QA Investigation Results

Pennsylvania Department of Health
NEW KENSINGTON DIALYSIS
Health Inspection Results
NEW KENSINGTON DIALYSIS
Health Inspection Results For:


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Initial Comments:


Based on the findings of an onsite unannounced Medicare recertification survey completed on December 21, 2022, New Kensington Dialysis, was found to be in compliance with the requirements of 42 CFR, Part 494.62, Subpart B, Conditions for Coverage of Suppliers of End-Stage Renal Disease (ESRD) Services-Emergency Preparedness.













Plan of Correction:




Initial Comments:


Based on the findings of an onsite unannounced Medicare recertification survey completed on December 21, 2022, New Kensington Dialysis, was found to have the following deficiencies and to be in substantial compliance with the 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 reviews of facility policy, observations, and staff (EMP) interview, the facility failed to ensure hand hygiene was performed by patients who held access sites for three (3) of three (3) observations of Discontinuation of Dialysis and Post Dialysis Access Care for AV Fistula or Graft. (OBS 1-3.)


Findings included:


Review of facility policy on 12/21/2022 at approximately 3:30pm revealed: "...POST DIALYSIS VASULAR ACCESS CARE: FISTULA/GRAFT USING SAFETY FISTULA NEEDLES...Procedure...9. the patient will be encouraged to hold their own site if their condition permits. When the patient holds their cannulation sites, the patient will be offered gloves and perform hand hygiene when completed..."


OBS #1, conducted 12/19/2022 at approximately 10:30am, upon completion of dialysis treatment at station 2, patient held pressure to both access sites independently. Patient failed to perform hand hygiene after holding sites and before exiting treatment floor.

OBS #2, conducted 12/21/2022 at approximately 10:30am, upon completion of dialysis treatment at station 1, patient held pressure to both access sites independently. Patient did not perform hand hygiene after holding sites and before exiting treatment floor.

OBS #3, conducted 12/21/2022 at approximately 11:00am, upon completion of dialysis treatment at station 2, patient held pressure to both access sites independently. Patient did not perform hand hygiene after holding sites and before exiting treatment floor.

Interview with the Facility Administrator, Manager of Clinical Services, and Regional Operations Director on 12/21/2022 at approximately 4:00pm confirmed the above findings.
























Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 12/21/22. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-04-01B "Post Dialysis Vascular Access Care: Fistula/Graft Using Safety Fistula Needles" and Policy 1-05-01 "Infection Control for Dialysis Facilities" with emphasis on but not limited to: 1. Vascular Access Care: 1) the patient will be encouraged to hold their own sites if their condition permits. When the patient holds their cannulation sites, the patient will be offered gloves and performs hand hygiene when completed. Rationale: Gloves and hand hygiene protects patient and family members from cross contamination. 2. Infection Control: 1) Patients are encouraged to wash their hands and access extremity upon entering the treatment area prior to the initiation of dialysis and wash their hands after treatment before leaving treatment area. Verification of attendance at in-service will be evidenced by teammate's signature on in-service sheet. The Facility Administrator or designee will conduct infection control audits to verify all patients complete hand washing upon entering the treatment area, hand hygiene upon removing gloves when holding access sites, and handwashing prior to leaving the treatment area: 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 reviews of medical records (MR), facility policy, and staff (EMP) interview, the facility failed to provide the necessary care and services to manage the patient's volume status for four (4) of six (6) MR reviewed. (MR1,2,4, & 5)


Findings included:


Review of facility policy on 12/21/2022 at approximately 3:30pm revealed: "...CWOW-PRE-INTRA-POST TREATMENT DATA COLLECTION, MONITORING, NAD NURSING ASSESSMENT...ABNOMAL FINDINGS... Unless other abnormal parameters aer established by the facility Governing Body and documented in the Governing Body Meeting minutes, the following are considered abnormal findings and should be repoted to the licensed nurse and documente in the patient's medical record...Blood pressure-Intradialytic: Difference of 20 mm/Hg increase or decrease from patient's last intradialytic treatment BP reading......"

Review of MR on 12/20/2022 between approximately 1:00pm and 3:30pm revealed:

MR 1, admission date 11/16/2021, six treatment dates reviewed 10/20/2022-12/13/2022.
Treatment record dated 10/20/2022 documented blood pressure obtained by patient care technician (PCT) as follows:
12:31pm- 216/87, 1:01pm-191/81, readings reflect decrease in systolic blood pressure of 25mm/Hg, no evidence licensed nurse notified.
11:01pm-191/81, 1:30pm-166/86, readings reflect decrease in systolic blood pressure of 25mm/Hg, no evidence licensed nurse notified.
1:30pm-166/86, 2:00pm-195/99, readings reflect increase in systolic blood pressure of 29mm/Hg, no evidence licensed nurse notified.

