Fall Region Forums - 2014

Fall Region Forums - 2014

Doug BeardsleyVP Member Services

Care Providers of Minnesota

Home Care Survey Findings

(Class A, Class F, and Predicting Comprehensive)

New MDH Comprehensive Surveys

• Zero have been completed yet

• BUT – The Class A and Class F surveys have very clear and consistent survey findings -

• These survey findings easily align with Comprehensive Statutes expectations.

What is being cited during home care surveys?

50%+

ProvidingAcceptedHealth,Nursing,

or MedicalStandardsof Practice

30%-40%Individualized Abuse

Prevention Plans

Content of Service Plan

Content of Client Record

Tuberculosis Protocols

Quality Assurance Plan(Class A)

20%-30%Supervision of Unlicensed

Personnel

Competency Testing

Medication Records

Annual Infection Control Training

Reporting Suspected Maltreatment

Informing Clients ofComplaint Procedure

Current home care survey deficiencies issued in 50% or more of surveys (7-16-13 thru 7/15/14)

Class A: Bill of Rights – the right to receive care and services subject to accepted medical or nursing standards

Class F: The EXACT SAME requirement

Comprehensive: The EXACT SAMErequirement They are the EXACT SAME:

Nothing Changes!

Bill of Rights – the right to receive care and services subject to accepted health, medical, or nursing standards

This deficiency is issued when surveyor observations indicate that the service that is being provided by the home care provider is not aligned with commonly accepted medical or nursing standards for the service. It also usually indicates that there is not a different, more specific rule or statute regarding the unacceptable service being provided available to be issued by the surveyor or investigator.


Examples of what supports this deficiency:• Client refusal to receive ordered treatments was not properly documented in the record.

• Physician was not notified for dressing changes regarding wound care.

• Size of wound not measured and not documented in clients clinical record.

• No policies regarding tracheotomy care when such services were being performed.

• Proper hand washing procedures by employees were not followed. Employee did not change gloves as they left and entered clients’ apartments multiple times. Cross contamination imminent.

• There was not an assessment or risk/benefit completed for use of siderails.


Examples of what supports this deficiency:• Unsafe siderails used.• No documentation for injection sites of insulin and Lantus.• No falls assessments for clients who experienced falls• Changes in condition occurred without further evaluation by a RN• Pain not assessed• Causes of bruising not assessed• Infection control issues: handwashing, gloving, multiple glucometer use, improper disposal of sharps, etc.• Improper administration of medications: eye drops, inhalers, timing of meds with meals, no indications

for use of antipsychotic medications, improper documentation, etc.

• Thickened liquids not given as ordered

Current home care survey deficiencies issued in 30%-40% of surveys (7-16-13 thru 7/15/14)

Class A: Individualized Client Abuse Prevention Plans


Comprehensive: The EXACT SAMErequirement They are the EXACT SAME:

Nothing Changes!

Individualized Abuse Prevention Plans -

Each home health care agency shall develop an individual abuse prevention plan for each vulnerable adult receiving services from them. The plan shall contain an individualized assessment of:

1. the person's susceptibility to abuse by other individuals, including other vulnerable adults;

2. the person's risk of abusing other vulnerable adults; and

3. statements of the specific measures to be taken to minimize the risk of abuse to that person and other vulnerable adults. For the purposes of this paragraph, the term "abuse" includes self- abuse.

Individualized Abuse Prevention Plans -

Examples of what supports this deficiency:• These plans are not part of our normal procedures• No policies or procedures for abuse prevention plans• Unable to locate any plans• Not completed for any client on caseload.• Abuse prevention plans had been completed at admission, but not updated when new

identified vulnerabilities surfaced.• Risks were identified, but no specific measure to minimize abuse were developed.• Nursing assessment regarding risk of abuse was not completed.• The interventions/actions to minimize abuse were not individualized per client.• RN assessment for abuse assessment did not include title, dates, or signature of staff member

filling out form.• Client who consistently refuses treatments had not been assessed for the potential for self-

abuse with planned interventions.

