Audit Tips for Clinical Documentation

Clinical documentation and clinical management relate to section 1.3.1 to 1.3.8 of the Health and Disability Services Standards and are referred to in section D5.4 of the ARRC.  There are key reference documents which provide reference at residential care facility level which should be used in conjunction and addition to your organisation policies and procedures.  These reference documents include:

 

  • Age Related Residential Care (ARRC) contract
  • NZS 8134:2008 Health and Disability Services Standards
  • Clinical best practice (EBP) guidelines – eg; Lippincott
  • The Code of Health & Disability Consumers Services Rights 1996

 

Clinical documentation errors of any type noted during audits will result in partial attainments at best.  This is an indication there could be risk associated with gaps in service. In a previous article about medication management we noted that even a single signature missing off an administration signing sheet was enough for the auditor to assign a partial attainment finding.

 

Below are some of the common compliance gaps which relate to clinical documentation:

   
General compliance

gaps

Missed signatures off notations.

Not dated.

Not signed by the author with a full signature.

No designation written with signature.

Not legible.

Inconsistent structure of resident files.

Unclear or unsecured archiving of documents.

Privacy breaches due to clinical documents placed in a situation that allowed unauthorized viewing.

Initial assessments

including InterRai

Not completed within time-frames defined in ARRC.

Baseline recordings at time of admission not recorded.

Assessment outcomes not used as a basis of care planning to link assessment to goals and interventions.

Additional detailed assessments not reviewed in a timely manner eg; six monthly to coincide with InterRai reassessments.

Failure to re-assess for each period of admission eg; respite care.

Clinical risk

Assessment not describing risk.

Risk not reflected in care plan interventions.

Lack of risk reviews.

Level of risk noted in interRai assessments not included in care planning

Progress notes

Not recorded in on a shift by shift basis.

Lack evidence of regular registered nurse input.

Writing beyond the bottom line of the page.

Failure to put resident identifiers on each side of each page (this applies to other clinical documents as well).

Lack evidence of interventions being implemented.

Lack evidence of RN response to clinical symptoms reported by care staff.

Lack of evidence of rationale for PRN medication administration or the resulting effect.

Short Term

Care Plans

Not developed for changes in clinical status eg; increased pain; infection; wounds, change in medication (to allow evaluation of effectiveness).

24 hours plans not developed for residents displaying behaviours of concern (challenging behaviours).

Not evaluated regularly (I suggested at least once every 7 days) by a Registered Nurse.

Not recorded as resolved or transferred to Long Term Care Plan.

Not developed to implement instructions included in General Pracitioner consultation plans recorded in notes.

Long Term

Care Plan (LTCP)

Not reflective of all presenting potential and actual medical / clinical problems.

Not documented within 3 weeks of the date of admission (ARRC requirement).

Not changed at the time of health status / functional change.

Interventions not reflective of each medical diagnosis.

Interventions not changed within LTCP to reflect changes recorded in care plan evaluations.

Frequency of clinical assessment for each actual clinical presentation eg; pain.

Do not clearly indicate the level of function, assistance required for each component of care / support.

Do not clearly evidence input and instruction from Medical or Nurse practitioner / Physiotherapist, Diversional Therapist, Dietitian,Psychiatric services             for the elderly etc.

Care Plan

Evaluations

Review of care plans not reflecting changes in residents health status as they occur.

Not reflective of how well the care plan goals/ objectives have been met since the previous evaluation.

Not completed within ARRC defined time-frames (at least six monthly).

Multi-Disciplinary

Input

Lack evidence of MDT input into care plan reviews and/or evaluations.

Lack evidence of resident, Next of Kin (NOK) / Family / Whanau / EPOA input into assessment and care planning.

Lack of evidence of timely referral in response to clinical presentation eg; unintentional weight loss not referred to Dietitian.

Failure to evidence implementing instructions ofMedical or Nurse Practitioner eg; B/P to be recorded daily for the next 7/7 may be noted in the medical           consultation notes however not evidenced as having been done.

Lack evidence of notification to NOK / EPOA relating to resident adverse events, change in health status, medical consults etc.

