INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection conducted on November 17, 2020 through November 19, 2020 by staff from the Department of Drug and Alcohol Programs, Bureau of Program Licensure. Based on the findings of the on-site inspection, The Healing Way 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:
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Plan of Correction
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704.7(b) LICENSURE Counselor Qualifications
704.7. Qualifications for the position of counselor.
(a) Drug and alcohol treatment projects shall be staffed by counselors proportionate to the staff/client and counselor/client ratios listed in 704.12 (relating to full-time equivalent (FTE) maximum client/staff and client/counselor ratios).
(b) Each counselor shall meet at least one of the following groups of qualifications:
(1) Current licensure in this Commonwealth as a physician.
(2) A Master's Degree or above from an accredited college with a major in chemical dependency, psychology, social work, counseling, nursing (with a clinical specialty in the human services) or other related field which includes a practicum in a health or human service agency, preferably in a drug and alcohol setting. If the practicum did not take place in a drug and alcohol setting, the individual's written training plan shall specifically address a plan to achieve counseling competency in chemical dependency issues.
(3) A Bachelor's Degree from an accredited college with a major in chemical dependency, psychology, social work, counseling, nursing (with a clinical specialty in the human services) or other related field and 1 year of clinical experience (a minimum of 1,820 hours) in a health or human service agency, preferably in a drug and alcohol setting. If a person's experience did not take place in a drug and alcohol setting, the individual's written training plan shall specifically address a plan to achieve counseling competency in chemical dependency issues.
(4) An Associate Degree from an accredited college with a major in chemical dependency, psychology, social work, counseling, nursing (with a clinical specialty in the human services) or other related field and 2 years of clinical experience (a minimum of 3,640 hours) in a health or human service agency, preferably in a drug and alcohol setting. If a person's experience was not in a drug and alcohol setting, the individual's written training plan shall specifically address a plan to achieve counseling competency in chemical dependency issues.
(5) Current licensure in this Commonwealth as a registered nurse and a degree from an accredited school of nursing and 1 year of counseling experience (a minimum of 1,820 hours) in a health or human service agency, preferably in a drug and alcohol setting. If a person's experience was not in a drug and alcohol setting, the individual's written training plan shall specifically address a plan to achieve counseling competency in chemical dependency issues.
(6) Full certification as an addictions counselor by a statewide certification body which is a member of a National certification body or certification by another state government's substance abuse counseling certification board.
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Observations
The project failed to ensure that employee #5, whom was hired as a counselor on May 11, 2002, met the educational requirements to be a counselor. At the time of the hire, the employee had a Bachelor's Degree in Business Administration, which is a non-qualifying degree for the position of counselor.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
As of 12-30-2020 the following action has been addressed, Employee#5 has been demoted to Counselor Assistant. Program Director will supervise Employee# 5 weekly to ensure that appropriate counseling competency will be provided to The Healing Way clientele. Employee#5 will also be provided in-house training/education to increase his knowledge of counseling and chemical dependency competency. Upon hiring new candidates The Healing Way will have a listing requirements for counselors that will include specific educational credentials, professional certificates, areas of knowledge and other qualifications to ensure that this deficiency does not re-occur in the future. |
709.28 (c) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(c) The project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record.
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Observations
The project failed to obtain an informed and voluntary consent to release information form from the client for the disclosure of information contained in the client record in one of seventeen client records reviewed.Client #13 was admitted on July 31, 2017 and was discharged on October 20, 2020. There was a letter sent ot another treatment facility documented in the client's record on September 2, 2020; however, there was no proper consent to release information form signed by the client prior to the disclosure.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
As of 12/14/2020 the Program Director will monitor charts during monthly supervision to ensure that all informed and voluntary consent to release information be signed by the client prior to the disclosure.
The Healing Way is unable to provide proper consent to release information for Client#13 due discharge status. |
709.28 (c) (2) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(c) The project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record. The consent must be in writing and include, but not be limited to:
(2) Specific information disclosed.