Individualized Abuse Prevention Plans -Issues that tend to trigger the need for an updated abuse prevention plan:• Dialysis• Dementia, Confusion, Cognitive Deficits• Traumatic Brain Injury• Parkinson’s• Socially inappropriate behaviors (sexual)• Hallucinations, Delirium• Elopements• Wandering into other tenants apartments• Aggressive behavior (verbal, physical,

threatening, combative)• Inability to summon for assistance

• Inability to follow directions• Inability to communicate needs• Behavior symptoms• Sensory limitations • Chronic Pain• Suicidal threats• Frequent falls• Frequent bruising• Lacking ability to adhere to safety

precautions consistently• Unsafe smoking

Current home care survey deficiencies issued in 30% - 40% of surveys (7-16-13 thru 7/15/14)

Class A: Required contents of Service Agreement

Class F: Required contents of Service Plan

Comprehensive: Required contents of Service Plan They are the ALMOST

THE SAME

Required Contents of Service Agreement: Class A

The service agreement must include: A. A description of the services to be provided, and their frequency;B. Identification of the persons or categories of persons who are to provide the services;C. The schedule or frequency of sessions of supervision or monitoring required, if any;D. Fees for services; andE. A plan for contingency action that includes:

1. The action to be taken by the licensee, client, and responsible persons, if scheduled services cannot be provided;

2. The method for a client or responsible person to contact a representative of the licensee whenever staff are providing services;

3. Who to contact in case of an emergency or significant adverse change in the client's condition;4. The method for the licensee to contact a responsible person of the client, if any; and5. Circumstances in which emergency medical services are not to be summoned,

consistent with the Adult Health Care Decisions Act, Minnesota Statutes, chapter 145B, and declarations made by the client under that act.

Required Contents of Service Plan: Class FThe service plan must include:

A. A description of the assisted living home care service or services to be provided and the frequency of each service, according to the individualized evaluation required;

B. The identification of the persons or categories of persons who are to provide the services;C. The schedule or frequency of sessions of supervision or monitoring required by law, rule, or the client's condition

for the services or the persons providing those services, if any; D. The fees for each service; andE. A plan for contingency action that includes:

1. The action to be taken by the class F home care provider licensee, client, and responsible person if scheduled services cannot be provided;

2. The method for a client or responsible person to contact a representative of the class F home care provider licensee whenever staff are providing services;

3. The name and telephone number of the person to contact in case of an emergency or significant adverse change in the client's condition;

4. The method for the class F home care provider licensee to contact a responsible person of the client, if any; and

5. The circumstances in which emergency medical services are not to be summoned, consistent with Minnesota Statutes, chapters 145B and 145C, and declarations made by the client under those chapters.

Required Contents of Service Plan: Comprehensive The service plan must include:

1. a description of the home care services to be provided, the fees for services, and the frequency of each service, according to the client's current review or assessment and client preferences;

2. the identification of the staff or categories of staff who will provide the services;3. the schedule and methods of monitoring reviews or assessments of the client;4. the frequency of sessions of supervision of staff and type of personnel who will supervise staff; and5. a contingency plan that includes:

i. the action to be taken by the home care provider and by the client or client's representative if the scheduled service cannot be provided;

ii. information and a method for a client or client's representative to contact the home care provider

iii. names and contact information of persons the client wishes to have notified in an emergency or if there is a significant adverse change in the client's condition, including identification of and information as to who has authority to sign for the client in an emergency; and

iv. The circumstances in which emergency medical services are not to be summoned consistent with communicated advance health directives, living wills, POLST forms, etc.

Required Contents of Service Plan: Comprehensive• The service plan must be written and signed by the home care provider and client

or client’s representative.• The service plan must be in place within 14 days after initiation of home care

services• The service plan must be revised based on client assessments• The service plan must provide information to the client about changes to the

provider's fee for services• The service plan must provide information about how to contact the Office of the

Ombudsman for Long-Term Care.• Staff providing home care services must be informed of the service plan• The service plan must be part of the client record• The home care provider must implement and provide all services required by the

service plan• Notice of any change in fees must be a part of the service plan

Service Plans and Service Agreements -Examples of what supports this deficiency:

• Lacked documentation of the schedule or frequency of supervision or monitoring

• Lacked a contingency plan in the event when services could not be provided

• Lacked a description of services being provided• Lacked the frequency of services being provided• Lacked identification of who would be providing services• Lacked fees• Lacked licensee contact name and number (part of contingency plan)

Service Plans and Service Agreements -Examples of what supports this deficiency:

• Lacked a name and phone number of a person to contact in case of an emergency situation or client change in condition (part of contingency plan)

• Did not identify the circumstances when emergency medical services are not to be summoned (part of contingency plan)

• No descriptions of what was included in a “bundled” service• Billed services did not match fees in Service Agreement• Service Plans not signed• Services included in the Agreement did not match services being provided

to clients during the survey period (alarms, medication storage, treatments, oxygen, CPAP, nebulizers, toileting, blood glucose etc.)


