INITIAL COMMENTS
|
This report is a result of an on-site inspection conducted for the approval to use a narcotic agent, specifically Methadone, in the treatment of narcotic addiction. This inspection was conducted on July 16 to 18, 2013, by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, RHD Montgomery County Methadone Center was found not to be in compliance with the applicable chapters of 4 PA Code and 28 PA Code which pertain to the facility. The following deficiencies were identified during this inspection.
|
Plan of Correction
|
715.9(a)(4) LICENSURE Intake
(a) Prior to administration of an agent, a narcotic treatment program shall screen each individual to determine eligibility for admission. The narcotic treatment program shall:
(4) Have a narcotic treatment physician make a face-to-face determination of whether an individual is currently physiologically dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenance treatment. The narcotic treatment physician shall document in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction.
|
Observations
Based on the review of patient records, the facility failed to determine current dependency in one of four records reviewed.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. Four patient records were reviewed for physician documentation of evidence of a one year history of addiction.
Patient # 15 was admitted on September 11, 2012, and discharged on January 23, 2013. The patient record documented prior treatment at an inpatient facility and completed detoxification in August 2012. The facility failed to document evidence of a one year history of addiction.
The findings were reviewed with the Facility Director and Clinical Supervisor.
This is a repeat deficiency from the monitoring visit on 7/20/2012.
|
Plan of Correction
A meeting has been held with the Program Director, Medical Director, Clinical Supervisor and Intake Personnel to review requirements regarding admission criteria and the need for documented 1 year history of Opioid Addiction. Medical Director and Program Director will monitor this documentation for compliance prior to admission. Date Completed August 5, 2013. |
715.16(c)(1)(i-iv) LICENSURE Take-home privileges
(c) A narcotic treatment program shall require a patient to come to the narcotic treatment program for observation daily or at least 6 days a week for comprehensive maintenance treatment, unless a patient is permitted to receive take-home medication as follows:
(1) A narcotic treatment program may permit a patient to reduce attendance at the narcotic treatment program for observation to three times weekly and receive no more than a 2-day take-home supply of medication when, in the reasonable clinical judgment of the narcotic treatment physician, which is documented in the patient record:
(i) A patient demonstrates satisfactory adherence to narcotic treatment program rules for at least 3 months.
(ii) A patient demonstrates substantial progress in rehabilitation.
(iii) A patient demonstrates responsibility in handling narcotic drugs.
(iv) A patient demonstrates that rehabilitation progress would improve by decreasing the frequency of attendance for observation.
|
Observations
Based on the review of patient records, the facility failed to ensure that the patient met the requirements to have reduced attendance at the narcotic treatment program in one of two records reviewed.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. Two patient records were reviewed for no more than a two-day take-home supply of medication. One patient record contained documentation of an approval for take-home medication that did not meet criteria for eligibility for take-home status.
Patient # 1 was admitted January 22, 2013. A two-day take-home supply was approved by the narcotic treatment physician and documented on February 6, 2013, 15 days after the patient entered treatment. The patient did not meet eligibility requirements to receive the two-day supply of take-home medication as patients are required to be in treatment for at least 90 days before he or she can be considered for take-home status.
The findings were reviewed with the Facility Director and Clinical Supervisor and confirmed.
|
Plan of Correction
A meeting has been held with the Program Director, Medical Director, Clinical Supervisor and Intake Personnel to review requirements regarding Take Home medication criteria and eligibility and the need for Medical Director approval meeting this criteria and any exceptions to this must be made solely by the Medical Director. Program Director will oversee this project.Date Completed 8/5/2013 |
715.16(c)(3)(i-viii) LICENSURE Take-home privileges
(c) A narcotic treatment program shall require a patient to come to the narcotic treatment program for observation daily or at least 6 days a week for comprehensive maintenance treatment, unless a patient is permitted to receive take-home medication as follows:
(3) A narcotic treatment program may permit a patient to reduce attendance at the narcotic treatment program for observation to one time weekly and receive no more than a 6-day take-home supply of medication when in the reasonable clinical judgment of the narcotic treatment physician, which is documented in the patient record:
(i) A patient demonstrates satisfactory adherence to narcotic treatment program rules for at least 3 years.
(ii) A patient demonstrates substantial progress in rehabilitation.
(iii) A patient demonstrates responsibility in handling narcotic drugs.
