Advocates4QualitySafePatientCare wishes to thank the California Department of Public Health (CDPH) for responding promptly to our request for dialysis facility surveys. Our request was the result of patients, their family members, and significant others, who wanted to be aware of the survey findings for their unit, but were fearful to ask the facility for a copy, or even to request one through the state. Some patients had even requested for their unit to share the survey findings with them, but were brushed-off. We understand the level of fear and how a patient, or their loved one comes to such. Therefore, we have posted the California 2020 facility surveys which include initial inspections, recertification inspections and complaint investigations. We hope that this meets the needs of the many who have contacted us.
As advocates, we found it interesting that when the Conditions for Coverage (federal regulations for dialysis facilities) were revised, that there was no regulation mandating dialysis clinics to post their most recent survey report in a conspicuous place. When we submitted our public comment, for the revised Conditions, we suggested such. Question – Why do we not see this level of transparency. A few states post the surveys on their website and a few states have state-level regulations that call for sanctions for certain level deficiencies.
It is important when reading the surveys to know and understand that after the Surveyors inspect the unit, they return to their office and write a document named “Statement of Deficiencies” (F2567). After writing this document which includes the deficiencies, identifying what regulation was not in compliance, the F2567 is returned to the dialysis facility. Upon the facility’s receipt of the survey document from the state, the facility is then required to develop a writiten Plan of Correction (POC). This POC is then returned to the CDPH (Licensing & Certification Division) for review and acceptance, or denial. The facility is suppose to adhere to their POC.
In our review of these surveys, we were shocked to see the numbers of cited deficiencies in infection control. We are reminded of being told by many dialysis healthcare professionals that delivery of care would change with the newly revised Conditions. It is our opinion that nothing has changed in regards to implementing effective infection control practices since the new Conditions were released, as evidenced in these surveys. Furthermore, we are greatly concerned that we saw ‘involuntary discharges’ with no staff interventions focused on determining reasons for a patient’s behavior and/or staff’s behavior.
These surveys, again, clearly demonstrate that there needs to be a complete overhaul and cultural transformation in the dialysis units so that patients receive quality safe care. Providers need to ensure that their staff understand that facility policies and procedures MUST be followed, that managers are supervising appropriately and that staff are fully educated and trained. Until providers understand that this is the foundation of delivery of quality safe care, we will continue to see such deficiencies that place patients in harm’s way.
Another, most important component of this process that one must remember is that the Surveyors are only looking at a sample of medical records and interviews. If their observations identify noncompliance then further records might be reviewed and the process expanded. However, one must ask the following question, “If a facility has, for instance, a total census of 180 patients, the sample might be only 15 patients. This leads to a further question – “If there are deficiencies noted within this sample group, are these deficiencies occurring outside this sample? There is no way to tell unless all medical records are reviewed. An example is the patient who is not included in the sample but whose EDW is not reached, and there are no staff/physician interventions documented in the medical record, and the patient has negative outcomes as a result of continually being over EDW. Or the patient, who is not in the sample but had complications due to the wrong potassium or calcium dialysate being used. As advocates, this is the scarey part for us, especially after we have communicated with so many patients who have shared problems they have encountered.
In conclusion, we must remember that if the cited deficiencies in these survey findings are happening to a small sample, then what are the chances that other patients are experiencing the same? A good chance, we believe.
Roberta Mikles, BA RN, Director
Note: We are experiencing some problems with the surveys and ability to open, please contact Roberta at or call 858-675-1026. We will be happy to email you any of the surveys.
surveys conducted Jan-Aug 2020
Davita (see below and click on facility)
North Hollywood Dialysis
Union City Dialysis
Walnut Creek Dialysis
West Sacramento Dialysis
DCI – (see below and click on facility)
Fresenius (FMC) (see below and click on facility)
Imperial County Dialysis-El Centro
Rancho Cucagmonga Dialysis
Rancho – Rancho Bernardo Dialysis
Santa Barbara Dialysis
South Orange County Dialysis – Santa Ana
San Bernardino Dialysis
San Diego South – Gateway Dialysis
Woodland Hills Dialysis
Independent – non profit (see below and click on)
Santa Clara Dialysis
Sierra View District Dialysis
West Coast Dialysis
Independent – profit (see below and click on)
Desert Cities – Victorville Dialysis
Pluma 8th St Dialysis
RAI (see below and click on)
Broadway Dialysis – Chula Vista
Mission Gorge – San Diego