QA Investigation Results

Pennsylvania Department of Health
AGE IN PLACE HOME CARE
Health Inspection Results
AGE IN PLACE HOME CARE
Health Inspection Results For:


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Initial Comments:


Based on the findings of an unannounced onsite complaint survey completed April 29, 2024, Age in Place Home Care was found not to be in compliance with the requirements of 28 Pa. Code, Health Facilities, Part IV, Chapter 611, Subpart H. Home Care Agencies and Home Care Registries.








Plan of Correction:




611.52(a) LICENSURE
Criminal Background Checks

Name - Component - 00
The home care agency or home care registry shall require each applicant for employment or referral as a direct care worker to submit a criminal history report obtained at the time of application or within 1 year immediately preceding the date of application.

Observations:


Based on review of employee files and an interview with the agency Community Development Manager, the agency failed to submit a criminal history report obtained at the time of application or within 1 year immediately preceding the date of application for two (2) out of three (3) employee files (EF) initial hiring requirements reviewed (EF#1, EF#3).

Findings include:


A review of EFs was conducted on April 25, 2024 at approximately 11:00 a.m. Employee date of hire (DOH) is listed below.

EF#1 DOH 04/02/24: No documentation provided of criminal history report being obtained at the time of application or within 1 year (365 days) immediately preceding the date of application. Pennsylvania State Police criminal history report obtained 04/05/24. The employees first work shift with a consumer was on 04/02/24.

EF#3 DOH 03/22/24: No documentation provided of criminal history report being obtained at the time of application or within 1 year (365 days) immediately preceding the date of application. Pennsylvania State Police criminal history report obtained 03/28/24. The employees first work shift with a consumer was on 03/23/24.


An interview conducted with the agency Community Development Manager on April 25, 2024 at approximately 2:15 p.m. and email correspondence with the Community Development Manager on April 29, 2024 confirmed the above findings.












Plan of Correction:

We will begin by pulling a master list of all employees who have been hired to ensure they all have the background check complete. If we identify any missing we wil then immediate conduct those backgrounds. We will begin utilizing a new hire summary which will flag to the employee who conducts the criminal background checks to know who and when one needs to be done. we will conduct a training with all office staff to reiterate the regulation and importance of timely hiring. We will reiterate the importance of sending over the new hire summary in a timely manner and ensure the New Hire Summary is notated for those who we need to quickly hire so we can prioritize that persons background to be run priority so it is complete prior client contact. We will be revamping our monthly self audit form and begin checking 10 files monthly to ensure future compliance. All oversight will be conducted by the Agency Director & Agency Office Supervisor.


















611.52(c) LICENSURE
Federal Criminal History Record

Name - Component - 00
If the individual required to submit or obtain a criminal history report has not been a resident of this Commonwealth for the 2 years immediately preceding the date of the request for a criminal history report, the individual shall obtain a federal criminal history record and a letter of determination from the Department of Aging, based on the individual ' s Federal criminal history record, in accordance with the requirements at 6 PA. Code 15.144(b) (relating to procedure).

Observations:


Based on a review of employee files and an interview with the agency Community Development Manager, agency failed to obtain a federal criminal history record and a letter of determination from the Department of Aging for one (1) out of three (3) employee files (EF) initial hiring requirements reviewed (EF#1).

Findings include:

A review of EFs was conducted on April 25, 2024 at approximately 11:00 a.m. Employee date of hire (DOH) is listed below.

EF#1 DOH 04/02/24: No documentation provided to show that the applicant was a resident of Pennsylvania (Pa.) for the 2 years immediately preceding application for employment. Agency failed to obtain a federal criminal history record and a letter of determination from the Department of Aging. Pa. Drivers License issued 09/26/23 with an expiration date of 02/03/27. 'Application for Employment' record was reviewed. Work history section lists employer with an incomplete address (no city/state). 'From' "2019" To: "2022." No other Pa. proof of residency documentation provided.
No proof of Pa. residency from 04/02/22-09/26/23.


