INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection, and a methadone monitoring inspection conducted on October 4 - 5, 2016 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Echo Treatment Center LLC 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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715.9(b)(2) LICENSURE Intake
(b) Exceptions to the requirements in subsection (a) are:
(2) Upon readmitting a patient who has been out of a narcotic treatment program for 6 months or less after a voluntary termination, the narcotic treatment program shall update the information in and review the patient 's file to show current opiate narcotic dependency, but need not conduct a physical examination and applicable laboratory tests. Privileges earned during the previous treatment may be reinstated at the discretion of the narcotic treatment physician.
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Observations
The narcotic treatment program failed to document the physician's face to face determination of the patient's current dependency when readmitting the patient for treatment in one of one patient records reviewed during the annual licensing and methadone monitoring inspection conducted on October 4 - 5, 2016.
Patient # 4 was discharged from treatment on June 29, 2016 and readmitted into treatment on July 6, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016,management staff reviewed readmission process with Director to ensure staff understanding of process and that current dependency is required at readmission.
The physician will make a face to face determination of the patient's current dependency and document this in the patient record for readmission.
The nursing supervisor will ensure that the deficiency does not reoccur by conducting random reviews of the patient records to verify that readmission documentation is completed.
Director believes that all staff have been retrained and understand the procedure for readmission under six months as stated by the regulation. |
715.14(a) LICENSURE Urine testing
(a) A narcotic treatment program shall complete an initial drug-screening urinalysis for each prospective patient and a random urinalysis at least monthly thereafter.
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Observations
The facility failed to provide documentation of a complete drug screening urinalysis prior to the administration of methadone, a narcotic agent in three of eight patient records reviewed during the annual licensing, and methadone monitoring inspection conducted on October 4 - 5, 2016. A complete drug screen includes receiving the results from the CLIA and Department of Health approved laboratory.
Patient # 1 was admitted into treatment and administered methadone on March 22, 2016. The drug screen results were not received until March 24, 2016.
Patient # 4 was admitted into treatment and administered methadone on July 6, 2016. The drug screen results were not received until July 19, 2016.
Patient # 8 was admitted into treatment and administered methadone on March 15, 2016. The drug screen results were not received until March 24, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016, clinical and medical staff met with Director and reviewed the procedure for the requirement by regulation that a complete drug screen result from a CLIA and Department of Health approved laboratory be completed and received prior to administration of methadone. The nurse supervisor or other medical personnel will ensure that the clinical drug screen result is available prior to the administration of methadone. The nurse supervisor will randomly review patient records to ensure that the procedure is followed and to ensure that this deficiency does not reoccur.
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715.15(b) LICENSURE Medication dosage
(b) The narcotic treatment physician shall determine the proper dosage level for a patient, except as otherwise provided in this section. If the narcotic treatment physician determining the initial dose is not the narcotic treatment physician who conducted the patient examination, the narcotic treatment physician shall consult with the narcotic treatment physician who performed the examination before determining the patient 's initial dose and schedule.
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Observations
The narcotic treatment physician failed to determine the proper dosage level for a patient by writing standing orders for the patient's induction phase in three of eight patient records reviewed during the annual licensing, and methadone monitoring inspection conducted on October 4 - 5, 2016.
The following standing order was written by the physician in patient records # 2, 3 and 5.
"Patient is to begin daily dose of 30 mgs. diskette methadone on (initial dosing date). Monitor for adverse reaction in one hour. If no signs or symptoms of adverse reaction patient may increase to 40 mgs. on (initial dosing date). Beginning on (second day of dosing date) patient may increase dose 5 mgs PRN for withdrawal signs or symptoms, and/or if patient reports use of heroin during the first 7 days of the induction phase, with the maximum dose NOT to exceed 50 mgs. daily diskette methadone. Each 5 mgs. daily dose increase must be monitored for 30 minutes for adverse reaction."
These standing orders required the nurse to determine if the dosage change was appropriate for a patient. The physician is the only practitioner authorized to determine dosage orders and/or changes.
Patient # 2 was admitted into treatment on March 26, 2016 and discharged on August 4, 2016. Standing orders were written by the physician on March 29, 2016.
