INITIAL COMMENTS
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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 August 22-24, 2011 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.
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Plan of Correction
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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 a review of patient records, the facility failed to restrict the determination of dose and schedule to the physician in three of four patient records.
The findings include:
Seventeen patient records were reviewed on August 22-24, 2011. Four patient records were reviewed for documentation of dose and schedule changes after being given written notice of termination. Three patient records contained documentation that staff other than the physician determined the detoxification schedule.
Patient # 9 was admitted February 25, 2011. Employee # 1, not a physician, wrote a detoxification order on July 12, 2011. The physician signed it on July 18, 2011. A nursing employee documented an order to hold the patient at a specific dose on July 14, 2011 and the physician signed it on July 18, 2011.
Patient # 11 was admitted April 18, 2006. Employee # 1, not a physician, wrote a detoxification order on July 14, 2011. The physician signed it on July 18, 2011.
Patient #12 was admitted October 31, 2006. Employee # 1, not a physician, wrote a detoxification order on July 14, 2011. Employee # 2, a physician, issued a verbal order on July 15, 2011 to initiate an administrative detoxification. Employee # 3, a physician, on July 18, 2011, signed the verbal order issued by employee # 2 and the written order by employee # 1.
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Plan of Correction
A meeting was held with the Medical Director, PA-C and the Prograsm Director to ensure that dose determination and schedule will be restricted to the Medical Director only effective immediately. The Program Director will monitor for compliance. Completed 9/9/11 |
715.23(b)(5) LICENSURE Patient records
(b) Each patient file shall include the following information:
(5) The results of all annual physical examinations given by the narcotic treatment program which includes an annual reevaluation by the narcotic treatment physician.
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Observations
Based on the review of patient records, the facility failed to complete the annual physical with a re-evaluation by the physician in two of three patient records reviewed.
The findings include:
Seventeen patient records were reviewed August 22-24, 2011. Three patient records were required to have an annual physical with a re-evaluation by the physician.
Patient # 11 was admitted April 18, 2006. The annual physical exam was completed on May 19, 2011 by the Certified Physician Assistant (PAc), but did not include a re-evaluation by the physician.
Patient # 13 was admitted June 14, 2003. The annual physical exam was completed on June 20, 2011 by the Certified Physician Assistant (PAc), but did not include a re-evaluation by the physician.
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Plan of Correction
A meeting was held with the Medical Director, PA-C, and Program Director to ensure that all Physical Examinations done by the PA-C will include a re-evaluation by the Medical Director. The Program Director will monitor this procedure to insure compliance. Completed 9/9/11 |
715.23(b)(15) LICENSURE Patient records
(b) Each patient file shall include the following information:
(15) Psychosocial evaluations of the patient.
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Observations
Based on the review of patient records and administrative documentation, the facility failed to ensure the psychosocial evaluations were a clinical assessment of the historical data collected in three of five patient records or completed within the policy-stated 30 days of admission.
The findings include:
Seventeen patient records were reviewed on August 22-24, 2011. Five patient records were reviewed for psychosocial evaluations.
Patient # 3 was admitted March 3, 2011. The psychosocial evaluation was dated March 14, 2011 and was a documentation of patient reported data and did not contain documentation of a clinical assessment of the collected historical information.
Patient # 5 was admitted December 16, 2010. The psychosocial evaluation was dated January 4, 2011 and was a documentation of patient reported data and did not contain documentation of a clinical assessment of the collected historical information.
Patient # 7 was admitted December 14, 2010. The psychosocial evaluation was dated February 11, 2011, more than the 30 days of admission stated in the policy and procedure manual reviewed on August 22, 2011. Also, it was a documentation of patient reported data and not did not contain documentation of a clinical assessment of the collected historical information.
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Plan of Correction
A clinical meeting was held on 9/26/11 by the Clinical Supervisor and with the MCMC staff to address the ongoing problem of psychosocial assessments and to instruct regarding the completion of them that the assessment summary shall be evaluative as opposed to historical based on the data collection. This will be monitored by the Clinical Supervisor and overseen by the Program Director. Date Completed: 9/26/11 |
715.23(d)(1) LICENSURE Patient records
(d) A narcotic treatment program shall prepare a treatment plan that outlines realistic short and long-term treatment goals which are mutually acceptable to the patient and the narcotic treatment program.
(1) The treatment plan shall identify the behavioral tasks a patient shall perform to complete each short-term goal.
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Observations
Based on the review of patient records, the facility failed to document behavioral steps to complete the treatment goals in three of six patient records.
The findings include:
Seventeen patient records were reviewed August 22-24, 2011. Six patient records were reviewed for treatment plan documentation compliance. Three patient records failed to ensure action steps were developed to aid the patient in reaching the agreed upon treatment goals.
Patient # 7 was admitted December 14, 2010. The comprehensive treatment plan developed with the patient contained objectives to be met rather than action steps to reach the short term and long term goals that were identified in the treatment plan.
Patient # 10 was admitted April 27, 2011. The comprehensive treatment plan developed with the patient contained objectives to be met rather than action steps to reach the short term and long term goals that were identified in the treatment plan.
Patient # 13 was admitted June 14, 2003. The treatment plan updates developed with the patient contained no action steps to reach the short term and long term goals that were identified in the treatment plan. In addition, the stated goals were not written in a manner that could be measured for progress.
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Plan of Correction
A clinical meeting was held on 9/26/11 by the Clinical Supervisor and with the MCMC staff to address the ongoing problem of treatment plans not outlining realistic short and long term measurable goals which are mutually acceptable to the patient and the NTP. Clinical Supervisor will monitor for compliance and Program Director will monitor. Date Completed: 9/26/11 |