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 September 11-13, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Aldie Counseling Center 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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715.9(c) LICENSURE Intake
(c) If a patient was previously discharged from treatment at another narcotic treatment program, the admitting narcotic treatment program, with patient consent, shall contact the previous facility for the treatment history.
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Observations
Based on the review of patient records, the facility failed to contact the previous narcotic treatment facility for the patient's treatment history in two of four patient records reviewed.
The findings include:
Twenty patient records were reviewed September 11-13, 2013. Four patient records required contacting the prior narcotic treatment facility for the previous narcotic treatment history that was reported by the patient. The facility failed to document an attempt to contact the previous narcotic treatment facility in patient records # 6 and 7.
This finding was reviewed with the Pharmacotherapy Coordinator on 9/11/2013 and was not disputed.
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Plan of Correction
Applicants being admitted to the program will sign release of information forms for all previous narcotic treatment facilities where they were treated, at the time of their orientation to Aldie's methadone maintenance program. The Program Coordinator will be responsible for securing these release forms and sending them to the specific facilities. Releases, documented attempts to secure the information, and the actual information will be filed in the patient's record. The Clinical Director will review new admission charts for compliance. |
715.10(c) LICENSURE Pregnant patients
(c) Counseling records and other appropriate patients records shall reflect the nature of prenatal support provided by the narcotic treatment program.
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Observations
Based on a review of patient records, the facility failed to ensure that pregnant patients' records reflect the nature of prenatal support provided by the narcotic treatment program in two of four patient records reviewed.
The findings include:
Twenty patient records were reviewed on September 11-13, 2013. Four records were reviewed for documentation that reflected the nature of prenatal support provided by the narcotic treatment facility. The facility failed to document prenatal support in patient records # 1 and 2.
This finding was discussed with the Pharmacotherapy Coordinator and was not disputed.
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Plan of Correction
All clinicians will be trained by the Program Coordinator on the need for, and proper documentation of, prenatal support provided by the treatment facility. The Program Coordinator will review the progress notes and treatment plans of all pregnant patients to ensure that clincians are documenting coordination of care with prenatal care providers and other identified support services. |
715.15(a) LICENSURE Medication Dosage
(a) The narcotic treatment physician shall review the dosage levels at least twice a year, with each review occurring at least 2 months apart, to determine a patient 's therapeutic dosage.
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Observations
Based on a review patient records, the narcotic treatment physician failed to document the dosage levels were reviewed at least twice a year, with each review occurring at least two months apart, to determine the patient's therapeutic dosage.
The findings include:
Twenty patient records were reviewed on September 11-13, 2013. Seventeen patient records were reviewed for documentation from the narcotic treatment physician's review of the patient's therapeutic dosage level. One of seventeen records failed to include documentation that the narcotic treatment physician reviewed the patient's dosage level at least twice a year, specifically patient records # 4.
Patient # 4 was admitted on November 5, 2009. Review of record # 4 revealed the narcotic treatment physician conducted a dosage review on December 1, 2012. This was the only dose review documented in the record record for 2012.
This finding was discussed with the Pharmacotherapy Coordinator and was not disputed.
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Plan of Correction
The Program Coordinator has develeloped a tracking system whereby each patient's medication dosage will be reviewed a minimum of twice per year by the narcotic program phsyician. One review will take place at the time of their annual phsycial exam and the second will take place, no more than 6 months, but no less than 2 months, following the exam. The Clinical Director will conduct charts audits to ensure that at least two medication dosage reviews are taking place annually for each patient. |
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 review of patient records, the facility failed to ensure that the narcotic treatment physician determined the patient's dose and schedule.
The findings include:
Twenty patient records were reviewed on September 11-13, 2013. Two patient records were reviewed for documentation for an involuntary termination decision. Patient # 8 was admitted on March 29, 2011 and was discharged on April 11, 2013. The patient received and signed the administrative withdrawal notification for non-compliance on March 16, 2013. In the notification letter the patient was informed that she would begin a 21 day detoxification from the program. The notification was signed by the patient, a counselor, and the pharmacotherapy coordinator. Review of the record revealed the medical director was not involved in the determination to terminate this patient's treatment. The patient met with the medical director on March 16, 2013 for their annual physical. The medical director documented that the patient should continue in methadone maintenance treatment. There were no medical notes by the physician that indicated the patient was going to be therapeutically discharged. There was no documentation in the record that indicated that the narcotic treatment physician was involved in the decision to start this patient on a 21 day detox on March 16, 2013. Further review of the record indicated that the narcotic treatment physician did document a dose change order on March 19, 2013. This order was documented after the decision to terminate the patient was written and signed by the client, counselor, and pharmacotherapy coordinator.
An interview with the pharmacotherapy coordinator confirmed this finding.
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Plan of Correction
The Program Coordinator will be responsible for revising the Notice of Review of Client Appeal Letter to include a signature line for the physician making the decision to terminate the client. Additionally, when a client is being considered for involuntary termination from the program, a case consultation will be done with the physician and documented in the client's chart. When the physician decides to involuntarily terminate the client, a copy of the letter and case consultation will be provided to the other narcotic treatment physcian so they are aware of this decision. Additionally, the detoxification order will be entered into the automated dispensing system immediately following the decision to terminate (with detoxification start date to follow notification of the client)so the actual order is available to the other physician. The Program Coordinator will be responsible for ensuring that the forms are being completed by the physician, a copy is given to the other physian and the order is entered into the computer system. |