INITIAL COMMENTS
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This report is a result of an onsite follow-up inspection pertaining to the plans of correction for an administrative review of August 3, 2012 of the July 18, 19 and 20, 2012, methadone monitoring inspection. The follow-up inspection was conducted on January 22 and 23, 2013, by staff from the Department of Drug and Alcohol Programs Licensure. Based on the findings of the onsite follow-up inspection, RHD Montgomery County Methadone Center was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during this inspection:
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Plan of Correction
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715.16(f) LICENSURE Take-home priveleges
(f) An exception granted under subsection (d) shall continue only for as long as the temporary disability or exceptional circumstance exists. When a patient is permanently disabled, that case shall be reviewed at least annually to determine whether the need for the exception still exists.
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Observations
Based on the review of patient records and administrative documentation, the facility failed to annually review the exception for 13-day take-home to determine whether the need still existed.
The findings include:
Twenty patient records were reviewed July 18 to 20, 2012. The Methadone Monitoring Questionnaire documented nine patients at the facility had 13-day take home privileges by exception. Two records were reviewed for documentation of annual determination for continuation of the exception due to permanent physical disability. Both records failed to include documentation that the justification for 13-day take homes still existed, specifically in patient records #18 and 20.
The findings were reviewed with the Facility Director and Clinical Supervisor.
This remained out of compliance at the time of the follow up.
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Plan of Correction
A clinical Meeting will be held by the Clinical Supervisor with the Clinical Staff and the PA-c and Medical Director to address the need to conduct an annual review of the 13 day exceptions to determine if the need continues to exist. PA-C will be responsible to oversee this project and Program Director will oversee to ensure for compliance. Completion date 2/22/13
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715.17(c)(1)(i-vi)) LICENSURE Medication control
(c) A narcotic treatment program shall develop and implement written policies and procedures regarding the medications used by patients which shall include, at a minimum:
(1) Administration of medication.
(i) A narcotic treatment physician shall determine the patient 's initial and subsequent dose and schedule. The physician shall communicate the initial and subsequent dose and schedule to the person responsible for the administration of medication. Each medication order and dosage change shall be written and signed by the narcotic treatment physician.
(ii) An agent shall be administered or dispensed only by a practitioner licensed under the appropriate Federal and State laws to dispense agents to patients.
(iii) Only authorized staff and patients who are receiving medication shall be permitted in the dispensing area.
(iv) There shall be only one patient permitted at a dispensing station at any given time.
(v) Each patient shall be observed when ingesting the agent.
(vi) Administering and dispensing shall be conducted in a manner that protects the patient from disruption or annoyance from other individuals.
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Observations
Based on the review of patient records, someone other than the narcotic treatment physician documented the patient's dose schedule in one of two records reviewed.
The findings include:
Five patient records were reviewed on January 23, 2013. Two patient records were reviewed for involuntary termination. The medication orders were reviewed for the two patients.
Patient # 5 was admitted on August 18, 2009, and involuntarily discharged on October 3, 2012. The record was reviewed for documentation of the narcotic treatment physician initiating the dose change. The narcotic treatment physician signed an order on September 18, 2012. The physician's signature was in black ink. The checkmark for the administrative detox, the 14 day detoxification dose, the facility director's signature and date were in blue ink. Other documentation of the physician's order was requested and it was reported this was the only documentation in the record. A review of this documentation could not confirm that the dose schedule was prepared by the physician.
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Plan of Correction
A meeting was held between the Medical Director and the Program Director to establish protocol for the administrative discharge of a patient and the need for the Narcotics Physician to prepare the dose schedule for the individual and document justification thereof. All future Administrative Dicharges will be done upon the recommendation of the PD but soley decided by the evaluation of the Patient by the Medical Director and written justification of this order. Program Director will monitor this documentation for completeness Completed 2/21/13 |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on the review of patient records, the facility failed to provide each patient an average of 2.5 hours of psychotherapy per month during the patient's first 2 years of treatment in one of one record.
The findings include:
Five patient records were reviewed on January 23, 2013. Two patient records were reviewed for psychotherapy services within the first 2 years of treatment.
Patient # 6 was admitted September 18, 2012. The average psychotherapy hours were reviewed for the months of October, November and December 2012. The patient averaged 1.83 hours of psychotherapy for the three months reviewed.
The findings were reviewed with the facility director and clinical supervisor and confirmed.
This is a repeat citation from August 3, 2012.
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Plan of Correction
A clinical meeting will be held by the Clinical Supervisor with the Clinical Staff to review the need for patients to receive at least the minimum of 2.5 Clinical Hours per month during the first 2 years of treatment. Clinical supervisor will monitor for compliance and Program Director will oversee this coompliance. Completion Date 2/22/2013 |
715.21(1)(i-iv) LICENSURE Patient termination
A narcotic treatment program shall develop and implement policies and procedures regarding involuntary terminations. Involuntary terminations shall be initiated only when all other efforts to retain the patient in the program have failed.
(1) A narcotic treatment program may involuntarily terminate a patient from the narcotic treatment program if it deems that the termination would be in the best interests of the health or safety of the patient and others, or the program finds any of the following conditions to exist:
(i) The patient has committed or threatened to commit acts of physical violence in or around the narcotic treatment program premises.
(ii) The patient possessed a controlled substance without a prescription or sold or distributed a controlled substance, in or around the narcotic treatment program premises.
(iii) The patient has been absent from the narcotic treatment program for 3 consecutive days or longer without cause.
(iv) The patient has failed to follow treatment plan objectives.
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Observations
Based on the review of patient records, the facility failed to restrict the reasons for involuntary termination to those reasons allowed by regulation in two of two patient records.
The findings include:
Five patient records were reviewed on January 23, 2013. Two patient records were reviewed for involuntary termination, # 4 and 5
Patient # 4 was admitted on November 22, 2011, and involuntarily discharged on October 11, 2012. The reason for discharge was identified on a Notification of Decision Regarding Involuntary Transfer or Administrative Detoxification form dated September 19, 2012. The form stated the following reasons: "ongoing drug related activity reports, i.e., attempts to buy urine, alleged selling of pills, threatening behavior in clinic, i.e., verbal abuse with staff." The form noted an appeal must be received by September 21, 2012. A second Notification of Decision Regarding Involuntary Transfer or Administrative Detoxification form was dated September 24, 2012. The form stated "as per our agreement, 14 day detox will start on September 25, 2012."
Patient # 5 was admitted on August 18, 2009, and involuntarily discharged on October 3, 2012. The reason for discharge was identified on a Notification of Decision Regarding Involuntary Transfer or Administrative Detoxification form dated August 20, 2012. The form stated the following reason: "Confrontation with another patient in a threatening manner." The form noted an appeal must be received by August 23, 2012. A second Notification of Decision Regarding Involuntary Transfer or Administrative Detoxification form was dated September 18, 2012, with an appeal date of September 21, 2012. The form stated "On 8/20/12 you were given a letter requesting that you transfer. I have not received a written appeal to date but your counselor and I agreed to put you on a 45 day contract to complete services, give clean urines, etc. You have failed repeatedly to follow through with your counselor regarding this to date. Therefore, at this time you are on a 14 day administrative detox."
This is a repeat citation from August 3, 2012.
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Plan of Correction
A Management meeting has been held with the Program Director, Clinical Supervisor, Medical Team to review criteria for reasons to restrict the reasons for involuntary terminations to the reasons allowed in the Licensure regulations only. Program Director will monitor for compliance. Completed 2/13/2013 |