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Observations
The facility failed to keep disclosures of client identifying information within the limits established by 4 Pa. Code 255.5 (b) for releases of information in five of seventeen client records reviewed.Client #1 was admitted on May 27, 2020 and was active at time of inspection. A release of information form to a probation agency, signed and dated by the client on May 27, 2020, allowed for the release of bloodwork, which exceeds the limits established by 4 Pa. Code 255.5. Additionally, a release of information form to another treatment facility, signed and dated on May 27, 2020, did not document any specific information to be disclosed.Client #4 was admitted on December 4, 2019 and was discharged on March 11, 2020. A release of information form to a probation agency, signed and dated by the client on December 4, 2019, allowed for the release of "patient information" and failed to specifically identify what information would be disclosed.Client #5 was admitted on November 7, 2019 and was discharged on March 30, 2020. A release of information form to an emergency contact, signed and dated by the client on November 12, 2019, did not document the specific information to be disclosed.Client #6 was admitted on January 13, 2020 and was discharged on July 22, 2020. Release of information forms to a probation agency and a parole board, both signed and dated by the client on January 17, 2020, allowed for the release of "patient information" and failed to specifically identify what information would be disclosed.Client #7 was admitted on December 12, 2019 and was discharged on January 12, 2020. A release of information form to a probation agency, signed and dated by the client on December 12, 2019, allowed for the release of patient information, biopsychosocial and urine drug screens, all of which exceeds the limits established by 4 Pa. Code 255.5. These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The following plan of action has been addressed as of 12/14/2020. Clinical Staff place within client charts a revised Confidentiality form which provides client identifying information within the limits established by 4 Pa. Code 255.5(b). Additionally, Counselors will regularly monitor charts during supervision to ensure accuracy in this area. Counselor will also update charts as required yearly to remain in compliance.
Client #1 chart has been updated with revised ROI forms which provides the accurate releasing of information provided within established limits by 4Pa. Code 255.5(b).
Client#7, client#4, client#6 and client#5 charts could not be updated due to clients discharged status.
Clinical staff have been retrained as of 12/14/2020 on how to accurately disclose of clients identifying information within the limits established by 4 Pa. Code 255.5 (b).
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709.28 (c) (4) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(c) The project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record. The consent must be in writing and include, but not be limited to:
(4) Dated signature of client or guardian as provided for under 42 CFR 2.14(a) and (b) and 2.15 (relating to minor patients; and incompetent and deceased patients).
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Observations
The project failed to obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record that included a dated client signature in two of seventeen client records reviewed.Client #5 was admitted on November 7, 2019 and was discharged on March 30, 2020. A release of information form to a probation agency was missing a dated client signature; however, it was documented in the client record that there was communication between the project and the probation agency on February 19, 2020.Client #15 was admitted on August 18, 2017 and was discharged on February 28, 2020. A release of information form to another treatment facility was missing a dated client signature; however, it was documented in the client record that there was communication between the project and the other treatment facility on February 25, 2020.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The following plan of action has been addressed as of 12/14/2020. Client#5 and client# 15 charts could not be updated due to clients being discharged; Staff members were retrained on the accuracy of completing ROI forms.
Confidentiality forms will be reviewed with clients while obtaining a signature during the process of communicating with other treatment facilities. ROI forms will be dated and signed and placed in active charts. All clients will be offered a copy of informed and voluntary consent for disclosure of information that includes a date and client's signature before placed in active charts.
The Program Director and Clinical Staff will monitor charts randomly to ensure compliance in this area.
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709.28 (c) (5) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(c) The project shall obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record. The consent must be in writing and include, but not be limited to:
(5) Dated signature of witness.
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Observations
The project failed to obtain an informed and voluntary consent from the client for the disclosure of information contained in the client record that included a dated witness signature in two of seventeen client records reviewed.Client #5 was admitted on November 7, 2019 and was discharged on March 30, 2020. A release of information form to a probation agency was missing a dated witness signature; however, it was documented in the client record that there was communication between the project and the probation agency on February 19, 2020.Client #15 was admitted on August 18, 2017 and was discharged on February 28, 2020. A release of information form to another treatment facility was missing a dated witness signature; however, it was documented in the client record that there was communication between the project and the other treatment facility on February 25, 2020.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
As of 12/14/2020 Staff were retrained on how to accurately complete ROI. Client #5, #15 have been discharged, revised ROI were not able to be updated.
The following plan of action has been addressed as of 12/14/2020 all Clinical Staff were retrained in-house how to accurately complete ROI forms. The Program Director educated Clinical staff on the importance of providing accurate dated witness signature on required documentation.
ROI forms will be dated and signed in all new and current client charts. Additionally, Clinical Staff will continue to regularly monitor charts to ensure compliance in required documentation. Counselor will update charts as required yearly to remain in compliance.
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709.28 (d) LICENSURE Confidentiality
§ 709.28. Confidentiality.
(d) A copy of a client consent shall be offered to the client and a copy maintained in the client record.