Class A: Required contents of the Client Record

Class F: Required contents of the Client Record

Comprehensive: Required contents of Client Record They are the ALMOST

THE SAME

Class A, Class F, and Comprehensive: Required Contents of Client Record

Class A and Class F required contents of the Client Record are worded differently. However, they are almost identical in expectations, just worded differently.

Comprehensive home care blended the two and created 15 required elements of the client record -

Required Contents of Client Record: Comprehensive

Contents of a client record include the following for each client:

1. identifying information, including the client's name, date of birth, address, and telephone number;

2. the name, address, and telephone number of an emergency contact, family members, client's representative, if any, or others as identified;

3. names, addresses, and telephone numbers of the client's health and medical service providers and other home care providers, if known;

4. health information, including medical history, allergies, and when the provider is managing medications, treatments or therapies that require documentation, and other relevant health records;

Required Contents of Client Record: ComprehensiveContents of a client record include the following for each client:

5. client's advance directives, if any;6. the home care provider's current and previous assessments and service plans;7. all records of communications pertinent to the client's home care services;8. documentation of significant changes in the client's status and actions taken in

response to the needs of the client including reporting to the appropriate supervisor or health care professional;

9. documentation of incidents involving the client and actions taken in response to the needs of the client including reporting to the appropriate supervisor or health care professional;

Required Contents of Client Record: Comprehensive

Contents of a client record include the following for each client:

10. documentation that services have been provided as identified in the service plan;11. documentation that the client has received and reviewed the home care bill of rights;12. documentation that the client has been provided the statement of disclosure on

limitations of services;13. documentation of complaints received and resolution;14. discharge summary, including service termination notice and related documentation,

when applicable; and15. other documentation required under this chapter and relevant to the client's services

or status.

Content of Client Record DeficienciesExamples of what supports this deficiency:

• It took more than two weeks to enter first entry into client’s clinical record.

• The client’s clinical record did not show physician orders for

treatments

• The client’s record did not record if licensed or unlicensed personnel provided services.


• The client’s record did not record the reason for the termination of treatment

• The record did not show whether client’s condition improved where they did not need services or declined where client needed different services

• Significant events or changes in condition not documented in the client

record – NOTE: communication books and logs issue

• Condition of client did not match what was described in client record


• Visits to doctor, ER, hospital not documented

• The condition of client was not included in the discharge summary

• No reason provided when client terminated services and switched provider

• No discharge summary was included in client clinical history


Class A: Tuberculosis (infection control)


Comprehensive: The EXACT SAME requirement They are the EXACT SAME:

Nothing Changes!

TB: Class A, Class F, and ComprehensiveA home care provider must establish and maintain a TB prevention and control program based on the most current guidelines issued by the Centers for Disease Control and Prevention (CDC). Components of a TB prevention and control program include:

1. Screening all staff providing home care services, both paid and unpaid, at the time of hire for active TB disease and latent TB infection.

2. Developing and implementing a written TB infection control plan.

TB DeficienciesExamples of what supports this deficiency:

• Community risk assessment was not completed by the facility/organization(see CDC form and MDH instructions)

• No staff person was identified as being responsible for infection control or TB • There were no specific written policies and procedures regarding prevention and

control of tuberculosis – all staff interviewed stated they were unaware of the need for a TB program

• Personnel files (or staff medical files) lacked evidence of two-step TB skin test at time of employment

• Home care staff were unable to locate personnel files and therefore was unable to provide documentation that TB screen and testing had been completed

TB DeficienciesRequired components were missing:

• The employee file indicated that the employee had direct contact with clients before acquiring the first-step results of TB skin test• No infection control plan had been developed by the home care provider• TB skin test was not measured in mm as required in CDC guidelines• Only the first step of the two-step mantoux was completed or documented (note – shortage of tuberculin serum in some parts of the state)


Class A: Two or More Quality Assurance Initiatives per year

Class F: No such requirement

Comprehensive: One or more Quality Management Initiatives per year They are the ALMOST

THE SAME

Quality Assurance: Class A

The Class A home care provider shall establish and implement a quality assurance plan, described in writing, in which the provider must:

1. Monitor and evaluate two or more selected components of its services at least once every 12 months; and

2. Document the collection of data3. Document the analysis of data 4. Document actions taken (if any) as a result of the initiatives

Quality Management: Comprehensive• The Comprehensive home care provider shall engage in quality management

appropriate to the size of the home care provider and relevant to the type of services the home care provider provides.

