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Pennsylvania Department of Drug & Alcohol Programs
Inspection Results

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NUESTRA CLINICA REHABILITACION
50 EAST NEW STREET
LANCASTER, PA 17602

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Survey conducted on 06/13/2011

INITIAL COMMENTS
 
This report is a result of an onsite follow-up inspection regarding the plans of correction for the January 24, 2011 through January 25, 2011 licensure renewal inspection. The follow-up inspection was conducted on June 13, 2011 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the onsite follow-up inspection, Nuestra Clinica Rehabilitacion was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during this inspection.
 
Plan of Correction

709.32(c)(4)  LICENSURE Medication Control

709.32. Medication control. (c) The project shall have a written policy regarding medications used by clients which shall include, but not be limited to: (4) Methods for control and accountability of drugs.
Observations
Based on a review of the facility's medication administration records and an interview with the facility director, the facility failed to document medication records in accordance with facility policy.



Findings:



Facility policy titled "Nuestra Clinica Residential Medication Policies Section 709.32c" Page 4 states: "In the event that a client refuses a prescribed medication, staff will document the client's refusal in the Medication Administration Log and contact the on call medical staff to review the situation if the client's refusal could be considered an immediate health risk."



Facility policy titled "Nuestra Clinica Residential Medication Policies Section 709.32c" Page 7 states: "When a client discontinues taking a particular type of prescribed medication, the disposal of that medication will be documented on his medication log if appropriate, by the staff member who disposed of medication."



The facility failed to follow their policy and document whether or not a client received their medication, whether a client refused their medication, whether the medication was discontinued, or whether the medication was being taken as prescribed, in five medication records reviewed.



Client # 1

Drug: Vistaril 25 MG - Frequency: take 1 to 2 caps at bedtime



Dates not taken: 6/9/2011, 6/10/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: Who entered the information (staff signature), the prescription date, the prescribing doctor, the client's dated signature indicating their agreement to take the medication, and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.







Client #2



Drug: Risperdal 1 mg, Prescribed on 5/20/11, Frequency: Take 1.5 tablets every AM. Dates not taken: 5/22/11, 5/23/11, 5/25/11, 5/26/11, 6/2/11, 6/3/11 and 6/13/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication, and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.







Drug: Trazodone 100 mg: Frequency: 1 tablet at bedtime. Date not taken: 5/26/11, 5/27/11, 5/28/11, 5/29/11, 5/31/11, 6/4/11, 6/5/11, 6/6/11, 6/7/11, 6/8/11, 6/9/11, 6/10/11, 6/11/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication, and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Cogentin 0.5 mg. Frequency: Take twice a day (form states morning and evening dose time). The medication administration record only shows that the client was taking one dose in the evening from May 20, 2011 through June 12, 2011.



Facility staff reported that the client was taking a double dose in the evening. This was not documented on the medication administration record. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication, and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.







Client #4

Drug: Chlorpromazine 100 mg. Prescribed on 5/20/11. Frequency: 1 tablet at bedtime. Dates not taken: 5/22/11, 5/29/11, 6/3/11, 6/5/11 and 6/6/11.



There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Client #9

Drug: Valtrex 500 MG. Prescribed on 5/26/11. Frequency: 1 tablet everyday.



Dates not taken: 5/28/11, 5/29/11, 5/30/11 5/31/11 and 6/1/11. There was no documentation as to why the client skipped or missed a dosage.





Client #10



Drug: Benztropine 0.5 mg. Prescribed on 1/13/11. Frequency: 1 tablet at bedtime.



Dates not taken: 5/12/11, 5/18/11, 5/21/11 and 6/09/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for following dates: 5/3/11, 5/4/11, 5/5/11, 5/10/11, 5/11/11, 5/14/11, 5/16/11, 5/17/11, 5/19/11, 5/20/11, 5/25/11, 5/30/11, 6/1/11, 6/2/11, 6/10/11 and 6/11/11. There was no documentation of the prescribing physician.







Drug: Risperidone 2 mg. Prescribed on 5/2/11. Frequency: 1 tablet by mouth at bedtime. Dates not taken: 5/12/11, 5/18/11 and 6/9/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for following dates: 5/3/11, 5/4/11, 5/5/11, 5/10/11, 5/11/11, 5/14/11, 5/15/11, 5/16/11, 5/17/11, 5/19/11, 5/20/11, 5/23/11, 5/25/11, 5/30/11, 6/1/11, 6/2/11, 6/6/11, 6/10/11 and 6/11/11. There was no documentation of the date of the prescription.