Patient # 3 was admitted into treatment on April 5, 2016 and discharged on June 10, 2016. Standing orders were written by the physician on April 5, 2016.
Patient # 5 was admitted into treatment on April 11, 2016 and discharged on October 2, 2016. Standing orders were written by the physician on April 12, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016, Director met with the NTP physician and reviewed initial dosage regulations and best practices.
Director confirms that the NTP physician understood that his previous short cascading standing orders for the administration of methadone is against regulation. Director believes that the NTP physician understands the initial dosage level regulations and best practices and had ceased this practice prior to annual licensing inspection.
The NTP physician will be the only person to make decisions on ordering/changing doses.The nursing supervisor will conduct random chart reviews to ensure compliance and that this deficiency does not reoccur. |
715.16(a)(3) LICENSURE Take-home privileges
(a) A narcotic treatment program shall determine whether a patient may be provided take-home medications.
(3) The narcotic treatment physician shall document in the patient record the rationale for permitting take-home medication.
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Observations
The narcotic treatment physician failed to document in the patient record the rationale for permitting take-home medication in one of two patient records reviewed during the annual licensing, and methadone monitoring inspection conducted on October 4 - 5, 2016.
Patient # 8 was admitted into treatment on March 15, 2016. Patient # 8 was granted take-home medication on May 17, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016, Director updated and changed the operations manual that was written incorrectly addressing take home medication.
All clinical and medical staff reviewed the updated regulation in the operations manual. All staff were given a written copy of the updated take home medication policy and procedure.
Director reviewed with Medical Director that his documented rational for permitting take home medication must be in the patient record.
Director believes that all staff after retraining have a full understanding of the regulations regarding take home medication.
Clinical supervisor will randomly review client records to ensure compliance and that this deficiency does not reoccur. |
715.16(c) LICENSURE Take-home privileges
(c) A narcotic treatment program shall require a patient to come to the narcotic treatment program for observation daily or at least 6 days a week for comprehensive maintenance treatment, unless a patient is permitted to receive take-home medication as follows:
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Observations
The facility failed to require a patient to come to the narcotic treatment program for observation daily in one of two patient records reviewed during the annual licensing, and methadone monitoring inspection conducted on October 4 - 5, 2016. In addition, the facility failed to ensure a patient was permitted to receive take-home medication in one of two patient records.
The facility is open 7 days per week for daily dosing. The facility's policy indicates that a patient may be eligible for take-home medication privileges after 60 days of treatment. State regulations do not permit a patient to receive a take-home supply of medication until 3 months of satisfactory adherence to narcotic treatment program rules.
Patient # 8 was admitted into treatment on March 15, 2016. The facility granted the patient a one day take-home supply of medication per week on May 17, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016, Director updated and changed the operations manual that was written incorrectly addressing take home medication.
All clinical and medical staff reviewed the updated regulation in the operations manual. All staff were given a written copy of the updated take home medication policy and procedure.
All patients will be required to dose daily unless eligible for take home medications. Take home medications are not permitted until patient has three months into treatment.
Director has changed the take home medication approval form and has added the director signature prior to presenting to medical director to ensure that this deficiency does not reoccur.
Director believes that all staff after retraining have a full understanding of the regulations regarding take home medication. |
709.93(a) LICENSURE Client records
709.93. Client records.
(a) There shall be a complete client record on an individual which includes information relative to the client's involvement with the project. This shall include, but not be limited to, the following:
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Observations
The facility failed to document a complete client record in three of eight client records reviewed during the annual licensing inspection conducted on October 4 - 5, 2016.
No case consultation notes were documented in the following client records:
Client # 1 was admitted into treatment on March 22, 2016 and discharged on October 4, 2016.
Client # 2 was admitted into treatment on March 26, 2016 and discharged on August 4, 2016.
Client # 5 was admitted into treatment on April 11, 2016 and discharged on October 2, 2016.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 6th 2016, Director met with Clinical Supervisor and reviewed the regulations and the operations manual that a case consultation note be performed for every client and that all discharged clients must have a case consultation note to have a complete record.
clinical Supervisor will randomly review records to ensure that case consultations notes are being competed to ensure that this deficiency does not reoccur. |