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 18-20, 2012 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.
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Plan of Correction
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715.16(b)(1-8) LICENSURE Take-home privileges
(b) The narcotic treatment physician shall consider the following in determining whether, in exercising reasonable clinical judgment, a patient is responsible in handling narcotic drugs:
(1) Absence of recent abuse of drugs (narcotic or non-narcotic), including alcohol.
(2) Regular narcotic treatment program attendance.
(3) Absence of serious behavioral problems at the narcotic treatment program.
(4) Absence of known recent criminal activity.
(5) Stability of the patient 's home environment and social relationships.
(6) Length of time in comprehensive maintenance treatment.
(7) Assurance that take-home medication can be safely stored within the patient 's home.
(8) Whether the rehabilitative benefit to the patient derived from decreasing the frequency of attendance outweighs the potential risks of drug diversion.
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Observations
Based on the review of patient records, the facility failed to document that the narcotic treatment physician considered the criteria in 715.17 (b) (1-8) prior to granting take home medication privileges in two of six patient records.
The findings include:
Twenty two patient records were reviewed on September 18-20, 2012. Six patient records reviewed had been granted take home medication privileges. There was no documentation that the narcotic treatment physician considered 715.17 (b) (1-8) prior to granting take home medication privileges in patient records # 4 and 13.
Patient # 4 was admitted into treatment on November 28, 2011. The patient had transferred into treatment from another narcotic treatment program and was immediately granted take-home privileges. There was no documentation that the criteria had been considered prior to the granting of take-home privileges.
Patient # 13 was admitted into treatment on November 28, 2011. The patient had transferred into treatment from another narcotic treatment program and was immediately granted take-home privileges. There was no documentation that the criteria had been considered prior to the granting of take-home privileges.
The Facility Director was interviewed on September 20, 2012 and confirmed the findings.
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Plan of Correction
This regulation was reviewed by the Facility Director with the Medical Director and all clinical staff on 9/25/12. The facility Transfer In checklist was updated to reflect the confirmation of take home information from the transfering clinic as well as the cue for the physician here to review the 8-point criteria prior to granting continued take home privileges. The Clinical Supervisor will monitor compliance with this regulation in all charts for incoming trnasfers. |
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 a review of patient records, the facility failed to document that the narcotic treatment physician determined the patient's dosing schedule in two of five patient records.
The findings include:
Twenty two patient records were reviewed on September 18-20, 2012. Five patient record were reviewed for take-home medication privileges. There was no documentation that the narcotic treatment physician determined the patient's schedule in patient records # 4 and 13.
Patient # 4 was admitted into treatment on November 28, 2011. The patient had transferred into treatment from another narcotic treatment program. The patient had 6 day take home privileges from the transferring facility. The patient was provided with privileges for a 6-day take-home supply of medication upon transfer. The patient's record included documentation that the physician confirmed the patient had 6 day take home medication privileges at the previous facility, however, there was no documentation of a current doctor's order granting the patient a 6-day take-home supply of medication.
Patient # 13 was admitted into treatment on November 28, 2011. The patient had transferred into treatment from another narcotic treatment program. The patient had 6 day take home privileges from the transferring facility. The patient was provided with privileges for a 6-day take-home supply of medication upon transfer. The patient's record included documentation that the physician confirmed the patient had 6 day take home medication privileges at the previous facility, however, there was no documentation of a current doctor's order granting the patient a 6-day take-home supply of medication .
The Facility Director was interviewed on September 20, 2012 and confirmed the findings.
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Plan of Correction
This regulation was reviewed by the Facility Director with the Medical Director and all clinical staff on 9/25/12. The Medical Director will ensure that all incoming transfer patients with take home privileges are re-evaluated for those privileges using the 8-point criteria prior to the take home privileges being granted. He will ensure that there is an appropriate order written in the file prior to the privileges being issued to the patient. The Facility Director will review each transfer file upon admission to ensure compliance with the regulation. This review process is effective as of 10/1/12. |
715.20(1) 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.
(1) The transferring narcotic treatment program shall transfer patient files which include admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient.
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Observations
Based on a review of patient records, the facility failed to document that it transferred patient records which included admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, current status of the patient and contained the written consent of the patient in one of two patient records.
The findings include:
Twenty two patient records were reviewed on September 18-20, 2012. Two of the patients reviewed transferred to another narcotic treatment facility and required a transfer of patient records. There was no documentation that the facility transferred the documentation in patient record # 20.
Patient # 20 was admitted on October 7, 2009 and transferred to another narcotic treatment program on May 9, 2012. There was no documentation that the the transferring narcotic treatment program released the required documentation from the patient's record to the receiving agency as requested.
The Facility Director was interviewed on September 20, 2012 and confirmed the findings.
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Plan of Correction
This regulation was reviewed by the Clinical Supervisor and Facility Director with all clinical staff on 9/25/12. The Clinical Supervisor will reveiw each chart of patients who transfer to another facility within 48 hours of the transfer to ensure that the required documentation is sent to the new facility. The Clinical Supervisor will ensure that the counselor involved in the case properly documents the transfer of the appropriate records in the chart. This review process was effective as of 10/1/12. |