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 and buprenorphine, in the treatment of narcotic addiction. This inspection was conducted on August 20-21, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, White Deer Run, Inc. 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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715.17(b) LICENSURE Medication control
(b) A narcotic treatment program shall develop policies and procedures regarding verbal medication orders, including the issuing and receiving of orders, identifying circumstances when orders are appropriate and documenting orders, in accordance with applicable Federal and State statutes and regulations.
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Observations
Based on the review of patient records, the facility failed to ensure the physician signed and dated a verbal order in two of two patient records reviewed.
The findings include:
Fifteen patient records were reviewed August 20-21, 2013. Two patient records contained documentation of a physician's verbal order. Patient record # 4 contained documentation of two verbal order and neither were signed by the issuing physician. The second patient record had a signed verbal order without a date, therefore there was no way to determine it was signed within 24 hours as required.
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Plan of Correction
Verbal Physician orders will be signed and dated within 24-hours by physician. Chart containing the verbal/telephone order will be placed on the physicians desk by charge nurse from each shift for signature.
Director of Nursing will conduct training with medical staff on communication between nursing and physicians to ensure all verbal/telephone orders are signed within 24 hours.
Director of Nursing will complete 10 chart audits on a monthly basis to ensure that charts and forms located in the chart are within compliance.
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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 the review of patient records, the facility failed to restrict the reasons for involuntary termination to those reasons allowed by regulation in one of four patient records.
The findings include:
Eighteen patient records were reviewed August 20-21, 2013. Six patient records were reviewed for involuntary, or therapeutic, discharge. Two patient records contained documentation of the patient being discharged for reasons other than those allowed by regulation.
Patient # 15 was admitted July 17, 2013 and administratively discharged for "refusing mandatory medication" on July 19, 2013. There was no documentation of why the patient was refusing to take the medication or any documentation of therapeutic interventions if the medications were important for the patient's safety and well-being during the detoxification process.
Patient # 18 was admitted July 16, 2013 and administratively discharged on July 21, 2013 for "refusing to go to rehab". There was no other information documented in the patient record, such as that the patient wanting to leave against advice. There was no documentation of any therapeutic interventions.
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Plan of Correction
Clinical and Medical staff will participate in team meetings with Clinical Director and Nursing Director to review the involuntary termination policy for clients in the narcotic treatment program.
During the meetings, the policy will be distributed which outlines what constitutes the ability to involuntarily discharge someone from treatment.
Patients involved in problematic behaviors that could lead to an involuntary discharge will go through the following process:
1-The problem behaviors will be incorporated into their treatment plan and process.
2-The unit supervisor will meet with the clinical director to review case.
3-The clinical director will review case with regional administrator to discuss plan of action and to receive recommendations.
4-Regional Administrator will determine whether the patient will be in-voluntarily discharged from the program.
In situations where an act or threat of violence has occurred, contact will be made to the clinical director, medical staff, and the regional administrator. In such situations, the patient may be involuntarily discharged without participating in the above mentioned steps.
Prior to any involuntary discharge from treatment, staff will ask patient to sign termination form; outlining the purpose of termination. If patient refuses to acknowledge this or sign the form, staff will mail a copy of the form/letter informing them of their discharge/termination from treatment to the client with a copy of the appeal process and form. Staff will write on communication sheet whether they gave client a copy of the form or whether it was mailed and when to the client.
Nursing will also be made aware of all involuntary discharges in order to review any medical concerns.
Medical records and supervisors will audit 10 charts monthly to track that these forms are being utilized and that the letters are being documented on the communication log.
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