An Update on Indiana’s Progress in Implementing CMS’s Home and Community-Based Services Rule

Indiana’s Office of Medicaid Policy and Planning (OMPP) provided the following update to IHCA concerning the implementation of the CMS HCBS rule.  To view a PowerPoint from CMS concerning the final rule, click here.  IHCA will maintain active involvement with OMPP as the implementation plans become more clear.

The Centers for Medicare and Medicaid Services (CMS) issued a final rule for home and community-based services (HCBS) effective March 17, 2014. Indiana has six 1915(c) HCBS waivers, one grant and three 1915(i) HCBS State plan programs that are affected by this rule:

1915(c) HCBS Waivers
• Aged and Disabled Waiver (A&D)
•         Traumatic Brain Injury Waiver (TBI)

• Money Follows the Person Grant (MFP)    
•         Community Integration and Habilitation Waiver (CIH)
•         Family Supports Waiver (FSW)
•         Psychiatric Residential Treatment Facility Transition Waiver (PRTF)

1915(i) HCBS State Programs
•         Adult Mental Health & Habilitation Services (AMHH)
•         Child Mental Health Wraparound Services (CMHW)
•         Behavioral and Primary Healthcare Coordination (BPHC) 

States submitting a 1915(c) waiver renewal or waiver amendment within the first year of the effective date of the rule need to develop a transition plan to ensure that the specific waiver meets the settings requirements. Within 120 days of the submission of that 1915(c) waiver renewal or waiver amendment the state must submit a plan that lays out timeframes and benchmarks for developing a transition plan for all the state’s approved 1915(c) waiver and 1915(i) HCBS state plan programs.

The Community Integration & Habilitation Waiver (CIH) is due to expire September 30th. Given the short time frame since the March 17, 2014 effective date of the final rule, CMS has advised the state to develop a high level transition plan specific to the CIH waiver for submission with the renewal.

This initial transition plan will outline timeframes for the assessment of current licensure and certification requirements, for assessing those settings which may not be compliant, and for developing a comprehensive transition plan and process for bringing all HCBS settings into compliance. The CIH initial transition plan, or “work plan”, will be posted for 30 day public comment by the middle of July.  Following review of the public comments the CIH renewal will be submitted to CMS.

Submission of the CIH renewal will trigger the 120 day period for Indiana to develop a more comprehensive transition plan for all the state’s approved 1915(c) and 1915(i) HCBS programs. We anticipate that the comprehensive transition plan will be released for additional public comment in late October with submission to CMS due by early December.

The HCBS Final Rule Compliance Project team is being lead by Angie Amos and is composed of staff from each of the FSSA Divisions (DA, DDRS, DMHA, and OMPP).   The team has been reviewing standards (e.g. licensing, certification, etc.) to possibly address provider groups on the basis of state requirements (both in identifying compliant settings and possibly targeted elements to be addressed).  This triage approach will allow us to systematically focus on those areas most at risk of being noncompliant. Assessment tools are being developed which can then be used to evaluate individual settings.

Assuring compliance with the HCBS Final Rule is a large, long term project. CMS is developing additional guidance which will address the implications regarding the Final Rule for non-residential settings, transition planning, and person-centered planning.  Indiana will submit a more fully developed transition plan for assuring compliance with these areas after receipt of the technical guidance from CMS.  A 30 day public input period will be provided prior to the submission of any revised Transition Plan.

Federal Guidance Issued: Protecting Residents from Financial Exploitation

The federal Consumer Financial Protection Bureau (CFPB) released a new manual on June 26, 2014 that is designed to help assisted living and nursing facilities identify and report fraud committed against their residents. Titled, “Protecting Residents From Financial Exploitation:  A Manual for Assisted Living and Nursing Facilities,” the manual focuses heavily on financial abuse committed by residents’ friends and family members.   The manual also discusses common senior scams and is designed to be used by providers.  Click here for to access the manual.  The CFPB provided the following summary statement about the manual, including instruction on how to order free copies of the manual:

To equip assisted living and nursing facility staff with the know-how to prevent and spot the warning signs of elder financial abuse, today the Consumer Financial Protection Bureau released a guide to protecting residents from financial exploitation.

Too often, vulnerable adults fall prey to con artists, family members, fiduciaries, professional advisers and others who steal their nest eggs and threaten their financial security.  Here are just a couple of examples: 

A son steals $315,000 from his elderly mother’s retirement accounts and frequents casinos. When he doesn’t pay his mother’s rent, she’s evicted from her assisted living facility. 