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Observations
The project failed to ensure that a copy of a client consent was offered to the client in eleven of seventeen client records reviewed.Client #1 was admitted on May 27, 2020 and was a current client at the time of the inspection. A release of information form to a probation agency, signed and dated by the client on May 27, 2020, did not document whether the client was offered a copy of the release form.Client #3 was admitted on July 15, 2020 and was a current client at the time of the inspection. A release of information form to a probation agency, signed and dated by the client on July 15, 2020, did not document whether the client was offered a copy of the release form.Client #4 was admitted on December 4, 2019 and was discharged on March 11, 2020. A release of information form to a probation agency, signed and dated by the client on December 4, 2019, did not document whether the client was offered a copy of the release form.Client #5 was admitted on November 7, 2019 and was discharged March 30, 2020. A release of information form to an emergency contact, signed and dated by the client on November 12, 2019, did not document whether the client was offered a copy of the release form.Client #6 was admitted on November 13, 2019 and was discharged on July 22, 2020. A release of information form to a probation agency, signed and dated by the client on November 17, 2020, did not document whether the client was offered a copy of the release form.Client #9 was admitted on December 19, 2019 and was a current client at the time of the inspection. A release of information form to an emergency contact, signed and dated by the client on January 20, 2020, did not document whether the client was offered a copy of the release form.Client #10 was admitted on March 28, 2019 and was a current client at the time of the inspection. A release of information form to an emergency contact, signed and dated by the client on April 23, 2020, did not document whether the client was offered a copy of the release form.Client #11 was admitted on January 14, 2016 and was a current client at the time of the inspection. A release of information form to an emergency contact, signed and dated by the client on January 2, 2020, did not document whether the client was offered a copy of the release form.Client #12 was admitted on October 12, 2017 and was a current client at the time of the inspection. A release of information form to an emergency contact, signed and dated by the client on September 28, 2020, did not document whether the client was offered a copy of the release form.Client #13 was admitted on July 31, 2017 and was discharged on October 20, 2020. A release of information form to an emergency contact, signed and dated by the client on August 13, 2020, did not document whether the client was offered a copy of the release form.Client #17 was admitted on October 17, 2020 and was a current client at the time of the inspection. Release of information forms to an emergency contact and another treatment facility, signed and dated by the client on October 19, 2020, did not document whether the client was offered a copy of the release form.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
As of 12/14/2020 a copy of the consent form will be reviewed with client, signed and placed in client #1, and Client#3 and Client#10 active chart. Counselors were retrained on ROI forms while addressing the importance of offering a copy to client and documenting whether a copy of the consent was offered by marking the required check box. Client # 1, 3, 10, 11, 12, 17 and #9 ROI forms will be reviewed and updated via Telehealth. Clients will be offered a copy of their consent forms. Each form will be updated with documentation displaying whether a copy of the consent form was offered and filed in client active chart. The Program Director and Clinical Staff will regularly monitor charts to ensure compliance in ROI documentation.
Client# 4, 5, 13, 14 and 6 have been discharged, revised ROI forms were not able to be updated.
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709.33 (a) LICENSURE Notification of termination.
§ 709.33. Notification of termination.
(a) Project staff shall notify the client, in writing, of a decision to involuntarily terminate the client ' s treatment at the project. The notice shall include the reason for termination.
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Observations
The project failed to notify the client, in writing, of a decision to involuntarily terminate the client's treatment at the project in two applicable client records reviewed.Client #13 was admitted on July 31, 2017 and was involuntarily discharged on October 20, 2020. Client #14 was admitted on August 4, 2017 and was involuntarily discharged on August 11, 2020.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The following plan of action has been addressed as of 12/14/2020. The Program Director facilitated a demonstration to re-teach clinical staff how to accurately notify clients in writing of the decision to involuntarily terminate clients treatment.
Client#13, 14 were discharged and The Healing Way is unable to provide in writing a decision to involuntarily terminate the clients treatment
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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
The program failed to provide each patient, in the program for the first 2 years, an average of 2.5 hours of psychotherapy per month, 1 hour of which shall be individual psychotherapy in two applicable patient records reviewed.Patient #9 was admitted on December 19, 2019 and was a current client at the time of the inspection. This patient only received one psychotherapy hour for the months of May 2020, June 2020, July 2020, August 2020, September 2020 and October 2020.Patient #10 was admitted on March 28, 2019 and was a current client at the time of the inspection. This patient only received one psychotherapy hour for the months of May 2020, June 2020, July 2020, August 2020, September 2020 and October 2020.These findings were reviewed with program staff during the licensing process.
