Failure to Submit NFSS and Implement PASRR-Recommended OT Services
Penalty
Summary
The deficiency involves the facility’s failure to coordinate PASRR-recommended services and to submit a Nursing Facility Specialized Services (NFSS) request within the required timeframe for a resident with significant cognitive and neurological impairments. The resident, an older female with Parkinson’s disease, epilepsy, cognitive communication deficit, and unspecified intellectual disabilities, had a BIMS score of 6 indicating severe cognitive impairment and was identified as receiving PASRR services related to ID/DD. Her care plan noted that a customized manual wheelchair was acquired through PASRR and that she would participate in habilitation coordination to establish a PASRR plan. A PASRR program spreadsheet showed that an IDT meeting occurred for this resident, but the PASRR department did not receive an NFSS service request for an OT assessment and OT services, despite the PASRR meeting resulting in a request for OT to address self-feeding and seating. The resident’s PCSP form indicated that specialized OT was not needed, while an OT evaluation and plan of treatment documented that she was receiving skilled OT services with a focus on restoration and compensation, paid by Managed Care Part B rather than PASRR funds. An OT discharge summary stated that the resident was not on PASRR as originally thought, so OT would be held, and listed the reason for discharge as exhausted benefits. Interviews with the MDS nurse, DON, Regional MDS nurse, and administrator revealed that no documentation of an NFSS submission could be produced, and the Regional MDS nurse acknowledged that OT services were provided under another payor source and that he did not see an NFSS request in the record. The DON stated the NFSS was not filed because the resident was already receiving OT services, which she believed were through PASRR. This failure to submit a complete and accurate NFSS request within 20 business days after the IDT meeting, as required by 26 TAC §554.2704(i)(7), and to incorporate PASRR recommendations into the assessment, care plan, and transition of care, constituted the cited deficiency.
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