Drug: Klor-Conmzo. Prescribed on 5/3/11. Frequency: 1 tablet daily. Dates not taken: 5/30/11, 5/31/11, 6/9/11 and 6/10/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/5/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 5/28/11, 6/6/11 and 6/8/11.



Drug: Furosemide 40 mg. Prescribed on 5/3/11. Frequency: 1 tablet daily. Dates not taken: 5/11/11, 5/30/11, 5/31/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/5/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 5/28/11, 6/6/11 and 6/8/11







Drug: Omeprazole 20 mg. Prescribed on 5/5/11. Frequency: 1 capsule daily. Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/4/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 5/28/11, 6/6/11 and 6/8/11. There was no time documented for the dosage given on 6/17/11. There was no documentation of the prescribing physician.



Drug: Folic Acid 1 mg. Prescribed on 5/3/11. Frequency: 1 tablet in the morning.



Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/10/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/5/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 6/6/11, 6/7/11 and 6/8/11. There was no documentation of the prescribing physician.

Drug: Thiamine 100 mg. Prescribed on 5/2/11. Frequency: 1 tablet daily. Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/2/11, 5/5/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 6/6/11 and 6/8/11. There was no documentation of the prescribing physician.

Drug: ASA 325 mg. Prescribed on 5/2/11. Frequency: 1 tablet daily. Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/2/11, 5/5/11, 5/9/11, 5/14/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 6/6/11, 6/8/11 and 6/10/11. There was no documentation of the prescribing physician.

Drug: MVI. Prescribed on 5/2/11. Frequency: 1 tablet daily by mouth. Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/9/11, 6/11/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/2/11, 5/9/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11, 6/6/11 and 6/8/11. There was no documentation of the prescribing physician.



Drug: Citalopram 20 mg. Prescribed on 5/2/11. Frequency: 1 tablet daily by mouth.



Dates not taken: 5/3/11, 5/30/11, 5/31/11, 6/8/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/2/11, 5/5/11, 5/10/11, 5/16/11, 5/18/11, 5/23/11, 5/24/11 and 6/6/11. There was no documentation of the prescribing physician.



Drug: Glucotrol 5 mg. Prescribed on 5/5/11. Frequency: 2 tablet daily with food



Date not taken: 5/9/11, 5/23/11, 5/24/11, 5/25/11, 5/26/11, 5/27/11, 5/30/11, 5/31/11, 6/1/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/16/11, 5/18/11, 5/28/11, 6/6/11 and 6/8/11. The time of day the dosages were given on 5/5/11 and 5/6/11 were missing.





Drug: Gabapentin 300 mg. Prescribed on 5/5/11. Frequency: 1 tablet by mouth 2x daily. Dates not taken: 5/27/11, 5/30/11, 5/31/11, 6/2/11, 6/3/11 and 6/11/11.



There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 5/24/11, 5/25/11, 5/26/11, 5/30/11, 6/1/11, 6/6/11, 6/8/11, 6/10/11 and 6/11/11. There was no documentation of the time the client took the dose on 6/9/11. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Warfarin 7.5 mg. Frequency: 1 tablet daily along with 2 mg tablet. Dates not taken: 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 6/6/11, 6/8/11 and 6/10/11. The medication administration record was missing the following information: the prescription date, the prescribing physician, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.



Drug: Warfarin sodium 2 mg. Prescribed on 5/26/11. Frequency: 1 tablet daily with 7.5 mg. Dates not taken: 5/30/11, 5/31/11, 6/9/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 6/6/11 and 6/8/11. The medication administration record was missing the following information: staff signature and date who entered the information, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Metformin 850 mg. Frequency: 1 tablet twice daily then ???



Dates not taken: 5/30/11 (only once), 5/31/11 (only once), 6/11/11 (only once) and 6/9/11 (not at all). There was no documentation as to why the client skipped or missed a dosage. The client sign off was missing for the following dates: 6/2/11, 6/8/11, 6/10/11 and 6/11/11. The medication administration record was missing the following information: staff signature and date who entered the information, the prescription date, the prescribing physician, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Client #11



Drug: Effexor xr 75 mg. Prescribed on 5/30/11. Frequency: Take 1 capsule daily in the AM. Dates not taken: 6/4/11, 6/6/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given. The clients ID number was not documented on the medication form.