The pastor of a 77-year-old man with Alzheimer’s and Parkinson’s diseases makes 130 withdrawals from the man’s bank account but fails to make nursing home payments on his behalf for nine months. The man was nearly discharged from his nursing home.

CFPB’s action-oriented guide gives facility staff the tools to:
• Prevent financial exploitation and scams by educating staff, residents, and family members about warning signs and precautions
• Recognize, record, and report financial abuse as early as possible using a model protocol and a team approach
• Get help from first responders in the community.
While the guide is geared for assisted living and nursing facilities, it will also be helpful to operators of other senior living facilities.  Family members of residents can read the guide to learn the red flags of financial exploitation, and can share the guide with staff of their loved ones’ facilities.  Long-term care ombudsman can benefit from tips in the guide.

You can read our blog and download the manual from the CFPB’s website. Also, you can order free hard copies—single or bulk orders (if the listing is not up yet, it will be later today).  See our Director talk about elder financial exploitation on video. Today’s press release about the guide is here.

To report cases of financial abuse in Indiana, a facility must follow the ISDH incident reporting procedures and if a crime is suspected report to local law enforcement.  In addition, financial exploitation should be reported to the Indiana Attorney General at 317- 232-6330, Adult Protective Services at 800-246-8909, and your local ombudsman.  The Indiana Attorney General’s office also has an Identity Theft unit that can be reached at 800-382-5516 or by email at  IDTheft@atg.in.gov.

CMS Established a Provider Relations Coordinator for the RAC Process

The Centers for Medicare and Medicaid Services (CMS) recently announced the establishment of a Provider Relations Coordinator to help increase program transparency and offer more efficient resolutions to providers affected by the medical review process (here). 

The Provider Relations Coordinator’s purpose is to improve communication between providers and CMS.  While providers should continue to take questions about specific claims directly to the Recovery Auditor or Medicare Administrative Contractor (MAC) who conducted the review, providers can raise larger process issues to the Coordinator.  For example, if a provider believes that a Recovery Auditor is failing to comply with the documentation request limits or has a pattern of not issuing review results letters in a timely manner, CMS encourages providers to contact the Provider Relations Coordinator.  Prior to the establishment of this new CMS initiative, AHCA members often contacted AHCA staff to help facilitate an escalation of their medical review issues with CMS.  Hopefully this new process will help streamline the resolution of such issues.  

CMS indicted that providers can also send suggestions about how to improve the Recovery Auditor or MAC medical review process to the CMS Provider Relations Coordinator. 

The CMS Provider Relations Coordinator is Latesha Walker, and she can be contacted at:

• RAC@cms.hhs.gov  (for Recovery Auditor review process concerns/suggestions)
• MedicareMedicalReview@cms.hhs.gov   (for MAC review process concerns/suggestions)

If you have any questions or are not satisfied with CMS follow-up when using this new process, please contact Dianne De La Mare or Dan Ciolek at AHCA.

Indiana Medicaid Rate Update

- January, April and July 2014 Rate Setting
As of June 30, 2014 Indiana Medicaid has been unable to set the 1/1/14 rates, and will not be issuing 4/1/14 or 7/1/14 rates, as CMS has yet to approve the State Plan Amendment (SPA) filed late last year to increase nursing facility reimbursement by 2% effective 1/1/14.  It is not entirely clear why CMS has yet to approved the SPA, but IHCA has become aware that CMS has been asking many rounds of questions to Indiana Medicaid concerning issues that are not related to nursing facility reimbursement rates.  Once the SPA is approved, Indiana Medicaid will work to implement the rate increase as soon as possible, but no definitive timeline is available.  As mentioned above, this delay is impacting issuance of 4/1 and 7/1 rates. 

