The Texas OIG audited a rehabilitation and memory care facility to determine if staffing requirements were met for patient safety and to review whether clients were properly notified about facility certifications. The facility, which is licensed by Texas Health and Human Services, provides nursing services and residential care to Medicaid clients, some of whom have been diagnosed with Alzheimer’s disease or a related condition. In advertising as a memory care facility, they were identified by the OIG’s annual audit risk assessment regarding assisted living facilities advertising as providing memory care services without disclosing whether the facility holds a certification to serve residents with Alzheimer’s disease.
The OIG also determined the facility needed to improve situations involving staffing and specialized training for direct care providers. Specifically, the facility did not:
- Provide a written notice disclosing the facility is not certified to provide specialized care and treatment for residents with Alzheimer’s disease and related disorders, as required, to each resident, as well as each prospective resident or the next of kin or guardian.
- Ensure adequate front desk staffing to (a) reduce the risk of residents leaving the facility unattended and (b) fully comply with COVID-19 emergency rules.
- Have a process to ensure staff completed all required training prior to caring for residents.
Auditors provided the facility with recommendations that will address the areas of concern and allow the facility to reduce potential risks to Medicaid clients.
Compliance Perspective
Issue
States have specific licensing requirements which facilities must meet in order to be compliant. Disorientation and wandering are symptoms for people with Alzheimer’s and related disorders, which can be dangerous if the resident wanders out of the facility. The Alzheimer’s Association estimates six in ten people living with Alzheimer’s and related disorders will wander at least once. Facilities should be adequately staffed with measures in place to deter residents from eloping. Facilities must also provide orientation and annual trainings to all facility direct care staff addressing how to care for residents. Many states have additional requirements for staff who provide direct care to residents with Alzheimer’s disease and related disorders.
Discussion Points
- Review policies and procedures for ensuring provision of adequate monitoring, sufficient staffing, and that there is adequate security to prevent residents from wandering away from the facility. Also review policies and procedures regarding training of staff who provide direct care to residents.
- Train all staff regarding the importance of providing adequate monitoring and care for the residents. Train direct care staff, including agency staff, according to federal and state requirements, and document that the trainings occurred. File the signed documents in each employee’s education file.
- Routinely audit to ensure that staffing levels meet state and federal requirements, to determine if residents at risk for elopement are adequately assessed and monitored by staff to prevent their unauthorized exit from the facility, and to confirm that related care plan interventions are identified and implemented. Also audit to ensure staff are adequately trained according to federal and state requirements.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice*
