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 June 24 -25, 2013 by staff from the Program Licensure Division. Based on the findings of the on-site inspection, Pennsylvania 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:
Administrative documentation that included counselor caseloads was reviewed and discussed with the project director on June 25, 2013. Employee #1 was hired as a full time counselor assistant on May 12, 2013 and was assigned a caseload of 35 clients. Since this employee was not eligible for a caseload, the clients became unassigned. Therefore, the facility exceeded the 35:1 client/counselor ratio.
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Plan of Correction
The facility failed to comply with regulation 715.8(1)(vi) requiring the facility to maintain counselor caseloads to no more than 35 to 1.
In order to maintain the client/counselor 35:1 ratio, the Facility Director along with the Senior Counselor will track census and staff composition. Miner's Medical will not accept clients over the census in order to remain in compliance with this regulation. |
715.8(2) 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):
(2) Counselor assistants. A counselor assistant eligible for a counseling caseload may be included in determining FTE ratios.
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Observations
Based on a review of the narcotic treatment program monitoring questionnaire, the facility failed to maintain one FTE (full time equivalency) counselor for every 35 active patients, as required.
The findings include:
On June 24-25, 2013, the narcotic treatment program monitoring questionnaire and active patient case lists were reviewed. Per regulation, the counseling caseload for one FTE counselor in an outpatient narcotic treatment program may not exceed 35 active patients. The current census of the facility is 232 patients. There are 197 active patients who are assigned to counselor caseloads. The facility has 35 active patient records that were not assigned to a qualified counselor assistant.
Employee #1 is a counselor assistant who was assigned a caseload of 35 patients. A review of the personnel record and supervision notes revealed the employee had not received a positive assessment from their supervisor to be eligible to carry a caseload.
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Plan of Correction
The facility failed to comply with regulation 715.8(2) requiring the facility to maintain counselor caseloads to no more than 35 to 1. Employee #1 who is Counselor Assistant currently maintains a caseload of 34 clients. The Senior Counselor is responsible for providing weekly supervision and documentation for Counselor Assistants. The Facility Director will review employee files monthly to ensure that employees have proper supervision and will review completed trainings on all staff upon hire and throughout the year. Facility Director along with the Senior Counselor will assign caseloads after a complete positive assessment of the Counselor Assistant at hire and monthly thereafter. |
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 the review of patient records, the facility failed to restrict the reasons for involuntary termination to those allowed by regulation in one of three patient records.
The findings include:
Fifteen patient records were reviewed June 24-25, 2013. Three patient records were reviewed for involuntary or therapeutic discharge. One patient record contained documentation of the patient being discharged for reasons other than those listed by regulation.
Patient # 4 was admitted March 1, 2012 and discharged on March 25, 2013. The patient received a discharge letter on March 8, 2013 that stated he was being discharged for failing to follow his treatment plan. The patient appealed his termination notification and stated he would make payments towards his arrears, however, the facility denied his appeal and started him on a 14 day detox. The patient record included an annual physical conducted by the narcotic treatment physician on March 6, 2013. The narcotic treatment physician assessed him to be appropriate and should continue in methadone maintenance treatment. Two days later on March 8, 2013 the patient received a discharge notification. A progress note dated March 15, 2013 stated if the patient were to make significant payments towards arrears and go to inpatient for his continued cocaine abuse they would reconsider his discharge. The patient did try to get funding for inpatient treatment, but was denied because he had $168 in costs and fines to pay. The facility failed to document efforts were made to retain the patient in the program.
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Plan of Correction
The facility failed to comply with regulation 715.21(1)(i-iv)regarding patient #4's termination from the program. The Facility Director and/or Lead Counselor will ensure that all clinical measures/interventions are utilized prior to any client discharge. Facility Director/Lead Counselor will discuss potential client discharges prior to the clinic's weekly Team meeting and will educate staff regarding discharge protocol on 8.1.2013 Team meeting. Will document in weekly Team meetings minutes to ensure compliance with this regulation ongoing. |
715.23(b)(15) LICENSURE Patient records
(b) Each patient file shall include the following information:
(15) Psychosocial evaluations of the patient.
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Observations
Based on the review of patient records, the facility failed to document a comprehensive psychosocial evaluations in four of six patient records.
The findings include:
Fifteen patient records were reviewed on June 24-25, 2013. Six patient records were reviewed for documentation of a comprehensive psychosocial evaluation. The facility failed to document a comprehensive psychosocial evaluation in records # 1, 8, 9 and 13.