MR 2, admission date 11/8/2022, six treatment dates reviewed 11/29/2022-12/17/2022.
Treatment record dated 12/17/2022 documented blood pressure as follows:
12:32pm-Registered Nurse (RN) documented 180/71, 1:02pm-PCT documented 154/62, readings reflect decrease in systolic blood pressure of 26mm/Hg, no evidence licensed nurse notified.

MR 4, admission date 8/10/2022, six treatment dates reviewed 11/17/2022-12/13/2022.
Treatment record dated 12/6/2022 documented blood pressure obtained by PCT as follows:
12:00pm-135/73, 12:30pm-115/64, readings reflect decrease in systolic blood pressure of 20mm/Hg, no evidence licensed nurse notified.
1:00pm RN documented 105/60, 1:30pm PCT documented 127/94, readings reflect increase in systolic blood pressure of 22mm/Hg, no evidence licensed nurse notified.
1:30pm PCT documented 127/94, 2:00pm PCT documented 147/77, readings reflect increase in systolic blood pressure of 20mm/Hg, no evidence licensed nurse notified.
Treatment record dated 12/15/2022 documented blood pressure obtained by patient care technician (PCT) as follows:
2:10pm-146/67, 2:30pm-120/63, readings reflect decrease in systolic blood pressure of 26mm/Hg, no evidence licensed nurse notified.

MR 5, admission date 12/27/2021, six treatment dates reviewed 11/17/2022-12/13/2022.
Treatment record dated 12/6/2022 documented blood pressure as follows:
10:31am, RN documented 122/66, 10:54am, PCT documented 144/75, readings reflect increase in systolic blood pressure of 20mm/Hg, no evidence licensed nurse notified.
Treatment record dated 12/8/2022 documented blood pressure obtained by PCT as follows:
7:44am-139/66, 8:01am-163/81, readings reflect increase in systolic blood pressure of 24mm/Hg, no evidence licensed nurse notified.
10:31am-102/68, 11:01am- 128/64, readings reflect increase in systolic blood pressure of 26mm/Hg, no evidence licensed nurse notified.
11:01am- 128/64, 11:16am-95/57, readings reflect decrease in systolic blood pressure of 33mm/Hg, no evidence licensed nurse notified.
Treatment record dated 12/15/2022 documented blood pressure obtained by PCT as follows:
7:43am-100/67, 8:02am-127/69, readings reflect increase in systolic blood pressure of 27mm/Hg, no evidence licensed nurse notified. Narrative reports PCT rechecking blood pressure. 8:08am-133/67, reading reflects additional increase in systolic blood pressure of 6mm/Hg with recheck, no evidence licensed nurse notified.
Treatment record dated 12/17/2022 documented blood pressure as follows:
9:32am RN documented 155/83, 10:02am PCT documented 133/59, readings reflect decrease in systolic blood pressure of 22mm/Hg, no evidence licensed nurse notified.


Interview with the Facility Administrator, Manager of Clinical Services, and Regional Operations Director on 12/21/2022 at approximately 4:00pm confirmed the above findings.








Plan of Correction:

The Facility Administrator or designee held mandatory in-service(s) for all Clinical Teammates starting on 12/21/22. 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) Intra dialytic treatment monitoring and data collection which may be performed by the PCT or licensed nurse includes vital signs and treatment monitoring at least every 30 minutes. At minimum obtain and document...blood pressure. 2) Any changes in patient conditions or concerns will be documented and reported to nurse at any time. 3) Abnormal Findings: Unless other abnormal parameters are established by the facility Governing Body and documented in the Governing Body Meeting minutes, the following are considered abnormal findings and should be reported to the licensed nurse and documented in the patient's medical record. Blood pressure: Blood Pressure-Intradialytic: Difference of 20 mm/Hg increase or decrease from patient's last intradialytic treatment BP reading. 4) All findings, interventions and patient response will be documented 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 treatment records audits to verify documentation of proper notification to, and response by the licensed nurse regarding abnormal findings: 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 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 reviews of medical records (MR), facility policy, and staff (EMP) interview, the facility failed to follow facility policy for treatment times not met for three (3) of six (6) MR reviewed. (MR1-3)


Findings included:


Review of facility policy on 12/21/2022 at approximately 3:30pm revealed: "...CWOW-PRESCRIBED TREATMENT TIME NOT MET...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..."

