INITIAL COMMENTS
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This report is a result of a complaint investigation conducted on March 12, 2021 by staff from the Bureau of Program Licensure. Based on the findings of the complaint investigation Habit OPCO Inc - Allentown was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility.
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Plan of Correction
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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 a complaint investigation that took place March 12, 20201 and March 15, 2021, the facility failed to discharge a client based on the four requirements listed in this regulation.
The complainant involved is being involuntarily discharged that doesn't meet the requirements.
The findings were reviewed with facility staff during the investigation.
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Plan of Correction
Plan of Correction:
The action of the Facility was in direct concert with the policies and procedures which were provided to the patient via the Patient Handbook and reviewed while completing preliminary treatment plan. Additionally, consistent with §715.21(1) specific language relating to the, '...in the best interests of the health or safety of the patient...' as this Pt. was dually enrolled with another MAT prescriber and failed to report such to the Facility. Based on the PDMP that was run, but not made available to the Medical Director in a timely fashion, the Pt. in question had filled said Rx 25 times prior. During the Facilities inquiry to same, Pt. provided conflicting reports first stating they [Pt.] were, "Holding the medication for another patient..." the Pt., "...did not fill this Rx...someone must have done it using my name/information..." and the following day admitting that they did, in fact, fill the Rx to, "...give it to my girlfriend..."; such admission being in direct violation of various statutes and laws.
The Pt. was offered a medical seven (7) day detox as per §715.21 and to remain as a medication/drug free Pt. pending the conclusion of the current Rx; which Pt. refused.
Pt. was also offered a higher level of care (HLC) which they also refused.
The findings were reviewed with facility personnel yet not in agreement with same based the best interests of Pt. health and safety.
Facility CD will review and reeducate all personnel as to: timeliness of PDMP submissions to medical personnel, ensure counseling and Tx plans include specific language highlighting the dual-enrollment protocols per Acadia, State and Federal Regulations for all Pt.'s. and will provide all during a mandatory full staff meeting with the Regional Director as the presenter to same. This meeting will occur on Wednesday April 7, 2021.
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715.22(c) LICENSURE Patient grievance procedures
(c) Penalties may not be initiated prior to final resolution with the exception that penalties may be initiated against patients who have committed acts of physical violence or who have threatened to commit acts of physical violence in or around the narcotic treatment program premises.
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Observations
Based on a complaint investigation that took place March 12, 20201 and March 15, 2021, the facility failed stop the taper prior to the final resolution of the client's grievance.
The complainant involved is being tapered even though a grievance was submitted to the facility on March 12, 2021.
The findings were reviewed with facility staff during the investigation.
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Plan of Correction
Pursuant and in concert with §715.22 Pt. was provided with a continued, medically ordered seven (7) day taper and to remain as an actively enrolled medication/drug free Pt. as such is deemed the most appropriate measure in the interest of Pt.'s health and safety. Pt. was offered various resolution options to his initial filing of a complaint which they did not accept. The continued taper remained in place based on the active knowledge/awareness of Pt. possession of another MAT Rx medication and admission to same, and the potential health and safety measures that such presents.
Facility will review during a mandatory all staff meeting the protocols surrounding the implementation of interrupted Pt. care and the need to achieve final resolution to same along with a definition of what defines a physical violence in or around the NTP. This training will occur in concert with the aforementioned on April 7, 2021 and will be facilitated by the RD, CD and MD to ensure a multi-disciplinary presentation to same is afforded to all personnel of the OTP.
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