(iv) A patient demonstrates that rehabilitation progress would improve by decreasing the frequency of attendance for observation.
(v) A patient demonstrates no major behavioral problems.
(vi) A patient is employed, is actively seeking employment, attends school, is a homemaker or is considered unemployable for mental or physical reasons.
(vii) A patient is not known to have abused alcohol or other drugs within the previous year.
(viii) A patient is not known to have engaged in any criminal activity within the previous year.
|
Observations
Based on the review of patient records, the facility failed to ensure that the patient met the requirements to have reduced attendance at the narcotic treatment program in one of two records reviewed.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. Two patient records were reviewed for no more than a six-day take-home supply of medication. One patient record contained documentation of a take-home supply of medication that did not meet eligibility, # 6.
Patient record # 6 documented an admission date of November 17, 2010. A six-day take-home supply was approved by the narcotic treatment physician and documented on March 8, 2013, which was 2 years and 4 months after the patient entered treatment. The patient did not meet eligibility to receive the six-day supply of take-home medication.
The findings were reviewed with the Facility Director and Clinical Supervisor and confirmed.
|
Plan of Correction
A meeting has been held with the Program Director, Medical Director, Clinical Supervisor and Intake Personnel to review requirements regarding Take Home medication criteria and eligibility and the need for Medical Director approval meeting this criteria and any exceptions to this must be made solely by the Medical Director. Program Director will oversee this project.Date Completed 8/5/2013 |
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.
|
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 in one of two patient records.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. 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. One record failed to include documentation that the justification for 13-day take homes still existed, specifically in patient record #10.
The findings were reviewed with the Facility Director and Clinical Supervisor and confirmed.
This is a repeat deficiency from the monitoring visit on 7/20/2012.
|
Plan of Correction
A meeting has been held with the Program Director, Medical Director, Clinical Supervisor to review 13 day take home exceptions to insure that the Medical Director evaluates and documents on going need for 13 Take Home Bottles. Program Director will monitor this for compliance. Date Completed 8/9/13 |
715.17(b) LICENSURE Medication control
(b) A narcotic treatment program shall develop policies and procedures regarding verbal medication orders, including the issuing and receiving of orders, identifying circumstances when orders are appropriate and documenting orders, in accordance with applicable Federal and State statutes and regulations.
|
Observations
Based on the review of patient records, the facility failed to ensure the physician signed and dated within 24 hours after submitting a verbal order in two of three patient records reviewed.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. Three records contained documentation of a physician's verbal order.
Patient record #1 documented a "Medication Order Request" on January 25, 2013, for a dose increase due to withdrawal symptoms. Based on the "Dose History Report," the patient received the 10 mg dose increase on January 25, 2013. The physician signed the order on January 28, 2013.
Patient record #4 documented a "Medication Order Request" on March 1, 2013, for a dose decrease due to sedation. Based on the "Dose History Report," the patient received the 5 mg dose reduction on March 1, 2013. The physician signed the order on March 4, 2013.
The findings were reviewed with the Facility Director and Clinical Supervisor and confirmed.
|
Plan of Correction
A meeting was held between the Program Director and Medical Director to discuss and determine the proper protocol for the signing of verbal orders within the required regulatory timeframes. Medical Director has agreed to not issue verbal orders unless she is available to sign such orders within the required timeframes.Date Completed: August 14, 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.
|
Observations
Based on the review of patient records and administrative documentation, the facility failed to restrict the reasons for involuntary termination to those reasons allowed by regulation in one of two patient records.
The findings include:
Fifteen patient records were reviewed July 16 to 18, 2013. Two patient records and the Notification of Termination documentation were reviewed for involuntary termination. One patient record contained documentation of the patient being discharged for reason other than those listed by regulation.
Patient # 13 was admitted on November 4, 2010, and involuntarily discharged on February 27, 2013. The Notification of Termination form stated "(y)ou have not followed through with acquiring your funding as directed. Your 7 day detox will begin on 2/16/2013."
The findings were reviewed with the Facility Director and Clinical Supervisor.
This is a repeat deficiency from the monitoring visit on 7/20/2013.
|
Plan of Correction
A meeting has been held with the Program Director, Medical Director, Clinical Supervisor to review criteria for involuntary discharge to ensure that involuntary discharges are only for reasons listed by regulation and not outside these bounds. Program Director will monitor this for compliance. Date completed 8/5/13 |