This is a difficult story for everyone
involved, most certainly the patients and their families and physicians, as
well as many hundreds of ex-employees and volunteers, donors and creditors.
It is a difficult story to report…like chasing chickens…particularly when transparency
doesn’t appear to be a value embraced by the current regime. Local reporters
must rely on the Freedom of Information Act to get past the obfuscation of the
spokesman for the distressed organization.
Jul 1, 2010 –
The Board
Chairman announces the appointment of a former public relations
and fundraising functionary with the San Diego Hospice Foundation
as President and Chief Executive Officer, succeeding Jan Cetti who has retired
after 14 years at the helm of SDHIMC
Feb, 2011
–
A
team of 8 Medicare auditors spend 5 days on site reviewing 149 charts of patients admitted
to service between 1/1/09 and 11/30/10, the results of which are, more than 2 years hence, yet to be disclosed,
according to CEO Pacurar.
Sept, 14
– Sept 22, 2011 –
A
team of 4 surveyors arrive from the CA Dept of Public health arrive to conduct a routine
Medicare re-certification survey. Initially 20 patients are sampled. The
survey which lasts 8 days includes home visits to 5 patients. Nine deficiencies are cited
including agency leadership for failure to assure
reporting of Adverse Events including errors in the use of a Computer-aided Drug Delivery (CADD)
pump resulting in a patient receiving
5x the prescribed dose of morphine sulfate. In the course of the survey
the agency spontaneously reports two additional similar recent events. The survey
sample is amended to include these patients. According
to the survey:
The facility failed to implement immediate corrective actions to prevent reoccurrence
of CADD pump (continuous ambulatory delivery device used
to deliver narcotic analgesia) narcotic
overmedication incidents, after
the first incident on 8/7/11. Within 40 days of the first incident, 2 more
patients were involved in CADD pump
narcotic overdose incidents. The
Vice President of Inpatient &
Nursing Services and the Manager of
Pharmacy
were notified of an Immediate
Jeopardy on 9/16/11 at 5:05P.M.
Less
than two hours after the Immediate Jeopardy designation, the Vice President of Inpatient & Nursing
Services.presents a 7-point plan of correction.
Surveyors respond favorably and the Immediate Jeopardy is abated
at 6:40 P.M.
State
surveyors return to verify implementation of the Plan of Correction
A
senior official of the Survey and Certification Division of Medicare writes:
Contrary to
your allegations of correction, however, this resurvey, completed on December
12,2011, documented your continued noncompliance with Federal health and safety
requirements. More specifically, as detailed on the enclosed the Statement of
Deficiencies (Form CMS2567), the contents of which are incorporated by
reference herein, the survey completed on December 12, 2011, documented
deficiencies that, on balance, reasonably support a conclusion…of continued
noncompliance with Federal health and safety requirements”.
Medicare
lifts its decertification warning, as a result of a revised Plan of Correction, which
perhaps includes engagement of an outside clinical compliance team. It is unknown whether a
formal Medicare Compliance Plan
exists, or if this represents the advent of such.
Pacurar
implements a patient care staff retraining program, presumably in response to the
findings reported by the outside clinical review team she has engaged.
A
moratorium on patient admissions is imposed for a weekend
In apparently
the first press report(s) (SD Union Times)
of the organization’s distress, several almost contradictory
claims are attributed to
President and Chief Executive Officer Pacurar.
o
Although post
payment audit results are still unknown, Pacurar said she believes there will
be enough financial pain to require layoffs of up to 200 of the hospice’s 870
employees. “The organization, after the first of the year, will look different
than it does today,” Pacurar said. “It
will be smaller. It will focus solely on the great care of hospice patients.”
o
Pacurar said
she believes the hospice is vulnerable to millions in rebates to Medicare
because the program has not been strict enough in making sure that its patients
are truly suffering from an illness likely to cause death within six months.
She said doctors and care givers operated for decades on an “open access”
policy that kept patients on hospice care for longer than six months, sometimes
without being able to demonstrate that their condition was worsening.
o
The executive
said she also dismissed the hospice’s previous chief medical officer (also the
Chief Financial Officer…reported elsewhere) and instituted a new compliance
department that will regularly audit patient charts before requesting payment
from Medicare.
o
It remains to
be seen, she said, how much of that amount the federal government will want
back. At first, officials said they worried that the number could be as high as
60 percent. However, a recent
conversation with a Medicare official gave them hope to believe any rebate will
not be so high that it will cripple the operation.“I’m quite excited about
moving forward. I have recently added new leadership to help me execute the
plan that we’ve developed to take us through this difficult time,” she said
o
Within weeks of that report, Medicare notifies the
organization they will be subject to 100% pre-payment claims review, but that
decision is almost immediately revised to 100% post payment claims review is instituted;
serious payment interruption is averted
In a December
meeting of the Board of Directors, the month-old Hospice Chief Operating Officer, who as
subsequently revealed in a Bankruptcy
Court deposition has no operational health care experience, much less
hospice, presents an "analysis" to the Board of Directors and the CEO, ostensibly a
strategic plan that features two
very grim options: (a.) continue to operate as best as possible, under
intensified regulatory scrutiny and possible financial damage as may potentially result from the Medicare
audits, repair the organization and maintain
the 35 year-old mission or (b.) accept the second option which the gentleman admits he favors: Shut it
down…
San Diego
Hospice and Palliative Care Corporation files Chapter 11. Subsequent reports reveal the Board of
Directors decision made in December
to close the organization. Reports also cite some type of affiliation arrangement with Scripps
Memorial Hospital that provides (a.) SDHIPC
a $5M operating loan, (b.) an offer to purchase SDHIPC-owned real estate for $10.7M subject to bankruptcy
court approval (c.) absorption of
remaining employees as well as (d.) patients (subject to Scripps qualification of eligibility) into a small (2012 unduplicated census: 86 patients), for-profit, licensed and
certified hospice in Poway, which Scripps
has acquired in the preceding days and weeks.
Mar 12, 2013 –
Deposition of San Diego Hospice & Institute of
Palliative Care Chief Operations Officer: