QA Investigation Results

Pennsylvania Department of Health
ST. LUKE'S QUAKERTOWN DIALYSIS
Health Inspection Results
ST. LUKE'S QUAKERTOWN DIALYSIS
Health Inspection Results For:


There are  13 surveys for this facility. Please select a date to view the survey results.

Surveys don't appear on this website until at least 41 days have elapsed since the exit date of the survey.



Initial Comments:


Based on the findings of an unannounced onsite Medicare recertification survey completed July 13, 2022, St. Luke's Quakertown Dialysis was identified to be in compliance with the following 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 survey completed July 13, 2022, St. Luke's Quakertown Dialysis was identified to have the following standard level deficiencies that were determined to be in substantial compliance with the following 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 review of facility policy/procedures, observations, and an interview with the facility Administrator, the facility failed to ensure the staff followed infection control protocols, included but not limited to, performing hand hygiene/donning clean gloves, for one (1) of two (2) 'Central Venous Catheter (CVC) Exit Site Care' and 'Initiation of Dialysis with Central Venous Catheter' observations (Observation #1).

Findings include:

A review was conducted of facility policy/procedure on July 12, 2022 at approximately 3:15 p.m. 'Procedure: 1-04-02B' 'Central Venous Catheter (CVC) with Clearguard HD Antimicrobial End Caps Procedure' (4) states "Remove old dressing and discard." .... (5) states "Remove gloves and discard. Perform hand hygiene per procedure and re-glove." ....(12) states "Place sterile 2x2 gauze over the catheter site ...." (14) states Remove gloves and discard, perform hand hygiene per procedure and re-glove." (15) states "Holding catheter with non-dominant hand, use other hand to place sterile 4x4 dressing under catheter limbs ..." (16) states "Using aseptic technique, remove each cap. One at a time, disinfect each CVC hub with a new alcohol prep pad. ....."

Observations conducted in patient treatment area on July 11, 2022 between approximately 8:30 a.m. - 1:30 p.m. revealed the following:

Observation #1: During observation #1 of 'Central Venous Catheter Exit Site Care' on 07/11/22 at approximately 10:50 a.m. of patient #6, station #9, employee #7 removed the old dressing and discarded. Employee #7 did not remove gloves/perform hand hygiene/donn clean gloves after removing the old dressing and before cleansing the area around the CVC exit site with antiseptic. Employee #7 cleansed area around the CVC exit site and applied a sterile dressing to the site. Employee #7 did not remove gloves/perform hand hygiene/donn clean gloves after 'Central Venous Catheter Exit Site Care' and prior to starting 'Initiation of Dialysis with Central Venous Catheter'.


An interview with the facility administrator on July 12, 2022 at approximately 3:30 p.m. confirmed the above findings.












Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 7/15/22. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-05-01 "Infection Control for Dialysis Facilities" and Policy 1-04-02B "Central Venous Catheter (CVC) with Clearguard HD Antimicrobial End Caps Procedure" with the emphasis on but not limited to: 1. Infection control: 1) Hand hygiene is to be performed upon entering the patient treatment area, prior to gloving, after removal of gloves, after contamination with blood or other infectious material, after patient and dialysis delivery system contact, between patients even if the contact is casual, before touching clean areas such as supplies and on exiting the patient treatment area. 2) Gloves are changed: ...When going from a "dirty" area or task to a "clean" area or task... 2. CVC care: 1) Step 4 - Remove old dressing and discard... 2) Step 7 - Remove gloves and discard. Perform hand hygiene per procedure and re-glove... 3) Step 8 -...clean exit site... 4) Step 10 - Remove gloves and discard, perform hand hygiene per procedure and re-glove. 4) Step 13 – Apply label to the dressing... 5) Step 14 - Remove gloves and discard, perform hand hygiene per procedure and re-glove. Verification of attendance at in-service will be evidenced by teammates signature on in-service sheet. The Facility Administrator or designee will conduct infection control audits with focus on proper glove wearing and hand hygiene during CVC care and treatment initiation: daily for two (2) weeks, then weekly for two (2) weeks. Ongoing compliance will be monitored with monthly infection control 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 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.


