialysis Services Rendered in Skilled Nursing Facilities with focus to provide compliance guidance in administering PD to patients residing in SNF. DaVita will provide initial and ongoing training to SNF licensed nurses who are designated as DaVita Trained Caregiver or Care Partners for the purpose of dialysis treatment oversight. Only DaVita Trained Caregivers or Care Partners who have completed DaVita's training program may be involved in the dialysis care of patients. Verification of attendance will be evidenced by teammate signature on in-service sheet. The patient training treatment record used during treatment/training in the facility will be updated to include a data field to record treatment start time. The FA will meet with the administrators of SNF facilities where PD patients receive PD treatments to review contract expectations related to initial and ongoing training and develop a plan to ensure ongoing training needs are communicated to DaVita. Training will be completed to ensure all nurses providing care in a SNF are trained by DaVita with competencies verified and documented. The FA or designee will audit all new PD patient admissions medical records monthly for three (3) months to verify the New PD Patient Pre-Treatment Nursing Assessment is completed prior to the initiation of treatment/training. In addition, the FA or designee will audit SNF PD patient flowsheets weekly for four (4) weeks and monthly for three (3) months to verify only trained SNF staff perform peritoneal dialysis treatments for patients as evidenced by signature on flow sheet. The results of the audits will be reviewed with the PD teammates and with the Medical Director at FHM-QAPI with supporting documentation included in the meeting minutes. The FA is responsible for compliance with this plan of correction.