The CEO of Saint Louise Regional Hospital is positive South County’s only hospital will not lose its Medicare funding, despite a recent federal inspection that threatened to terminate the hospital’s Medicare provider agreement in two months if Saint Louise does not correct its “deficiencies.”
“We feel our Medicare status will not be jeopardized,” CEO Joanne Allen recently assured the community. “And we’re very confident in that.”
In response to findings that show Saint Louise “failed to ensure that contracted temporary nursing agencies performed services in a manner that was safe and consistent with hospital policy,” Allen says the hospital is moving to reduce, or completely eliminate of all of its contracted registered nurses hired through temporary agencies. Saint Louise utilizes temporary nursing agencies to assist its regular staff in times of high patient volume, Allen explained.
The hospital was surveyed for a second time this year on June 14 by nine officials from the California Department of Public Health, Centers for Medicare and Medicaid Services, a federally funded agency that provides oversight to hospitals and health care providers.
During the resurvey – the results of which were made available to the public in early August – CMS identified “numerous serious instances … that posed immediate jeopardy to the health and safety of patients.”
One issue cited in the 59-page report involves a female patient who died in the intensive care unit after a contracted registered nurse administered a medication incorrectly while preparing a patient for a medical procedure.
Further probing by CMS revealed “there was no evidence the hospital had validated (the nurse’s) competency in providing care to patients in the ICU.”
Whether the nurse’s actions played a direct role in the patient’s death is currently under peer review by the hospital’s medical leadership staff, according to Allen.
Allen said she could not comment further on the incident as it is still under investigation.
The nurse – whose personnel file “revealed a list of procedures to which she self-attested to being proficient” – was one of eight contracted registered nurses at Saint Louise who did not have validated patient care competencies, according to CMS.
While Saint Louise previously accepted nurse competency reports from hiring agencies without conducting its own evaluations, Allen says this will no longer be the norm.
Saint Louise will instead hire additional per diem staff and bolster its roster of in-house core employees, according to Allen.
This will provide more “consistency” and the ability to provide a “higher level of quality care,” she said. “You know the staff, they’re part of the community, they’re a part of the associate team.”
Some other examples of areas where Saint Louise was found to be out of compliance with its conditions of participation as a Medicare provider include:
• One registered nurse was observed licking her fingers as she turned the pages of medical records. She then failed to wash her hands prior to handling a patient’s intravenous lines.
• Dietary services and food safety procedures. For example: Failing to log the proper cool-down time for cooked meat; failure to have an adequate “disaster menu” planned in case of an emergency; having an “over crowded, disorganized” freezer that prevented adequate cold air circulation.
• Failure to enforce the precise method of hand-washing required of food service staff.
• Failure to ensure that food services maintenance workers follow proper cleaning procedures. CMS cites a dirty can opener, dirty ice machine and dirty floor drains.
• Failure to ensure the correct storage and sanitation of certain devices/surgical instruments.
• Failure to correctly monitor the shelf life and storage guidelines for certain drugs and medical supplies.
Allen interprets the rigors of a CMS survey as a difficult but beneficial process that helps educate hospital staff, identify areas that need improvement and guide Saint Louise in establishing the best possible practices. CMS surveys are routine and part of day-to-day operations for any hospital, she explained.
“This is normal. We take it very seriously,” she said. “There are always opportunities to do something better. I think we’ve done that.”
The June 14 re-survey rides the wake of “serious” and “critical” deficiencies identified by CMS, which launched a survey at Saint Louise from Dec. 22, 2011 to Jan. 18, 2012 in response to complaints that a contracted dialysis nurse was talking on a cell phone while caring for a patient.
CMS spokesman Jack Cheevers could not provide specific data on the regularity of CMS surveys, “but I can tell you that it does occasionally happen that a hospital will undergo two surveys within the same year,” he said.
Per CMS protocol, Allen and her staff were given a tight deadline to draft and submit to a plan of correction to CMS that individually addresses each issue in the 59-page survey.
The next steps are to wait for the stamp of approval from CMS, although that will not necessarily assure continued Medicare funding.
Allen, who is confident CMS will validate the hospital’s plan of correction, anticipates a response from CMS in early October.
“Assuming the hospital’s plan of correction is acceptable, we will conduct an unannounced survey sometime before the termination date,” Cheevers explained.
If termination as a Medicare provider does occur, Saint Louise will not receive any payments for in-patient services rendered to Medicare beneficiaries admitted on, or to after the termination effective date, according to CMS.
Medicare funding accounts for 35 percent of the hospital’s total revenue, according to Allen.
Now, as Saint Louise awaits a response from CMS, one of Allen’s paramount concerns is making sure Medicare patients understand they can continue to receive care at Saint Louise in the interim.
The hospital has since posted on its website a summary of the survey report and plan of action in an effort to maintain transparency with the community.
“Our status has not changed. Medicare patients can come to Saint Louise and receive care as they always have,” said Allen. “It’s scary for the community – they don’t understand all the technicality of going through a CMS survey, and all they know is, ‘Can I continue to go to Saint Louise for my care? And my answer is ‘absolutely.’”