Initial Comments:Based on the findings of an off-site unannounced, complaint investigation survey conducted May 24, 2022 through May 27, 2022, Penn Highlands Community Nurses, was found not to be in compliance with the requirements of 42 CFR, Part 484, Subparts B and C, Conditions of Participation: Home Health Agencies. Plan of Correction:
484.60(b) STANDARD Conformance with physician orders Name - Component - 00 Standard: Conformance with physician or allowed practitioner orders.
Observations:
Based on review of agency policy and procedure, clinical records (CR), and interview with staff (EMP1), the agency failed to follow the physician's ordered plan of care for one (1) of three (3) clinical records reviewed (CR1).
Findings included:
Entrance interview with EMP1-agency administrator-Kristen Genevro on 9/30/22 related to complaint revealed the following : EMP1 reported to state surveyor that " On 9/2/22 patient daughter called in stating physical therapy assistant (PTA) Kelly turned patient oxygen from 3L(liters) NC(nasal canula) to 2 L NC patient became hypoxic (medical definition– deficient amount of oxygen reaching tissue) spo2(oxygen saturation) in the 80's% and patient passed out. family turned oxygen back up to 3L to recover. I was made aware of the complaint... Penn Highlands has an investigation procedure that was immediately initiated and followed… staff has been re-educated…. Patient has received a letter and follow up phone call”
10/4/22 at approximately 11:00 a.m. review of CR1 plan of care (POC) with a Start of Care (SOC) date: 8/26/22… revealed documentation of a physician order dated 8/26/22 to “administer O2 (oxygen) at prescribed flow rate…3(three) LPM (liters per minute) via NC (nasal canula) cont. (continuous)” Review of documentation/visit notes dated 9/1/22 and signed by agency physical therapy assistant (PTA) revealed that PTA “….reduced patient’s oxygen from 3(three) LPM via NC down to 2(two) LPM via NC…” There was no supporting documentation that updated/new physician orders were received.
Physical Therapy Assistant job description/policy reviewed approximately 1:00 pm on 10/4/22 revealed “Essential Core Job Duties…provides physical therapy services to home health patients according to directions of physical therapist and in accordance with the physician’s plan of care.”
An exit conference was conducted at approximately 2:20 PM on 10/4/22 with agency administrator (EMP1). Above findings were reviewed.
Plan of Correction:Mandatory education will be provided to our physical therapy assistants which will include the physical therapy assistant job description with week of 10/9/2022. staff will sign an acknowledgement form confirming that they have read, understand, and agree to adhere to the physical therapy assistant job description.
Disciplinary action and education to be completed by the supervisor and administrator on 10/11/2022 with the one employee involved with this patient care for not adhering to the physical therapy assistant job description specific to the physician plan of care.
An audit of 50% of active patients with physical therapy services will be conducted by the supervisor and quality staff using the "state survey audit tool" for compliance with following physician orders according to the job description. The audit will be for a period of 4 weeks. After 4 weeks and compliance is demonstrated the supervisor and quality staff will complete 25% audit of active patients with physical therapy services for compliance with following physician orders according to the job description. The results of the audit will be reported to the administrative team to determine additional audit frequency. Any patient chart found not to be in compliance will be reviewed with staff member involved with the patient treatment by the supervisor for education and/or potential disciplinary action.
PI manager will add results of this audit to our QAPI program for review at our QAPI meeting.
Initial Comments:Based on the findings of an unannounced off-site complaint investigation completed on October 4, 2022, found that Penn Highlands Community Nurses - St. Mary ' s was found not to be in compliance with the following requirements of PA Code, Title 28, Health and Safety, Part IV, Health Facilities, Subpart G, Chapter 601, Home Health Care Agencies. Plan of Correction:
601.31(d) REQUIREMENT CONFORMANCE WITH PHYSICIAN'S ORDERS Name - Component - 00 601.31(d) Conformance With Physician's Orders. All prescription and nonprescription (over-the-counter) drugs, devices, medications and treatments, shall be administered by agency staff in accordance with the written orders of the physician. Prescription drugs and devices shall be prescribed by a licensed physician. Only licensed pharmacists shall dispense drugs and devices. Licensed physicians may dispense drugs and devices to the patients who are in their care. The licensed nurse or other individual, who is authorized by appropriate statutes and the State Boards in the Bureau of Professional and Occupational Affairs, shall immediately record and sign oral orders and within 7 days obtain the physician's counter-signature. Agency staff shall check all medicines a patient may be taking to identify possible ineffective drug therapy or adverse reactions, significant side effects, drug allergies, and contraindicated medication, and shall promptly report any problems to the physician.
Observations:
Based on review of agency policy and procedure, clinical records (CR), and interview with staff (EMP1), the agency failed to follow the physician's ordered plan of care for one (1) of three (3) clinical records reviewed (CR1).
Findings include:
Entrance interview with EMP1-agency administrator-Kristen Genevro on 9/30/22 related to complaint revealed the following : EMP1 reported to state surveyor that " On 9/2/22 patient daughter called in stating physical therapy assistant (PTA) Kelly turned patient oxygen from 3L(liters) NC(nasal canula) to 2 L NC patient became hypoxic (medical definition- deficient amount of oxygen reaching tissue) spo2(oxygen saturation) in the 80's% and patient passed out. family turned oxygen back up to 3L to recover. I was made aware of the complaint... Penn Highlands has an investigation procedure that was immediately initiated and followed ... staff has been re-educated .... Patient has received a letter and follow up phone call "
10/4/22 at approximately 11:00 a.m. review of CR1 plan of care (POC) with a Start of Care (SOC) date: 8/26/22 ... revealed documentation of a physician order dated 8/26/22 to " administer O2 (oxygen) at prescribed flow rate ...3(three) LPM (liters per minute) via NC (nasal canula) cont. (continuous) " Review of documentation/visit notes dated 9/1/22 and signed by agency physical therapy assistant (PTA) revealed that PTA " ....reduced patient ' s oxygen from 3(three) LPM via NC down to 2(two) LPM via NC ... " There was no supporting documentation that updated/new physician orders were received.
Physical Therapy Assistant job description/policy reviewed approximately 1:00 pm on 10/4/22 revealed " Essential Core Job Duties ...provides physical therapy services to home health patients according to directions of physical therapist and in accordance with the physician ' s plan of care. "
An exit conference was conducted at approximately 2:20 PM on 10/4/22 with agency administrator (EMP1). Above findings were reviewed.
Plan of Correction:Mandatory education will be provided to our physical therapy assistants which will include the physical therapy assistant job description with week of 10/9/2022. staff will sign an acknowledgement form confirming that they have read, understand, and agree to adhere to the physical therapy assistant job description.
Disciplinary action and education to be completed by the supervisor and administrator on 10/11/2022 with the one employee involved with this patient care for not adhering to the physical therapy assistant job description specific to the physician plan of care.
An audit of 50% of active patients with physical therapy services will be conducted by the supervisor and quality staff using the "state survey audit tool" for compliance with following physician orders according to the job description. The audit will be for a period of 4 weeks. After 4 weeks and compliance is demonstrated the supervisor and quality staff will complete 25% audit of active patients with physical therapy services for compliance with following physician orders according to the job description. The results of the audit will be reported to the administrative team to determine additional audit frequency. Any patient chart found not to be in compliance will be reviewed with staff member involved with the patient treatment by the supervisor for education and/or potential disciplinary action.
PI manager will add results of this audit to our QAPI program for review at our QAPI meeting.
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