Client #12



Drug: Vistaril. Prescribed on 6/6/11. Frequency: Take one or two tab at bedtime



Dates not taken: 6/6/11, 6/10/11, 6/11/11, 6/12/11, 6/13/11 and 6/14/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Zoloft 50 mg. Prescribed on 5/26/11. Frequency: Take one everyday.



Dates not taken: 5/29/11, 5/31/11, 6/1/11, 6/2/11, 6/3/11, 6/4/11, 6/5/11, 6/6/11, 6/9/11, 6/10/11, 6/11,11, 6/13/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication.





Client #13



Drug: Zyprexa 15 mg. Frequency: Take one daily a bedtime. Dates not taken: 6/4/11, 6/8/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: staff signature and date who entered the information, the prescribing physician and the prescription date, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.

Staff did not sign the 6/2/11 dosing entry.



Drug: Trazodone 100 mg. Prescribed on 6/8/11. Frequency: Take one tab at bedtime. Dates not taken: 6/8/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication.



Drug: Ketoconazole. Frequency: Take one daily. Dates not taken: 6/4/11 and 6/8/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: staff signature and date who entered the information, the prescribing physician and the prescription date, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Client #14



Drug: Trazodone 100 mg. Prescribed on 4/21/11. Frequency: Take two at bedtime.



Dates not taken: 5/2/11, 5/3/11, 5/5/11, 5/6/11, 5/7/11, 5/9/11, 5/10/11, 5/19/11, 5/20/11, 5/22/11, 6/1/11, 6/3/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Client #15



Drug: Naproxen 500 mg. Prescribed on 5/3/11. Frequency: Take one tab twice daily. Dates not taken: 5/8/11 (one time), 5/9/11 (one time), 5/10/11 (not at all), 5/14/11 (one time), 5/15/11 (not at all), 5/16/11 (not at all), 5/21/11 (one time), 5/22/11 (one time), 5/23/11 (one time), 5/26/11 (one time), 5/27/11 (one time), 5/28/11 (not at all), 5/29/11 (not at all), 6/1/11 (one time), 6/2/11 (one time), 6/3/11 (one time), 6/6/11 (one time), 6/7/11 (not at all), 6/8/11 (not at all), 6/9/11 (not at all) 6/10/11 (not at all), 6/11/11 (not at all) and 6/12/11 (not at all). There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given. There was no documentation of the prescribing physician.







Drug: Simuastin 40 mg. Frequency: Take one at bedtime. Dates not taken: 6/10/11. There was no documentation as to why the client skipped or missed a dosage.



The medication administration record was missing the following information: staff signature and date who entered the information, the prescribing physician and the prescription date, the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.



Drug: Metformin HCL 1,000 mg. Prescribed on 5/22/11. Frequency: Take one twice daily. Dates not taken: 6/1/11 (one time), 6/6/11 (one time), 6/13/11 (morning dose not taken). There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Client #16



Drug: Seroquel 100 mg. Prescribed on 6/10/11. Frequency: Take one at bedtime



Dates not taken: 6/11/11 and 6/12/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.







Client #17



Drug: Citalopram (celexa) 40 mg. Prescribed on 5/28/11. Frequency: One tab every morning. Dates not taken: 5/29/11, 5/30/11, 5/31/11, 6/2/11, 6/3/11, 6/4/11, 6/5/11, 6/7/11, 6/8/11, 6/10/11, 6/11/11, 6/12/11 and 6/13/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Risperidone 2 mg. Prescribed on 5/28/11. Frequency: Take one at bedtime



Dates not taken: 5/29/11, 5/30/11, 5/31/11, 6/2/11, 6/3/11, 6/4/11, 6/5/11, 6/6/11, 6/7/11, 6/9/11, 6/10/11 and 6/11/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.





Drug: Lisinopril 10 mg. Prescribed on 5/28/11. Frequency: Take one once a day



Dates not taken: 5/29/11, 5/30/11, 5/31/11, 6/2/11, 6/3/11, 6/4/11, 6/5/11, 6/7/11, 6/8/11, 6/10/11, 6/11/11, 6/12/11 and 6/13/11. There was no documentation as to why the client skipped or missed a dosage. The medication administration record was missing the following information: the client's dated signature indicating their agreement to take the medication and the staff signature indicating the potential side effects were explained to the client and the date the explanation was given.