494.30(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 for the use of the thermometer for three (3) out of three (3) treatment area observations (Observation #1 - Observation #3).


Findings include:

A review was conducted of facility policy/procedure on July 12, 2022 at approximately 3:15 p.m. Policy #1-05-01 'Infection Control for Dialysis Facilities' section 'Dialysis Station Management' section (34) states "If electronic thermometers and/or blood glucose meters are used, measures will be taken to prevent cross contamination between patients. ....If the potential for contamination exists, the device outercasing is wiped with an appropriate disinfectant before being returned to clean area or using on another patient." Section (65) states "Items taken into the dialysis station will be disposed of, dedicated for use only on a single patient, or cleaned and disinfected before taken to a common clean area or used on another patient."


Observations conducted in patient treatment area on July 11, 2022 between approximately 8:30 a.m. - 1:30 p.m. revealed the following:

Observation #1: During a 'Discontinuation of Dialysis with Central Venous Catheter' observation on 07/11/2022 at approximately 9:10 a.m., of patient #7 at station #2, employee #5 did not disinfect the thermometer outercasing after obtaining patient's temperature and before returning to the bin attached to the mobile computer stand.

Observation #2: During a 'Access of AV Fistula or Graft for Initiation of Dialysis' observation on 07/11/2022 at approximately 9:48 a.m., of patient #8 at station #5, employee #4 did not disinfect the thermometer outercasing after obtaining patient's temperature and before returning to the bin attached to the mobile computer stand.

Observation #3: During a 'Discontinuation of Dialysis and Post Dialysis Access Care for AV Fistula or Graft' observation on 07/11/2022 at approximately 10:10 a.m., of patient #1 at station #10, employee #7 did not disinfect the thermometer outercasing after obtaining patient's temperature and before returning to the bin attached to the mobile computer stand.


An interview with the facility administrator on July 12, 2022 at approximately 3:30 p.m. confirmed the above findings.












Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 07/15/22. Surveyor observations were reviewed. Education included but was not limited to a review of Policy 1-05-01 "Infection Control for Dialysis Facilities" and Policy with emphasis on but not limited to: 1) If electronic thermometers and/or blood glucose meters are used, measures will be taken to prevent cross contamination between patients. For example, the thermometer should not be placed on potentially contaminated equipment such as the dialysis delivery system. If the potential for contamination exists, the device outer casing is wiped with an appropriate disinfectant before being returned to clean area or using on another patient. 2) Items taken into the dialysis station will be disposed of, dedicated for use only on a single patient, or cleaned and disinfected before taken to a common clean area or used on another patient. Verification of attendance at in-service will be evidenced by teammates signature on in-service sheet. The Facility Administrator or designee will conduct infection control audits to verify teammate compliance with disinfection of non-disposable thermometers per policy: daily for two (2) weeks, then weekly for two (2) weeks. Ongoing compliance will be monitored with monthly infection control audits. Instances of non-compliance will be addressed immediately. The Facility Administrator 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-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 a review of facility policy, a review of clinical records, a review of patient treatment flow sheets, and an interview with the facility Administrator; the facility failed to ensure the staff followed facility procedure for early termination of treatment for four (4) out of four (4) in-center hemodialysis clinical records reviewed (CR#6, CR#9 - CR#11).

