In October, Health Services Management, Inc., the parent company for Huntsville Health Care Center, agreed to pay the U.S. government $5 million to resolve a whistleblower lawsuit that included allegations that the company billed Medicare and Medicaid for “worthless services” and services that were not provided. The settlement includes an agreement to enter a Corporate Integrity Agreement with the OIG. The whistleblower was an employee of the facility who claimed she witnessed patient physical and verbal abuse and neglect, inadequate care, and the absence of basic services including food and water.
The common response to this settlement is “This can’t happen in our building!!!” But how is it prevented? With a strong QAPI program.
The Corporate Integrity Agreement in this case provides insight into what the OIG wants to see in a strong quality improvement program. You should use it as a checklist to review the adequacy of systems that promote and respond to quality of care issues timely and appropriately.
- QAPI program effectiveness
- Ability to identify a problem
- Ability to determine the scope or depth of the problem, including but not limited to whether the problem is isolated or systemic
- Ability to conduct a root cause analysis
- Ability to create and execute an action plan to address the problem
- Ability to monitor and evaluate whether the assessment, action plan and execution of the plan was effective, reliable and thorough
- Quality goals are in accordance with:
- Professionally recognized standards of health care
- Rules and regulations found in 42 C.F.R. Part 483
- State and local statutes and regulations
- Officially adopted internal facility policies and procedures
- Other related areas of quality
- Staffing requirements
- Ability to identify and correct physical plant problems
- Quality of care data sources
- CMS quality indicators
- Internal or external surveys or reports
- Hotline or other disclosure program reports or complaints
- Resident satisfaction surveys
- Staffing data
- Abuse or neglect reports
- Incidents that require hospitalization or emergency room treatment
- Psychotropic drug usage
- Any incident involving a resident that prompts a full internal investigation
- Resident records
- Reports from any quality assurance committee, peer review committee, medical review committee or other similar committee(s)
- Any other relevant data sources that can be used to improve resident care
Yes, many homes might see the “worthless services” headlines and move on without reading further. All the nursing homes we know are earnestly and tirelessly working to provide the highest quality care possible. QAPI doesn’t just aid the homes facing newsworthy quality breaches. QAPI can also help you take your quality assurance efforts even further.