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 methadone, in the treatment of narcotic addiction. This inspection was conducted on May 22, 2012 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, PA Care LLC, D/B/A Miners Medical 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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715.8(1)(vi) LICENSURE Psychosocial Staffing
A narcotic treatment program shall comply with the following staffing ratios as established in Chapter 704 (relating to staffing requirements for drug and alcohol treatment activities):
(vi) Outpatients. The counseling caseload for one FTE counselor in an outpatient narcotic treatment program may not exceed 35 active patients.
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Observations
Based on the review of administrative documentation, the facility failed to maintain counselor caseloads to no more than 35 to 1.
The findings include:
A review of administrative documentation on May 22, 2012 included the review of the qualifications of new staff. This review revealed that employees # 1 and 5 both possessed the degree appropriate for the position but were without the required experience necessary for the position. These staff were not able to be included in the computation of the staff to patient ratio and the facility was subsequently out of compliance with the ratio.
The findings were reviewed with the facility director.
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Plan of Correction
The facility failed to comply with regulation 704.7 stating that a counselor must present with a Bachelor's Degree from an accredited college and one year of clinical experience. On June 17, 2012 the facility director will change the title of employees #1 and 5 to Counselor Assistants. Modifications have been made to their case load to insure a ratio of no more than 34:1 active patients. The facility director instructed the Senior Counselor to provide and document weekly individual clinical supervision to both employees that includes training in areas of counseling techniques and clinical documentation. Supervision will also include co-facilitating individual sessions and group sessions a minimum of one time per week documented via co-signed progress notes and/or client record of service. The facility director will monitor weekly to insure compliance |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on a review of patient records, the facility failed to document an average of 2.5 hours of psychotherapy per month during the patient's first two years, in four of nine patient records.
The findings include:
Eleven patient records were reviewed on May 22, 2012. Nine patient records were reviewed for the completion of an average of 2.5 psychotherapy hours per month. A minimum of 2.5 hours is required for each patient in treatment during the first two years in treatment. The facility failed to document an average of 2.5 hours of psychotherapy per month in patient record # 1, 2, 5 and 6.
The review of patient records for compliance with psychotherapy included a review of the months of February, March and April, 2012.
Patient record # 1 provided documentation that patient # 1 received 2.5 hours of psychotherapy in February, 2.5 hours of psychotherapy in March, and 2.25 hours of psychotherapy in April for an average of 2.41 hours per month.
Patient record # 2 provided documentation that patient # 2 received 1.25 hours of psychotherapy in February, 1.25 hours of psychotherapy in March, and 0.0 hours of psychotherapy in April for an average of .833 hours per month.
Patient record # 5 provided documentation that patient # 5 received 1.00 hour of psychotherapy in February, 1.50 hours of psychotherapy in March, and 0.50 hour of psychotherapy in April for an average of 1.00 hours per month.
Patient record # 6 provided documentation that patient # 6 received 1.25 hours of psychotherapy in February, 1.25 hours of psychotherapy in March, and 1.25 hour of psychotherapy in April for an average of 1.00 hours per month.
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Plan of Correction
The facility failed to comply with regulation 715.19 stating that the program will provide a minimum of 2.5 hours of psychotherapy per month. The facility director and Senior Counselor will facilitate a training on June 27, 2012 to all counseling staff on the importance of providing each individual a minimum of 2.5 hours of counseling per month, engagement techniques, and clinical documentation. The facility director and/or senior counselor will conduct weekly chart audits and ongoing clinical supervision to insure compliance. |
715.21 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.
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Observations
Based on review of patient records, the facility failed to ensure all efforts had been initiated to retain the patient in treatment prior to an involuntary termination in one of two patient records.
The findings include:
Eleven patient records were reviewed on May 22, 2012, two were reviewed to determine compliance with the regulations pertaining to an involuntary patient discharge. Patient # 11, was admitted on May 12, 2011 and was involuntarily terminated on March 25, 2012 for financial reasons. The patient was given a supplemental treatment plan on February 7, 2012. Financial responsibility was identified on the treatment plan, with the stated expectation that that the patient's weekly payment amount would increase in an effort to manage the patient's current and back balance. The patient was in arrears with his payments for treatment and the treatment plan addressed this issue in the documentation. The patient received notification on March 9, 2012 that he had not been compliant with the supplemental treatment plan, dated February 7, 2012, and that he would be placed on a sixteen day involuntary detoxification. The brevity of this time period did not allow for clinical interventions to be pursued for patient # 2.
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Plan of Correction
The facility failed to comply with regulation 715.21. The facility director and senior counselor will provide a comprehensive training to all counselors on June 21, 2012 regarding compliance with involuntary termination guidelines, necessary documentation, and appropriate treatment interventions. Oversight to insure compliance will be provided by the facility director and senior counselor via ongoing clinical supervision. |
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 review of patient records, the facility failed to involuntarily terminate a patient for conditions established by the regulations in one of two patient records.
The findings include:
Eleven patient records were reviewed on May 22, 2012, two were reviewed to determine compliance with the regulations pertaining to involuntary discharges. Patient # 11, was admitted on May 12, 2011 and was involuntarily terminated on March 25, 2012 for financial reasons. The patient was given a supplemental treatment plan on February 7, 2012. Financial responsibility was identified on the treatment plan, with an expectation that the patient's weekly payment amount would increase. The patient was in arrears with his payments for treatment and the treatment plan addressed this issue in the documentation. The patient received notification on March 9, 2012 that he had not been compliant with the supplemental treatment plan, dated February 7, 2012 and that he would be placed on a sixteen day involuntary detoxification.
Financial noncompliance is not a condition identified by the Department as a reason to involuntarily terminate a patient.
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Plan of Correction
The facility failed to comply with regulation 715.21. The facility director and senior counselor will provide a comprehensive training to all counselors on June 21, 2012 regarding compliance with involuntary termination guidelines, necessary documentation, and appropriate treatment interventions. Ongoing clinical supervision will be provided by the facility director and senior counselor to insure compliance. |
715.23(d)(1) LICENSURE Patient records
(d) A narcotic treatment program shall prepare a treatment plan that outlines realistic short and long-term treatment goals which are mutually acceptable to the patient and the narcotic treatment program.
(1) The treatment plan shall identify the behavioral tasks a patient shall perform to complete each short-term goal.
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Observations
Based on the review of patient records, the narcotic treatment program failed to document and develop treatment plans to include support services and type and frequency. In nine records reviewed for support services in treatment plans, nine of nine records did not contain support services. Also, type and frequency of treatment was missing in six of nine patient records.
The findings include:
Eleven patient records were reviewed on May 22, 2012. Treatment plans were reviewed in nine patient records. The facility failed to document in the treatment plans the available support services that were available to the patient in all nine records, # 1, 2, 3, 4, 5, 6, 7, 8 and 9. Further, a review of treatment plans for type and frequency revealed that of the nine records reviewed, six failed to include type and frequency of treatment in records # 1, 2, 3, 4, 7 and 8
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Plan of Correction
The facility failed to comply with regulation 715.23. The facility director and senior counselor will provide a comprehensive training to counseling staff on July 05, 2012 to provide education on determining and documenting the type and frequency of psychotherapy the patient is to receive. The training will also address specific support services being recommended to the patient and documentation regarding the patient's use of and /or interaction with the recommended support services. The facility director and senior counselor will audit charts weekly and provide ongoing clinical supervision to insure compliance. |