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 November 29-30, 2010 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Progressive Medical Specialists, Inc 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 and a plan of correction is due on December 23, 2010.
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Plan of Correction
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715.17(c)(1)(i-vi)) LICENSURE Medication control
(c) A narcotic treatment program shall develop and implement written policies and procedures regarding the medications used by patients which shall include, at a minimum:
(1) Administration of medication.
(i) A narcotic treatment physician shall determine the patient 's initial and subsequent dose and schedule. The physician shall communicate the initial and subsequent dose and schedule to the person responsible for the administration of medication. Each medication order and dosage change shall be written and signed by the narcotic treatment physician.
(ii) An agent shall be administered or dispensed only by a practitioner licensed under the appropriate Federal and State laws to dispense agents to patients.
(iii) Only authorized staff and patients who are receiving medication shall be permitted in the dispensing area.
(iv) There shall be only one patient permitted at a dispensing station at any given time.
(v) Each patient shall be observed when ingesting the agent.
(vi) Administering and dispensing shall be conducted in a manner that protects the patient from disruption or annoyance from other individuals.
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Observations
Based on the observation of dosing, the facility failed to administer and dispense the medication in a manner that protected the patient from disruption or annoyance from other individuals.
The findings include:
Methadone monitoring was conducted November 29-30, 2010. Dosing was observed on November 30, 2010 from approximately 9:20 to 9:40 AM. It was observed that a patient at the window was engaging in conversation with someone other than the dispensing staff. This patient also stepped away from the window prior to the completion of his dosing and then returned to complete his dosing. The dispensing staff did not address the patient's behavior for either the talking or the stepping away from the window.
The project/facility director was present in the dosing area when the incident occurred and confirmed the patient had stepped away due to his child, who was waiting with another adult, falling and hitting his head. Patient went to check on his child.
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Plan of Correction
The dispensing nurse should have discussed the concern with the client.
The dispensing nurse and nurse supervisor were informed of the incident and that they must address clients who try to leave the window or have conversations with other people while at the window.
All medical staff members are aware of dosing policy. This policy was reviewed with medical staff again during the inspection visit.
Dispensing staff were instructed by the project and medical directors to consistently address any attempt made by a client to leave the dosing window. Nurse supervisor will be responsible in monitoring that dosing policy/procedures is being followed and report to director.
Director met with clinical and front office staff to review dosing procedures.
Signs were posted in each counselor office for clients to read regarding our dosing process and their responsibility.
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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. The consent shall be in writing and include, but not be limited to:
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Observations
Based on the review of patient records, the facility failed to document an informed and voluntary consent from the patient for the disclosure of information contained in the patient record in seven of seven patient records.
The findings include:
Twenty patient records were reviewed on November 29th and 30th. Per regulation, the project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the patient record. Seven patient records required an informed and voluntary consent from the patient. The facility failed to obtain an informed an voluntary consent for the disclosure of patient information to the emergency contact in client records # 1, 2, 3, 11, 12, 13 and 14.
Patient #1 was admitted on October 10, 2010. The facility did not document a release of information for the patient's emergency contact.
Patient # 2 was admitted on August 4, 2010 . The facility did not document a release of information for the patient's emergency contact.
Patient # 3 was admitted on May 5, 2010 . The facility did not document a release of information for the patient's emergency contact.
Patient # 11 was admitted on July 13, 2010. The facility did not document a release of information for the patient's emergency contact.
Patient # 12 was admitted on July 20, 2010. The facility did not document a release of information for the patient's emergency contact.
Patient # 13 was admitted on July 20, 2010. The facility did not document a release of information for the patient's emergency contact.
Patient # 14 was admitted on May 18, 2010. The facility did not document a release of information for the patient's emergency contact.
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Plan of Correction
This was corrected during the inspection visit.
The clinical staff was instructed by project director to review all files to determine the number of clients who did not have a valid consent for their emergency contact.
Once these clients were identified, the staff obtained a valid consent for their emergency contact. These valid consents are filed in the client's clinical chart.
Emergency contact release of information's/consent have been added to all new patient intake paperwork. Also, this consent has been added to the annual physical paperwork to ensure that a valid consent is on file for every patient at all times. This system has been used in the December annual physicals packets.
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