- Quality Assessment Fee Waiver
As reported in February 2014, Indiana Medicaid was required to re-submit its waiver to CMS for the Indiana Quality Assessment Fee.  IHCA has been informed that the waiver has been approved by CMS, however implementation of the increased QAF rates will not take place until the above mentioned SPA concerning the rate increase is implemented.  Below is the list of QAF rates (imposed on all non-Medicare patient days) under the new waiver:
$4.09 (formerly $4.00) per non-Medicare day if the total patient census is 62,000 days or more (formerly 70,000 days)
$16.37 (formerly $16.00) per non-Medicare day if the total patient census is less than 62,000 days (formerly 70,000 days)
$4.09 (formerly $4.00) per non-Medicare day for non-state government owned or operated (NSGO) nursing facilities that became a NSGO prior to 7/1/03
$16.37 (formerly $16.00) per non-Medicare day for non-state government owned or operated (NSGO) nursing facilities that became a NSGO on or after 7/1/03
Continuing Care Retirement Communities (CCRCs) as defined at IC 16-28-15-7(2), hospital based, or state owned (Indiana Veteran's Home) facilities are exempt from paying the assessment.  In addition, Indiana Medicaid has filed notice to file a new State Plan Amendment to extend the effective date of the QAF until June 30, 2017 as is authorized by State law.

- Value Based Purchasing
Satisfaction surveys for residents, family and staff are now in the field for the second year as part of Indiana Medicaid’s Value Based Purchasing program.  While these surveys are not yet part of the official reimbursement add-on, they are setting the baseline data for possible inclusion in the future.  It has been reported to IHCA that the roll-out of these surveys this year has gone much smoother than last year.  If you have any questions or concerns, please contact Zach Cattell at zcattell@ihca.org or 317-340-6416.

- RUGs IV
As previously reported, Indiana Medicaid has proposed changing the Medicaid reimbursement formula to utilized RUGs IV rather than RUGs III.  No decisions have been made concerning a transition to RUGs IV, specifically in terms of what grouper would be used, and ongoing discussions between Indiana Medicaid, the FSSA Division of Aging, and IHCA are taking place.  IHCA has been assured that no change will occur until July 1, 2016, at the earliest, thereby giving providers ample time to plan for the fiscal and operational impact that the transition will have.

AHCA Submits Comments to CMS on LSC 2012 Proposed Rule

On June 16, 2014 AHCA submitted comments to CMS concerning the LSC 2012 proposed rule.  Click here to read the submission. 

MDS Focused Survey Pilot Program Begins

CMS announced in S&C 14-22-NH that it would conduct on-site focused surveys of facilities concerning MDS 3.0 coding accuracy on a pilot basis.  Deficient practices identified will result in relevant citations being issued, and additional concerns will be referred to the state survey agency for further review.  CMS is rolling out these reviews on  pilot basis and have begun work in Maryland, Pennsylvania, and Virginia.  It is expected that 2 additional states will be added to the pilot, but those states have not been announced.  Click here for a copy of the notice that CMS issues to the facility administrator concerning the MDS focused surveys.

Residential Care Citation Update

In May 2014 the ISDH issued 50 Deficiency tags and 9 Offense tags to Residential Care Facilities.  Continuing the trend for 2014, Tag 273 concerning maintenance of food preparation and service areas in accordance with state and local sanitation standards was cited 8 times.   Through May, Tag 273 has been cited 24 times.  In addition, Tag 241 concerning the administration of medications by licensed nurses or QMAs was cited three times, for a total of 16 citations in 2014.  Tag 90 concerning reporting to the ISDH of unusual occurrences within 24 hours was cited 4 times in May, which vaults this tag to the 3rd most cited in 2014 with 10 total citations.  For a summary of the May residential care citations, click here.

ISDH IJ/SSQC Update

There were 6 events in May that were cited as IJ, all of which were also SSQC.  In total, 9 tags were cited as part of the 6 events.  This is the highest number of IJ/SSQC events since August of 2011, and the highest number of IJ/SSQC tags in a month since September of 2011. 

Two of the six events in May were related to resident elopement.  In one of those events, a resident briefly eloped that had been identified as an elopement risk and required monitoring for “tailgating” visitors who were entering or exiting the building.  This resident was standing by the doors of a facility and exited when a visitor entered the facility.  The second elopement issue concerned an unsecured window in the front of the facility that was left open as it was used to promote ventilation in the facility.  It appears the window was open overnight and the resident used the open window to leave the facility.

