INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection conducted on August 25-26, 2008 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Al-Assist Behavioral Health Care Center 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 and a plan of correction is due on September 29, 2008.
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Plan of Correction
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704.5(a) LICENSURE Project/Facility Director
704.5. Qualifications for the positions of project director and facility director.
(a) A drug and alcohol treatment project shall have a project director responsible for the overall management of the project and staff and each drug and alcohol treatment facility shall have a facility director responsible for the overall management of the facility and staff unless the project has but one facility.
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Observations
Based on a review of the facility's policy and procedures manual and administrative documentation on August 26, 2008, the facility failed to designate a project director who was responsible for the overall management of the project and staff.Findings:The facility did not designate a person who is responsible for the overall management of the project and staff, and who is officially responsible to the governing body.
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Plan of Correction
Standard in Non-Compliance
704.5(a) LICENSURE
Project/Facility Director:
In an effort to address the non-compliance of standard 704.4, a project director has been identified and placed in the role of project director for the overall management of the project and staff, and who is officially responsible to the governing body.
Correction Time: Completed |
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
Based on a review of 7 personnel records on August 26, 2008, the facility failed to document educational requirements that meet the qualifications in at least one of the paragraphs of 28 Pa. Code Subsection 704.7(b), relating to the qualifications for the position of counselor, in two personnel records where required.Findings:The facility did not document a major in chemical dependency, psychology, social work, counseling, nursing or other related field in personnel records # 7 and 8.
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Plan of Correction
Standard in Non-Compliance
704.7(b) LICENSURE
Counselor Qualifications:
In an effort to address and avoid any future non-compliance of standard 704.4(b). The Director of Behavioral Healthcare Services, Coordinator of Behavioral Healthcare Services, and Clinical Coordinator held individual meetings with the staff members identified as not meeting the educational requirements in at least one of the paragraphs of 28 Pa. Code Subsection 704.7(b). Both staff members were immediately restricted from providing counseling services to Drug and Alcohol consumers. One staff member's position was demoted from a Counselor III to an Intake Assessor and the other staff member received a lateral position in the MH program. All future/potential hires for the Drug and Alcohol program will be scrutinized based on 28 Pa. Code Subsection 704.7(b), by both the Clinical Team and the Human Resource Department. Failure to meet the educational and experience qualifications will result in a non-hiring of the applicant. This process will be monitored by the HR Director and the Director of Behavioral Healthcare Services.
Correction Time: Completed
Ongoing Monitoring
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704.11(a)(1) LICENSURE Training Needs assessments
704.11. Staff development program.
(a) Components. The project director shall develop a comprehensive staff development program for agency personnel including policies and procedures for the program indicating who is responsible and the time frames for completion of the following components:
(1) An assessment of staff training needs.
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Observations
Based on a review of personnel records on August 26, 2008 the facility failed to document an assessment of staff training needs in five of nine personnel records where required.Findings:The facility did not document an assessment of staff training needs in personnel records # 1, 3, 4, 5 and 6.
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Plan of Correction
Standard in Non-Compliance
704.11(a)(1)
LICENSURE Training Needs Assessments:
In an effort to address the non-compliance of standard 704.11(a)(1)(training needs assessment). The Director of Behavioral Healthcare Services and the newly appointed Project Director held a meeting on 9/29/08 with the Clinical Coordinators to review standard 704.11 (a)(1) along with the agencies policy and procedures manual as it relates to assessing staff training needs. According to the agencies policy in support of this standard, comprehensive training assessments are scheduled to be completed by the assigned supervisor with input from the staff: for each staff member during the month of November for the upcoming year. Clinical Coordinators and Supervisory staff were instructed to complete the comprehensive training assessment with input from the staff for each staff member no later than Friday, November 28, 2008. The Director of Behavioral Healthcare Services will review each training needs assessment ensuring accuracy and completion of the documents. A copy of the training assessments will be maintained in the training assessment binder. The original will be placed in each staff members' personnel record.
Completion Time: 11/28/08
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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.
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Observations
Based on a review of personnel records on August 26, 2008, the facility failed to document a written individual training plan appropriate to the employee's skill level and developed annually with input from both the employee and supervisor in six of seven personnel records where required.Findings:The facility did not document a written individual training plan in one personnel record, # 2. The facility did not document a training plan that indicated topics and presenters in personnel records # 3, 4, 5, 6 and 7.
