Home Health & Hospice Week

Hospitals that steer patients to their own home health subsidiaries could be driving themselves toward a survey disaster.

The Indiana State Department of Health initiated a complaint-based survey of Rochester, IN-based Woodlawn Hospital after receiving a letter from Lori Crispen, owner and administrator of Rochester-based Professional Home Care Inc., detailing a laundry list of criticisms about the hospital's referral practices to its own HHA, Woodlawn Home Health Care.

In a Nov. 5, 2002 letter to the ISDH obtained by Eli, Crispen alleged four specific examples of patients who were steered to Woodlawn's HHA during the hospital discharge planning process. Woodlawn HHA staff told patients there wasn't another agency in the town and Professional's staff worked in other cities, among other things, Crispen claimed in the letter. She also included complaints about assisted living facility deals.

Crispen felt compelled to write the letter after her referrals from the hospital came to a "screeching halt" in 2001, when new management took over the hospital's HHA, she tells Eli. Crispen founded Professional in 1996 and it remained a small but growing enterprise, serving more than 100 patients annually, until that year, she says.

In fact, Crispen didn't intend for the letter to be a formal complaint, she maintains. Rather, she was looking for guidance from ISDH officials on what she could do to save her business, the only other HHA in Fulton County in Northern Indiana.

ISDH surveyors lodged the letter as a complaint and visited Woodlawn Feb. 20, 2003 to conduct an investigation, says ISDH spokesperson Margaret Joseph. Surveyors then cited Woodlawn in three main areas, according to the survey's statement of deficiencies obtained by Eli:

1) Patient confidentiality. Woodlawn violated patient confidentiality when it allowed staff from its HHA to sit on "bi-weekly patient care conferences" for patients who were not yet admitted to its agency. The hospital also failed to have patients sign release forms allowing HHA staff to see patients' records upon referral. Finally, Woodlawn failed to list its HHA as an affiliate on its license.

2) Discharge planning. Woodlawn failed to perform effective discharge planning by not utilizing "available community resources" when it neglected to inform patients about other HHAs serving the area. Two records reviewed lacked documentation showing the hospital had given the patients a list of HHAs. And Woodlawn's discharge planning guide said while they had to pass out the list to patients, "we are not required to tell [patients] which HHC their physician prefers or orders."

3) Physician orders. One record reviewed lacked a physician's order for home care.

Following the survey, the hospital implemented a strategy to clean up its home care referral act, according to its plan of correction in the survey documents.

To address the patient confidentiality issues, Woodlawn corrected its license to show its agency as an affiliate, excluded all home health reps from its patient care conferences and adjusted its policy accordingly, and put in place a consent form for patients referred to HHAs. For six months, the provider will audit at least 50 percent of the charts for patients referred to home care for the consent forms.

Woodlawn also revised its referral policy to specify "each patient referred to home health care must be given a list of available agencies to select from." And physician orders must be present for a home care referral, the policy now states. The hospital promised to retrospectively audit for six months at least 50 percent of its home care-referred patients' charts for documentation of the list and written physician orders.

And Woodlawn in-serviced its case management department on the new policies, says the correction plan, accepted by ISDH March 28.

The hospital could be subject to a possible re-survey on site or over the phone to check up on its compliance with the correction plan, Joseph says.

But those actions didn't come soon enough to help Professional Home Care, which is set to close its doors May 6, laments Crispen. The HHA lost most of its staff when its patient rolls dwindled considerably. "They just closed us out, and now it's too late," she says.

Woodlawn officials didn't respond to repeated inquiries for this story.