Observations Based upon a review of three client records an interview with staff persons #1 and #2 on October 17, 2008, and follow up correspondence via telephone and e-mail on October 20, 2008, the facility failed to obtain an informed and voluntary consent from clients to release information contained in the client records.
Findings:
Client records #1, 2 and 3 lacked a signed consent to release information form to release client identifying information to the University of Pennsylvania for participation in a research project. In addition, the facility engaged in research and evaluation activities where client identifying information was released prior to and without approval from the Bureau of Drug and Alcohol Programs as required by 4 Pa. Code 255.7 (a)(3).
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Plan of Correction Effective immediately, clients who have elected to participate and given informed consent, will sign a release of information to the facility/agency who is conducting the project.
There are no research/study projects currently underway at NetSteps. If NetSteps is involved in any research/ study projects in the future, this policy will be in place which addresses Code 255.7 (Research and evaluation, and we will adhere to the policy. |