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Plan of Correction
Standard in Non-Compliance
704.11(b)(1)
LICENSURE Staff Development Program.
(b)Individual Traiing Plan. (1)Written Individaul Training Plan...
In an effort to address the non-compliance of standard 704.11(b)(1)(Individual Training Plan:[Written]). The Director of Behavioral Healthcare Services and the newly appointed Project Director held a meeting on 9/29/08 with the Clinical Coordinators to review standard 704.11 (b)(1) along with the agencies policy and procedures manual as it relates to developing an individaul training plan. According to the agencies policy in support of this standard, comprehensive individual training plans are scheduled to be completed by the assigned supervisor for each staff member utilizing information gathered from the assessment of training needs and supportive of the staff's job description, staff's training/ developmental desires, and skill level during the month of November for the upcoming year. Clinical Coordinators and Supervisory staff were instructed to complete the staff developmental/ training plan for each staff member no later than Friday, November 28, 2008. The Director of Behavioral Healthcare Services will review and sign off on each developmental/training
plan ensuring that each plan accurately documents/captures the training needs of each staff and to ensure that a developmental/training plan has been completed and appropriately documented for each staff. A copy of the developmental/ training plans will be maintained in the developmental/ training plan binder. The original will be placed in each staff members' personnel file. The developmental/ training plans will be review quarterly by the Clinical Coordinators to monitor progress. Findings of the reviews will be discussed with staff during their individual supervision.
Completion Time: 11/28/08
with quarterly monitoring
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704.11(c)(1) LICENSURE Mandatory Communicable Disease Training
704.11. Staff development program.
(c) General training requirements.
(1) Staff persons and volunteers shall receive a minimum of 6 hours of HIV/AIDS and at least 4 hours of tuberculosis, sexually transmitted diseases and other health related topics training using a Department approved curriculum. Counselors and counselor assistants shall complete the training within the first year of employment. All other staff shall complete the training within the first 2 years of employment.
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Observations
Based on a review of personnel records on August 26, 2008, the facility failed to document a minimum of six hours HIV/AIDS training using a Department approved curriculum in one of five personnel records.Findings:The facility did not document six hours of HIV/AIDS training in personnel record # 5.
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Plan of Correction
704.11 (c) (1) LICENSURE
Mandatory Communicable Disease Training.
In an effort to comply with Standard 704.11 (c) (1) Mandatory Communicable Disease Training, The Clinical Coordinators will monitor the counselors' developmental/training plan and schedule more intently to ensure that each counselor participate in BDAP's mandatory/required six (6) hours HIV/AIDS training within the first year of hire. Staff identified as out of compliance in our recent survey will participate in a Department approved curriculum training for HIV/AIDS within the next 4 months.
Correction Time: 120 days and ongoing
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705.28 (d) (5) LICENSURE Fire safety.
705.28. Fire safety.
(d) Fire drills. The nonresidential facility shall:
(5) Prepare alternate exit routes to be used during fire drills.
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Observations
Based on a review of administrative documentation on August 27, 2008, the facility failed to prepare alternate exit routes to be used during fire drills.Findings:The facility did not indicate on the fire drill documentation which exit route was utilized during fire drills. Only one fire drill log entry for the period of January 2008 through August 2008 indicated which exit was used.
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Plan of Correction
Standard in Noncompliance
705.28 (d) (5) Fire Safety
The Director of Behavioral Healthcare Services has notified security and the Environment of Care Committee in writing of the fire safety standard. The Security Officers have been instructed to document on the fire drill form which exit(s) route(s) was used during the drill. Failure to correctly document fire drill activity monthly inclusive of but not limited to date of fire drill, time, evacuation time, exit routes used, number of participants, and difficulties/catastrophes will result in a written reprimand. The EOC committee and Director of BHS will monitor this process to ensure compliance.
(Correction Time: Complete ? Monitoring ongoing)
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709.26(d)(5)(i) LICENSURE Personnel Management
709.26. Personnel management.
(d) The personnel records shall include, but not be limited to:
(5) Work performance evaluation including the following:
(i) Individual staff performance shall be evaluated at least annually.
