Failure to Ensure Required Physician Visits for Residents
Penalty
Summary
The facility failed to ensure that residents were seen by a physician during the required initial 30-day visit and at a minimum of every other visit, as mandated. Record reviews and interviews revealed that for six residents, physician visits were either not conducted or were substituted with visits by physician assistants (PAs) or advanced practice registered nurses (APRNs), who are not physicians. The Director of Nursing (DON) confirmed a misunderstanding regarding the requirements, believing that PAs or APRNs could perform all 60-day certifications and that the terms 'primary care physician' and 'primary care practitioner' were used interchangeably in the facility, despite acknowledging that they are not the same. For several residents, including those with complex medical histories such as chronic obstructive pulmonary disease, congestive heart failure, Alzheimer's disease, chronic kidney disease, and recent surgeries, medical records showed that recertification and routine visits were consistently performed by non-physician practitioners. In some cases, there was no evidence that a physician had evaluated the resident at any point during their stay. For example, one resident with multiple chronic conditions was only seen by a PA for all recertification visits, and another resident with Alzheimer's and chronic kidney disease had no record of ever being evaluated by a physician while in the facility. Additionally, documentation for other residents indicated that initial and subsequent required visits were completed by APRNs, with no physician involvement documented. In some instances, the facility's electronic health records incorrectly listed non-physician practitioners as the resident's physician. Interviews with the DON confirmed that these practices were routine and that physicians did not routinely see residents as required, resulting in non-compliance with federal regulations regarding physician oversight and resident care.