This is a repeat citation.

The facility was previously cited for noncompliance of this standard during the January 24, 2011 through January 25, 2011 licensing inspection. The facility's plan of correction submitted on March 10, 2011 and approved on March 22, 2011 stated the following:



" On February 16, 2011 a staff meeting was held and all staff were educated on the medication policy and asked to sign a form acknowledging attendance at the training. Staff were informed that in the event of a client refusing medication, the staff person must document the refusal in the medication book, date the book, and initial the medication log as to whether client failed to come in the office for mediation or that the client refused the medication. The on duty staff will then call the nurse and advise of the refusal. If the situation is not life threatening, the nurse,upon her return to the facility, will educate the client on the risks involved in medication non compliance. In addition, the nurse will advise the client's primary counselor of the non compliance issue and the counselor will add this problem to the treatment plan and future goals for the client. If the client remains non compliant they will be referred for a mental health assessment by psychiatrist. If the evaluation concludes the client should remain on medication then the client must adhere or face progressive disciplinary actions including loss of privileges up to possible discharge. If medication is discontinued by physician/psychiatrist it will be documented on the medication log, medication will be properly disposed of, and documentation of when and who disposed of the medication will be kept. Staff will also be held accountable for the documentation of medication and refusals. This will be overseen by the nurse,associate director and the project director. Failure to comply will result in disciplinary measures stated in the employee handbook, which includes possible termination. ***** The nurse will review the medication sheets daily for compliance. Any discrepancies will be reported to the associate director and the employee will be retrained by the nurse. If any employee has further problems with documentation after the initial training they will be placed on a probationary period to allow direct supervision of procedure. Failure to comply with policy during the probation period may result in disciplinary action up to and including termination**. "



An interview with the facility director on June 13, 2011 confirmed the findings.
 
Plan of Correction
A staff meeting was held on June 21, 2011. At this time several employees received warnings which were placed in their personnell file. THe nurse was also given a verbal warning for non compliance with daily monitoring of the medication book. The nurse agrees to review the medication sheets daily for compliance. Any discrepancies will be reported to the associate director, the director and the employee. If any employee has further problems with documentation additional training will be provided and disciplinary measures will escalate. Employee will not be allowed to observe self medication alone until satisfactory standards have been met. Retrainining has been scheduled for the entire staff to ensure understanding of self medication procedures. In addition any client that refuses or does not come at medication time will receive behavioral contract that if not followed could casue client to be transferred or discharged for non compliance of facility rules. We will also refer client back to psychiatrist for re-evaluation of medication and possible d/c or change in medications.

709.51(b)(6)  LICENSURE Psychosocial evaluation

709.51. Intake and admission. (b) Intake procedures shall include documentation of: (6) Psychosocial evaluation.
Observations
Based on a review of client records and an interview with the facility director, the facility failed to document psychosocial evaluations in four of eight client records.



The finding includes:





Eight client records were reviewed on June 13, 2011. Psychosocial evaluations were to be documented in four client records, #1, 2, 3 and 4. An interview with the facility director took place on June 13, 2011 and he confirmed that the evaluations were not documented.





Client records #1, 2, 3, and 4 failed to document the client's composite picture, problems/needs, assets/strengths, support systems, coping mechanisms, negative factors that might inhibit treatment and the counselor conclusions/impressions.





This is a repeat citation.



The facility was previously cited for noncompliance of this standard during the January 24, 2011 through January 25, 2011 licensing inspection. The facility's plan of correction submitted on March 11, 2011 and approved on March 22, 2011 stated the following:



"On February 4, 2011, the bio-psychosocial evaluations were expanded to prompt the clinician to write a clinical conclusion in narrative form at the end of the assessment. In addition, direct questions were added to the evaluation to prompt the clinician to ask probing questions. ... **Associate director will conduct chart audits on a weekly basis under the supervision of the project director. Clinicians that continue to exhibit difficulty following policy and procedure will be retrained in house and be registered for BDAP training's. Once a clinician has had the additional training they will be monitored for compliance. Any further deviance from protocol will lead to disciplinary measures that include probation up to and including termination."
 
Plan of Correction
Project Director held meeting with clinicians to discuss the evaluative process . The evaluations have been strengthenend to allow for both the clinician and the client to state their opion on composite picture.

The Clinial Supervisor will review records weekly for the next 60 days then quarterly to ensure copmpliance.

