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.

 

Moving  and Handling People – Good Practice Guidelines – December 2017

The Draft Moving and Handling guidelines are currently being finalised with the view to be implemented from December 2017.  Developed by Worksafe, they cover Health and Safety at Work Act 2015 (HSWA) duties and risk management for PCBUs in the health care industry and supersede the 2012 guidelines.  There are a range of factors noted in these which need to be taken into consideration for those building new facilities or doing refurbishment of existing facilities. There is also a raft of information on Bariatric Care which is an increasing part of the services being provided in residential care.

The draft guidelines include the following:

Please note that there is not a complete consensus on the criteria for classifying a person as bariatric based on weight or Body Mass Index (BMI). However some examples include those people:

– with a body weight greater than 140 kilograms.

– with a BMI greater than 40 (severely obese), or a BMI greater than 35 (obese) with co‑morbidities.

– with restricted mobility, or is immobile, owing to their size in terms of height and girth.

– whose weight exceeds, or appears to exceed, the identified safe working loads (SWLs).

Health risks for bariatric clients

People who have been bariatric for a considerable time face chronic and serious health conditions, many of which should be considered before moving or handling them. Health conditions to take into account include:

– skin excoriation

– rashes or ulcers in the deep tissue folds of the perineum, breast, legs and abdominal areas

– fungal infection

– bodily congestion, including causing the leaking of fluid from pores throughout the body, a state called diaphoresis, which makes the skin even more vulnerable to infections and tearing

– diabetes

– respiratory problems

– added stress to the joints, which may result in osteoarthritis.

Planning for bariatric clients:

The planning process for bariatric clients in order to reduce moving and handling risks should include:

– admission planning

– client assessment

– communication

– room preparation

– mobilisation plan

– equipment needs

– space and facility design considerations

– planning for discharge.

Facility and equipment needs for bariatric clients

Health care and other facilities providing care for bariatric clients need to provide adequate spaces for these clients. Some considerations could include:

– ramps and handrails at entrances

– bariatric wheelchairs

– that the facility’s main entrance has sufficient clearance

– adequate door clearance and weight capacity in lifts

It must be remembered that the above comes from a draft but as drafts often end up being very close to the finished document, I felt it timely to share this information. To read more on Health and Safety in the Workplace go 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

 

HCSL Mobile app for Internal Audits

Mobile app now available for conducting your residential care ARRC specific internal audits.

There are a full range of internal audits pre-loaded ready for use. Collectively, these audits reflect the criteria Certification auditors will be checking.

 

This process gives you the opportunity to be sure you’re on track with achieving compliance. The findings auto-populate into corrective action tables which prompt timely addressing of these corrective actions. This system syncs with your main computer system and makes reporting to management and Governance boards very easy.

 

The Certification auditors (after given specific access authority with your permission) are also able to access the results of the internal audits you’ve completed.

To view a brief video on the use of this system, click here.

Attendee Testimonial for Aged Care Education Study Day – July 2017

Topics included: Quality & Risk Management, Clinical Leadership, Clinical Documentation, EPoA, ARRC, Communication and Difficult Conversations

 

I am writing this endorsement on behalf of my colleague and myself, in relation to our attendance at the study day you hosted 5 July 2017.

The topics you presented were most relevant to our Registered Nurse role within the aged care sector, and between us both provided new learning opportunities, as well as refreshing the current knowledge we already held.

You addressed each session in a professional and engaging manner that held our attention, complemented by comprehensive written material as well as PowerPoint presentations, along with plenty of opportunity for questions and comments from the floor.

Gillian you are one of very few speakers that is able to hold my attention for more than one session let alone a whole study day, a perfect balance between speech and conversational styles!

We were also most impressed by the quality of the complementary gift bag that was given to each attendee containing not only goodies to help us through the day, but with something to take back to the workplace, I acknowledge both Cubro and Ebos for their support with this.

