Audit of pediatric services provider uncovers compliance issues

OIG auditors recently issued a report for a prescribed pediatric extended care center that found the facility did not comply with requirements for staffing ratios, employment checks and therapy services coordination. RGV Kidz Place received $1.15 million in Texas Medicaid reimbursement during the audit period and served 37 patients.

During the audit, 18 Texas Medicaid patient records were reviewed which showed that RGV Kidz Place had developed care plans that included information about authorized transportation and contained all required signatures. Additionally, RGV Kidz Place verified licenses for nursing staff, trained certified nursing assistants who provided services, and verified that staff members with driving duties had valid driver's licenses.

Auditors also noted that the facility did not always meet requirements for staffing during 24 of the 28 service dates that were tested. Using staff time sheets and service logs, auditors found times when transportation duties left the facility understaffed and registered nurses clocked out prior to all patients leaving. Additionally, on 17 of 28 service dates, it was found that a sufficient number of registered nurses had not been scheduled. RGV Kidz place explained that staffing shortages were the result of staff illness and difficulty in hiring qualified employees. The facility also claimed that the director of nurses who administered the facility could provide patient care as needed. Since the completion of the audit, more nurses have been hired to meet staffing requirements.

For 18 patients, auditors uncovered that access to occupational, physical, and speech therapy was also impacted when the facility did not coordinate with therapy providers as required in their plan of care. For some patients who did receive therapy, documentation errors were found in some care plans when RGV failed to include information about the therapy type, amount, duration, or frequency. The facility claimed it was not aware of the coordination requirements and that errors in documentation may be due to therapists not updating care plans. 

A review of hiring and staffing documents found that though RGV had performed licensing checks for nurses, it did not perform required employment screenings for all staff members. Auditors determined that RGV failed to check the Employee Misconduct Registry and the Nurse Aide Registry prior to hiring 24 of 29 staff members and had not conducted annual checks for any staff member employed for more than a year. The facility also failed to conduct monthly reviews of some employees against the Texas Exclusions Database and the Federal Exclusions Database.

Additionally, RGV did not conduct pre-employment criminal history checks before rehiring two staff members, which is required under program rules.

Completing all required background and exclusion reviews for facility staff is essential to providing a safe environment for Medicaid clients. Additional safety requirements that are in place to protect Medicaid clients were also found to be lacking during a site visit. Auditors found that the facility had not obtained an annual fire marshal's office inspection or conducted semiannual fire alarm testing. Additionally, electrical outlets were found uncovered which is a safety concern.

Transportation services were also reviewed by auditors, who found documentation errors, including not identifying which staff member was driving and who the patient was released to. There was also no documented reason for 19 patient transports that lasted longer than one hour. Failure to document patient transportation properly can directly impact a patient's care and safety, including providing a record of whether an individual was authorized to accept a client transported from the facility.

The OIG provided recommendations to the facility for all noted issues and was told by facility management that they would correct all procedures and the facility.