INITIAL COMMENTS
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This report is a result of an on-site inspection conducted for the approval to use a narcotic agent, specifically methadone, in the treatment of narcotic addiction. This inspection was conducted on May 28-30, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Parkside Recovery was found not to be in compliance with the applicable chapters of 4 PA Code and 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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715.20 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.
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Observations
Based on a review of administrative documentation, patient records, the facility failed to initiate a transfer within 7 days when the patient requested it in two of three patient records reviewed.
The findings include:
The policy and procedure manual was reviewed on January 25, 2010. The policy and procedure manual stated the transfer would be initiated within 7 days of the request.
Eighteen patient records were reviewed May 28-30, 2013.
Patient # 5 began requesting a transfer to a higher level of care in April and May 2012. The patient discussed it with the the counselor, but the counselor failed to document any effort on attempting a referral. The patient was eventually terminated September 10, 2012 without benefit of a transfer.
Patient # 18 requested a transfer July 12, 2012. There was no documentation the transfer referral was attempted. The patient was eventually terminated November 28, 2012.
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Plan of Correction
It is program policy that all requested transfers will be iniated within 7 days.Going forward all counselors will be re-trained in the client transfer policy. The procedure will be that counselors will be required to discuss requested transfers with the Clinical Supervisor the day the client makes the request.The request will be iniated by the counselor and clinical supervisor that day.There will be status reviews in the counselor weekly supervision sessions and at the weekly Multi Disciplinary Team meeting for every transfer request. The Clinical Supervisor will be responsible to assure the process is being followed. |
715.21(1)(i-iv) LICENSURE Patient termination
A narcotic treatment program shall develop and implement policies and procedures regarding involuntary terminations. Involuntary terminations shall be initiated only when all other efforts to retain the patient in the program have failed.
(1) A narcotic treatment program may involuntarily terminate a patient from the narcotic treatment program if it deems that the termination would be in the best interests of the health or safety of the patient and others, or the program finds any of the following conditions to exist:
(i) The patient has committed or threatened to commit acts of physical violence in or around the narcotic treatment program premises.
(ii) The patient possessed a controlled substance without a prescription or sold or distributed a controlled substance, in or around the narcotic treatment program premises.
(iii) The patient has been absent from the narcotic treatment program for 3 consecutive days or longer without cause.
(iv) The patient has failed to follow treatment plan objectives.
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Observations
Based on the review of patient records and administrative documentation, the facility failed to demonstrate all efforts to retain the patient were initiated prior to the involuntary termination of two of four patients reviewed.
The findings include:
Eighteen patient record were reviewed May 28-30, 2013. Four of the patient records were reviewed for involuntary termination documentation. The Notification of Program Termination form, administrative documentation, was reviewed May 28, 2013.
Two patient records contained documentation that included written notification of involuntary termination. Patient records # 5 and # 6 contained written notice to each respective patient they were being involuntarily terminated for failure to follow treatment plan goals. However, there was no documentation demonstrating the patient's failure to follow any treatment plan objectives, or efforts to retain the patients prior to initiating the involuntary terminations.
Patient # 5 had repeatedly requested a higher level of care to address ongoing continued use of illicit substances, but there was no documentation of an effort to make the referral.
Patient # 6 was involuntarily termination for failure to follow treatment plan objectives, but there was no documentation of what treatment plan objectives were not met.
The Notification of Program Termination form included multiple reasons for termination outside of the scope of the regulation. The reasons for discharge included excessive absences, failure to seek employment, training or education, and when determined to be appropriate by medical and psychiatric staff.
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Plan of Correction
In review of the findings the patient records identified were reviewed and it was determined that the incorrect form was being used by the clinical staff. The Program has started using the approved form and the policy that the other Parkside clinic is using. In addition, when any form is updated all old forms will be replaced and copies of the old form will be destryed. Counselors will be instructed at individual supervision sessions and in staff meetings to immediately destroy all copies of the old form. All staff will be re-trained in the use of the new form on 7/5/2013. The training will include detailed description of what is a justified reason for termination, detailed examples of acceptable interventions and the need for clinical staff to show documented evidence that all steps in the process have been followed. If all the above steps are not followed by the clinical staff the request by the counselor the request for termination by the counselor will not be accepted. The clinical supervisor will then provide supervision to the staff to assure all program termination are clinically appropriate and justified. |
715.23(b)(14) LICENSURE Patient records
(b) Each patient file shall include the following information:
(14) Case consultation notes regarding the patient.
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Observations
Based on the review of patient records, the facility failed to complete case consultations as required in nine of sixteen patient records reviewed.
The findings include:
Eighteen patient records were reviewed May 28-30, 2013. Sixteen patient records were reviewed for case consultations.
Patient # 2 was admitted May 14, 2009. The patient required at least annual case consultations. The last case consultation was dated May 9, 2012. There was no case consultation for May 2013 at the time of the inspection.
Patient # 5 was admitted May 27, 2010. The patient required at least annual case consultations. The patient was discharged September 10, 2012 as an involuntary detoxification. There was no case consultation for May 2012 at the time of the inspection.
Patient # 6 was admitted June 2011. The patient required quarterly case consultations the first year of treatment and at least annual case consultations thereafter. There were a total of two case consultations documented in the patient record at the time of the inspection; September 15, 2011 and December 10, 2011.
Patient # 8 was admitted May 24, 2011. The patient required at least annual case consultations. The last case consultation was dated May 22, 2012. There was no case consultation for May 2013 at the time of the inspection.
Patient # 12 was admitted January 17, 2013. The patient required at least one quarterly case consultation at the time of the inspection. There were no case consultations documented in the patient record at the time of the inspection.
Patient # 14 was admitted January 23, 2012. The patient required at least quarterly case consultations the first year. There were a total of two case consultations documented in the patient record at the time of the inspection; April 18, 2012 and July 17, 2012.
Patient # 15 was admitted May 23, 2011. The patient required at least quarterly case consultations the first year and an annual case consultation thereafter. There were no case consultations documented in the patient record at the time of the inspection.
Patient # 16 was admitted February 14, 2013. The patient required at least one quarterly case consultation at the time of the inspection. There were no case consultations documented in the patient record at the time of the inspection.
Patient # 17 was admitted September 13, 2012. The patient required at least quarterly case consultations the first year. There were no case consultations documented in the patient record at the time of the inspection.
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Plan of Correction
Based on the findings documented the entire case consultation process was reviewed by the program director and clinical supervisor. The following procedure has now been initiated. The program director and clinical supervisor will meet weekly to review the documentation tracker to identify what case consultation are due. The clinical supervisor will review with each individual counselor the patients on their caseload who need a case consultation and an expected completion date. The staff will be re-trained on the proper use of the tracker to assure all case consultations are completed in a timely manner. |