Citations were also issued in May for two events dealing with alleged sexual assault of a resident.  In one event the facility was cited for failure to ensure the facility staff reported a reasonable suspicion of a crime to law enforcement according to the Elder Justice Act, and in conformity with facility policy.  After discovering bruising of unknown origins during a routine skin assessment, the LPN immediately contacted the DON and then the Administrator of the discovery.  The LPN did not report to the policy as she was told by the DON and Administrator not to do so as they would be coming to the facility to deal with the situation.  After an internal investigation took place police were called until approximately 13 hours after the LPN’s discovery.  Based on the location and extent of bruising police investigators indicated this was certainly enough to form a reasonable suspicion of a crime, and it was ultimately called into police within the 24 hour window for injuries other than serious bodily harm (in certain circumstances sexual abuse can be deemed serious bodily harm/injury).  This event serves as a reminder that while facilities are permitted to help coordinate the reporting of reasonable suspicions of crimes to law enforcement, the policies on such practice should be clear and known to staff and should not discourage staff from making their own report if they want to do so.  This incident appears to have been otherwise immediately reported to the ISDH as an incident, however the ISDH appears to also have taken exception to the manner of the investigation conducted by the facility in that no male staff were interviewed as part of the process and the collection of the resident’s clothing was haphazard and not helpful to the separate police investigation.  In the second event concerning alleged sexual assault, a LPN witnessed a CNA pulling up their pant quickly as the LPN entered the room where the CNA was with a patient.  For this issue, the ISDH cited the lack of immediate reporting by the LPN to the Administrator per facility policy as the LPN did not notify the Administrator until 4 hours after witnessing the event.  The ISDH did not cite any failures with respect to the Elder Justice Act.

The last two events in May concerned PT/INR monitoring for a resident on Coumadin therapy, and another concerning the lack of clarification upon admission of the ordering of three anticoagulants for a resident.  Each issue results in hospitalization of the resident.

To view the May 2567s from the ISDH  and a summary of the 2014 IJ/SSQC events and citation, click here. 

Medicaid Eligibility Changes Are Here – Miller Trusts and Community Medicaid Impacted

After several months of planning and ongoing dialogue with Indiana Medicaid, changes to Medicaid eligibility for the disabled have taken effect on June 1st.  The major impacts of the changes are the elimination of the spend down option, the reliance on SSI and SSDI determinations for purposes of determining disability, the requirement for Miller Trusts for institutional patients or waiver patients, and the utilization of Medicare Savings Program for dual eligible patients between 100% of Federal Poverty and 185% of Federal Poverty.

• Impact on Community Medicaid

Though the spend down program was at times burdensome for patients and providers, the lack of a spend down program has real impact on those “community” Medicaid members that had access to nursing facility services under spend down.  Without spend down, an individual that makes more than 100% of Federal Poverty ($973/month) will not be eligible for Medicaid services unless they are SSI/SSDI.  Though not an everyday occurrence, nursing facilities that provided care to community Medicaid members for short term stays under the spend town program will find that those patients are no longer eligible.  Two examples of impact have come up recently from Indiana nursing facilities:

1.  Patient was not admitted to the hospital for the 3-day qualifying stay under Medicare and could not obtain Medicare coverage for the nursing facility stay and, while dually eligible under spend down, will not be eligible for Medicaid as of June 1 because the patient has income greater than 100% of Federal Poverty ($973/month).   Though the patient would be eligible for certain outpatient services paid for by Medicare and for premium and coinsurance support through Medicare Savings Program, the patient is not able to access nursing facility services under spend down and instead would have had to elect to be fully institutional and pay all income towards liability, less any deviations and Personal Needs Allowance.

2.  Patient had been admitted to the nursing facility as a Medicare patient and came to the end of the 100-day period, however needed a few more weeks or rehabilitation.  The has planned to utilized spend down as a community Medicaid member and did not want to become fully institutional as the patient would have lost all income to pay liability leaving no income to pay her rent for the apartment the patient intended to return to in a few weeks.

These examples illustrate the impact of spend down elimination on patients that do not elect, or should not be, fully institutional patients.  Nursing facilities should begin discussions with their hospital discharge planners and other hospital personnel to fully prepare for future patients that will certainly fall into these and other scenarios.

• Miller Trusts

As of close of business on May 29th Indiana Medicaid had completed 1,083 Miller Trusts that had been submitted.  There were 63 pending review at Indiana Medicaid’s legal office and 9 had been submitted to DFR and not yet turned over to Indiana Medicaid’s legal office.  The agency is not delaying implementation and termination of benefits will occur effective June 1st if Medicaid members that need Miller Trusts fail to submit the required documentation to their DFR caseworker by June 30th.  The implementation process for Miller Trusts has been frustrating as it has been difficult to follow guidance provided by Indiana Medicaid and often times determinations from DFR have not followed the guidance Indiana Medicaid issued.  IHCA has been informed that DFR personnel continue to be trained and issues that have been popping up are being corrected by DFR supervisors and regional managers.  Though that is a time consuming process, the hope is that with time the process will be smoother.

