Observations
Based on the the review of administrative documentation, the facility failed to limit the initiation of involuntary terminations to those reasons permitted by regulation.
The findings include:
The facility's patient handbooks and the grievance reports for 2008 and 2009 were reviewed on February 10, 2009. The first reviewed handbook contained a financial responsibility process starting at three days of non-payment and then again after eight days of non -payment. The first steps address the office manager informing the patient of the non-payment status ( 3 days) and then a meeting with the counselor and setting up a payment plan (5 days). The final step of the process after the eighth (8) day of non-payment is a financial contract with three days given to pay balance or a 21 day administrative taper is started and can only be stopped one time if payment is made during the taper. If another payment is missed, the taper resumes and is irreversible. The second handbook provided for review had these steps removed. However, neither handbook addresses helping the patient obtain financial assistance or even exploring the financial situation.
Both handbooks contained documentation of administrative tapers being initiated for refusal to provide a urine drug screen. At the second refusal, the patient must sign an agreement that if they refuse a third time, the administrative taper will be initiated. In addition, the handbook stated that loitering is also grounds for dismissal from the program.
The Grievance files reviewed showed patient # 1 receiving a notice of involuntary termination for financial non-compliance on January 29, 2009. During the grievance procedure, it became evident that the patient had been compliant with the established payment plan since the inception. There was no other documentation of any attempts to help the patient obtain financial assistance prior to the contract. Patient # 2 received notice of involuntary termination on December 30, 2008 for non-compliance with financial agreement and financial treatment goals and objectives. In review of the treatment plans, there were no financial goals and objectives. In addition, this patient was found to have paid according to the financial agreement established.
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Plan of Correction
The patient handbook was not updated when the financial process was written and approved by the Department of Health. This was an oversight of the Clinic Director. The patient handbook has been updated and placed in the admission charts and emailed
and reviewed with all staff. A memo will be posted for all patients in the lobby informing them to see the office manager or clinical staff to request a copy of the revised handbook. This will be posted the week of 3/16/09.
Administrative tapers will be initiated for the reasons outlined in DOH regulation 715.21.
To ensure that CTC remains in compliance with this regulation, all noncompliance cases will be reviewed by the clinical supervisors and clinic director weekly to assure that no unnecessary tapers are being presented and that all clinical interventions have been utilized. This will begin on 3/16/09. All efforts will be made and no inappropriate tapers begun.
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