INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection conducted on December 12-13, 2017 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Habit OPCO, Inc.-Watsontown, was found to be not in compliance with the applicable chapters of 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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709.30 (1) LICENSURE Client rights
§ 709.30. Client rights.
The project shall develop written policies and procedures on client rights and document written acknowledgement by clients that they have been notified of those rights.
(1) A client receiving care or treatment under section 7 of the act (71 P. S. § 1690.107) shall retain civil rights and liberties except as provided by statute. No client may be deprived of a civil right solely by reason of treatment.
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Observations
Facility policy and procedure manual was reviewed on November 20, 2017. The facility policy failed to include the following elements with regard to client rights:
(3) Clients have the right to inspect their own records. The project, facility or clinical director may temporarily remove portions of the records prior to the inspection by the client if the director determines that the information may be detrimental if presented to the client. Reasons for removing sections shall be documented in the record.
(4) Clients have the right to appeal a decision limiting access to their records to the director.
(5) Clients have the right to request the correction of inaccurate, irrelevant, outdated or incomplete information in their records.
(6) Clients have the right to submit rebuttal data or memoranda to their own records.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
Client Rights policy and procedure will be revised to include the client's rights to appeal a decision limiting access to records to the director; clients having the right to request the correction of inaccurate, irrelevant, outdated or incomplete information in their records clients have the right to submit rebuttal data or memoranda to their won record. Program Management will review policy and procedure revisions with all staff at the January, 18th 2018 staff meeting. |
715.6(d) LICENSURE Physician Staffing
(d) A narcotic treatment program shall provide narcotic treatment physician services at least 1 hour per week onsite for every ten patients
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Observations
Based on a review of the physician's schedule conducted on December 12, 2017, the facility failed to provide narcotic treatment physician services at least 1 hour per week onsite for every ten patients.
A schedule was submitted that indicated the hours worked for the physician and the physician extender staff, as well as the patient census, for the period from July 31, 2017 through December 1, 2017. The facility was not in compliance for the following weeks:
July 31-August 5, 2017: census 174, coverage 16.5 hours
August 6-12, 2017: census 171, coverage 6 hours
August 13-19, 2017: census 174, coverage 16.5 hours
August 20-26, 2017: census 174, coverage 0 hours
August 27-September 2, 2017: census 176, coverage 10 hours
September 3-9, 2017: census 175, coverage 15 hours
September 10-16, 2017: census 173, coverage 15.5 hours
September 17-23, 2017: census 173, coverage 0 hours
September 24-30, 2017: census 176, coverage 10 hours
October 1-7, 2017: census 176, coverage 9.5 hours
October 8-14, 2017: census 177, coverage 10 hours
October 29-November 4, 2017: census 181, coverage 16 hours
November 5-11, 2017: census 184, coverage 16 hours
November 12-18, 2017: census 182, coverage 16 hours
November 19-25, 2017: census 182, coverage 16 hours
November 26-December 2, 2017: census 184, coverage 16 hours
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Watsontown hired a new NTP Physician that began providing services on 10/16/17 for 16 hours per week. A new CRNP will begin working on 01/09/18 for 8 hours per week. Hours will be tracked by nursing and monitored by the Clinic Director to ensure compliance with this standard. |
715.6(e) LICENSURE Physician Staffing
(e) A physician assistant or certified registered nurse practitioner may perform functions of a narcotic treatment physician in a narcotic treatment program if authorized by Federal, State and local laws and regulations, and if these functions are delegated to the physician assistant or certified registered nurse practitioner by the medical director, and records are properly countersigned by the medical director or a narcotic treatment physician. One-third of all required narcotic treatment physician time shall be provided by a narcotic treatment physician. Time provided by a physician assistant or certified registered nurse practitioner may not exceed two-thirds of the required narcotic treatment physician time.
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Observations
Based on a review of the physician's schedule conducted on December 12, 2017, the facility failed to ensure that a narcotic treatment physician provided at least one third of the required physician time.
A schedule was submitted that indicated the hours worked for the physician and the physician extender staff, as well as the patient census, for the period from July 31, 2017 through December 1, 2017. The facility was not in compliance for the following weeks:
August 6-12, 2017: census 171, coverage 6 hours all conducted by CRNP.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
With the addition of the CRNP on 01/09/18 at 8 hours a week, the nursing department will schedule the NTP Physician for 16 hours per week with the CRNP scheduled for 8 hours per week. All changes to this schedule will be approved and monitored by the Clinic Director to ensure compliance with this regulation. |
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 an observation of dosing procedures conducted on December 13, 2017, the facility failed to ensure that a narcotic treatment physician or physician extender submitted a written and signed medication order prior to a dose increase.