As to the termination of benefits effective June 1st, IHCA received answers to the following questions on May 29th that address submission of Miller Trust applications by June 30th and the seeking of guardianships for the same purpose.  The answers to the following questions were supplied by Tiffany Mulligan, General Counsel to the Family and Social Services Administration:

1.   Does the Miller Trust need to be approved by FSSA by June 30 in order for benefits to be reinstated effective June 1, or can it just be submitted by June 30 in order for benefits to be reinstated?

Answer:  For any member who may be experiencing an interruption in benefits on June 1 due to not having a Miller Trust, he or she can have eligibility for June reinstated by submitting a Miller Trust by June 30. The trust does not need to be approved for the reinstatement of benefits for June. While the trust is being reviewed, we will continue to consider the member eligible. If the trust is not approved, we will notify the member at least 10 days prior to losing eligibility, and the individual will obtain all appeal rights.

2.     Does the Miller Trust need to be in absolute compliance when submitted, or can it be modified after submission to meet FSSA requirements?  If so, which aspects can be modified after submission and which cannot?

Answer:  If the trust is incomplete (i.e. the trust is unsigned, does not include supporting documentation), our office (Office of General Counsel) will send it back to our Division of Family Resources and ask for additional information.  If the trust is invalid, we will send it back to DFR and recommend rejection of the trust.  As I understand it, in both cases, DFR will send the individual a pending verification form, which will list any problems with the Medicaid application.  DFR gives individuals 13 days to return the application with additional or corrected information.  They discontinue or deny eligibility if they don’t receive a response within the 13 day time period.  If they do receive additional or corrected information, DFR will consider the additional information. 

3.     Is the filing of a petition for guardianship that includes a Miller Trust adequate to continue the application, or does the court need to affirm by June 30?

Answer:   If the person has filed a petition for guardianship with a Court and attaches a Miller Trust that will be established for the individual by June 30 if the guardianship is approved, we will go ahead and process the application.  We do not wait for the court to affirm the guardianship.  A legal guardian may not be necessary if there is medical documentation showing the person is incapacitated and a family member is acting on behalf of the individual to establish the trust.  Further, we are allowing Authorized Representatives to create Miller Trusts for members as well as people who have power-of-attorney for the Medicaid member.

• Medicare Savings Program

Dually eligible patients above 100% of Federal Poverty and not disabled per SSI/SSDI are eligible for Medicare premium and copayment/coinsurance support through the Medicare Savings Program.  The premium support ends when income hits 150% of Federal Poverty, but support for Part B costs continue until income hits 185% of Federal Poverty.  All current Medicaid beneficiaries that are above 100% of Federal Poverty were to be automatically enrolled in the program as of June 1st.  Future enrollees must affirmatively enroll in program.   For more, see FAQs 22-35 at http://www.in.gov/fssa/ddrs/4861.htm#Transition_dual.

If you have questions about the eligibility changes or need assistance with Indiana Medicaid or DFR concerning an application or issue, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001.

Indiana Medicaid Rate Update

Without any updates in the month of May, there is no official word from CMS on the approval of the 2% Medicaid rate increases that is set to be retroactively implemented as of January 1, 2014.  Similarly, no official word has come from CMS on the approval of the updated waiver for Indiana’s QAF that was submitted in February.  For details on both of these issues, see the February posting from IHCA’s Insights at http://blog.ihca.org/2014/02/indiana-medicaid-rate-update-vbp-1114.html.  IHCA is set to meet with representatives from Indiana Medicaid and the Division of Aging on these topics, as well as RUGS IV and Value Based Purchasing.  More to come on all of these subjects in the future.

PEPPER Report Update

The SNF Program for Evaluating Payment Patterns Electronic Report (PEPPER) has recently been updated with data through September 2013 and has also changed its comparison group criteria.  If you have not already seen the below, we encourage you to access your facility’s PEPPER report.

The Q4FY13 release of your new Skilled Nursing Facility (SNF) Program for Evaluating Payment Patterns Electronic Report (PEPPER), with statistics through September 2013, is now available for download through the Secure PEPPER Access page at PEPPERresources.org. To obtain your SNF's PEPPER, the Chief Executive Officer, President or Administrator of your SNF should:

1. Review the Secure PEPPER Access Guide.
2. Visit the Secure PEPPER Access page at PEPPERresources.org.
3. Review the instructions and obtain the information required to authenticate access.
4. Click on the button to Access the Secure Portal.
5. Complete all the fields.
6. Download your PEPPER.