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Plan of Correction
The following action has been addressed as of 12/14/2020: The Program Director educated Clinical staff on the importance of providing each client an average of 2.5 hours of psychotherapy per month during the clients first 2 years, and 1 hours of individual psychotherapy.
The Program Director will monitor charts randomly to ensure compliance in this area.
Clinical staff reviewed The Healing Way Handbook with Client #9 and #10 to encourage consisted participation with 2.5 hours of psychotherapy (individual/group) sessions per month in order to remain within treatment compliance.
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715.19(2) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(2) A narcotic treatment program shall provide each patient at least 1 hour per month of group or individual psychotherapy during the third and fourth year of treatment. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
The program failed to ensure that each patient, in the program during the third and fourth years, at least 1 hour per month of group or individual psychotherapy in two applicable patient records reviewed.Patient #13 was admitted on July 31, 2017 and was discharged on October 20, 2020. In August 2020, the patient had zero psychotherapy hours. Patient #15 was admitted on August 18, 2017 and was discharged February 28, 2020. In October 2020, the patient had zero psychotherapy hours. These findings were reviewed with program staff during the licensing process.
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Plan of Correction
The following action has been addressed as of 12/14/2020: Clinical Staff have been retrained in- house on the importance of providing each client an average of 2.5 hours of psychotherapy per month during the clients first 2 years, and 1 hours of individual psychotherapy.
The Program Director provided Clinical staff with an audit tracking form to assist with monitoring clients' individualized psychotherapy services. The Program Director will monitor charts randomly to ensure that each client meets the required psychotherapy mandated hours in order to remain in compliance in this area.
Clinical staff reviewed The Healing Way Handbook with Client #13 to encourage consisted participation with 2.5 hours of psychotherapy (individual/group) sessions per month in order to remain within treatment compliance.
Client # 15 was discharged on February 28, 2020. The Healing Way Clinical Staff was unable to engage in a discussion focused on treatment compliance.
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715.20(3) 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.
(3) The transferring narcotic treatment program shall document what materials were sent to the receiving narcotic treatment program.
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Observations
The program failed to document what materials were sent to the receiving narcotic treatment program in one of ten applicable patient records reviewed.Patient #15 was admitted on August 18, 2017 and was transferred to another narcotic treatment program on February 28, 2020. There was a transfer packet in the patient's record; however, there was no documentation of what materials were sent to the receiving program. These findings were reviewed with program staff during the licensing process.
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Plan of Correction
As of 12/14/2020 the following plan of action has been addressed: The Program Director retrained Clinical staff on the importance of documenting what materials will be sent to the receiving narcotic treatment program when transferring a client. The Program Director developed an audit check list to provide to counselors when transferring a client to another facility to ensure accuracy in this area.
Client #15 charts could not be updated due to client being discharged.
The Program Director will provide continued training in this area to ensure validity.
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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
The project failed to ensure that treatment and rehabilitation plans were reviewed and updated at least every 60 days in six of seventeen client records reviewed. Client #2 was admitted on June 9, 2020 and was a current client at the time of the inspection. A treatment and rehabilitation plan updated was documented on September 9, 2020 and the next update was due no later than November 9, 2020; however, there was no update documented in the client record at the time of the inspection.Client #9 was admitted on December 19, 2019 and was a current client at the time of the inspection. A comprehensive treatment and rehabilitation plan was documented on January 23, 2020 and the next treatment and rehabilitation plan update was due no later than March 23, 2020; however, the next update was no documented until April 14, 2020. Additionally, a treatment and rehabilitation plan updated was documented on August 25, 2020 and the next update was due no later than October 25, 2020; however, there was no update documented in the client record at the time of the inspection.Client #10 was admitted on March 28, 2019 and was a current client at the time of the inspection. A treatment and rehabilitation plan update was documented on December 13, 2019 and the next treatment and rehabilitation plan update was due no later than February 13, 2020; however, the next update was no documented until April 28, 2020. Additionally, a treatment and rehabilitation plan updated was documented on August 18, 2020 and the next update was due no later than October 18, 2020; however, there was no update documented in the client record at the time of the inspection.Client #11 was admitted on January 14, 2016 and was a current client at the time of the inspection. A treatment and rehabilitation plan update was documented on January 22, 2020 and the next treatment and rehabilitation plan update was due no later than March 22, 2020; however, the next update was no documented until April 29, 2020. Additionally, a treatment and rehabilitation plan updated was documented on April 29, 2020 and the next update was due no later than June 29, 2020; however, the next update was not documented until July 31, 2020.Client #13 was admitted on July 31, 2017 and was discharged on October 20, 2020. A treatment and rehabilitation plan updated was documented on June 17, 2020 and the next update was due no later than August 17, 2020; however, there was no update documented in the client record at the time of the inspection.Client #14 was admitted on August 4, 2017 and was discharged on August 11, 2020. A treatment and rehabilitation plan update was documented on January 7, 2020 and the next treatment and rehabilitation plan update was due no later than March 7, 2020; however, the next update was no documented until April 24, 2020. These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
During group supervision Clinical Staff were retrained on initial treatment and rehabilitation planning documentation.