• The quality management activity means evaluating the quality of care by periodically reviewing client services, complaints made, and other issues that have occurred and determining whether changes in services, staffing, or other procedures need to be made in order to ensure safe and competent services to clients.

• Documentation about quality management activity must be available for two years.

• Information about quality management must be available to surveyors or investigators at the time of the survey, investigation, or license renewal.

Quality AssuranceExamples of what supports this Class A deficiency:

Based on interview and record review, the licensee failed to establish and implement a quality assurance plan, in writing, that identified required elements. The findings include:

• During the entrance conference, employee X verified the licensee had not implemented a quality assurance plan.

• During the entrance conference, employee Y verified the licensee had not established a quality assurance plan.

• A review of the licensee’s administrative manual revealed a lack of evidence of a quality assurance plan.

• Program had a complying policy and procedure in place, but it had not been followed.

• When queried regarding a quality assurance plan, employee X stated:

• I just work on communications randomly

• Client’s call and say “thank-you”


Class A: Supervision of Home Health Aides

Class F: Supervision of Unlicensed Personnel

Comprehensive: Supervision of Unlicensed Personnel They are the ALMOST

THE SAME

Supervision of Home Health Aides: Class A Supervision or monitoring of Home Health Aides must be provided no less often than the following schedule:

1. Within 14 days after initiation of home health aide tasks; and

2. Every 14 days thereafter, or more frequently if indicated by a clinical assessment, for home health aide tasks such as medication management or delegated nursing tasks.

3. Every 60 days thereafter, or more frequently if indicated by a clinical assessment.

Supervision of Unlicensed Personnel: Class F Supervision or monitoring must be provided no less often than the following schedule:

1. Within 14 days after initiation of assisted living home care services that require supervision by a registered nurse; and

2. At least every 62 days thereafter, or more frequently if indicated by a nursing assessment and the client's individualized service plan.

Supervision of Unlicensed Personnel: Comprehensive• Staff who perform delegated nursing or therapy home care tasks must be

supervised by an appropriate licensed health professional or a registered nurse periodically where the services are being provided to verify that the work is being performed competently and to identify problems and solutions related to the staff person's ability to perform the tasks.

• Supervision of staff performing medication or treatment administration shall be provided by a registered nurse or appropriate licensed health professional and must include observation of the staff administering the medication or treatment and the interaction with the client.

• The direct supervision of staff performing delegated tasks must be provided within 30 days after the individual begins working for the home care provider and thereafter as needed based on performance.

Staff Supervision Examples of what supports this deficiency:

• Supervisory visits not done or not documented. • Plan of Care stated the RN needed to provide supervisory visits every 14

days for client. These visits were not completed or not documented.• Plan of Care state the RN needed to provide supervisory visits at least

every 62 days for client. These visits were not completed or not documented.

• Medication administration in Class A requires RN supervision of every 14 days. However, chart reflected RN supervisory visits occurred only every 60 days.

Staff Supervision Examples of what supports this deficiency:

• RN did not complete initial 14 days assessment and supervision, or completed it outside of the 14 day time period.

• All correction orders were issued because of failure to follow the timelines for staff supervision visits. (Many seemed to either make up their own schedules or disregard the regulations all together.)

• The licensee did not have a policy or procedure pertaining to the frequency of required supervisory visits.


Class A: Competency Testing of Home Health Aides for Delegated Nursing Tasks

Class F: Competency Testing of Unlicensed Personnel for Delegated Nursing Tasks

Comprehensive: Competency Testing ofUnlicensed Personnel for DelegatedNursing Tasks

They are the ALMOST THE SAME

Competency Testing: Comprehensive• A registered nurse or licensed health professional may

delegate tasks only to staff who are competent and possess the knowledge and skills consistent with the complexity of the tasks and according to the appropriate Minnesota practice act.