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Observations
Based on a review of personnel records on August 25 and 26, 2008, the facility failed to document at least annually an individual work performance evaluation in four of six personnel records where required. Findings:The facility did not document an annual individual work performance evaluation in personnel records # 3, 4, 5 and 6.
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Plan of Correction
Standard in Noncompliance
709.26(d)(5)(i) Personnel Management:
In an effort to comply with Standard 709.26(d)(5)(i) Personnel Management, the Project Director, HR Director, and Director of Behavioral Healthcare held a meeting to determine strategies to avoid late annual performance evaluations: Results of the meeting: Supervising staff will receive via email from the HR department a list of all supervised staffs' annual performance evaluation due dates. Annual performance evaluations will be submitted via email to the supervisor 45 days prior to the due date. Reminders of the upcoming performance evaluation due date for each staff will be sent via email from the HR department 30 days prior, 15 days prior, and 24 hours prior to the due date if not yet received. Notification of failure to meet the annual performance evaluation due date will be forwarded to the Project Director and Director of Behavioral Healthcare Services resulting in a written reprimand.
Correction Time: Complete
Monitoring - ongoing
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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 shall be in writing and include, but not be limited to:
(2) Specific information disclosed.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document informed and voluntary consent forms containing specific information to be disclosed in four of five client records where required. #s 1, 2, 3 and 4. Findings:The facility provided consent to release information forms that did not indicate the specific information to be released. Additionally consent to release information forms released information to insurance companies, health and hospital plans or other third party payers or to criminal justice entities that was is excess of the limitations imposed at 4 Pa Code Subsection 255.5(b) in client records # 1, 2, 3 and 4.
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Plan of Correction
Standard in Noncompliance
709.28 (c)(2) Confidentiality
In an effort to comply with regulation 709.28, the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. In addition, the Director of BHS and clinical Coordinators held a meeting with all the Clinical Staff and Medical Records Clerks to review Standard 709.28 and to review the agency's Confidentiality policy and procedures supportive of Standard 709.28(c) (2) / 4 Pa code Subsection 255.5(b), and to reiterate the importance of accurately documenting on the informed and voluntary consent form the specific information to be released/disclosed with the clear understanding that the released/disclosed information must not exceed the limitation set forth in 4 Pa Code Subsection 255.5(b): 1. whether the client is or is not in treatment; 2. The prognosis of the client; 3. The nature of the project; 4. A brief description of the progress of the client; and 5. a short statement as to whether the client has relapsed into drug and alcohol and frequency of such relapse. In addition, staff was instructed not to exceed the parameters of State and Federal Confidentiality Regulations outlined in 4 Pa Code 255.5 when completing monthly reports for the Federal / State Court systems, insurers, residential facilities, and/or hospitals. All staff were informed during the meeting that failure to comply with the Confidentiality policy and procedures, Standard 709.28(c) (2), 4 Pa Code Subsection 255.5(b) will result in 1. (First violation) a written reprimand 2. (Second violation) suspension without pay, pending termination of employment. Informed and voluntary consent forms will be randomly audited weekly for compliance by the Client Service Coordinator and Medical Records Clerks to ensure compliance. A random audit of each therapist caseload will be conducted periodically by the Clinical Coordinator to ensure that standard 709.28 (c)(2) is being followed properly.
Correction Time: Correction Completed Monitoring On-going
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709.28(c)(3) 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 shall be in writing and include, but not be limited to:
(3) Purpose of disclosure.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document informed and voluntary consent forms containing the purpose for the release of information in two of five records where required., #s 1 and 3.Findings:The facility did not indicate the purpose for disclosure or they documented reasons in excess of the limitations imposed at 4 Pa Code 255.5(b) when releasing information to insurance companies, health or hospital plans or criminal justice entities in client records # 1 and 3.