The Program Director and Clinical staff will regularly monitor charts to ensure treatment plans are updated at least every 60 days.
The Program Director provided clinical staff with an audit form to ensure accuracy of all clinical charts.
The Program Director provided Counselors with an audit form to be utilize when auditing charts to ensure treatment plans are updated as required. Charts will be audited randomly to ensure accuracy and compliance in treatment and rehabilitation planning during group supervision.
The following plan of action was addressed as of 12/17/2020: The Program Director facilitated a training on accurate treatment planning. Chart monitoring will be done on a weekly basis during group supervision to ensure compliance of initial (30/60) day comprehensive treatment and rehabilitation planning.
Client # 2, 9, 10, and 11 treatment plans have been reviewed, updated and signed. Clinical staff were retrained on treatment planning documentation. Clinical staff were provided an audit tracking form to be completed to ensure accurate completion of treatment and rehabilitation planning.
Client #13 and #14 were discharged, treatment plan updates were not able to be developed.
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709.92(c) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(c) The project shall assure that counseling services are provided according to the individual treatment and rehabilitation plan.
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Observations
The project failed to assure that counseling services are provided according to the client's individual treatment and rehabilitation plan in eight of seventeen client records reviewed.Client #1 was admitted on May 27, 2020 and was a current client at the time of the inspection. A comprehensive treatment plan was completed on May 27, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per week. There were no documented group counseling sessions in the client record for the months of June 2020, July 2020, August 2020, September 2020, October 2020 and November 2020. Client #9 was admitted on December 19, 2019 and was a current client at the time of the inspection. A treatment plan update was completed on January 23, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of June 2020, July 2020, August 2020, September 2020, October 2020 and November 2020.Client #10 was admitted on March 28, 2019 and was a current client at the time of the inspection. A treatment plan update was completed on December 13, 2019, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of January 2020 through November 2020.Client #11 was admitted on January 14, 2016 and was a current client at the time of the inspection. A treatment plan update was completed on January 22, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of January 2020 through November 2020.Client #12 was admitted on October 12, 2017 and was a current client at the time of the inspection. A treatment plan update was completed on January 30, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of April 2020 through August 2020.Client #13 was admitted on July 31, 2017 and was discharged on October 20, 2020. A treatment plan update was completed on December 24, 2019, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of January 2020 through November 2020. Additionally, there was no individual counseling session documented for the month of August 2020.Client #14 was admitted on August 4, 2017 and was discharged on August 11, 2020. A treatment plan update was completed on January 7, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per month. There was no documented individual counseling session in the client record for the months of March 2020.Client #15 was admitted on August 18, 2017 and was discharged February 28, 2020. A treatment plan update was completed on January 27, 2020, indicating that the client was to receive one individual counseling session and one group counseling session per month. There were no documented group counseling sessions in the client record for the months of January 2020 through November 2020. Additionally, there was no individual counseling session documented for the month of October 2020.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
As of 12/17/2020 the following plan of action were addressed: Clinical staff have been provided an audit form to assist with monitoring clients' individualized psychotherapy services that shall meet required State Regulations. Staff have been educated on providing 2.5 hours of psychotherapy per month during the client's first 2 years and 1 hours of individual psychotherapy. The Program Director will audit client charts randomly to ensure that each client meet the required psychotherapy mandated hours in order to remain in compliance in this area. Clinical staff were retrained to ensure that counseling services are provided according to the individual treatment and rehabilitation plan.
Client # 1, 9, 10, 11, 12, 13, 14 and 15 treatment plans were updated accordingly. Clinical staff reviewed The Healing Way Handbook with Client #1, 9, 10, 11, 12, 13, 14, and 15 to encourage consisted participation with 2.5 hours of psychotherapy (individual/group) sessions per month in order to remain within treatment compliance and assure counseling services are provided.
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