INITIAL COMMENTS
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This report is a result of an on-site complaint investigation conducted on January 28, 2020, by staff from the Department of Drug and Alcohol Programs, Bureau of Quality Assurance for Prevention & Treatment. Based on the findings of the on-site investigation, Habit OPCO, Inc.-Pottstown was found to be not in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during this investigation.
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Plan of Correction
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704.12(a)(6) LICENSURE OutPatient Caseload
704.12. Full-time equivalent (FTE) maximum client/staff and client/counselor ratios.
(a) General requirements. Projects shall be required to comply with the client/staff and client/counselor ratios in paragraphs (1)-(6) during primary care hours. These ratios refer to the total number of clients being treated including clients with diagnoses other than drug and alcohol addiction served in other facets of the project. Family units may be counted as one client.
(6) Outpatients. FTE counselor caseload for counseling in outpatient programs may not exceed 35 active clients.
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Observations
The facility failed to maintain counselor caseload at or below 35 active clients per clinician.
A list was submitted by facility staff that contained the names of all clients on each counselor ' s caseload.
Counselor #1 had 52 clients listed,10 of whom were being seen less than twice per month; this yields a caseload of 42 active clients.
Counselor #2 had 55 clients listed, 4 of whom were being seen less than twice per month; this yields a caseload of 51 active clients.
Counselor #3 had 60 clients listed, 4 of whom were being seen less than twice per month; this yields a caseload of 56 active clients.
This information was shared with the facility staff in order to address the condition.
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Plan of Correction
In concert with 704.12 additional staffing pattern adjustments have been made. Two new counselors commenced their employment on 2/3/20.A reassignment of caseloads occurred and accurately reflect regulation expectations for all clinical personnel.
The Clinical Supervisor will review ratios weekly when assigning new admissions to counselors. The Clinic Director will review on a monthly or as needed basis to ensure compliance is maintained.
Additionally, a thorough review of the existing staffing patterns that are in place at HOI-Pottstown CTC will be conducted by the Regional Director and the Clinic Director.
Based on the current census and those who meet the criteria of licensing alert 01-14, the facility will meet the 35:1 requirement. |
715.19(2) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(2) A narcotic treatment program shall provide each patient at least 1 hour per month of group or individual psychotherapy during the third and fourth year of treatment. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
The facility failed to provide 1 hour of counseling to a client in the third year of treatment in 1 of 3 records reviewed.
Client #2 was admitted on 7/18/2017 and was an active client at the time of the investigation.
There was no counseling provided or scheduled from 7/25/19 through 11/7/19.
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Plan of Correction
The Clinical Supervisor and Director will review the regulations again in weekly group and individual supervision with clinicians.
The Clinical Supervisor will also monitor documentation of counseling compliance with all clinical staff using the available program software. During individual clinical supervision bi-weekly the Clinical Supervisor will work with each clinician to identify any patients who are in danger of not meeting the monthly counseling requirements, and develop a plan to assist those patients in meeting the required hours as per their treatment plans.
Patients who are in danger of not meeting the monthly counseling requirement will be scheduled for additional counseling appointments, including individual and group session. Recalcitrant patients will be put on a counseling contract which will be reviewed with the patient weekly. Each patient will be scheduled for individual and group counseling in accordance with state regulations, using newly acquired scheduling software. Patients will also receive a written notice of their counseling appointments, which they will be required to sign to verify that they received the notice. For particularly problematic patients, individual counselors will be contacted by phone to remind them of their counseling appointments one day in advance. |
715.23(b)(14) LICENSURE Patient records
(b) Each patient file shall include the following information:
(14) Case consultation notes regarding the patient.
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Observations
The facility failed to document a case consultation for a client in the third year of treatment in 1 of 3 records reviewed.
Client #2 was admitted on 7/18/2017 and was an active client at the time of the investigation.
There were no case consultations documented in the record at the time of the investigation.
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Plan of Correction
The Clinical Director will review the regulations in weekly staff meeting.
The Clinical Supervisor will review case consults to ensure counseling compliance with all clinical staff using the available program software. During the our weekly case consultation meeting counselor will present their patients and receive feedback from the multi disciplinary team; which includes the Clinical Director, Clinical Supervisor and Medical Director. Clinical supervisor will work with each clinician to identify any patients who are out of compliance with their case consults and present them in weekly meetings.
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709.92(c) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(c) The project shall assure that counseling services are provided according to the individual treatment and rehabilitation plan.
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Observations
The facility failed to provide counseling according to the treatment plan in 1 of 3 records reviewed.
Client #2 was admitted on 7/18/2017 and was an active client at the time of the investigation. Treatment plan updates, dated 10/22/2019 and 12/18/2019, indicated a type and frequency of 1 groups session and 1 individual session per week for the next 60 days from the dates of the respective plans. The last documented group sessions were conducted on 6/14/19 and 6/21/19 and the last documented individual sessions were conducted on 7/11/19 and 7/25/19. No other clinical sessions were documented and three notes were documented stating that individual sessions were scheduled on 3/19/19, 11/7/19 and 11/26/19 that were cancelled by the client.
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Plan of Correction
The Clinical Director will review the regulations in weekly staff meeting.
The Clinical Supervisor will review treatment plans to ensure counseling compliance with all clinical staff using the available program software. During the second week of the month, the Clinical Supervisor will work with each clinician to identify any patients who are out of compliance with their treatment plan goals and develop a plan to assist those patients in meeting the goals identified on their treatment plan.
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709.92(d) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(d) Counseling shall be provided to a client on a regular and scheduled basis.
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Observations
The facility failed to provide counseling on a regular and scheduled basis in 1 of 3 records reviewed.
Client #2 was admitted on 7/18/2017 and was an active client at the time of the investigation.
There was no counseling provided or scheduled from 7/25/19 through 11/7/19. The last documented group sessions were conducted on 6/14/19 and 6/21/19 and the last documented individual sessions were conducted on 7/11/19 and 7/25/19. No other clinical sessions were documented, and three notes were documented stating that individual sessions were scheduled on 3/19/19, 11/7/19 and 11/26/19 that were cancelled by the client.
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Plan of Correction
The Clinical Supervisor and Director will review the regulations in weekly group and individual supervision with clinicians.
The Clinical Supervisor will also monitor documentation of counseling compliance with all clinical staff using the available program software. During individual clinical supervision bi-weekly the Clinical Supervisor will work with each clinician to identify any patients who are in danger of not meeting the monthly counseling requirements, and develop a plan to assist those patients in meeting the required hours as per their treatment plans.
Patients who are in danger of not meeting the monthly counseling requirement will be scheduled for additional counseling appointments, including individual and group session. Recalcitrant patients will be put on a counseling contract which will be reviewed with the patient weekly. Each patient will be scheduled for individual and group counseling in accordance with state regulations, using newly acquired scheduling software. Patients will also receive a written notice of their counseling appointments, which they will be required to sign to verify that they received the notice. For particularly problematic patients, individual counselors will be contacted by phone to remind them of their counseling appointments one day in advance.
In addition, counselor who are identified as having low show rates and cancellations will be coached on patient engagement and motivational interviewing techniques during clinical supervision.
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