Policy and

procedures

Not consistent with service delivery as noted in clinical documentation.

 

Internal audits are available through the online HCSL quality system utilised by our clients which allows tracking of compliance status and corrective actions as part of on-site quality and risk management. This means when the auditors arrive, there will be no surprises and you’ll know you’ve achieved excellence in care in conjunction with providing a compliant service.

If you have any comments to make about this article, please contact us here.

 

Testimonial from Tainui Village – New Plymouth

Upon reading one policy everything fell neatly into place. I found her documentation to be outstanding.  It is very reassuring to know that every policy and procedure is the most up to date and designed to meet audit requirements.  All her forms are easily accessible and very user friendly.   We can instantly benchmark against others.  At the click of a button we can analyse falls, infections and adverse events.   Creating graphs and other information for Board reports takes minutes rather than hours.

Having come from a background of many years in QA, HSE and Electronic Document Management in the Oil and Gas Industry, when I entered the aged care sector, it was a huge “eye opener”.  After sitting through several handovers and meetings and listening to discussions on medications etc I felt as if I was listening to a foreign language.  Oh my goodness I thought and then Gillian’s documentation arrived together with a visit from her shortly after.

Gillian’s enthusiasm and commitment for both the aged care sector and her documentation is contagious.  I feel I can now discuss, with the knowledge I have acquired in a few short months, aspects of aged care I never knew existed.  Gillian is only a phone call or email away and all queries are always answered promptly, no matter how minor.

 

Thank you very much Gillian.

Lois Lash – Quality Assurance

Tainui Village –  October 2017

 