The venue was great with easy access and good parking, and it was clean and refreshing providing plenty of comfort and personal space for those attending. I will be recommending my associates to make a note in their diary for next time. Thank you Gillian

Kind regards

Lyn Black

Bloomfield Court Retirement Home – Canterbury

Success Leaves Clues

Success leaves clues but often these aren’t being picked up so you miss the learning and miss the opportunity to recognise growth or gain continuous improvement in your audits.

In residential care, HealthCert (MoH) Certification processes appear solely to promote a goal of verifying compliance with requirements. Looking deeper however, the goal of meeting requirements ensures the protection and support of those in your care. This can then be evidenced in a way that’s reflective of service received as meaningful, safe and appropriate by individual residents.

It’s no longer an expectation that you’ll have a number of partial attainments as a result of an external audit. The expectation is full compliance and showing evidence of continuous improvement, going over and above the base ‘pass-mark’ brings you into line with your high performing peers. I’ve heard managers say “but it’s the Auditors job to find things wrong so we expect to get partial attainments.”  That is out-dated thinking and doesn’t fit the current audit and compliance environment or continuous improvement philosophy.

Systems can’t be implemented to show compliance, if staff are not looking at policies and procedures, or using them to guide services and care of residents. If individual staff or managers do what they think best, based on previous experience, without verifying whether that practice is still appropriate or best practice, they do themselves and residents a disservice.

Success leaves clues.  It’s apparent when quality systems are implemented, outcomes are checked in a measurable way, recorded, examined, analysed and greater gains identified for future implementation.  This is a cycle and if you have the right tools to record your continuous improvement projects on, you too will be in the elite who are out-performing those who continue to have multiple partial attainments (deficits) in audit.   Don’t be a provider that looks at others saying it’s ok for them; they have this or that or the other reason for their success but we don’t have those things so we can’t achieve.  Don’t make others extraordinary to let yourself off the hook.  You can have, and deserve to have, all the recognition for the amazing work you perform just like others who are achieving four years.

The lack of a robust up to date quality system, along with deficits in implementation, will lead you down an expensive compliance track. Expensive in loss of reputation as audits are published and accessed online by the public, expensive in loss of time trying to figure things out yourself, increased risk to residents, loss of financial resources as you end up being audited more often than would have otherwise been necessary. The better you achieve at audit, the longer your period of certification, the less often you are audited and therefore less often you’re paying auditors fees!

A common failing in the care facilities under Temporary Management has been from the lack of a proven quality system and application of that system into service provision. I’ve been contracted into a number of sites as a Temporary Manager over the years and this has consistently been the case.

If you would like a free Continuous Improvement Project template to help you identify and record your success, contact us and we’ll email it to you.

Go here to read testimonials from a few of our clients.

Influenza season

Prepared for winter coughs and colds?

Winter is fast approaching and now is the time to be preparing your facility for the season’s usual crop of influenza, coughs and colds.

Last year the elderly were hit hard with, not just influenza, but also other respiratory viral infections. Many were admitted to hospital with complications such as pneumonia.

The predominant circulating influenza strain in 2016 was Influenza A, H3N2, different from the previous year’s Influenza A, H1N1. Although covered by the vaccine, last year’s predominant strain changed slightly from what was covered in the vaccine and there were numerous reports of laboratory confirmed cases of young vaccinated adults who still acquired influenza. Despite this, vaccination still affords some protection and symptoms are less severe than without it. This is the same for the elderly whose uptake of the influenza vaccine is not so good – experts agree that there are still benefits from the elderly having an annual influenza vaccine.

Some of the other respiratory viruses last year that caused severe disease in our elderly included coronavirus, rhinovirus and parainfluenza.