Patient # 1 was admitted 5/2/2013. The documented psychosocial evaluation failed to include a clinical assessment of the patient's coping mechanisms.
Patient # 8 was admitted 3/18/2013. The documented psychosocial evaluation failed to include a clinical assessment of the patient's coping mechanisms.
Patient # 9 was admitted 5/8/2013. The documented psychosocial evaluation failed to include a clinical assessment of the patient's coping mechanisms.
Patient # 13 was admitted 3/6/2013. The documented psychosocial evaluation failed to include a clinical assessment of the patient's coping mechanisms.
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Plan of Correction
The facility failed to comply with regulation #715.23(b)(15) regarding documentation in resident #1, 8, 9, and 13's psychosocial evaluation to include a clinical assessment of the patients' coping mechanisms. On 8.1.2013, the Facility Director and Senior Counselor will provide a staff training session in the area of clinical assessment to include assessing each client's coping mechanisms. Ongoing monitoring and supervision will be provided by the Facility Director and Senior Counselor.
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715.23(b)(23) LICENSURE Patient records
(b) Each patient file shall include the following information:
(23) Discharge summary.
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Observations
Based on a review of patient records, the facility failed to document a complete discharge summary that included the patient's reason for treatment, services offered and client's status upon discharge in five of six patient records.
The findings include:
Fifteen patient records were reviewed on June 24-25, 2013. Six records were reviewed for discharge summaries. Four of the six records failed to document the client's reason for entering treatment, specifically records # 3, 4, 5 and 6. Four of the six records also failed to document the client's status upon discharge, specifically records # 3, 4, 6 and 7.
Patient # 3 was admitted on 8/11/2011 and discharged on 1/29/2013. The discharge summary failed to document the patient's reasons for treatment and the patient's status upon discharge.
Patient # 4 was admitted on 3/1/2012 and discharged on 3/25/2013. The discharge summary failed to document the patient's reasons for treatment and the patient's status upon discharge.
Patient # 5 was admitted on 5/17/2012 and discharged on 2/5/2013. The discharge summary failed to document the patient's status upon discharge.
Patient # 6 was admitted on 12/27/2011 and discharged on 1/29/2013. The discharge summary failed to document the patient's reasons for treatment and the patient's status upon discharge.
Patient # 7 was admitted on 5/31/2012 and discharged on 1/1/2013. The discharge summary failed to document the patient's reasons for treatment.
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Plan of Correction
The facility failed to comply with regulation #715.23(b)(23) regarding the discharge summary providing the following information: the patient's reasons for treatment and the patient's status upon discharge.
On 8.1.2013, the Facility Director and Senior Counselor will provide a staff training session in the area of writing a comprehensive discharge summary that includes, but is not limited to, all Department and Facility required information. Training will also include proper documentation of Discharge Summaries and will include: Client's Reason for Treatment, Services Offered, and Client's Status upon Discharge. Ongoing monitoring and supervision will be provided by the Facility Director and Senior Counselor.
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715.23(b)(24) LICENSURE Patient records
(b) Each patient file shall include the following information:
(24) Follow-up information regarding the patient.
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Observations
Based on the review of patient records, the facility failed to document the attempt to conduct patient follow-up in two of six patient records reviewed.
The findings include:
Fifteen patient records were reviewed June 24-25, 2013. Six patient records required documentation of an attempt or completion of a follow up contact. According to the facility's policy, follow-up will be completed within one week of the day the referral is to be made for transfers. For all others a phone call will be completed within 7 days, three months and twelve months after discharge. The facility failed to document a follow-up attempt in patient records # 3 and 4.
Patient # 3 was admitted August 11, 2011. The patient was discharged on January 29, 2013. Follow-up attempts were required by February 5, 2013 and April 29, 2013. The facility failed to document follow-up in this patient record as of the time of the inspection.
Patient # 4 was admitted March 1, 2012. The patient was discharged March 25, 2013. A follow-up attempt was required by April 1, 2013. The facility failed to document follow-up in this patient record as of the time of the inspection.
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Plan of Correction
The facility failed to comply with regulation #715.23(b)(24)regarding Follow-up information for each patient. The Facility Director and Senior Counselor will conduct an in-service regarding Miner's Medical policy regarding Follow-up and the specific time frames involved on 8.1.2013. The Facility Director and/or Senior Counselor will conduct monthly, chart audits to ensure ongoing compliance with this regulation. Additionally, the In-Service will include training on proper documentation of a client's follow-up. |