Policies and Procedures folders

Policies & Procedures

Policy No. Titles for residential care service policies and procedures
CSM Care Services Manual introduction page
CS1 Admission to hospital for medical emergency
CS2 Adverse Health Policy
CS3 Anti-coagulation monitor
CS4 Warfarin blood monitoring results
CS5
CS6 Bereavement / Termination Care policy
CS6 A Bereavement notification form (and resource material)
CS7 Blood Glucose monitor form
CS7 A Blood sugar levels record sheet
CS7 B Diabetes Testing and Treatment sheet
CS7 C Blood glucose monitor form
CS8 Blood sugar equipment check
CS9 Blood sugar testing
CS10 Case Conference for care plan review forms
CS11 Care Plan Review Schedule
CS11 A Doctors Visits Schedule
CS12 Catheter management policy
CS12 A Catheter change schedule
CS13 Continence management policy
CS13 A Continence assessment form
CS13 B Continence Voiding Chart and Bowel chart
CS14 Clinical Management Policy (includes resource directly and key responsibilities)
CS14 A Robinson’s Resident Acuity & Clinical Risk Assessment
CS15 Challenging behavior assessment form
CS15 A Behavior monitoring chart
CS15 B Challenging behavior assessment form
CS16 Diversional Therapy – Quality of life policy
CS16 A Diversional Therapy – Residential profile
CS16 B Diversional Therapy – Care plan
CS16 C Diversional Therapy – Activities attendance register
CS16 D Diversional Therapy – Care plan evaluation form
CS16 E Sample Activities Calendar
CS17
CS18
CS19 Falls Prevention Programme
CS19 A Falls Risk Assessment – Coombe’s Assessment Form
CS19 B Repeated Falls Analysis – Accident Summary
CS19 C Resident Mobility Assessment Chart
CS19 D Resident Mobility Guide Form
CS19 E Post Falls Investigation Form
CS20 Fluid Balance Chart
CS20 A Daily Fluid Balance Chart (more reflective of hospital level care)
CS21 Handover sheet
CS22 Health status and clinical risk assessment policy
CS22 A Health status and clinical risk assessment form
CS23 ‘Health Promotion’ Initiative Planner
CS24 Lab form – Pathology report storage sheet
CS25
CS26 Long Term Care Plan (Including InterRai prompts and Evaluations)
CS26 A Short term care plan for acute issues
CS26 B Treatment Sheet
CS26 C Daily Care Summary (for inside wardrobe reference in resident room)
CS27 Care Plan multi-disciplinary review policy (and associated form)
CS28 Administration of medication policy – different version supplies for those using Medimap / 1 Chart
CS28 A Administration of medication procedure – different version supplies for those using Medimap / 1 Chart
CS28 B Glucagon Administration
CS28 C Blister pack contents verification
CS28 D Medication competency assessment forms
CS28 E Insulin competency assessment form
CS28 F Medication changes / order notification
CS28 G Medication order sheet – supplied for non-electronic system users
CS28 H Medication Signing sheet – supplied for non-electronic system users
CS28 I PRN medication signing sheet – supplied for non-electronic system users
CS28 J Medication error analysis form
CS28 K  Medication error analysis form
CS28 L  Respite / short term resident medication signing
CS28 M  Self Medication resident initial competency reviews
CS28 N  Self medicating – shift by shift verification
CS28 O Medication Returned to Pharmacy form
CS28 P Medication Key Holder Register
CS28 Q Injection Register form
CS30 Nebulizer usage and maintenance policy
CS31 Neurological Recordings policy
CS31 A Neurological Observation sheet
CS32 Podiatrist Service agreement
CS33 Pain Management policy
CS33 A Pain – Detailed Assessment form
CS33 B Pain – Review Assessment form
CS33 C Pain – ABBEY pain scale (for non-verbal resident)
CS33 D Pain – ABBEY pain scale reviews form
CS34 Personal hygiene and grooming policy
CS35 Pharmacy Service Agreement
CS36 Temp, Pulse and Respirations monitor form
CS36 A General Recordings record (optional use)
CS36 B Weight and Blood Pressure Monitor form
CS36 C Blood Pressure Monitor form
CS37 Pressure Injury Risk policy
CS37 A Pressure Injury Clinical Procedures
CS37 B Pressure Injury risk assessment form
CS38 Nursing (care) progress notes form
CS38 A Pressure Note Writing Guidelines
CS39 Medical Notes progress forms
CS40 Restraint / Enabler use policy and procedure
CS40 A Restraint / Enabler Authorisation form
CS40 B Restraint / Enabler Monitoring record
CS40 C Restraint / Enabler Register
CS40 D Restraint / Enabler Assessment prior to use
CS40 E Restraint / Enabler monitoring guidelines
CS40 F Restraint Approval Group Review meeting
CS40 G Restraint / Enabler Review form
CS41 RN – Medical practitioner communication
CS42 Sleep and Comfort policy
CS42 A Sleep Monitor form
CS43 Turn Chart for bed-ridden resident
CS44 Weight Management policy
CS44 A Weight Monitoring chart
CS45 Wound Management policy
CS45 A Wound care plan / dressing schedule
CS45 B Wound care competency assessment
Policy No. Title for residential care food services policies and procedures
FSM Food Services Manual introduction page
FS1 Admission Food & Nutrition Information
FS1 A Breakfast Order forms
FS2 Food brought into the facility
FS3 Food Safety policy
FS4 Food Services for the Elderly
FS4 A Food & Nutrition guidelines for the older person
FS4 B General tips for helping older persons eat etc.
FS4 C Ageing Process and Care Provisions Issues
FS4 D Eating Difficulties – Dry or Sore Mouth
FS4 E Fluids – Preventing Constipation
FS4 F Food and Medication Interactions
FS4 G Vitamin and Mineral Supplements
FS5 Food Services Questionnaire for Residents
FS6 Safety Checklist for Kitchen Services Areas
FS7
FS7 A Sample Menu – Winter 1
FS7 B Sample Menu – Winter 2
FS7 C Sample Menu – Winter 3
FS8 Microbiological Data Sheets – food Safety
FS9 Food services ordering and monitoring
FS10 Food services preferred suppliers
FS11 Food/fluid Intake Chart
FS12 Resident Food / Fluids Preferences at a glance form
FS13 Food Services Staff Responsibilities
FS14 Food Storage Policy
FS15 Food Thawing Policy
FS16 Meal Service Policy
FS16 A Resident Meal Receipt Verification Form
Policy No. Policy Title for Residential Care Service Delivery policies and procedures
SD1 Acquisitions Order Form
SD2 Common Abbreviations
SD3 Communication Policy
SD3 A   –  Sensory Communication Policy
SD4 Clinical documentation and report writing policy
SD5 Day Care Policy
SD5A Day Care – Client Care Plan
SD6 Family / Whanau / Resident Representative Contact sheet
SD7 Reassessment Referral Policy
SD8 Resident Inquiry for Admission Form
SD8 A Resident Inquiry for Admission Form (alternative form)
SD9 Resident Medical File Checklist
SD10 Transfer / Discharge of Residents Policy
SD10 A Transfer / Discharge Form
SD11 Medical Services Contract
SD12 Authorised Signatures register
SD13 Change of Resident Status Notification
SD14 Internal Telephone Numbers Listing