Review of MR on 12/20/2022 between approximately 1:00pm and 3:30pm revealed:

MR 1, admission date 11/16/2021, prescribed treatment time 3 hours and 30 minutes, six treatment dates reviewed 10/20/2022-12/13/2022.
Treatment record dated 10/20/2022 documented treatment duration to be 2 hours and 54 minutes, 36 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 10/27/2022 documented treatment duration to be 2 hours and 55 minutes, 35 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 12/1/2022 documented treatment duration to be 1 hour and 2 minutes, 2 hours and 28 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 12/13/2022 documented treatment duration to be 2 hours and 56 minutes, 34 minutes short of prescribed treatment time. No evidence doctor notified.

MR 2, admission date 11/8/2022, prescribed treatment time 3 hours and 30 minutes, six treatment dates reviewed 11/29/2022-12/17/2022.
Treatment record dated 11/23/2022 documented treatment duration to be 1 hour and 46 minutes, 1 hour and 44 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 12/1/2022 documented treatment duration to be 5 minutes, 3 hours and 25 minutes short of prescribed treatment time. No evidence doctor notified.

MR 3, admission date 8/15/2022, prescribed treatment time 3 hours and 30 minutes, six treatment dates reviewed 11/17/2022-12/13/2022.
Treatment record dated 11/17/2022 documented treatment duration to be 2 hours and 20 minutes, 1 hour and 10 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 12/8/2022 documented treatment duration to be 1 hour and 48 minutes, 1 hour and 42 minutes short of prescribed treatment time. No evidence doctor notified.
Treatment record dated 12/10/2022 documented treatment duration to be 2 hours and 57 minutes, 33 minutes short of prescribed treatment time. No evidence doctor notified.


Interview with the Facility Administrator, Manager of Clinical Services, and Regional Operations Director on 12/21/2022 at approximately 4:00pm confirmed the above findings.







Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 12/21/22. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-01-09 "Prescribed Treatment Time Not Met" with emphasis on but not limited to: 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. 2) If a patient's treatment is shortened/early terminated, the RN will document the event in the patient's medical record. Documentation will include, as appropriate: ...Whether the patient's nephrologist was notified... Verification of attendance is evidenced by teammate's signature on in-service sheet. The Facility Administrator or designee will conduct flowsheet audits to verify patient treatments which are not are meeting prescribed treatment times for greater than thirty minutes are correctly documented, and that the Registered Nurse has documented notification of patient's nephrologist in the patient's medical record: 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 audit results with teammates during homeroom meetings and with the Medical Director during monthly Quality Assessment 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)(5) STANDARD
POC-VASCULAR ACCESS-MONITOR/REFERRALS

Name - Component - 00
The interdisciplinary team must provide vascular access monitoring and appropriate, timely referrals to achieve and sustain vascular access. The hemodialysis patient must be evaluated for the appropriate vascular access type, taking into consideration co-morbid conditions, other risk factors, and whether the patient is a potential candidate for arteriovenous fistula placement.


Observations:



Based on reviews of observations, facility policy, and staff (EMP) interview, the facility failed to follow facility policy for post dialysis access care for AV Fistula or graft for three (3) of three (3) observations (OBS#1-4.)


Findings included:


Review of facility policy on 12/21/2022 at approximately 3:30pm revealed: "...POST DIALYSIS VASULAR ACCESS CARE: FISTULA/GRAFT USING SAFETY FISTULA NEEDLES...Procedure...13. Once bleeding has stopped, discard gauze or band-aid use to hold site. Inspect site for any trauma and for hemostasis. 14. Apply band-aid type or sterile dressing over cannulation site..."


OBS #1, conducted 12/19/2022 at approximately 10:30am at station #2: EMP 2 removed needles and taped folded gauze over site and patient applied pressure. Without observing site to confirm hemostasis applied 2 additional pieces of tape over site and repeated same process for site 2. EMP did not observe either site to confirm hemostasis or change the gauze after patient held site.

OBS #2, conducted 12/21/2022 at approximately 10:30am at station #1: EMP 4 removed needles and taped folded gauze over site and patient applied pressure. Without observing site to confirm hemostasis applied 4"x4" gauze pad over both covered sites and taped in place. EMP did not observe either site to confirm hemostasis or change the gauze after patient held site.

