Inappropriate Discharge and Inadequate Documentation for Two Residents
Penalty
Summary
The facility discharged two residents without appropriate reasons and failed to properly document the discharges, as required by regulation. For one resident with metastatic skin cancer and multiple comorbidities, the facility issued a Notice of Medicare Non-Coverage (NOMNC) and informed the family that hospice care could not be provided at the facility, despite the admission contract stating hospice care was available. The family was not informed of any service limitations at admission and expressed concerns about the discharge, especially since the resident’s spouse had dementia and could not provide adequate care at home. The facility staff, including the Social Services Director (SSD) and Director of Nursing (DON), stated the resident was being discharged due to the need for hospice care, but there was no documentation that the resident met any regulatory criteria for facility-initiated discharge. The facility also failed to provide documentation supporting their claim that the discharge was family-initiated. For the second resident, who had advanced dementia and severe cognitive impairment, the facility issued a NOMNC and planned for discharge due to poor participation in rehabilitation and the need for a memory care unit. The attending physician noted the resident was not a good candidate for the facility’s short-term rehabilitation program, but there was no documentation that the facility was unable to meet the resident’s needs or that the resident met the regulatory requirements for discharge. The family was not made aware of any limitations in the facility’s services and struggled to find an appropriate placement due to a pending Medicaid application. Interviews with facility staff confirmed that discharges were often initiated when residents plateaued in therapy or were no longer participating, regardless of whether regulatory discharge criteria were met. The facility’s admission contract and agreements with hospice providers indicated that hospice care could be provided, contradicting staff statements to families. The lack of proper documentation and failure to meet regulatory requirements for discharge were confirmed by the Nursing Home Administrator and DON during the survey.