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 methqadone and bupreenorphine, in the treatment of narcotic addiction. This inspection was conducted on July 30, 2013 to August 1, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Eagleville Hospital 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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715.15(b) LICENSURE Medication dosage
(b) The narcotic treatment physician shall determine the proper dosage level for a patient, except as otherwise provided in this section. If the narcotic treatment physician determining the initial dose is not the narcotic treatment physician who conducted the patient examination, the narcotic treatment physician shall consult with the narcotic treatment physician who performed the examination before determining the patient 's initial dose and schedule.
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Observations
Based on a review of patient records, the facility failed to document the consultation between the narcotic treatment physician determining the initial dose and the narcotic treatment physician, or physician extender performing the physical examination in two of two records.
The findings include:
Twelve patient records were reviewed July 30, 2013 to August 1, 2013. Two patient records were required to document a consult between the narcotic treatment physician determining the initial dose and the narcotic treatment physician performing the physical examination in one of the three records.
Patient #3 was admitted March 15, 2013. The Certified Registered Nurse Practitioner (CRNP) completed the physical examination on March 15, 2013. The narcotic treatment physician determined the initial dose March 16, 2013, but failed to document the consultation with the CRNP who completed the physical examination.
Patient # 6 was admitted April 23, 2013. The patient was seen by a physician for a physical on April 23, 2013. Another physician documented on April 24, 2013 that he had conferred with the physician extender. The physician extender did not complete the physical exam. There was no documentation of a consult with the physician who had completed the physical exam.
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Plan of Correction
The Director of Medical of Service will re-educate medical staff on the regulations and documentation requirements for determination of dosing when the prescribing physician has not completed an examination of the patient the patient and the necessary consultation required by 8/31/2013.
When consultation is not feasible the prescribing physician will perform and examination and document in the chart as indicated
Additional documentation elements will be entered into the EMR system to enhance current documentation.
Documentation of the basis for determining current opiate dependency and determination of dose will be added to the existing Quality Management chart review processes.
Quality Management Chart Review processes completed monthly and reported quarterly to the Quality Management Committee by the Medical Director beginning September 30, 2013 for a period of 4 months.
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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 ensure the narcotic treatment physician was the one to determine the initial and subsequent schedule in patient record # 6.
The findings include:
Twelve patient records were reviewed July 30, 2013 to August 1, 2013. Twelve patient records required the physician to determine the patient's initial and subsequent dose and schedule. Patient record # 6 was admitted April 23, 2013. The patient was seen by a physician for a physical on April 23, 2013. Another physician documented on April 24, 2013 that he had conferred with the physician extender. The physician extender documented a note that the patient was to continue a methadone taper for detox. There was no indication the physician had actually made this determination.
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Plan of Correction
The Director of Medical of Service will re-educate medical staff on the documentation requirements for determination of dosing by 8/30/2013
Prior to administration of an agent, a narcotic treatment practitioner will review medical records, history and physical. Then after meeting with the patient in a face to face meeting and examining the patient will determine the patient's initial and subsequent dose and schedule.
The narcotic treatment physicians 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.
An area will be added to the current electronic medical record as approved by the Medical Department and added by the Clinical Informatics department.
This will specify the type of review and provide as an attestation to ensure corresponding the type of review has occured.
Quality Management Chart Review processes will be completed monthly and reported quarterly to the Quality Management Committee by the Medical Director beginning September 30, 2013 for a period of 4 months. |