Failure to Coordinate and Oversee Behavioral Health Services Provided by External LCSW
Penalty
Summary
The facility failed to identify, assess, and coordinate behavioral health services for three residents who were receiving individual psychosocial therapy from a Licensed Clinical Social Worker (LCSW). The LCSW, employed by a local hospital's behavioral health program, provided ongoing cognitive behavioral therapy to residents within the facility without physician oversight, formal referral, or interdisciplinary coordination. The LCSW accepted self-referred residents, regardless of whether a clinical need had been identified, and did not communicate with facility staff, the nurse practitioner, or the physician regarding which residents were receiving services. Interviews with facility staff, including the Social Services Director, RN, ADON, Administrator, NP, and Physician, confirmed that there was no communication or coordination regarding the therapy services being provided. The facility was unable to conduct appropriate psychosocial assessments, implement monitoring interventions, or evaluate the effectiveness or necessity of the therapy. The LCSW stated that, due to confidentiality, she did not inform facility staff or medical personnel of the residents receiving therapy, and all referrals were self-initiated by cognitively intact residents. Record reviews showed that the LCSW provided therapy to 21 residents, including the three sampled residents, none of whom exhibited behaviors or mood symptoms according to their MDS assessments. There were no physician orders, care plans, or notifications to resident representatives regarding the therapy services. The lack of oversight and coordination resulted in the facility being unaware of the therapy being provided, with no monitoring or follow-up for changes in residents' psychosocial or behavioral health status.