Findings include:

A review was conducted of facility policy/procedure on July 12, 2022 at approximately 3:15 p.m. Policy # 1-01-09 'Prescribed Treatment Time Not Met' 'Policy' '(Prescribed Treatment Time Not Met' (1) states "If shortened/early termination of treatment time exceeds 30 or more minutes, the RN will notify the attending nephrologist to discuss the appropriate intervention (if any), including what additional medical orders may be necessary to address the patients specific needs." (2) Reasons why a patients treatment may be terminated early include, but are not limited to: ....Facility emergency (power outages, weather related emergencies, other facility wide equipment failure) ...."(3) If a patients treatment time is shortened/early terminated, the RN will document the event in the patients medical record. Documentation will include, as appropriate: ....Whether the patients nephrologist was notified; ...."

A review of clinical records was conducted on July 12, 2022 between approximately 1:00 p.m. - 3:15 p.m. Date of Admit is listed below.


CR#6, Date of Admit 06/22/21: Physician orders for Hemodialysis state treatment time "240 minutes." Patient treatment flow sheet dated 01/29/22 was reviewed.
On 01/29/22 patient treatment flow sheet stated Duration : "161" (early termination of treatment time >30 minutes). The treatment flowsheet 'Reason for prescription time not met: Facility emergency ("RO water issue ....."). No documentation of the the patient's nephrologist being notified.

CR#9, Date of Admit 10/26/21: : Physician orders for Hemodialysis state treatment time "210 minutes." Patient treatment flow sheet dated 01/29/22 was reviewed.
On 01/29/22 patient treatment flow sheet stated Duration : "167" (early termination of treatment time >30 minutes). The treatment flowsheet 'Reason for prescription time not met: Facility emergency ("RO water issue ....."). No documentation of the the patient's nephrologist being notified.

CR#10, Date of Admit 09/24/20: : Physician orders for Hemodialysis state treatment time "225 minutes." Patient treatment flow sheet dated 01/29/22 was reviewed.
On 01/29/22 patient treatment flow sheet stated Duration : "152" (early termination of treatment time >30 minutes). The treatment flowsheet 'Reason for prescription time not met: Facility emergency ("RO water issue ....."). No documentation of the the patient's nephrologist being notified.

CR#11, Date of Admit 12/30/21: : Physician orders for Hemodialysis state treatment time "240 minutes." Patient treatment flow sheet dated 01/29/22 was reviewed.
On 01/29/22 patient treatment flow sheet stated Duration : "149" (early termination of treatment time >30 minutes). The treatment flowsheet 'Reason for prescription time not met: Facility emergency ("RO water issue ....."). No documentation of the the patient's nephrologist being notified.


An interview with the facility administrator on July 12, 2022 at approximately 3:30 p.m. confirmed the above findings.












Plan of Correction:

The Facility Administrator or designee held mandatory in-services for all clinical teammates starting on 07/15/22. 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. NOTE: Shortened/Early Termination of the dialysis treatment includes all reasons the prescribed dialysis time is not met by 30 or more minutes. 2) Reasons why a patient's treatment may be terminated early include, but are not limited to: Facility emergency (power outages, weather-related emergencies, and other facility wide equipment failure... 3) 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.


494.150(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 a review of facility policy/procedure, observations, and an interview with the facility Administrator, it was determined the facility failed to follow policy for addressing patient hypertension post treatment, per policy, for two (2) of five (5) patient clinical records (CR) reviewed (CR#1, CR#3); failed to ensure staff followed facility policy for COVID-19 employee screening for one (1) of one (1) 'COVID-19 Response 'Entrance Evaluation Tracker' employee and patient screening forms reviewed (Form #1), and failed to notify the appropriate facility personnel, per policy, of the water treatment system failing, for one (1) of one (1) water log reviews (Water Log Review #1).