Audit Tips – Common findings in audits

Audits in the aged residential care sector in New Zealand are assessed against their ability to comply with a raft of legislation, standards and contractual requirements.

Below are common findings which continue to be reported on during audits:

 

Criteria

Gaps in meeting full compliance

Consumer Rights

– 1.1

·         Complaints management processes not completed as per                   requirements. Eg; not being logged on the complaints                         register, time-frames not being met, lack of evidence of                     resolution.

Organisational Management

– 1.2

·         Not completing internal audits

·         Not evidencing completion of regular meetings

·         Corrective action plans not being developed or completed

·         Lack evidence of investigation

·         Lack evidence of family notifications of adverse events

·         Lack evidence of reference checks at time of employing new             staff

·         Lack of 1st Aid certified staff member on each duty in each                 work area – this must consider the size, and layout of your                   building.

·         No signed employment agreement or job description

·         Lack evidence of timely completion of orientation

·         Annual appraisals not completed for all staff

Service Delivery

– 1.3

·         Lack of timely clinical assessment

·         Lack of assessment and care-planning related to behaviours               of concern (challenging behaviours)

·         Lack of evidence in progress notes of Registered Nurse input

·         Lack of evidence in progress notes of interventions from long             term care plan

·         Lack of evidence of family / residents input

·         Lack of evidence of outcomes from clinical assessments                     (including InterRai) being used to inform the care plan

·         Transcribing of medications in care plans

·         Doctor’s instructions in medical notes not followed /                             implemented

·         Wound assessment chart not updated as per wound care plan

·         Neurological observations not completed following falls                      where there was a possibility of the resident having sustained             a head injury

·         GP reviews not recorded at time-frames determined in ARRC

·         Lack of evidence of RN acting on caregivers reporting of                     adverse health symptoms in progress notes.

Safe and Appropriate Environment

– 1.4

·         Lack of evidence of medical calibration of equipment

·         Hoists not checked and verified as fit for use.

·         Surfaces unable to be cleaned adequately

·         Non labelled or decanted chemicals

·         Lack of evidence of hot water temperatures not exceeding 45            degrees

 

Restraint minimisation and safe practice – 2.0

·         No evidence of enabler monitoring

·         Lack of evidence of incomplete restraint register.

Infection prevention and control

– 3.0

·         Infection control nurse in care facilities who have not                           completed training in infection prevention and control and                  therefore cannot demonstrate relevant knowledge on which              to base practice and monitor staff performance.

·         Not all infections are noted on the infection register. Your                    policy and procedure should include the internationally                      recognised definitions for infections on which to base your                  monitoring.  For those of you using the HCSL policies and                   procedures, these definitions are noted within the Anti-                     microbial  Policy – document code IC1.

 

 

Ensure your internal audits review the above common errors to verify you are providing safe and appropriate services in all aspects of your service.

For more assistance with this contact us.

Pressure Injuries – ACC may be able to help

‘Pressure injury’ according to ACC can be classified in some instances as a ‘treatment related injury’ and therefore you may have the option of gaining support / assistance from ACC in relation to treatment of the pressure injury. In their 2011 fact-sheet, ACC noted “Pressure areas are a significant source of treatment injury claims and impact on both patient morbidity and mortality (1). Between July 2005 and March 2011, ACC accepted 506 claims for pressure areas, and notified 45 as adverse events to the Ministry of Health”.

