INITIAL COMMENTS
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This report is a result of an onsite licensure renewal and methadone monitoring inspection. The inspection was conducted on March 30-31, 2017 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the onsite inspection, Pinnacle Treatment Center PA - VI, LLC d/b/a Greenfield Counseling 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 the inspection:
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Plan of Correction
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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
The facility failed to document that a physician assistant may perform functions of a narcotic treatment physician in a narcotic treatment program if the records are properly countersigned by the medical director or a narcotic treatment physician.Ten patient records were reviewed on March 30 & 31, 2017. Patient records #9 and 10 include documentation of intake physical examinations completed by the physician assistant without a physician countersignature within 3 days.Patient #9 was admitted on January 31, 2017 and the physician assistant performed a physical on that same day. There was no documentation of a physician countersignature.Patient #10 was admitted on February 17, 2017 and the physician assistant performed a physical on that same day. There was no documentation of a physician countersignature.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The facility failed to document that a physician assistant may perform functions of a narcotic treatment physician in a narcotic treatment program if the records are properly countersigned by the medical director or a narcotic treatment physician. The facility director met with the medical director and the physician assistant on April 4, 2017 to ensure it was fully understood what functions Federal, State and local laws and regulations authorize, and if these functions are delegated to the physician assistant by the medical director that the records are properly countersigned by the medical director. The facility director will be responsible to ensure that they medical director is properly monitoring any delegated functions and the patient record is properly countersigned. |
715.9(a)(4) LICENSURE Intake
(a) Prior to administration of an agent, a narcotic treatment program shall screen each individual to determine eligibility for admission. The narcotic treatment program shall:
(4) Have a narcotic treatment physician make a face-to-face determination of whether an individual is currently physiologically dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenance treatment. The narcotic treatment physician shall document in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction.
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Observations
The narcotic treatment program failed to have a narcotic treatment physician make a face-to face determination and document in the patient's record the basis for determining an individual's physiological dependence upon a narcotic drug.Ten patient records were reviewed on March 30 & 31, 2017. The physician assistant completed the documentation of addiction form in patient records #4, 9 and 10.Patient #4 was admitted on March 30, 2017. The physician assistant completed the documentation of addiction form on March 30, 3017, which included a current and one year history of opiate dependence. There was no documentation or signature by the narcotic treatment physician.Patient #9 was admitted on January 31, 2017. The physician assistant completed the documentation of addiction form on January 31, 2017, which included a current and one year history of opiate dependence. There was no documentation or signature by the narcotic treatment physician.Patient #10 was admitted on February 17, 2017. The physician assistant completed the documentation of addiction form on February 17, 2017, which included a current and one year history of opiate dependence. There was no documentation or signature by the narcotic treatment physician.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The narcotic treatment program failed to have the medical director make a face-to face determination and document in the patient's record the basis for determining an individual's physiological dependence upon a narcotic drug. It is the responsibility of the medical director to have a face-to face encounter with each patient resulting in a determination of eligibility for MMT. The facility director consulted with the medical director and physician assistant on April 4, 2017 to ensure it was fully understood the medical director or another narcotic treatment physician must make the determination of a 1 year history of opiate dependence. It was further stressed that the physician assistant is never to complete a determination of opiate dependency. It is the responsibility of the facility director to ensure the medical director documents in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction. |
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
The facility failed to ensure that the narcotic treatment physician determined the proper dosage level for a patient.Ten patient records were reviewed on March 30-31, 2017. The physician assistant, not the physician, documented the medication order in patient records #4, 9, and 10.Patient #4 was admitted as a transfer on March 30, 2017. The physician assistant wrote the order for 106 mgs of methadone on March 30, 2017 at 8:15 AM and patient #4 was medicated at 8:23 AM on that same day. The physician countersigned the order on March 30, 2017 at 8:28 AM. Patient #9 was admitted on January 31, 2017. The physician assistant wrote the order for 30 mgs of methadone on January 31, 2017 at 7:56 AM and patient #4 was medicated at 8:36 AM on that same day. The physician countersigned the order on January 31, 2017 at 2:18 PM. In addition, the order was written as a standing order with 30 mgs on 1/31/17, 40 mgs on 2/1/17 and 50 mgs on 2/2/17.Patient #10 was admitted on February 17, 2017. The physician assistant wrote the order for 30 mgs of methadone on February 17, 2017 at 8:36 AM and patient #4 was medicated at 8:45 AM on that same day. The physician countersigned the order on February 17, 2017 at 1:02 PM. In addition, the order was written as a standing order with 30 mgs on 2/17/17 and 40 mgs on 2/18/17.These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The facility failed to ensure that the narcotic treatment physician determined the proper dosage level for a patient. It is the responsibility of the medical director to determine the patient's initial and subsequent dose and schedule. The facility director consulted with the medical director and physician assistant on April 4, 2017 to ensure it was fully understood the medical director or another narcotic treatment physician shall determine the patient 's initial and subsequent dose and schedule. The physician will communicate the initial and subsequent dose and schedule to the person responsible for the administration of medication. Each medication order and dosage change will be written and signed by the medical director/narcotic treatment physician, but never the physician assistant. It is the responsibility of the facility director to ensure the medical director documents the initial and any subsequent dose change and schedule in the patient 's record. |