An interview conducted with the agency Community Development Manager on April 25, 2024 at approximately 2:15 p.m. and email correspondence with the Community Development Manager on April 29, 2024 confirmed the above findings.


Repeat deficiency.









Plan of Correction:

We will be adding proof of residency to our compliance page in HHA as we have identified that it was missing. we will be running a report to be able to go back and update the compliance page for all caregivers to ensure our compliance. If we identify any additional missing we will contact that employee and get it fixed OR send them for the neccesary FBI check. We will be revamping our caregiver monthly self audit form and begin checking 10 files monthly to ensure future compliance. We will also conduct a training to reeducate all office staff of the regulation requirements to ensure the Proof of Residency is from no more than 2 years prior to the caregiver first worked date. All oversight will be conducted by the Agency Director & Agency Office Supervisor.




















611.55(e) LICENSURE
Competency Requirements

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

Observations:


Based on a review of employee files and an interview with the agency Community Development Manager, agency failed to provide documentation showing annual competency review covering all required sixteen (16) subject areas for one (1) of three (3) employee files (EF) annual documentation requirements reviewed (EF#4).

Findings include:

A review of EFs was conducted on April 25, 2024 at approximately 11:00 a.m. Employee date of hire (DOH) is listed below.

EF#4, DOH 03/24/23: No documentation provided of a 2024 annual competency review containing all sixteen (16) required elements.


An interview conducted with the agency Community Development Manager on April 25, 2024 at approximately 2:15 p.m. and email correspondence with the Community Development Manager on April 29, 2024 confirmed the above findings.










Plan of Correction:

We will run a report from HHA to identify those caregivers who have not yet completed the annual competency requirements for this year. For those who have not yet completed them, we will be reaching out to get them complete within the next 30 days. We will conduct an eduction to ensure the office staff understand the regulation and the details behind how we comply. upon hire all caregivers are required to complete the direct care worker knowledge test. This test touches base on all 16 elements required. Within 90 days of hire date, the caregivers are also required to complete watching video in-services followed by a 5-10 question quiz passing with an 80% or better at which time a certificate is received. Annually the same process is completed where the caregiver completes a list of in-services selected by the agency director, which touch base on all 16 elements, the certificates are then uploaded to the caregiver file in HHA. we will continue to monitor our competency requirements by conducting our monthly self audit checks.
















611.56(a) LICENSURE
Health Screening

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

Observations:


Based on a review of employee files and an interview with the agency Community Development Manager, the agency failed to ensure each direct care worker and other office staff or contractors with direct consumer contact, prior to consumer contact, was screened for and is free from active mycobacterium tuberculosis, in accordance with CDC (Center for Disease and Control) guidelines, for one (1) out of three (3) employee files (EF) initial hiring requirements reviewed (EF#3).

Findings Include:

The CDC guidelines state that all Health Care Workers (HCW) should receive baseline tuberculosis screening upon hire, using a two-step tuberculin skin test (TST) or a single blood assay for tuberculosis (TB) to test for infection with tuberculosis. After baseline testing for infection with tuberculosis, HCWs should receive TB screening annually. HCWs with a baseline positive or newly positive test for tuberculosis infections should receive one chest radiograph result to exclude tuberculosis disease. (CDC Guidelines for preventing the transmission of Mycobacterium tuberculosis in health-care settings, 2005. Morbidity and Mortality World Report 2005; RR-17').(http://www.cdc.gov/mmwr/pdf/rr/rr5417.pdf.)
*Baseline (preplacement) screening and testing, in addition to the IGRA (interferon-gamma release assay) or TST, shall include a symptom screen questionnaire and an individual TB risk assessment. Serial screening and testing not routinely recommended. Annual TB education is recommended. (CDC/MMWR/May 17, 2019/Vol. 68/No. 19).
A review of EFs was conducted on April 25, 2024 at approximately 11:00 a.m. Employee date of hire (DOH) is listed below.