 

Check list for winter virus planning

  • Encourage and offer seasonal influenza vaccination to both staff and residents
  • Ensure hand sanitiser is available for visitors at the entrance of the home
  • Consider displaying a poster discouraging visitors with symptoms – a poster is available from CDHB communications
  • Remind staff and residents about good cough etiquette / respiratory hygiene
  • Have a good stock of tissues and hand sanitiser for residents
  • Remind staff to stay off work if sick – no-one wants their germs!
  • Educate staff about S&S of influenza – not all residents will display fever or cough
  • Keep residents in their rooms if symptomatic and introduce droplet precautions, i.e. droplet masks for staff providing cares
  • If you suspect an outbreak then confirm the outbreak[1] and introduce control measures[2]

Ensure all infections are logged into you infection register (for HCSL QA online uses – this is part of your infection log process) – remember your outbreak notification requirements as per your policies and procedures.  If you would like more assistance with this please contact us.

 

This article kindly contributed by: Ruth Barratt RN, BSc, MAdvPrac (Hons) – Independent Infection Prevention & Control Advisor (Canterbury)

Infectprevent@gmail.com

[1]  Infection Prevention & Control Guidelines for the management of a respiratory outbreak in ARC / LTCF

[2] A Practical Guide to assist in the Prevention and Management of Influenza Outbreaks in Residential Care Facilities in Australia

Village Manager – Chatswood Retirement Village

I have found that having Gillian’s (the HCSL) system available has been a huge help to our village. Documents are easily accessible at my fingertips and it hasn’t taken long to memorise some of the codes for the more frequently used ones.

 

If we are having trouble finding a document or we want to make any adjustments, Gillian is always very accommodating and helpful. She is easily contacted by telephone or email and if she is busy, always gets back to me as soon as she is able to. I particularly like that if I want to type into a document, Gillian makes this available.

 

When the documents are due for updating, Gillian takes care of this, printing all of the documents and putting them into new folders for us. She even delivers them personally, which is always a pleasure. I find Gillian very approachable and extremely knowledgeable and happy to share her knowledge.

 

Gillian assists us with our training requirements by coming to Chatswood and going through the annual compulsory subjects with myself and my staff. She is great at presenting and the passion about her work shows in the way she shares her own experiences with us.

 

I look forward to our continued working relationship.

Kyla Hurley – Village Manager

January 2017

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.

Quality Management Systems

The below question and answer were published in the New Zealand Aged Care Association industry ‘In-Touch’ newsletter (19th February 2016).

Question: A member asks “if we purchase a comprehensive quality management system from a provider how assured are we that the system will meet full compliance, come certification and surveillance audit time, as requirements and compliance expectations change frequently?

NZACA Clinical Advisor Answer: “You should be purchasing a complete quality management system that will comply with the Health and Disability Standards specifications, health and safety requirements and meet DHB/ARRC contractual requirements.

The provider of the system would normally initially tailor the full quality management package to reflect accurately the site specifications, H.R. component, and best practice guidelines, after consultation with the owner and management on site. These documents need to be site specific. The provider will normally contract to the site, which sets out obligations between the provider and the site management.

The contract will include the full review and updates of policies and procedures on a bi-annual basis, unless specified more frequently, to keep documents accurate and reflective of best practice. There may be an educational element provided within the contract as well, to benefit staff knowledge and skills. There is normally a good document control system in place and cross referencing of information where required.

Quality management systems are reliant on the skills and knowledge of the site personnel working with them, the way the system is managed and the outcomes/reviews, content and information extricated from the use of the system to improve quality care provision/outputs. The documentation system is reflective of the people using them, and the depth to which documentation and information is created, analysed and utilised for improvements.

Auditors on site rely on the provision of robust up-to-date policies and site adherence to them. Partial attainments can sometimes result from staff deviating from, or not following, their sites actual policies or processes as outlined in their quality management system.”

Where can you get such a system? 

Here at Healthcare Compliance Solutions Ltd we provide the services described above and noted as being optimal for achieving excellence in care and audit outcomes. 

Request a no obligation consultation here.