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 buprenorphine, in the residential detoxification from opioid dependence. This inspection was conducted on September 29-30, 2008 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Firetree Ltd Pottsville was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. Deficiencies were identified during this inspection and plan of correction is due on November 12, 2008.
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Plan of Correction
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715.6(a)(1)(i)-(iii) LICENSURE Physician staffing
(a) A narcotic treatment program shall designate a medical director to assume responsibility for administering all medical services performed by the narcotic treatment program
(1) A medical director shall be a physician and shall have obtained one of the following:
(i) Three years documented experience in the provision of services to persons who are addicted to alcohol or other drugs, including at least 1 year of experience in the treatment of narcotic addiction with a narcotic drug.
(ii) Certification in addiction medicine by the American Society of Addiction Medicine.
(iii) A certificate of added qualifications in addiction psychiatry by the American Board of Psychiatry and Neurology, Inc.
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Observations
Based on the review of administrative documentation and staff interviews on September 29, 2008, the facility failed to provide sufficient information to determine how the new medical director meets the qualifications for medical director of a narcotic treatment program.Findings: There was no documentation for physician employee # 1 to determine the qualifications and whether the physician meets at (i) (ii) or (iii).
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
715.6(b)(1-9) LICENSURE Physician Staffing
(b) A narcotic treatment program may employ narcotic treatment physicians to assist the medical director. A narcotic treatment physician 's responsibilities include:
(1) Performing a medical history and physical exam.
(2) Determining diagnosis and determining narcotic dependence.
(3) Reviewing treatment plans.
(4) Determining dosage and all changes in doses.
(5) Ordering take-home privileges.
(6) Discussing cases with the treatment team.
(7) Issuing verbal orders pertaining to patient care.
(8) Assessing coexisting medical and psychiatric disorders.
(9) Treating or making appropriate referrals for treatment of these disorders.
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Observations
Based on a review of the policy and procedure manual, as well as the physician's Drug Enforcement Administration (DEA) registration and job description, on September 29, 2008, the facility failed to ensure the physician employed to assist the medical director was eligible to properly assist the medical director.Findings: Physician employee # 2 does not meet the qualifications as stated in the Title XXXV, Section 3502 of the Children ' s Health Act of 2000 (DATA 2000), nor does the physician's DEA registration indicate that he received a waiver to meeting these qualifications.
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
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 a review of five patient records on September 29-30, 2008, the facility failed to ensure a physician completed a face to face determination of current dependency in three of the five patient records reviewed to determine eligibility.Findings:Patient record # 3 was admitted on 9-25-08 and discharged 9-30-08. The patient was never seen by a physician while receiving treatment. The only means documented in the record to determine physiologic dependency on a narcotic drug was the use of an instant "dipstick" drug test. There was no documentation by the physician recording the basis for determination of dependency.Patient record # 4 was admitted to treatment at the facility on 8-20-08 and discharged on 8-25-08. The physician completed a face to face contact based on a signed physical examination on 8-20-08, but did not document the basis or even a determination, of current physiologic dependency. The results of an instant dipstick drug test on 8-20-08 was recorded in the patient record. Patient record # 5 was admitted on 9-23-08, was given an instant dipstick drug test on 9-23-08, started on Subutex on 9-23-08 and seen by the physician three days later, on 9-26-08, also the date of discharge.
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
715.14(a) LICENSURE Urine testing
(a) A narcotic treatment program shall complete an initial drug-screening urinalysis for each prospective patient and a random urinalysis at least monthly thereafter.
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Observations
Based on a review of five patient records on September 29-30, 2008, the facility failed to obtain a complete urine drug screen prior to the administration of Subutex, a narcotic agent. Findings: Patient record # 1 contained documentation that indicated that Subutex was administered to the patient 8-22-08 prior to the results of the urine drug screen which were not received until 8-23-08. Patient record # 3 contained documentation that indicated that the patient was medicated with Subutex on 9-26-08. There was no documentation that the patient was ever seen by a physician.Patient record # 5 contained documentation that indicated that Subutex was administered to the patient on 9-23-08 prior to the results of the urine drug screen which were not received until 9-24-08. .
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
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.
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Observations
Based on the review of five patient records on September 29-30, 2008, the facility failed to ensure the physician signed the verbal order.Findings:Patient record # 3 contained documentation of the administering nurse receiving a verbal order from the physician on September 25, 2008. On September 30, 2008, the patient was discharged and the order still had not been signed.
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
715.23(b)(4) LICENSURE Patient records
(b) Each patient file shall include the following information:
(4) The results of an initial intake physical examination.
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Observations
Based on a review of five patient records on September 29-30, 2008, the facility failed to ensure an initial intake physical examination in one of the five records reviewed.Findings:Patient record # 3 did not contain a physical examination.
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |
715.24(3) LICENSURE Narcotic detoxification
If a narcotic treatment program provides narcotic detoxification services, the narcotic treatment program shall develop and implement narcotic detoxification policies and procedures which include the following:
(3) A 1-year physiologic dependence is not required for narcotic detoxification although documentation of current dependency is required.
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Observations
Based on the review of five patient records on September 29-30, 2008, the facility failed to ensure documentation of current dependency(of how long) was determined or documented in four of the five records reviewed. Findings: Patient record # 1 lacked documentation of the physician's determination of current dependency, though a narcotic detoxification protocol was implemented. Patient record # 3 lacked documentation of the physician's determination of current dependency, though a narcotic detoxification protocol was implemented. Patient record # 4 lacked documentation of the physician's determination of current dependency, though a narcotic detoxification protocol was implemented. Patient record # 5 lacked documentation of the physician's determination of current dependency, though a narcotic detoxification protocol was implemented.
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Plan of Correction
This facility does not file electronically, a Plan of Correction is on file with the Department of Health. |