EF#3 DOH 03/22/24: No documentation provided of a TB test upon hire. One (1) TST was obtained 04/11/24. Employees first work shift assignment with a consumer was 03/23/24.


An interview conducted with the agency Community Development Manager on April 25, 2024 at approximately 2:15 p.m. and email correspondence with the Community Development Manager on April 29, 2024 confirmed the above findings.













Plan of Correction:

We will run a compliance report from HHA to determine if anyone is missing the Tuberculosis testing. If anyone is missing this compliance item we will make sure they go to get the testing. We are looking into alternate location options to streamline our PPD testing abilities, rather than having this item done at multiple facilities therefore the results coming from multiple entities, we are looking into options that are closer to our office, allowing us to streamline the process, therefore resulting in a faster turnaround to getting the test done and results back. We will be creating a monthly self audit form specifically to monitor the PPD Testing. We will begin to monitor 10 random files monthly to ensure continued compliance. All oversight will be conducted by the Agency Director & Agency Office Supervisor


611.57(a) LICENSURE
Consumer Rights

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

Observations:


Based on a review of consumer files, agency staffing calendar/completed visits documentation, and an interview with the agency Community Development Manager, agency failed to ensure services were provided as agreed upon for one (1) of three (3) consumer files (CF) reviewed (CF#1).

Findings include:

A review of CFs was conducted on April 25, 2024 at approximately 10:45 a.m. Consumer start of service (SOS) is listed below.

CF#1 SOS 03/23/24: This consumer is the subject of an AAA (Area Agency on Aging) Northampton event report dated 04/16/24. The event report alleges that services were not provided as agreed upon.

A review of the consumers waiver authorization (02/01/22-02/28/22) revealed the consumers approved hours are 12 hours per day, 7 days per week.

A review of the agency staffing calendar/time hours completed (February/March/April 2024)was completed on 04/25/24 at approximately 1:00 p.m.

On April 9, 2024 8/12 hours were completed.
On April 10, 2024 4/12 hours were completed.
Per the agency Community Development Manager, the agency did not fulfill the entire 12 hour shift due to no authorization/issues with backlogs from the payor source. (This consumer is a waiver program participant.)

No documentation provided of the agency providing written notice to the consumer for one or all of the following required reasons: The consumer has failed to pay for the services, despite notice, and/or the consumer is more than 14 days in arrears, and/or the health and welfare of the direct care worker was at risk.

The consumer is being serviced through a waiver program. The waiver includes but is not limited to 'Personal Care' Task #126, 'Hygiene', 'Times a week '7', 'Saturday, Sunday, Monday, Tuesday, Wednesday, Thursday, Friday.' No documentation provided of the following task being completed according to the consumers "Plan of Care':

03/28/24: No Hygiene completed (2 shifts).
03/30/24: No Hygiene completed.
04/02/24: No Hygiene completed (2 shifts).
04/07/24: No Hygiene completed.
04/10/24: No Hygiene completed.
04/12/24: No Hygiene completed.
04/22/24: No Hygiene completed.



An interview conducted with the agency Community Development Manager on April 25, 2024 at approximately 2:15 p.m. and email correspondence with the Community Development Manager on April 29, 2024 confirmed the above findings.










Plan of Correction:

We will be conducting an audit of all authorizations in our system to ensure accuracy. This will allow us to ensure we are scheduling the correct amount of hours per week according to the auth. Due to this citation we realized that when a caregiver is utilizing telephony, they do not have an option to notate the client is refusing a service. For any tasks being declined by the client, we will begin to complete a formal timesheet for said visit to document the declined task when the caregiver is utilizing telephony. If cg is using the mobile app, a note will be made in the app connecting to said visit of when the task is declined. We will conduct an office staff training to educate on the new process to ensure our compliance with making sure the POC matches everything we should be doing with the client. We will also begin conducting 5 monthly self audits specifically on the consumer authorizations during our monthly QMP meeting. All items will be monitored by the agency office supervisor & agency director.