OBS #3, conducted 12/21/2022 at approximately 11:00am at station #2: EMP 2 removed needles and taped folded gauze over site and patient applied pressure. Without observing site to confirm hemostasis applied 2 additional pieces of tape over site and repeated same process for site 2. EMP did not observe either site to confirm hemostasis or change the gauze after patient held site.


Interview with the Facility Administrator, Manager of Clinical Services, and Regional Operations Director on 12/21/2022 at approximately 4:00pm confirmed the above findings.



















Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 12/23/22. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-04-01B "Post Dialysis Vascular Access Care: Fistula/Graft Using Safety Fistula Needles" with emphasis on but not limited to: 1) Once bleeding has stopped, discard gauze or band-aid used to hold site. Inspect site for any trauma and for hemostasis. 2) Apply band-aid type or sterile dressing over cannulation site... Verification of attendance is evidenced by teammate's signature on the in-service sheet. The Facility Administrator or designee will conduct vascular access care audits post dialysis to verify care is compliant with policy, and sites are inspected post bleeding for trauma and hemostasis: daily for two (2) weeks, weekly for two (2) weeks, and monthly for two (2) months. 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 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.





494.150(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 and procedure, observation, and staff interview, the medical director failed to ensure rounding physicians followed facility policy and procedure for physician orders for patient care.

Findings included:

Review of facility policy on 12/21/2022 at approximately 3:30pm revealed: "...PHYSICIAN ORDERS FOR PATIENT CARE...GENERAL: ...2. A physician, in accordance with DaVita Medical Staff Bylaws, federal and state regulations, provides orders for patient care activities in one of the following ways: a. Hand writes or electronically enters orders in the patient medical record, b.Gives verbal or telephone orders, c. Gives orders via DaVita approved secure message via DaVita approved secure message service ("Secure Message")..., d. Approves by signature patient specific standing orders..."

Review of binder located at nurse's station labeled "MD/NP orders" on December 21, 2022, at approximately 12:00pm revealed lined pages wth written dates located at the top of each. Patient names are handwritten on the left and notes to the right. No signature or evidence of who made notations. Nurse manager, at this time, confirmed these to be orders from the physician or extenders upon rounding. Confirmed initials beside each note to belong to this individual, Nurse Manager, and to serve as evidence that notes were "put in as orders by self."
Documentation in binder failed to adhear to facility policy. Documentation not transcribed as physician orders. Process does not reflect verbal order. documentation not entered in secure messaging service.

Interview with the Facility Administrator, Manager of Clinical Services, and Regional Operations Director on 12/21/2022 at approximately 4:00pm confirmed the above findings.







Plan of Correction:

A Governing Body meeting was held on 01/04/23 with the Medical Director, Facility Administrator, Director of Nursing and Regional Operations Director to review the results of the survey ending on 12/21/22. The Governing Body reviewed Policy COMP-DD-017 "Medical Director Qualifications and Responsibilities" with the Medical Director, who acknowledges that he/she is responsible to ensure the facility teammates are trained and follow policy and procedure relative to patient admissions, patient care, infection control, and safety. Plans of correction have been developed and initiated to correct identified deficiencies and to sustain compliance.
The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 01/04/23. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 3-02-03 "Physician Orders for Patient Care" with emphasis on but not limited to: 1) A physician, in accordance with DaVita Medical Staff Bylaws, federal and state regulations, provides orders for patient care activities in one of the following ways: a. Hand writes or electronically enters orders in the patient medical record; b. Gives verbal or telephone orders; c. Gives orders via DaVita approved secure message via DaVita approved secure message service ("Secure Message")... d. Approves by signature patient specific standing orders. Verification of attendance is evidenced by teammate's signature on the in-service sheet. The Facility Administrator or designee will conduct physician orders audits to verify physicians are providing orders for patient care in compliance with one of four ways listed in DaVita policy: daily for two (2) weeks, and 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 Medical Director will review progress of teammate education, results of audits, and adherence to this plan of correction during monthly Quality Assessment and Performance Improvement meetings known as Facility Health Meeting. The Facility Administrator will report progress, as well as any barriers to maintaining compliance, with supporting documentation included in the meeting minutes. Action plans will be evaluated for effectiveness, new plans developed as applicable to achieve compliance with teammate adherence to policy and procedure. The Facility Administrator on behalf of the Governing Body is responsible for compliance with this plan of correction.