A Licensed Practical Nurse conducted a Nursing Assessment on a female patient who was in the induction phase of treatment. Based on a Clinical Opiate Withdrawal Scale and the results of the assessment the LPN increased the patient's dose from 35mg to 40mg.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Effective 12/13/17, the nurse conducting an assessment with a patient needing or requiring a dosage change will contact the NTP Physician or CRNP to obtain a verbal order prior to any change in dosage level. This procedure was reviewed with the medical department on 12/13/17 by the Clinic Director. |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Seven client records were reviewed on December 13, 2017, four of which were methadone client records; the facility failed to provide the required 2.5 hours of therapy per month during the first two years in treatment for one client.
Client #1 was admitted on 1/18/16 and was an active client at the time of the licensing inspection. Client received only 60 minutes of counseling per month from August thru November 2017.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Clinic Director to address clinical staff at the clinical supervisors meeting on 01/10/18 regarding the one out of seven patients reviewed found to be out of compliance with clinical hours. Clinic Director will review hours with counselors during individual clinical supervision sessions to discuss strategies to engage those individuals missing or avoiding clinical sessions. |
715.23(b)(5) LICENSURE Patient records
(b) Each patient file shall include the following information:
(5) The results of all annual physical examinations given by the narcotic treatment program which includes an annual reevaluation by the narcotic treatment physician.
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Observations
Seven client records were reviewed on December 13, 2017, four of which were methadone client records; the facility failed to conduct an annual physical examination on time for clients #1 & 5.
Client #1 was admitted on 1/18/16 and was an active client at the time of the licensing inspection. The annual physical exam was due to be completed by 1/18/17 but was not conducted until 2/10/17.
Client #5 was admitted on 2/8/13 and discharged on 9/15/17. The annual physical exam was due to be completed by 1/25/17 but was not conducted until 3/16/17.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Clinic Director will review inspection results with medical department regarding late annual physical exams on 12/29/17. The Clinic Director will monitor monthly the required annual physical exams to ensure that they are completed within timeframes for this standard. |
715.23(c)(1-7) LICENSURE Patient records
(c) An annual evaluation of each patient 's status shall be completed by the patient 's counselor and shall be reviewed, dated and signed by the medical director. The annual evaluation period shall start on the date of the patient 's admission to a narcotic treatment program and shall address the following areas:
(1) Employment, education and training.
(2) Legal standing.
(3) Substance abuse.
(4) Financial management abilities.
(5) Physical and emotional health.
(6) Fulfillment of treatment objectives.
(7) Family and community supports.
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Observations
Seven client records were reviewed on December 13, 2017, four of which were methadone client records; the facility failed to conduct an annual clinical evaluation on time for client #1.
Client #1 was admitted on 1/18/16 and was an active client at the time of the licensing inspection. The annual clinical evaluation was due to be completed by 1/18/17 but was not conducted until 2/8/17.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Clinic Director/Clinical Supervisor will provide a training on annual clinical evaluation time frames as 1 of 7 records reviewed was overdue. Training will occur on 01/10/18 |
709.92(b) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(b) Treatment and rehabilitation plans shall be reviewed and updated at least every 60 days.
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Observations
Seven client records were reviewed on December 13, 2017, four of which were methadone client records; the facility failed to update the treatment plan every 60 days in client records #1, 2, 3, 5 & 7.
Client #1 was admitted on 1/18/16 and was an active client at the time of the licensing inspection. A treatment plan update was documented on 8/21/17; a treatment plan update was due by 10/21/17 but was not documented until 10/24/17.
Client #2 was admitted on 8/31/17 and was an active client at the time of the licensing inspection. A comprehensive treatment plan was documented on 10/5/17; a treatment plan update was due by 12/5/17 but was not documented until 12/8/17.
Client #3 was admitted on 2/15/16 and was an active client at the time of the licensing inspection. A treatment plan update was documented on 8/29/17; a treatment plan update was due by 10/29/17 but was not documented until 10/31/17.
Client #5 was admitted on 2/8/13 and discharged on 9/15/17. A treatment plan update was documented on 5/19/17; a treatment plan update was due by 7/19/17 but was not documented at the time of the licensing inspection.
Client #7 was admitted on 4/19/17 and discharged on 8/16/17. A comprehensive treatment plan was documented on 5/19/17; a treatment plan update was due by 7/19/17 but was not documented until 7/21/17.
This information was reviewed with the facility staff during the licensing inspection.
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Plan of Correction
Clinic Director/Clinical Supervisor will provide a training on treatment plan timeframes as a result of treatment plans being late or not completed. Clinic Director will ensure to provide all future auditors the treatment plan exception and highlight all those who are on 120 day treatment plans as one patient was incorrectly cited for 60 day treatment plan. This training will be provided on 01/10/18 |