• Training and competency evaluations of unlicensed personnel providing comprehensive home care services must be conducted by a registered nurse, or another instructor may provide training in conjunction with the registered nurse.

Competency Testing: Comprehensive• When the registered nurse or licensed health professional

delegates tasks, they must ensure that prior to the delegation the unlicensed personnel is trained in the proper methods to perform the tasks or procedures for each client and are able to demonstrate the ability to competently follow the procedures and perform the tasks.

• If an unlicensed personnel has not regularly performed the delegated home care task for a period of 24 consecutive months the unlicensed personnel must demonstrate competency in the task to the registered nurse or appropriate licensed health professional.

Competency Testing: Comprehensive• The registered nurse or licensed health professional must

document instructions for the delegated tasks in the client's record.

ULP Competency TestingExamples of what supports this deficiency:

Competency testing was not conducted, or not properly documented, with unlicensed personnel by a registered nurse before the following procedures were completed:

• Refilling portable oxygen tanks• Conducing blood pressure checks• Performing catheter care• Using chair alarms • Conducting neurological assessments• Nasal cannula fit and distribution of

oxygen

• Conducting blood glucose testing.• Administration of Insulin via Insulin

pens or pre-dosed syringe• Preparing thickened liquids• Using mechanical lifts• Assisting with CPAPs

ULP Competency TestingExamples of what supports this deficiency:

• Instructions specified how to administer insulin with syringes and a vial but did not specify how to administer insulin with insulin pen (pen was being used).

• Specific instructions regarding the procedure to fill portable oxygen were not completed.

• Specific instructions for staff to check oxygen tanks every two hours were not included.

• Instructions provided on insulin administration were not specific to individual client.


Class A: Spread across multiple requirements

Class F: Medication Records

Comprehensive: Documentation of

Administration of

Medications and

Medication Set-up They are the ALMOST THE SAME

Medication Records: Class F• The name, date, time, quantity of dosage, and the method of

administration of all prescribed legend and over-the-counter medications, and the signature and title of the authorized person who provided assistance with self-administration of medication or medication administration must be recorded in the client's record following the assistance with self-administration of medication or medication administration.

• If assistance with self-administration of medication or medication administration was not completed as prescribed, documentation must include the reason why it was not completed and any follow up procedures that were provided.

Medication Records: Comprehensive• Each medication administered by comprehensive home care provider staff must be

documented in the client's record. The documentation must include the signature and title of the person who administered the medication. The documentation must include the medication name, dosage, date and time administered, and method and route of administration.

• The staff must document the reason why medication administration was not completed as prescribed and document any follow-up procedures that were provided to meet the client's needs when medication was not administered as prescribed and in compliance with the client's medication management plan.

• Documentation of dates of medication setup, name of medication, quantity of dose, times to be administered, route of administration, and name of person completing medication setup must be done at the time of setup.

Medication Documentation – Class FExamples of what supports this Class F deficiency:

• Nasal spray not administered as ordered, and then variance not documented

• Medications documented as given when left in med cups on the client’s kitchen table

• Documentation of meds given without witnessing them being administered, or documented as given before giving them

• Medications given but not documented

• PRN medications given reason for administration was not provided

• Medication error reports completed, but no notation of missed doses in client record

• At least one of the following was not documented: the medication name, dosage, date and time administered, and method and route of administration

Medication Documentation – Class FExamples of what supports this Class F deficiency:

• Syringes pre-filled by RN not documented (when and how many)

• No documentation indicating a RN had set-up medications

• Changes made to medication orders without physician consent (family determined dosages)

• No documentation indicating RNs had trained ULPs on insulin injections

• Medications not refilled timely, therefore medications not given, and no documentation in client record

• Oxygen administration not documented

• Oxygen liters per minute not documented


Class A: Annual Required Infection Control Inservice Training

Class F: Annual Required Infection Control Inservice Training

Comprehensive: Annual Required Infection Control

Inservice TrainingThey are the EXACT SAME:

Nothing Changes!

