CMS releases deficiency list


Wonder what your fellow home health agencies are doing wrong? CMS web site has a punch list

Home care providers hoping to insulate themselves against Survey citations by getting a look at what other agencies are doing wrong will find a new punch list on the Centers for Medicare and Medicaid Services (CMS) web site.


The detailed list of deficiencies shows that many agencies are still struggling with changes imposed by new Conditions of Participation in 2018.

"The new CoPs set much higher standards for care coordination, and many agencies have had some difficulty fully meeting the new requirements," said J'non Griffin, owner and president of Home Health Solutions.

"They're failing to notify the physician about all changes which could affect patient status, they're not documenting all the care team discussions that take place and they're dropping the ball on continuity of care by not meeting new transfer and discharge requirements," J'non said.

Failure to adequately document consultations and care accounted for many of the deficiencies on the list, she said.

"Many of these deficiencies are indicative of ongoing problems for agencies with documentation errors and oversight which leave them vulnerable," J'non said.

In several cases, standard level deficiencies were discovered during the investigation of a complaint lodged against an agency, and citations for deficiencies were issued even though the initial complaint was found to be unsubstantiated.

The list may be viewed in its entirety here. (You'll find the HHA Survey List under the Related Links section at the bottom of the CMS page.)

Wound care issues

The list shows that wound care is an area in which many agencies have ongoing problems. Among common problems cited were:

- Agency provided wound care without physician orders

- Agency did not follow physician orders. This was often due to documentation oversight, as when the physician had provided orders for the agency to apply Xeroform gauze to a patient's wound but there was no mention in the clinical notes that the RN had ever actually applied the gauze.

- Failure to document the wound at assessment and then at regular intervals thereafter , necessary for comparison.

- No education provided to the patient/caregiver(s) about wound care. - Failure to direct the patient to appropriate community resources to continue wound care after discharge.

Lack of care coordination Agencies were cited for many instances of failing to communicate important information to the physician. Examples included failing to notify the physician when the patient did not take an enteral feeding, when there were problems related to the care of a patient's Peripherally Inserted Central Cathetar (PICC) or failure to notify the physician when a wound had deteriorated.

Discharge problems Continuity of care is more important than ever under new CoPs, and many of the new requirements focus on communication of important information related to discharge. The list shows common problems at agencies include:

- Failure to notify the patient or his/her representatives when the plan of care changed and resulted in discharge or reduction of service

- Failure to discharge patient with instructions, including a complete and reconciled list of medications

Staff competency Agencies have issues in the area of staff competency as well, according to the list of deficiencies. Several citations were given because agencies had no documentation that staff orientation had taken place, or because the agency lacked a skills checklist for use as part of staff competency determination programs.

With thousands of deficiencies on the list, these are examples of just a few of the most common errors.

"I'm still reviewing and processing the data," J'non said. "But the list certainly shows overall that agencies are still struggling with some of the demands under new CoPs."



EDITOR'S NOTE: This article first appeared in the May issue of Absolute Agency, a free monthly e-newsletter from Home Health Solutions. If you'd like to receive our newsletters, sign up here.

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