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Plan of Correction
Standard in Noncompliance
709.28 (c) Confidentiality
In an effort to comply with regulation 709.28, the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. In addition, the Director of BHS and clinical Coordinators held a meeting with all the Clinical Staff and Medical Records Clerks to review Standard 709.28 and to review the agency's Confidentiality policy and procedures supportive of Standard 709.28(c) and 4 Pa code Subsection 255.5(b), and to reiterate the importance of accurately documenting on the informed and voluntary consent form the specific purpose for the disclosure of information to be released/disclosed with the clear understanding that the purpose for disclosing/releasing the information must not violate 4 Pa Code Subsection 255.5(b). All staff were informed during the meeting that failure to comply with the Confidentiality policy and procedures, Standard 709.28(c), 4 Pa Code Subsection 255.5(b) will result in 1. (First violation) a written reprimand 2. (Second violation) suspension without pay, pending termination of employment. Informed and voluntary consent forms will be randomly audited weekly for compliance by the Client Service Coordinator and Medical Records Clerks to ensure compliance. A random audit of each therapist caseload will be conducted periodically by the Clinical Coordinator to ensure that standard 709.28 (c) is being followed properly.
Correction Time: Correction Completed Monitoring On-going
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709.91(b)(3)(iii) LICENSURE Intake and admission
709.91. Intake and admission.
(b) Intake procedures shall include documentation of:
(3) Histories, which include the following:
(iii) Personal history.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document a complete personal history in three of four client records where required.Findings:The facility did not document a complete history of the client's family, legal, employment/vocation and education in two records # 1 and 4, and the entire personal history was missing in client record # 2.
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Plan of Correction
Standard in Noncompliance
709.91 (b)(3) (iii) Intake and Admission
In an effort to comply with regulation 709.91 (b)(3)(iii) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. In addition, the Director of BHS has scheduled an in-service training for Friday, November 21, 2008 to review all aspects of the intake and admission process and information required to be collected and documented including but not limited to the complete client's personal history: clients' family, legal, employment/vocation and education history and etc. A random audit of each therapist caseload will be conducted periodically by the Clinical Coordinators to ensure that standard 709.91 (b) (3)(iii) is being followed properly. Counselors found non-compliant of this regulation will receive additional support from the Clinical Coordinator during weekly individual supervision.
Correction Time: November 21, 2008 Monitoring On-going
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709.91(b)(6) LICENSURE Intake and admission
709.91. Intake and admission.
(b) Intake procedures shall include documentation of:
(6) Psychosocial evaluation.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document a complete psychosocial evaluation in three of four client records where required.Findings:The facility did not document an evaluation of the client's composite picture, problems/needs, support systems, coping mechanisms, assets/strengths, negative factors that may inhibit treatment, the client's attitude towards/ability to participate in treatment and the counselor's impressions in client records # 1, 2 and 4.
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Plan of Correction
Standard in Noncompliance
709.91 (b)(6) Intake and Admission
In an effort to comply with regulation 709.91 (b)(6) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. In addition, the Director of BHS has scheduled an in-service training for Friday, November 21, 2008 to review all aspects of the intake and admission process and information required to be collected and documented including but not limited to a complete psychosocial evaluation of the client's composite picture: client's problems/needs, support systems, coping mechanisms, assets/strengths, negative factors that may inhibit treatment, attitude towards treatment, ability to participate in treatment and the counselor's impressions of the client and etc. A random audit of each therapist caseload will be conducted periodically by the Clinical Coordinators to ensure that standard 709.91 (b) (6) is being followed properly. Counselors found non-compliant of this regulation will receive additional support from the Clinical Coordinator during weekly individual supervision.
Correction Time: November 21, 2008 Monitoring On-going
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709.92(a)(1) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(a) An individual treatment and rehabilitation plan shall be developed with a client. This plan shall include, but not be limited to, written documentation of:
(1) Short and long-term goals for treatment as formulated by both staff and client.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document complete individual treatment plans with short and long-term goals in three of four client records where required.Findings:The facility did not document treatment plan goals in terms of measurable criteria in client records # 1, 2 and 3.
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Plan of Correction
Standard in Noncompliance
709.92 (a)(1) Treatment and Rehabilitation Services
In an effort to comply with regulation 709.92 (a)(1) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. During this meeting, a Treatment Plan Compliance Auditing Team was identified. The TPCAT are scheduled to randomly audit Treatment Plans the 3rd Friday of each month beginning October 17, 2008. Audit compliance will be based on regulation 709.92 ..., and the agencies policy on treatment plan documentation. Findings from the audit will be analyzed and released to all staff via memorandum. Counselors identified as inadequate in treatment planning will receive additional support from the Clinical Coordinator. Counselors who fail to demonstrate improvement in the area of treatment planning despite additional support will be terminated no more than 90 days from the initial date deemed inadequate.
