INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection conducted on April 25-26, 2017 by staff from the Division of Drug and Alcohol Program Licensure, for the approval to use Methadone and Buprenorphine in the treatment of narcotic addiction. Based on the findings of the on-site inspection, Habit OPCO, Inc. was found not to be in compliance with the applicable chapters of 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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705.28 (d) (4) LICENSURE Fire safety.
705.28. Fire safety.
(d) Fire drills. The nonresidential facility shall:
(4) Maintain a written fire drill record including the date, time, the amount of time it took for evacuation, the exit route used, the number of persons in the facility at the time of the drill, problems encountered and whether the fire alarm or smoke detector was operative.
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Observations
The facility's fire drill records were reviewed on April 26, 2017 for the period of March 2016 - February 2017. For each month within the reviewed timeframe, the facility failed to maintain a written fire drill record that included the exit route used and the number of persons in the facility at the time of the drill.
This finding was reviewed with facility staff during the licensing inspection.
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Plan of Correction
As of March 2017, an updated form for fire drills was implemented that includes exit route and number of persons in facility at the time of the drill. |
709.28 (c) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(c) The project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record.
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Observations
Eleven client records were reviewed on April 25-26, 2017. The facility failed to obtain an informed and voluntary consent where consent was applicable for client record # 4.
Client # 4 was admitted into methadone maintenance treatment on 8/22/14 and was transferred to another narcotic treatment program on 4/13/17. The client's record contained a consent to release for the receiving narcotic treatment program. This consent form, signed and dated on 9/15/16, allowed for the release of the following information: treatment status verification, prognosis of patient, nature of project, progress of patient, and relapse information, including frequency. Documentation in the client's record indicated that on 4/4/17, the facility sent the following materials to the receiving narcotic treatment program: diagnostic/interpretive summary, dosing history, and past 6 months of urinalysis drug-screen results. The consent to release to the receiving narcotic treatment program did not allow for the release of this information.
This finding was reviewed with facility staff during the licensing inspection.
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Plan of Correction
Clinic Director reviewed policy and procedure for consent to release information with all staff on 05/04/17. Staff were instructed to include all portions of the ROI will be completed in the EMR including items to be released and the reason. Clinic Director will review all consents to release for transfer prior to releasing any information to ensure that the consent captures all necessary items that are released. Clinic Director also completes 7 random file reviews and will ensure that consent include all information released and take the necessary corrective action if the consents are found to be insufficient for the information released. |
709.33 (a) LICENSURE Notification of termination.
§ 709.33. Notification of termination.
(a) Project staff shall notify the client, in writing, of a decision to involuntarily terminate the client ' s treatment at the project. The notice shall include the reason for termination.
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Observations
Eleven client records were reviewed on April 25-26, 2017. The facility failed to document that written notification of involuntary termination from treatment was provided to the client for client record # 6.
Client # 6 was admitted on 4/27/15 for methadone maintenance treatment and was involuntarily terminated from the facility on 1/6/17. The client's record did not contain documentation that the client was provided written notification of the facility's decision to involuntarily terminate the client's treatment.
This finding was reviewed with facility staff during the licensing inspection.
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Plan of Correction
Clinic Director has reviewed the involuntary termination policy and procedure with all staff on 05/04/17 to ensure that all documents are completed as required in state regulations and company policy. |
715.6(d) LICENSURE Physician Staffing
(d) A narcotic treatment program shall provide narcotic treatment physician services at least 1 hour per week onsite for every ten patients
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Observations
An onsite licensing inspection was conducted on April 25-26, 2017. Based on the review of administrative documentation, the facility failed to continuously provide narcotic treatment physician services at least one hour per week onsite for every ten clients.
During the licensing process, weekly physician time sheets were reviewed for the time period of 1/1/17 - 3/25/17. Based on weekly census data for the methadone maintenance activity, insufficient onsite physician hours were provided for the following weeks:
1 - 7, 2017
8 - 14, 2017
15 - 21, 2017
22 - 28, 2017
29 - February 4, 2017
5 - 11, 2017
12 - 18, 2017
5 - 11, 2017
12 - 18, 2017
19 - 25, 2017
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
On 02/27/17, a CRNP was hired and began providing 13 hours a week of onsite services for our patients, while maintaining our physician hours of 8 per week. Our CRNP will provide 2/3 of the required physician time. The Clinic Director will develop and maintain a monthly schedule that denotes days and number of hours each professional will be providing each week ensuring that we meet the 1 hour: 10 patient ratio. The Clinic Director will review and sign off on time sheets weekly for the CRNP and the Physician. |
715.6(e) LICENSURE Physician Staffing
(e) A physician assistant or certified registered nurse practitioner may perform functions of a narcotic treatment physician in a narcotic treatment program if authorized by Federal, State and local laws and regulations, and if these functions are delegated to the physician assistant or certified registered nurse practitioner by the medical director, and records are properly countersigned by the medical director or a narcotic treatment physician. One-third of all required narcotic treatment physician time shall be provided by a narcotic treatment physician. Time provided by a physician assistant or certified registered nurse practitioner may not exceed two-thirds of the required narcotic treatment physician time.
