Observations
The facility failed to obtain an informed and voluntary consent from the client for the disclosure of information in three of twenty client records reviewed during the annual licensing inspection conducted on April 19 - 21, 2017.
The facility released by fax the client's name, prescription information and diagnosis to a pharmacy and a medication support agency in the following records:
Client # 11 was admitted on November 27, 2016 and discharged on December 18, 2016. The disclosure occurred on December 16, 2016.
Client # 14 was admitted on December 30, 2016 and discharged on January 20, 2017. The disclosure occurred on January 19, 2017.
Client # 20 was admitted on January 4, 2017 and discharged on January 26, 2017. The disclosures occurred on December 23 and December 26, 2016. In addition, the facility disclosed by fax the client's name, prescription and referral information to a treatment provider on January 25, 2017.
The findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The facility will obtain an informed and voluntary consent from every client for the disclosure of information.
Each individual enrolled in the Vivitrol program will review and sign a consent for the disclosure of information related to aftercare follow-up, their medical funding source as well as the specialty pharmacy that will be used to obtain their Vivitrol. No information will be released to an entity without a signed, specific consent that is within compliance of § 709.28.
Any information released to Health Insurance will remain in compliance with PA § 255.5. A Vivitrol Prior Authorization letter is provided to the Medical Insurance. This letter has §255.5 attached to it and an explanation is offer for the information we can and cannot provide.
The Nursing Director & Assistant Nursing Director met with the VIVITROL Coordinator and Asst. VIVITROL Coordinator to review the findings and the letter was developed on 4/24/17.
The Nursing Director and Assistant Nursing Director will select and check 14 random charts per month for six months to ensure compliance. The completion date for the inspection of the charts will be 11/30/17. |