As pressure injuries are a key focus for Ministry of Health (MoH) this year, auditors will be looking closely at the documentation around identification, management, treatment / care planning and evaluation of these events. Ensure you have comprehensive evidence of your clinical management processes.

Also remember when you log a pressure injury into the adverse event reporting system, you include the stage of the pressure injury. In the HCSL QA online system click ‘pressure injury’ in the ‘type of event’ box and then in the box directly under that, you can record the additional detail of the stage of the pressure injury.

The required MoH notification forms can be found here.  You will need the resident GP to complete a ACC45 form. Then contact ACC and rather than asking for what you want, ask what they can do to help. If you ask first, you may be missing out on something they could have provided access to.

For more information on seeking support contact Assistant ACC directly or the ACC Contracts Manager – CDHB Email: Leanne.davie@cdhb.health.nz

Medication Management Audit Tips

 

 Medication management relates to section 1.3.12 of the Health and Disability Services Standards and referred to in section D5.4 of the ARRC.  There are key reference documents which provide reference at facility level which should be used in conjunction and addition to your organisation policies and procedures.  These reference documents are (first two are key for residential care):

 

Medication errors of any type, when reporting through the audit process to MoH HealthCert as part of your audit, will receive a higher ‘weighting’ than other partial or non-attainments.  Even a single signature missing off an administration signing sheet may come into this category and mean your audit outcome is diminished.  Below are common errors which continue to be made:

Aspect of medication management 

Common Errors 

Medication charts

Not dated

Not signed by the prescriber

Not signed by the General Practitioner or Nurse Practitioner at each review (3 monthly)

Not legible

Allergies not documented (or inconsistent with other resident documents)

Transcribing on medication charts or PRN signing sheets

PRN medication charting does not include ‘indication for use’

Medication order does not include time, dose, frequency, route, type etc

Signing sheets

Missed signatures on the signing sheets

Only one signature (instead of two) on controlled drug administration records and register

PRN medication not signed for accurately

Self-medicating residents

Competency to verify self-medication not signed by prescriber

Competency for self-medication not signed as having been reviewed by prescriber (3 monthly)

Staff verification of self-medicating occurred not recorded on a shift by shift basis (as relevant to the individual residents medication order)

Not retaining a current list of all medication ordered for self-medicating residents

Storage

Medication not securely stored (also see ARRC D15.3(c)

Controlled drugs not entered accurately into Controlled Drug Register (at time of supply or return to pharmacy)

Controlled drugs not stored in locked cabinet in locked room

Drug trolley left in common areas unlocked

Expired medication continue to be stored on site (should be returned to pharmacy)

Medication for resident who has been discharge or deceased remain on site

Medication fridge temperature not monitored / recorded

Labels on medication containers not clear / legible

Identification of resident

Photograph not representative of current presentation of resident (photograph should be colour)

Photograph of residents not validated regularly

Medication errors

Not reported

Not managed (through an adverse event management process to ensure identification of contributing factor and preventive measures).

Competency

All staff (including Registered Nurses and Enrolled Nurses) involved in medication administration must have first successfully completed a medication competency

Annual review of medication competencies

If you’re uncertain about the competency of a particular staff member, do not be tempted to sign them off and monitor.  The risk is too high for the residents and your organisation.  Medication errors can be classified as ‘sub-standard care’ and due to the possible consequences, are at least a moderate risk.

Remember when changing staff around, the key priority is do you have a medication competent staff member on each duty and if controlled drugs are being administered, you need a minimum of two medication competent staff rostered on each duty.  Registered Nurses cannot be leaving the ‘hospital’ area of the facility to administer medication in other areas as this leaves the hospital residents vulnerable so this also needs to be factored into your rostering.  Refer to the Aged Related Residential Care Contract (ARRC) for further information.

Ensure your internal audits review the above common errors to verify you are providing safe and appropriate services in all aspects of medication management.