Findings include:

A review was conducted of facility policies/procedures on July 12, 2022 at approximately 3:15 p.m. Policy: 1-03-08 'Pre-Intra-Post Treatment Data Collection. Monitoring and Nursing Assessment' 'Purpose' states " To obtain and document baseline and ongoing information about the patient before, during, and after the dialysis treatment through data collection and nursing assessment. ...." 'Post Treatment Data Collection/Assessment' (15) states "The PCT (patient care technician) or licensed nurse will obtain and document basic data on each patient post dialysis and compare to pre dialysis findings. (160 If an abnormal finding(s) or concern is identified post treatment, this needs to be reported to the licensed nurse. The licensed nurse will assess the patient prior to discharge." 'Abnormal Findings' "..... , the following are considered abnormal findings and should be reported to the licensed nurse and documented in the patients medical record. ..." 'Blood Pressure Post Treatment:' "If the patient can stand: Standing systolic BP greater than 140 mm/Hg or less than 90 mm/Hg. Standing Diastolic BP greater than 90 mm/Hg or less than 50 mm/Hg." "If patient is unable to stand, document the reason and sitting BP." "Sitting BP for patients that cannot stand: Sitting systolic BP greater than 140 mm/Hg or less than 90 mm/Hg. Sitting Diastolic BP greater than 90 mm/Hg or less than 50 mm/Hg."


A review of clinical records was conducted on July 12, 2022 between approximately 1:00 p.m. - 3:15 p.m.

CR#1 Date of admission 12/14/2021: Treatment flowsheet dated 07/04/2022 reviewed. 'Vitals' 'Post Treatment' 'Blood Pressure Sit' "191/66." 'Blood Pressure Stand' "N/A." Patients Post Treatment vitals were entered by a PCT (employee #7). No documentation of the abnormal finding being reported to the licensed nurse.
Treatment flowsheet dated 07/08/2022 reviewed. 'Vitals' 'Post Treatment' 'Blood Pressure Sit' "186/63." 'Blood Pressure Stand' "207/68." Patients Post Treatment vitals were entered by a PCT (employee #5). No documentation of the abnormal finding being reported to the licensed nurse.


CR#3 Date of admission 06/13/2022: Treatment flowsheet dated 06/29/2022 reviewed. 'Vitals' 'Post Treatment' 'Blood Pressure Sit' "192/80." 'Blood Pressure Stand' "203/81." Patients Post Treatment vitals were entered by a PCT (employee #6). No documentation of the abnormal finding being reported to the licensed nurse.



Policy: 8-01-20 'COVID-19 Situation Guidance' section #1 states "Interim guidance developed by DaVita related to the COVID-19 situation ...... (a) For example but not limited to: ....., entrance evaluations, ....". 'COVID-19 Patient Management Plan Playbook (All modalities, except where otherwise indicated)' 'Step 1 Evaluate, screen, and disposition' 'First: COVID-19 Entrance Evaluation' "Conduct a timely COVID-19 Entrance Evaluation, using the COVID-19 Entrance Evaluation tracker, with 100 % of people entering your faciliy upon their arrival."


Review of facility 'COVID-19 Response 'Entrance Evaluation Tracker (All Modalities)'employee and patient screening forms on July 11, 2022, at approximately 11:45 a.m. revealed the following:

Form #1: COVID-19 Response 'Entrance Evaluation Tracker (All Modalities) employee and patient screening forms were reviewed from June 15, 2022 - July 11, 2022. Patient notes in the same time frame were also reviewed. Utilizing the screening Forms and the patient note entries, there was no documentation provided of screening of the following staff for the following dates:

06/15/2022: No documentation of employee #10 being screened upon entry into facility. Employee #10's name was listed with the date. The symptom screening section #1-#5 was left blank with no entries. 'Limited Encounter' patient note entry dated 06/15/22 at 9:10 a.m. shows employee#10 was in the facility on that date.

06/17/2022: No documentation of employee #5 being screened upon entry into facility. Employee #5's name was listed with the date. The symptom screening section #1-#5 was left blank with no entries.

07/08/2022: No documentation of employee #11 being screened upon entry into facility. 'Limited Encounter' patient note entry dated 06/15/22 at 3:23 p.m. shows employee #11 was in the facility on that date.