Process will begin July 1st and continue weekly until December 1,2011. Then every 3 months to maintain consistency.

709.53(a)(10)  LICENSURE Discharge Summary

709.53. Client records. (a) There shall be a complete client record on an individual which includes information relative to the client's involvement with the project. This shall include, but not be limited to, the following: (10) Discharge summary.
Observations
Based on the review of client records and an interview with the facility director, the facility failed to document discharge summaries in four of four closed client records reviewed.



The findings include:



Eight client records were reviewed on June 13, 2011. Discharge summaries where required in four closed client records, #5, 6, 7 and 8. Discharge summaries are to have documentation of the client's reason for treatment, services offered, response to treatment and the client's status at the time of discharge. Client records #5, 6, 7 and 8 did not have documentation of client's reason for treatment.



This is a repeat citation.



The facility was previously cited for noncompliance of this standard during the January 24, 2011 through January 25, 2011 licensing inspection. The facility's plan of correction submitted on March 11, 2011 and approved on March 22, 2011 stated the following:



"The discharge summaries were updated on February 4, 2011, and now specifically ask," what was the reason for treatment", and "response to treatment." In addition the staff was instructed by the project director to complete discharge summaries on day of discharge or within 7 days of discharge. Clinicians acknowledged that they understood discharge summaries could not be completed prior to discharge date. Clinical supervisor will monitor these summaries under direction of the project director."



An interview with the facility director on June 13, 2011 confirmed the findings.
 
Plan of Correction
Clinicians met with prject director and direviewedthe charts which were found non compliant. We found that discharge summaries were found deficient because they did not document all the neccessary information to complerer the summary. Charts will be reviewed upon discharge for the next 60 days by project director at time of discharge. If found to be non compliant project dirctor will immediately work with clinician to correct infomation. Reviews will take place from July 1st until September 1st tehn quarterly to ensure compliance.

709.53(a)(11)  LICENSURE Follow-up information

709.53. Client records. (a) There shall be a complete client record on an individual which includes information relative to the client's involvement with the project. This shall include, but not be limited to, the following: (11) Follow-up information.
Observations
Based on a review of client records and an interview with the facility director, the facility failed to document follow-up information in two of four closed client records reviewed.



The findings include:



Eight client records were reviewed on June 13, 2011. Four of the eight records were closed client records, #5, 6, 7 and 8. Two out of four client records reviewed, specifically records # 7 and 8, lacked documentation of a follow-up contact. Per the facility's policy and procedure, all clients will either be contacted within 7 days of discharge if being referred or 30 days following their discharge date.



Client # 7 was admitted on December 3, 2010 and discharged on March 10, 2011. As of the date of the inspection there was no documentation of the client's follow-up information in the record reviewed. The follow-up should have taken place by April 10, 2011.



Client #8 was admitted on December 17, 2010 and discharged on April 7, 2011. As of the date of the inspection there was no documentation of the client's follow-up information in the record reviewed. The follow-up should have taken place by May 7, 2011.



This is a repeat citation.



The facility was previously cited for noncompliance of this standard during the January 24, 2011 through January 25, 2011 licensing inspection. The facility's plan of correction submitted on March 11, 2011 and approved on March 22, 2011 stated the following:



"The associate director will be responsible for reviewing charts for follow up forms compliance. At the time of discharge, the discharge form will be semi completed with the name, date, and location of aftercare. The administrative assistant will make the call 7 days after discharge and document the adherence or lack of adherence to aftercare plan. If the client attended aftercare appointment a 30 day follow up form will be completed and the administrative assistant will follow up in 30 days documenting continued participation in treatment or discontinuance of treatment goals. All follow up will be placed in clients permanent record. This process will be overseen by the associate director."



An interview was conducted with the facility director on January 25, 2011 and it was confirmed that follow-up contact was not documented in client records #7 and 8.
 
Plan of Correction
The follow up care forms were found to be in another file instead of the individuals charts. The administrative assistant has been assigned to present weekly completed follow up forms to the associate director for review. The associate director will review the follow up file each week to ensure compliance. This will be done weekly for the next 60 days beginning July 1st until December 1 2011, and then monthly to ensure compliance.