Annual Infection Control Inservice Training: Class A, Class F, and Comprehensive

All three types of home care licenses require staff to participate in annual infection control training that includes the following topics:

Required Annual Infection Control Topics:

1. Infection control techniques used and implementation of infection control standards

2. A review of hand-washing techniques3. The need for and use of protective gloves, gowns, and masks4. Appropriate disposal of contaminated materials and equipment

such as dressings, needles, syringes, and razor blades5. Disinfecting reusable equipment6. Disinfecting environmental surfaces7. Reporting of communicable diseases

Annual Infection Control Training Examples of what supports this deficiency:

• It was not done

• It was not documented


Class A: Required Timely Reporting of Suspected Maltreatment or Exploitation to the CEP (VAA)

Class F: Required Timely Reporting of

Suspected Maltreatment or

Exploitation to the CEP (VAA)

Comprehensive: Required Timely

Reporting of Suspected Maltreatment

or Exploitation to the CEP (VAA)

They are the EXACT SAME:Nothing Changes!

VAA: Class A, Class F, and Comprehensive• All staff of a home care provider are mandated reporters• All clients of a home care provider are considered

vulnerable adults or children• A mandated reporter who has reason to believe that a

vulnerable adult (or child) is being or has been maltreated, or who has knowledge that a vulnerable adult has sustained a physical injury which is not reasonably explained shall immediately make an oral report to the common entry point

VAA: Class A, Class F, and Comprehensive• Each provider shall establish and enforce an ongoing

written procedure to ensure that all cases of suspected maltreatment are reported.

• If a provider has an internal reporting procedure, a mandated reporter may meet the reporting requirements by reporting internally. However, the provider remains responsible for complying with the immediate reporting requirements of this section.

VAA: Class A, Class F, and Comprehensive• A facility may not prohibit a mandated reporter from

reporting externally, and a facility is prohibited from retaliating against a mandated reporter who reports an incident to the common entry point in good faith.

• For home care, “immediately” means within 24 hours• Some exceptions apply, but be careful…• Verbal or physical aggression between clients – unless serious harm results• Certain accidents• Certain errors in the provision of therapeutic conduct

VAA ReportingExamples of what supports this deficiency:

• Significant medication errors not reported to the CEP

• Unexplained injuries that are suspicious in nature or not reasonably explained not reported to the CEP

• Resident-to-Resident altercations with injuries not reported to the CEP

• Suspected thefts of medications, money, checks, credit cards, debit cards, gift cards, etc., not reported to the CEP

• Reports of suspected verbal, physical, or sexual abuse not reported to the CEP

• Reports of suspected neglect not reported to the CEP

• Internal documents (client records, incident reports, communication logs, etc.) document reportable circumstances that were not reported.


Class A: Informing Clients of Compliant Procedure (with required elements)

Class F: Informing Clients of Compliant Procedure (with required elements)

Comprehensive: Informing Clients of

Compliant Procedure

(with required elements)

They are the ALMOST THE SAME

Complaint Procedure: Class A and Class FAll three types of home care licenses require the provider to give (and document) their complaint procedure for receiving, investigating, and resolving complaints to the client or client’s representative.

For Class A and Class F, the complaint procedure must contain five required elements:

Complaint Procedure: Class A and Class F1. The client's right to complain to the licensee about the

services received;2. The name or title of the person or persons to contact with

complaints;3. The method of submitting a complaint to the licensee;4. The right to complain to the Minnesota Department of

Health - Office of Health Facility Complaints; and5. A statement that the provider will in no way retaliate

because of a complaint.

Complaint Procedure: ComprehensiveFor Comprehensive, the complaint procedure must contain four required elements:1. The client's right to complain to the home care provider about

the services received2. The name or title of the person or persons with the home care

provider to contact with complaints3. The method of submitting a complaint to the home care

provider4. A statement that the provider is prohibited against retaliation

Providing Compliant Complaint ProcedureExamples of what supports this deficiency:

• The right to complain to the Office of Health Facility Complaints was missing from the complaint procedure statement.

• A statement that the provider will not retaliate because of a complaint was missing from the complaint procedure statement.

• No name or title was given to contact within facility if a complaint arises.• No methodology of how to file a complaint with the facility or state agency.• Document was missing company name and phone number from the complaint

procedure statement.• No receipt of written notice given to resident.• No established system to handle and resolve complaints was established.• The person who was listed as the contact to field the complaint no longer worked at

home care agency.

Take-Aways:• Look at the examples provided• Audit your home care agency to determine if you

have similar deficient practices (make sure you audit for compliance with the type of home care you have in place)

• Make changes, and re-audit!• Implement Comprehensive Home Care changes

where possible (only when more restrictive)

Documents

Fall Region Forums - 2014