Correction Time: October 17, 2008 Monitoring On-going
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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
Based on a review of five client records on August 26, 2008, the facility failed to document a treatment plan update with an assessment of the client's progress in relationship to the stated goals of the comprehensive treatment plan in three of four client records where required.Findings:The facility did not document a treatment plan update at least every 60 days in client records # 1, 2 and 3.
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Plan of Correction
Standard in Noncompliance
709.92(b) Treatment and Rehabilitation Services
In an effort to comply with regulation 709.92 (b) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. During this meeting, a Treatment Plan Compliance Auditing Team was identified. The TPCAT are scheduled to randomly audit Treatment Plans, Treatment Plan Updates, and Aftercare Plans the 3rd Friday of each month beginning October 17, 2008. TPCAT will be auditing based on regulation 709.92 ... and 709.93..., and the agencies policy on treatment plan update documentation. Findings from the audit will be analyzed and released to all staff via memorandum. Counselors identified as inadequate in treatment planning will receive additional support from the Clinical Coordinator. Counselors who fail to demonstrate improvement in the area of treatment planning despite additional support within 30day junctures will be terminated no more than 90 days from the initial date deemed inadequate of meeting Standard 709.92 (b) with emphasis on timely completion, and assessing the client's progress or lack of progress towards the treatment goals, and the agencies Treatment Plan Update Policies.
Correction Time: October 17, 2008 Monitoring On-going
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709.93(a)(8) LICENSURE Client records
709.93. 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:
(8) Case consultation notes.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document a complete aftercare plan in two of two client records where required.Findings:The facility did not document the client's future goals with time frames, the method and frequency of continuing contact to provide client support and the criteria for re-entry into the project in client records # 1 and 4.
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Plan of Correction
Standard in Noncompliance
709.93(a)(8) Client records:
In an effort to comply with regulation 709.93 (a)(8) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. During this meeting, a Treatment Plan Compliance Auditing Team was identified. The TPCAT are scheduled to randomly audit Treatment Plans, Treatment Plan Updates, and Aftercare Plans the 3rd Friday of each month beginning October 17, 2008. TPCAT will be auditing based on regulation 709.92...and 709.93 ..., and the agencies policy on aftercare plans. Findings from the audit will be analyzed and released to all staff via memorandum. Counselors identified as inadequate in treatment planning will receive additional support from the Clinical Coordinator. Counselors who fail to demonstrate improvement in the area of treatment planning despite additional support within 30day junctures will be terminated no more than 90 days from the initial date deemed inadequate of meeting Standard 709.93(a)(8) with emphasis placed on identifying client's future goals with timelines, method and frequency of continuing contact, and criteria for re-entry, and the agencies Aftercare Plan Policies.
Correction Time: October 17, 2008 Monitoring On-going
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709.93(a)(11) LICENSURE Client records
709.93. 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.
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Observations
Based on a review of five client records on August 26, 2008, the facility failed to document follow-up information in two of two client records where required.Findings:The facility did not document follow-up information to determine the disposition of the referral or the progress and status of the client in client records # 4 and 5.
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Plan of Correction
Standard in Noncompliance
709.93(a)(11) Client records:
In an effort to comply with regulation 709.93 (a)(11) the written findings from the August 26, 2008 were discussed with all staff during the general staff meeting. During this meeting, a Treatment Plan Compliance Auditing Team was identified. The TPCAT are scheduled to randomly audit Treatment Plans, Treatment Plan Updates, and Aftercare Plans the 3rd Friday of each month beginning October 17, 2008. TPCAT will be auditing based on regulation 709.92...and 709.93 ..., and the agencies policy on aftercare plans. Findings from the audit will be analyzed and released to all staff via memorandum. Counselors identified as inadequate in treatment planning will receive additional support from the Clinical Coordinator. Counselors who fail to demonstrate improvement in the area of treatment planning despite additional support within 30day junctures will be terminated no more than 90 days from the initial date deemed inadequate of meeting Standard 709.93(a)(11) with emphasis on follow-up and the agencies Aftercare Plan Policies.
Correction Time: October 17, 2008 Monitoring On-going
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