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 23 and 24, 2010 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Alliance Medical Services 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 July 18, 2010.
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Plan of Correction
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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
Based on the review of time sheets, census reports and an interview with the facility director, the narcotic treatment program failed to provide at least one hour of physician time per week on site for every ten patients.The findings include:On June 23 and 24, 2010 census reports, physician time sheets and physician extender time sheets were reviewed for the months of February, March, April, May and June of 2010. Per regulation , a "narcotic treatment program shall provide narcotic treatment physician services at least 1 hour per week onsite for every ten patients." There were insufficient onsite physician hours in February, March, April, May and June of 2010.During the week of February 22, 2010, the census was 218 patients and 20 physician hours. During the week of March 1, 2010, the census was 219 patients and 20 physician hours.During the week of March 8, 2010, the census was 219 patients and 20 physician hours. During the week of March 22, 2010, the census was 219 patients and 20 physician hours. During the week of March 29, 2010, the census was 219 patients and 20 physician hours.During the week of April 5, 2010, the census was 217 patients and 20 physician hours.During the week of April 12, 2010, the census was 217 patients and 17.5 physician hours.During the week of April 19, 2010, the census was 217 patients and 17.5 physician hours.During the week of April 26, 2010, the census was 215 patients and 20 physician hours. During the week of May 3, 2010, the census was 218 patients and 20 physician hours.During the week of May 10, 2010, the census was 218 patients and 20 physician hours.During the week of May 17, 2010, the census was 217 patients and 20 physician hours.During the week of May 24, 2010, the census was 218 patients and 20 physician hours.During the week of May 31, 2010, the census was 218 patients and 17.5 physician hours. During the week of June 7, 2010, the census was 218 patients and 20 physician hours. During the week of June 16, 2010, the census was 217 patients and 17.5 physician hours.This is a repeat citation.
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Plan of Correction
The facility failed to provide the required physician hours that are based on current census.
The facility director will develop a weekly schedule for the physician, based on the 1:10 ratio for active patients. The physician assistant will monitor compliance on a daily basis. The facility director is responsible to oversee this process and will adjust weekly based on current census. The facility director will also be responsible for training the physician related to this regulation.
These changes will be completed by 7/15/2010.
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715.20(4) LICENSURE Patient transfers
A narcotic treatment program shall develop written transfer policies and procedures which shall require that the narcotic treatment program transfer a patient to another narcotic treatment program for continued maintenance, detoxification or another treatment activity within 7 days of the request of the patient.
(4) The receiving narcotic treatment program shall document in writing that it notified the transferring narcotic treatment program of the admission of the patient and the date of the initial dose given to the patient by the receiving narcotic treatment program.
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Observations
Based on the review of patient records and an interview with the facility director, the facility failed to document that it notified the transferring narcotic treatment program of the admission of the patient and date of the initial dosing of the patient in two of three patient records.The findings include:Fifteen patient records were reviewed on June 23 and 24, 2010. Three patient records were reviewed for documentation of notification to the transferring narcotic treatment program of the admission and date of initial dosing of the transferred patient. Per regulation, the receiving narcotic treatment program is to" notify the transferring narcotic treatment program of the admission of the patient and date of the initial dose given to the patient by the receiving narcotic treatment program." Patient # 5 was transferred by another narcotic treatment program and admitted on 4/26/10. There was no documentation in the patient record of the transferring narcotic treatment program being notified of the date of the initial dose of the patient.Patient #8 was transferred by another narcotic treatment program and admitted on 3/18/10. There was no documentation in the patient record of the transferring narcotic treatment program being notified of the date of the initial dose of the patient.
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Plan of Correction
AMS failed to document that it notified the transferring narcotic treatment program of the admission of the patient and date of the initial dosing of the patient.
It is the responsibility of the medical staff to notify the transferring program upon admission and initial dosing of the patient. The nurse is responsible to contact the transferring program with this information and to document this contact in the medical chart.
The physician/physician assistant is responsible to provide training to medical staff in this area. The physician assistant is responsible for ongoing compliance through reveiw of patient records on the day of admission.
These actions will be completed by 7/20/2010. |
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 a review of patient records, the policy and procedure manual and and an interview with the facility director, the facility failed to document that the patient received written notification of an involuntary termination.The findings include:Fifteen patient records and the policy and procedure manual were reviewed on June 23 -24, 2010. One patient record was reviewed for notification of involuntary termination. Per regulation, a narcotic treatment program shall develop policies and procedures regarding involuntary terminations including notifying "the client, in writing, of a decision to involuntarily terminate the client's treatment at the project." Patient #7 was admitted on 9/19/08. Patient #7 was referred to a "higher level of care" due to not being compliant with his treatment plan. Patient #7 refused the referral and appealed the decision. Patient #7 was involuntarily discharged on 10/5/09. Patient #7 was verbally given notice of his involuntary termination from the narcotic treatment program. An interview with the facility director on June 24, 2010 confirmed that the patient did not receive written notification of his involuntarily termination from the narcotic treatment program.
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Plan of Correction
The facility did not document that the patient had received a written notification of involuntary termination.
The facility utilizes a written notification for patients that will be involuntarily terminated. It is the procedure for AMS to provide this letter to the patient and a copy to be placed in the clinical chart.
It is the responsibility of the clinical supervisor to insure that this documentation is included in the record through regular reveiw. In addition, supervision is utilized to provide additional training and oversite as indicated. Finally, the clinical supervisor will provide inservice training to assist in gaining compliance.
All actions to resolve this issue will be completed by 7/25/2010.
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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, facility policy and procedure manuals and an interview with the facility director, the facility failed to document follow-up in accordance with the the narcotic treatment program's policy and procedure. The findings include:Fifteen patient records were reviewed June 23-24, 2010. Six patient records were reviewed for follow-up documentation. Patient records #7 and #9 did not have documentation of a patient follow up attempt or contact in accordance with the narcotic treatment program's policy and procedure. Patient #7 was admitted on 9/19/08 and discharged on 10/5/09. There was no documentation in the patient record that, in accordance with the narcotic treatment program's policy and procedure, a three month follow up attempt was completed. Patient #9 was admitted on 11/10/05 and discharged on 7/20/09. There was no documentation in the patient record that, in accordance with the narcotic treatment program's policy and procedure, a three month follow up attempt was completed.
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Plan of Correction
The facility failed to document follow up efforts in a consistent manner.
It is the responsibility of the facility to provide follow up information in accordance with policy and procedure.
The clinical supervisor will provide inservice training on follow up contacts. All attempts or contacts will be documented in the patient chart. The clinical supervisor will monitor discharged pt. charts for compliance. In addition, a data base report will be utilized for monitoring and compliance. Clinical supervision will be utilized for ongoing training. The clinical supervisor is responsible for compliance in this area.
The corrective action will be completed by 7/25/2010. |