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Observations
An onsite licensing inspection was conducted on April 25-26, 2017. Based on the review of administrative documentation, the facility failed to ensure that one-third of all required narcotic treatment physician time was provided by a narcotic treatment physician.
During the licensing process, weekly physician time sheets were reviewed for the time period of 1/1/17 - 3/25/17. Insufficient onsite hours by a narcotic treatment physician were provided for one week out of the time period reviewed.
During the week of March 5 - 11, 2017, the patient census was 178. The facility was required to provide at least 17.8 physician hours onsite, of which, 5.9 hours were to be provided by a narcotic treatment physician. For this week, 11 onsite physician hours were provided, all of which were provided by a certified registered nurse practitioner. The facility failed to document the provision of onsite physician hours by a narcotic treatment physician.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
During the week of March 5-11, no hours were provided on-site by a physician due to illness. As of 05/01/17, Watsontown has developed relationships with two NTP doctors that provide emergency coverage onsite in the event of an unexpected or expected absence. The Clinic Director develops and maintains a monthly schedule for both the CRNP and the physician to ensure that the required number of hours per week are met and will monitor during the course of the month. Clinic Director will review and sign off on timesheets for the Physician and the CRNP each month to ensure that all required time is documented. In the case of an unexpected absence, Clinic Director will contact Addiction Associates to assist in providing the needed coverage. For expected absences, Clinic Director will schedule covering physicians during that time in advance and place them on the monthly schedule. |
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
Six client records were reviewed for the methadone maintenance activity on April 25-26. The narcotic treatment physician failed to document evidence of a 1 year history of narcotic drug addiction for client records #'s 1 and 2.
Client # 1 was admitted into methadone maintenance treatment on 3/28/16 and was still active in treatment. Documentation in the client's record indicated that the physician's documention of addiction was completed on 3/28/16. The physician failed to document evidence of a 1 year history of narcotic drug addiction.
Client # 2 was re-admitted into methadone maintenance treatment on 8/26/16 and was discharged on 2/27/17. The client had a prior episode of methadone maintenance treatment at the facility from 4/25/16 - 8/10/16. Documentation in the client's record indicated that the physician's documentation of addiction was first completed on 4/25/16. The physician failed to document evidence of a 1 year history of narcotic drug addiction. Upon the client's readmission to the facility on 8/26/16, a physician's documentation of addiction was completed on 8/26/16. This assessment only documented the client's history of addiction for the time period between treatment episodes.
This finding was reviewed with facility staff during the licensing inspection.
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Plan of Correction
Clinic Director will review all new intake charts within 7 days of admission to ensure that the physician documents verification of 1 year of opioid dependence at admission. |
715.21(2) 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.
(2) A patient terminated involuntarily, except a patient who commits or threatens to commit acts of physical violence, shall be afforded the opportunity to receive detoxification of at least 7 days. The detoxification may take place at the facility or the patient may be referred to another narcotic treatment program or hospital licensed and approved by the Department for detoxification.
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Observations
Six client records were reviewed for the methadone maintenance activity on April 25-26, 2017. For client record # 6, the facility failed to document that a client who was involuntarily terminated from treatment was afforded the opportunity to receive at least 7 days of detoxification.
Client # 6 was admitted on 4/27/15 for methadone maintenance treatment, and was involuntarily terminated from treatment on 1/6/17, for non-attendance and for failing to follow treatment plan objectives.
A medical note documented in the client's record, dated 12/31/16, indicated that the client was being suspended for non-attendance. A follow-up case note, dated 1/5/17, indicated that the client requested to meet with the physician to restart methadone dosing. The same note documents that the client would be informed on the involuntary termination. The client's dosing history log indicated that the client received their final dose of methadone on 12/28/16. The client was absent for dosing on 12/22/16, 12/29/16, and 12/30/16. The dosing history log indicated that dosing for the client was then suspended for the following dates: 12/31/16, 1/1/17, 1/2/17, 1/3/17, 1/4/17, and 1/5/17. A case management note dated for 12/30/16 indicated that facility staff met with the client, and the client was directed to return for dosing after attending a compliance meeting on that day. A contact note dated for 1/1/17 indicated that the client returned to the facility for dosing on that day, and was informed that they were required to have a face-to-face with the physician prior to being dosed again. The same contact note indicated that the client was given a physician appointment for 1/6/17. An administrative intervention note, dated 1/5/17, indicated that facility staff met with the client. At this time, the client was informed that they were being involuntarily terminated from treatment.
Documentation in the client's record failed to indicate that the client was afforded the opportunity to receive at least 7 days of detoxification.
This finding was reviewed with facility staff during the licensing inspection.
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Plan of Correction
Involuntary termination policy and procedure will be reviewed with the medical team and clinical staff on 06/09/2017 to ensure adherence to state regulations and company policy as it relates to 7 day tapers following involuntary termination. |