Policy: 2-03-01 'Water Treatment Systems Minimum Component Requirement' 'General' (6) states "in the event of equipment failure of the dialysis quality water treatment system, follow the approved facility specific 'Water Contingency Plan'.
'Water Contingency Plan' (Davita St. Lukes Quakertown) states "In the event the Reverse Osmosis (RO) water treatment system fails to provide dialysis quality water or you experience chlorine breakthrough, immediately notify your Biomedical Technician (BMT). The BMT will then make the decision to make the repair themselves, or contact outside vendor for assistance and or provide alternative water purification such as Deionized Water (D.I.)."

Policy: 4-07-01 'Facility Emergency Management Plan (ICHD, Home)' 'Water Contingency Plan' (5) states "In the event the RO system is found to be inoperable due to system failure or water product quality, the Medical Director, Facility Administrator/designee, local Biomed department, and ROD (Regional Operations Director) will be notified. Local Biomed department will promptly make arrangements for RO repair. The Medical Director will decide if appropriate to switch to deionization (DI) as an alternate water treatment method until the RO system is repaired. If deemed appropriate by the Medical Director, local Biomed department will promptly make arrangements for DI to be used.

Water Log Review #1: The facility water logs were reviewed on July 13, 2022 at approximately 2:00 p.m. On 01/31/22, 02/01/22, and 02/02/22 documentation shows the facility utilized a DI system as an alternate water treatment method due to the RO system malfunctioning. Documentation provided of the facility Administrator being notified of the RO water issue on 01/29/22 at 10:18 a.m. and patient treatment times being shortened.
No documentation of immediately notifying the Biomedical Technician. No documentation provided of notifying the facility Medical Director to determine if appropriate to switch to deionization water (DI) as an alternate water treatment method until the RO system is repaired.
Per the facility Administrator, the DI vendor arrived at the facility on 01/30/22 and completed tasks included but were not limited to installing the DI tanks.
Documentation was provided of a 'Governing Body Meeting' held on 01/31/22 at 1:15 p.m. which included the Medical Director, facility Administrator, Regional Operations Director, and the facility Nurse Manager. The meeting included minutes on the RO system not working properly and DI tanks are now in use.


An interview with the facility administrator on July 12, 2022 at approximately 3:30 p.m. confirmed the above findings.













Plan of Correction:

On 07/15/22, a Governing Body meeting with the Medical Director, Facility Administrator, Director of Nursing and Regional Operations director to review results of the CMS survey ending 07/13/22. The Governing Body reviewed Policy COMP-DD-017 "Medical Director Qualifications and Responsibilities". The Medical Director acknowledges that he/she is responsible to ensure that 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 non-physician providers. Plans of correction were developed and initiated to correct identified deficiencies and sustain compliance. Surveyor observations were reviewed and education for all teammates was conducted starting on 7/15/22. Education included but was not limited to a review of these facility policies: 1. Policy 1-03-08 "Pre- Intra- Post Treatment Data Collection, Monitoring and Nursing Assessment" with emphasis on but not limited to: 1) Purpose: To obtain and document baseline and ongoing information about the patient before, during and after the dialysis treatment through data collection and nursing assessment... 2) The PCT or licensed nurse will obtain and document basic data on each patient post dialysis and compare to pre dialysis findings. 3) If an abnormal finding(s) or concern is identified post treatment, this needs to be reported to the licensed nurse. The licensed nurse will assess the patient prior to discharge. 4) 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 post treatment: a. If the patient can stand: Standing systolic BP greater than 140 mm/Hg or less than 90 mm/Hg; Standing diastolic BP greater than 90 mm/Hg or less than 50 mm/Hg... b. If patient is not able to stand, document reason and sitting BP. c. Sitting BP for patient's that cannot stand: Sitting systolic BP greater than 140 mm/Hg or less than 90 mm/Hg; Sitting diastolic BP greater than 90 mm/Hg or less than 50 mm/Hg. 2. COVID-19 Response "Entrance Evaluation Tracker" with emphasis on but not limited to: 1) Evaluate one hundred percent (100%) of people entering your facility in a timely manner. 2) Document responses on the following pages (Entrance Evaluation Tracker)... 3. Policy 2-04-02 Daily Water Treatment System Monitoring" with emphasis on but not limited to: 1) All observations and test results will be within the limits specified on the Daily Water Treatment Log. If observations or test results are found outside the specified limits, follow the instructions given on the Daily Water Treatment Log for the parameter(s) in question. In addition to following the log form instructions, the teammate completing the log will notify the Facility Administrator/designee and Biomed teammate assigned to the facility of any observation or test result found outside the limit specified on the Daily Water Treatment Log. 4. Water Treatment: A. Policy 2-03-01 "Water Treatment Systems Minimum Component Requirement" and facility specific "Water Contingency Plan" (DaVita St. Luke's Quakertown #06928) with emphasis on but not limited to: 1) In the event of equipment failure of the dialysis quality water treatment system, follow the approved facility specific Water Contingency Plan. 2) DI tank(s) will not be used without the prior approval of the Area Biomed Supervisor, Facility Administrator and Medical Director. B. Water Contingency Plan with emphasis on but not limited to: 1) In the event the Reverse Osmosis (RO) water treatment system fails to provide dialysis quality water or you experience chlorine break through, immediately notify your Biomed Technician (BMT). 2) The BMT will then make the determination to make the repair themselves, or contact an outside vendor for assistance and or provide alternative water purification such as Deionized Water (D.I.). C. Policy 4-07-01 "Facility Emergency Management Plan (ICHD, Home)" Water Contingency Plan with emphasis on but not limited to: 1) In the event the RO system is found to be inoperable due to system failure or water product quality, the Medical Director, Facility Administrator/designee, local Biomed department and ROD will be notified. Local Biomed department will promptly make arrangements for RO repair. The Medical Director will decide if appropriate to switch to deionization (DI) as an alternate water treatment method until the RO system is repaired. If deemed appropriate by the Medical Director, local Biomed department will promptly make arrangements for DI to be used. Verification of attendance is evidenced by teammate's signature on the in-service sheets. The Facility Administrator or designee will conduct audits post education to verify sustained compliance with policies: 1. The Facility Administrator or designee will conduct flowsheet audits to verify proper documentation of data collection, appropriate notification of abnormal findings to nurse and response by nurse: 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. 2. The Facility Administrator or designee will audit one hundred percent (100%) of COVID-19 Entrance Evaluation forms to confirm complete documentation: daily for two (2) weeks, weekly for two (2) weeks, and monthly for two (2) months. 3. The Facility Administrator or designee will conduct an audit of the Daily Water Log to verify accurate and complete timely entries and appropriate notification of appropriate Biomed Technician, Facility Administrator or Medical Director as required by evidence of system failure: daily for two (2) weeks, weekly for two (2) weeks and monthly for two (2) months. Implementation of the Water Contingency Plan will be fully documented in Governing Body meetings until the emergency has been resolved and normal facility services have resumed. All instances of non-compliance will be addressed immediately. The Facility Administrator or designee will review audit findings with teammates during homeroom meetings. The Medical Director will review all audit results, and plan of correction progress, as well as any barriers to maintaining compliance, with supporting documentation included in the meeting minutes. Action plans will be evaluated for effectiveness, and new plans developed as applicable, in order to achieve compliance with teammates' adherence to policy and procedure. The Regional Operations Director or designee will validate that the survey findings and the plans of correction are being reviewed in Governing Body and Quality Assessment Performance Improvement meetings known as Facility Health Meetings, monthly for three (3) months. The Governing Body is responsible for the oversight of all activities of the dialysis center. The Medical Director is responsible to ensure teammates adhere to facility policies and procedures. The Facility Administrator is responsible for compliance with this plan of correction.