The SNF PEPPER will be available to download as a Microsoft Excel file for approximately one year. The previous Q4FY12 SNF PEPPER, originally released in August 2013, will be made available via the Secure PEPPER Portal in the summer of 2014; an email notification will be sent when these PEPPERs are available.
New for this release in the SNF PEPPER: The "State" comparison group now includes all SNFs in a state. Previously, the "State" comparison group included all SNFs in a state that were in the same MAC jurisdiction. As a result, state percentiles will be available for most SNFs; state percentiles will differ from the previous PEPPER release.

For more information, visit the SNF Training and Resources section of PEPPERresources.org.

Grant Solicitation to Expand National Partnership to Improve Dementia Care in Nursing Homes

CMS released S&C-30-NH to announce up to $500,000 in grants (in $60,000 minimum increments) to fund development of unique strategies for safe reduction of antipsychotic medication use in persons with dementia and to build from existing work of the National Partnership.  More details may be found in the memo (click here). 

Pasteurized Eggs Only – CMS Releases Guidance Concerning Preparation of Eggs

On May 20, 2014 CMS released S&C 14-34-NH (click here) that provides guidance to state survey agencies concerning the serving of pasteurized and unpasteurized eggs.  A nursing center that uses and serves unpasteurized eggs must ensure the eggs are fully cooked until both the yolk and white are completely firm.  If a nursing center uses pasteurized eggs, they may serve them as “soft-cooked”, “soft-scrambled”, or :sunny-side up”.

The use of signed agreements between the nursing center and a resident/patient (or the resident’s/patient’s legal representative) releasing the nursing center of liability if the patient/resident becomes ill due to eating unpasteurized eggs prepared by the nursing center that are  not cooked until the yolk and white are completely firm are not permitted.  This guidance is effective immediately.

F441 – Revised Surveyor Guidance

CMS released S&C 14-25-NH that revises guidance concerning Single Use Device reprocessing.  The guidance (click here) clarified that nursing homes can purchase single-use devises when they are reprocessed an entity that is registered with the FDA. 

Residential Care Citation Update

In April 2014 the ISDH issues 34 Deficiency tags and 7 Offense tags to Residential Care Facilities.  This is the high mark for any month so far in 2014, and the highest since the government shutdown in 2013 that permitted more surveys of Residential Care Facilities to take place since SNFs/NFs were not being surveyed.  While there a were a few tags concerning infection control, pharmacy services, and residents rights in April, the number of citations for Tag 273, 9 in April, and Tag 241, 5 in April, continue to be the most cited tags in 2014 (and 2013).

Tag 273 concerning maintenance of food preparation and service areas in accordance with state and local standards was cited due to issues with:
(1) lack of employees wearing hairnets or hairnets not completely covering all hair (including facial hair);
(2) broken or inoperable food transport containers;
(3) overflowing trash cans;
(4) unkempt service areas; and
(5) food service employees without gloves. 
Tag 241 concerning medication administration according to physician orders was cited for:
(1) crushing pills without a physician order;
(2) discontinuing a medication without having the physician order recorded in the chart;
(3) incorrect dosage administration;
(4) antibiotic orders being switched but both drugs continuing to be administered; and
(5) a QMA not observing the resident actually taking the medication that was dispensed to the resident.

Overall for the year the top cited tags at the Deficiency or Offense level are Tag 273 (16 times), Tag 241 (13 times), Tag 117 (7 times), Tag 90 (6 times) and Tag 217 (6 times).  Please click here for a summary of the April citations.

ISDH IJ/SSQC Update

There were three events in April that led to three IJ citations, all of which were SSQC.  The first citation, F314, was issued for alleged failure to prevent the development of a stage 2 pressure ulcer that developed into a stage 4 pressure ulcer.  The resident was admitted for rehabilitation for a fractured right humerus and spotty documentation concerning treatment and dressing changes were identified during the survey.  The second citation, F329, was issued for the alleged failure to ensure laboratory tests were obtained and monitored as ordered for residents reviewed for anticoagulation medication.  The third citation, F333, was issued for alleged failure to administer one of three ordered antibiotics, resulting in a medication error.  Please click here for a summary of the IJs/SSQCs and for the April 2567s.