INITIAL COMMENTS
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This report is a result of an administrative review of the written report of the findings of an on-site licensure inspection conducted for the approval to use a narcotic agent, specifically methadone, in the treatment of narcotic addiction. This inspection was conducted on July 18, 19 and 20, 2012 by staff from the Division of Drug and Alcohol Program Licensure. Based on the administrative review of findings from 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 administrative review:
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Plan of Correction
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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.
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Observations
Based on the review of patient records, the facility failed to determine current dependency in one of five records reviewed.
The findings include:
Twenty patient records were reviewed July 18 to 20, 2012. Five patient records were reviewed for physician documentation of current physiological dependence.
Patient # 3 was admitted on March 27, 2012, and discharged on July 16, 2012. The physician documented the patient was a "transfer from detox/rehab," having been in treatment for detoxification from opiates immediately prior to admission to the facility. The facility failed to document current dependency.
The findings were reviewed with the Facility Director and Clinical Supervisor.
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Plan of Correction
A meeting has been held by the Program Director with the PA-C and the Medical director on 8/13 to review MCMC criteria regarding admissions to MMT to ensure that a face to face determination of whether an individual is currently dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenence treatment.Medical Director will conduct assessment and Program Director will monitor for compliance.
Completed 8/13/12 |
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.
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Plan of Correction
A clinical Meeting has been 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.
Completed 8/14/12 |
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 eight of ten records.
The findings include:
Twenty patient records were reviewed July 18 to 20, 2012. Ten patient records were reviewed for psychotherapy services within the first 2 years of treatment. Patient records #1, 2, 5, 8, 9, and 14 failed to have the average of 2.5 hours of psychotherapy per month during their first 2 years of treatment. Additionally, the facility failed to document one hour of individual psychotherapy per month in records, # 3, 4.
Patient # 1 was admitted June 17, 2010, and discharged March 19, 2012. The average psychotherapy hours were reviewed for the months of December 2011, January and February 2012. The patient averaged 1.17 hours of psychotherapy for the three months reviewed.
Patient # 2 was admitted on February 22, 2012, and discharged on July 5, 2012. The average psychotherapy hours were reviewed for the months of April, May and June 2012. The patient averaged 1.75 hours of psychotherapy for the three months reviewed.
Patient # 3 was admitted on March 27, 2012, and discharged on July 16, 2012. The facility failed to document individual psychotherapy for the month of June 2012.
Patient # 4 was admitted on July 6, 2011, and discharged on April 12, 2012. The patient record failed to document one hour of individual psychotherapy for the months of February 2012, March 2012 and April 2012.
Patient # 5 was admitted on October 5, 2011, and discharged on May 8, 2012. The average psychotherapy hours were reviewed for the months of February, March and April 2012. The patient averaged 1.17 hours of psychotherapy for the three months reviewed.
Patient # 8 was admitted on April 21, 2011, and discharged on July 9, 2012. The average psychotherapy hours were reviewed for the months of April, May, and June 2012. The patient averaged 1.92 hours of psychotherapy for the three months reviewed.
Patient # 9 was admitted on February 24, 2011, and discharged on June 5, 2012. The average psychotherapy hours were reviewed for the months of March, April, and May 2012. The patient averaged 1.08 hours of psychotherapy for the three months reviewed.
Patient # 14 was admitted on October 5, 2011. The average psychotherapy hours were reviewed for the months of April, May, and June 2012. The patient averaged 1.92 hours of psychotherapy for the three months reviewed.
The findings were reviewed with the Facility Director and Clinical Supervisor.
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Plan of Correction
A clinical meeting has been 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. Completed 8/14/12 |
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 seven patient records.
The findings include:
Twenty patient records were reviewed July 18 to 20, 2012. Seven patient records were reviewed for involuntary termination. Two patient records contained documentation of the patient being discharged for reason other than those listed by regulation.
Patient # 1 was admitted on June 17, 2010, and involuntarily discharged on March 19, 2012. The reason for discharge was identified as "due to outstanding fiscal bill."
Patient # 3 was admitted on March 27, 2012, and involuntarily discharged on July 16, 2012. The reason for discharge was identified as "not able to afford treatment at this time."
The findings were reviewed with the Facility Director and Clinical Supervisor.
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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 8/14/12 |