704.9(c)  LICENSURE Supervised Period

704.9. Supervision of counselor assistant. (c) Supervised period. (1) A counselor assistant with a Master's Degree as set forth in 704.8 (a)(1) (relating to qualifications for the position of counselor assistant) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 3 months of employment. (2) A counselor assistant with a Bachelor's Degree as set forth in 704.8 (a)(2) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 6 months of employment. (3) A registered nurse as set forth in 704.8 (a)(3) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 6 months of employment. (4) A counselor assistant with an Associate Degree as set forth in 704.8 (a)(4) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 9 months of employment. (5) A counselor assistant with a high school diploma or GED equivalent as set forth in 704.8 (a)(5) may counsel clients only under the direct observation of a trained counselor or clinical supervisor for the first 3 months of employment. For the next 9 months, the counselor assistant may counsel clients only under the close supervision of a lead counselor or a clinical supervisor.
Observations
Based on a review of personnel records and an interview with the facility director, the facility failed to document direct observation and close supervision for employee #4, a counselor assistant.



The findings were:



Four employee records were reviewed on June 13, 2011. Employee #7 was hired as a house manager on October 8, 2008 and promoted to counselor assistant on January 4, 2010. Employee # 7's only qualifications for the position is the possession of a high school diploma.



A review of the personnel and staff records for employee #7 confirmed that no documentation was available to demonstrate direct observation was conducted on employee #7 from January 4, 2010 through April 4, 2010. In addition, no documentation was available to demonstrate close supervision for Employee #7 from April 4, 2010 to June 13, 2011.



This is a repeat citation.



The facility was previously cited for noncompliance of this standard during the January 24, 2011 through January 25, 2011 licensing inspection. The facility's plan of correction submitted on March 11, 2011 and approved on March 22, 2011 stated the following:



"The facility director had a meeting with clinical supervisor to discuss the missing documents. The clinical supervisor was given a copy of the policy pertaining to counselor assistant training and supervision. Policy guidelines will be strictly adhered to in future training of counselor assistants. The disciplinary process was explained for non adherence to policy and procedures. This process progresses from warnings up to and including termination of employee for failure to comply with the policy. This will be supervised and monitored by facility director."



A conversation with the acting facility director on June 13, 2011 confirmed that no documentation was available to demonstrate that direct or close observation was conducted for employee #7.
 
Plan of Correction
The clinical supervisor was written up by project director and the disciplanary measure was placed in his personel file. The clinical supervisor admitted that he has mistakenly forgot to complete and/or print observations. Emploee #7 has now had observations documented since the inspection and the project director will check the file weekly to make sure the procedure is being completed and documented. Non compliance could cause further disciplinary measure up to and including further training and/or termination.

704.11(b)(1)  LICENSURE Individual training plan.

704.11. Staff development program. (b) Individual training plan. (1) A written individual training plan for each employee, appropriate to that employee's skill level, shall be developed annually with input from both the employee and the supervisor.
Observations
Based on a review of the policy and procedure manual, personnel files, and an interview with the associate director, the facility failed to document individual training plans as per facility policy in four of seven employee records.



The findings include:



On January 24, 2011, the policy and procedure manual and seven personnel records were reviewed. Facility policy titled Staff Development Program, Individual Training Plan for each NCR Staff Person, stated:



An individual training plan will be developed annually by July 30 for all clinical and non clinical employees with input from both the employee and supervisor. This plan will identify subject areas, potential resources for training which meet the requirements for the employee's position, skill level and interest.



The facility's current training year runs from July 1, 2010 to June 30, 2011. Three out of seven employee records did not include documentation of a training plan completed by July 30, 2010, specifically records #1, 2, and 7 and one of seven records did not included a training plan at all, specifically record #6.



Employee #1's training plan was due by July 30, 2010 and had not been completed until August 10, 2010.



Employee #2's training plan was due by July 30, 2010 and had not been completed until August 20, 2010.



Employee #7's training plan was due by July 30, 2010 and had not been completed until August 24, 2010.



Employee #6's training plan was due by July 30, 2010 and had not been completed as of the date of inspection.



The associate director was interviewed on January 25, 2011. The associate director advised that she was unaware they were due by July 30, 2010 as per the facility's policy.
 
Plan of Correction
Associate directore reviewed the policy on training plans. The facility director will supervise the completion of training plans prior to the July 30th due date. Employee training needs survey will be distributed in May of each year and each supervisor will complete the training plan and have it reviewed by associate director. Training plan will be placed in employees permanent file.

AS of today 6/23/11 all training plans have been completed and placed in personnel files.

 
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