In this edition of The State of IJs, we’re spotlighting certain Immediate Jeopardy (IJ) citations issued to nursing homes in Washington but could be cited anywhere in the US. These citations represent the most serious level of noncompliance with health and safety regulations, whereby a resident’s is at immediate risk for serious injury, harm, impairment or death. Understanding the circumstances behind these citations can help providers proactively address vulnerabilities and improve care and services outcomes. See how easy it is to link deficient practices to more than one F-tag below and not necessarily at the same Scope/Severity.
Key Noncompliance Findings
F770 Laboratory Services (S/S = K)
Due to non-payment of the lab vendor four (4) residents did not have ordered lab testing completed related to specific conditions that required lab testing, including critical labs for therapeutic drug levels, chemical and metabolic status, and to rule out a urinary tract infection. The potential for negative outcomes for these residents was evident – delay in treatment, drug toxicity, decline in medication conditions, hospitalizations and a decline in quality of life. There was a lack of follow-up to ensure that the labs were completed as ordered and results followed up on.
F835 Administration (S/S = L)
As part of the surveyor’s investigation into lab tests not being obtained/performed as ordered, a review of the facility’s finances was undertaken. This review resulted in multiple vendors being specifically named in the Statement of Deficiencies (SOD) along with the amount overdue for payment and the current status of services, including a water shut off notice or agency staff no longer being sent. The facility indicated that all invoices were forwarded to the parent corporation for payment – the invoices were all processed including using individual payment plans. The SOD ends with “the facility was managing cash flow” but the impact of resident care and services is apparent.
Compliance Insights
This is a relatively unique situation, but here’s some areas facilities should consider to avoid situations like these – even related to your Finance department.
Laboratory services have to be recognized for the importance that they play in the health of residents.
- A sound system needs to include a contract with a responsible vendor that obtains lab samples as per medical order including completing scheduled visits, phlebotomist communication with the nursing staff whenever a specimen cannot be obtained for follow-up with the ordering practitioner, and timely vendor-facility interaction to develop a plan for payment, change visit schedule, etc.;
- Nursing ensuring all labs are transcribed as per facility policy;
- Nurses are educated on the facility’s policy for laboratory services and know their responsibilities for follow-up when a lab test is not obtained or the results not reported, actions to take for a reported critical lab value, physician and lab vendor communication, as well as the all-important progress note entry.
Administration has multiple responsibilities regarding the overall management of the facility. Systems for all departments and disciplines need to function well and smoothly and this can only be achieved through the Administrator’s leadership of the team. One of the areas that needs special attention is the condition of the facility’s financial status. This can only be achieved with careful monitoring of accounts payable and receivable to identify cash flow issues that need to be addressed in a timely manner so that all necessary resident care and services can be provided. Auditing and corrective action plans are needed in the Finance Department, just like all the others.
The Best Way to Handle an IJ? Prevent It.
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