Statement of the Long Term Care Community Coalition on Reports of Multiple Deaths at the Florida Nursing Home Rehabilitation Center at Hollywood Hills.

We are extremely distressed by reports of multiple resident deaths at the Rehabilitation Center at Hollywood Hills nursing home.  Nursing homes are charged with safeguarding vulnerable residents 24-hours a day, 7-days a week. Every facility that is licensed by Medicare and/or Medicaid makes a promise to residents and their loved ones that they will provide sufficient staffing, care and other services necessary to ensure that every resident is safe, comfortable and able to live with dignity. In addition to the promises made to individuals, these promises extend to the American public, which pays for a substantial portion of nursing home care, including care provided by this for-profit nursing home.

Safeguarding residents during hurricanes and other natural disasters is a longstanding, integral component of nursing home requirements in this country. We believe that it should go without saying that a nursing home has the available resources – and its staff sufficient knowledge – to take the steps necessary to avoid residents being placed in dangerous or precarious situations. However, because, too often, facilities do not provide sufficient staff or services that meet minimum standards, the federal government has established specific requirements and guidelines for ensuring that residents are protected under emergency circumstances.  Following  are excerpts from CMS materials on federal emergency preparedness requirements (“CMS Emergency Preparedness Rule” presentation, available at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html):

  1. An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters, including internal emergencies and a man-made emergency (or both) or natural disaster. This approach is specific to the location of the provider or supplier and considers the particular type of hazards most likely to occur in their areas. These may include, but are not limited to, care-related emergencies, equipment and power failures, interruptions in communications, including cyber-attacks, loss of a portion or all of a facility, and interruptions in the normal supply of essentials such as water and food. [Emphasis in original.]
  2. Policies and procedures must address a range of issues including subsistence needs, evacuation plans, procedures for sheltering in place, tracking patients and staff during an emergency. [Emphases added.]
  3. Coordinate  patient care within the facility, across health care providers, and with state and local public health departments and emergency management systems.
  4. Develop and maintain training and testing programs, including initial training in policies and procedures. Demonstrate knowledge of emergency procedures and provide training at least annually. Conduct drills and exercises to test the emergency plan.
  5. Facility-Based: When discussing the terms “all-hazards approach” and facility-based risk assessments, we consider the term “facility-based” to mean that the emergency preparedness program is specific to the facility. Facility-based includes, but is not limited to, hazards specific to a facility based on the geographic location; Patient/Resident/Client population; facility type and potential surrounding community assets (i.e. rural area versus a large metropolitan area). [Emphasis added.]
  6. Long-term care… facilities must share information from the emergency plan with residents and family members or representatives. [Emphasis added.]

In addition, we believe that it is important to note that this facility has a low overall rating on Nursing Home Compare, with particularly low ratings for its health inspection performance. As of today (September 13, 2017) this nursing home has two out of five stars for its overall rating and only one out of five stars (the lowest possible) for its health inspection rating. It rated above average for its staffing rating, however, it is important to note that this rating component is currently self-reported by facilities and unaudited by either the state or federal governments.

The facility’s Nursing Home Compare profile can be accessed here:https://www.medicare.gov/nursinghomecompare/profile.html#profTab=0&ID=105021&Distn=2.5&loc=HOLLYWOOD%2C%20FL&lat=26.0112014&lng=-80.1494901.

It is our belief that more questions need to be asked about the preparedness of this facility, whether it had and followed an appropriate emergency plan and whether or not the Florida Department of Health took the steps necessary to ensure that this facility was in compliance with minimum standards.