Cavuto,Ceci ia (DADS) Fri, Apr 29, 2016 at 11:41 AM To: "Hacker, Holly" Here is the answer to your question about how surveyors made their findings: The surveyor based her conclusions on review of the clinical records, hospice protocols and interviews. The RN surveyor analyzed the findings and determined that the hospice nurses continued to administer the medications even though there was no evidence in the record the client needed the drug at the time of the administration. She determined hospice staff did not follow the agency protocols for the administration of medications. She determined the staff did not follow regulations for the state home health licensing rules regarding the documentation of medications and they did not follow the Texas Board of Nursing (BON) rules regarding documentation and provision of care. She used her knowledge and experience as a Registered Nurse, her prior knowledge and experience as a former provider of hospice care in a home health setting and her knowledge and experience of state regulations as a surveyor in making the determination that ten clients were over- medicated. The surveyor identified the overmedication was not due to improper physician medication orders. The surveyor determined the ordered drugs, dosing and frequency prescribed by the physicians were appropriate for hospice patients. Rather, the surveyor?s conclusion that ten clients were overrnedicated stemmed from the hospice agency nurse?s improper implementation of those orders to the individual clients.