Observations Based on a review of client records on January 22, 2009 the facility failed to obtain an informed consent prior to the disclosure of client information. The findings include:Four active client records were reviewed on January 22, 2009. The facility did not document in writing the purpose of disclosure in two of the four records reviewed. Client record # 2 - Admitted 10/29/2008. Three consents to release information were reviewed in client record # 2. One of the three consents to release information did not include documentation of the purpose for the disclosure of the client identifying information. Client record # 4 - Admitted 12/19/2008. Four consents to release information were reviewed in client record #4. One of four consents to release information did not include documentation of a purpose for the disclosure of client identifying information.
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Plan of Correction Plan of Correction:
Standard in Noncompliance
709.28 (c) (3) Confidentiality
In an effort to comply with regulation 709.28, the written findings from the January 22, 2009 were discussed with all staff during the general staff meeting. In addition, the Director of BHS held a meeting with the Clinical Coordinators and Medical Records Clerks to review Standard 709.28 (c) (3), 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). In an effort to further avoid any infractions of this regulation, the form was revised to include precise optional statements that specify purpose for the disclosure of information to be released/disclosed. 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) (3) is being followed properly.
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