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 October 1 - 2, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Progressive Medical Specialists, Inc. 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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715.9(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
Based on a review of patient records, the facility failed to document that the narcotic treatment physician determined current dependency and evidence of a one year history of addiction in two of nine patient records. The findings include:Twelve patient records were reviewed on October 1 - 2, 2013. Nine patient records were reviewed for documentation of current dependency and one year history of addiction. Patient records #6 and # 11 documented that current dependency and one year history of addiction were completed by someone other than the narcotic treatment physician. Patient #6 was admitted to treatment on 6-27-2013 and was discharged on 8-20-2013. Documentation of current dependency and one year history of addiction was completed on 6-26-2013 by physician assistant. Patient #11 was admitted to treatment on 5-21-2013. Documentation of current dependency and one year history of addiction was completed on 5-20-2013 by physician assistant. The findings were reviewed with the facility director and the nurse and were not disputed.
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Plan of Correction
Director met with medical director and discussed findings from inspection on October 2, 2013 and October 7, 2013.
Medical charts that we reviewed at our inspection were reviewed by MD, Project director and nurse supervisor on October 7, 2013 and it is understood by MD what he is required to complete in regards to documents and what the PA is allowed to complete.
Medical director and project director spoke to dispensing staff, nurse supervisor and PA on October 7, 2013 and discussed inspection results as well as medical activity that only the/a MD can perform.
MD will be the only staff member that will complete any new admission physicals/paperwork which should prevent this from occurring again.
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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
Based on a review of patient records, the facility failed to ensure that the initial medication order was written and signed by the narcotic treatment physician in six of nine patient records. The findings include: Twelve patient records were reviewed on October 1 - 2, 2013. Nine patient records were reviewed for the initial medication order which shall be written and signed by the narcotic treatment physician. Patient records # 3, 4, 6, 10, 11, and 12 documented initial medication orders that were completed by someone other than the narcotic treatment physician. Patient #3 was admitted to treatment on 2-21-2013 and was discharged on 3-26-2013. The initial medication order was written on 2-20-2013 by someone other than the narcotic treatment physician. Patient #4 was admitted to treatment on 1-31-2013 and was discharged on 4-15-2013. The initial medication order was written on 1-30-2013 by someone other than the narcotic treatment physician. Patient #6 was admitted to treatment on 6-27-2013 and was discharged on 8-20-2013. The initial medication order was written on 6-27-2013 by someone other than the narcotic treatment physician. Patient #10 was admitted to treatment on 8-28-2013. The initial medication order was written on 8-28-2013 by someone other than the narcotic treatment physician. Patient #11 was admitted to treatment on 5-21-2013. The initial medication order was written on 5-20-2013 by someone other than the narcotic treatment physician. It appears the nurse completed the order, the physican assistant signed the order, and the physician signed the order.Patient #12 was admitted to treatment on 3-26-2013. The initial medication order was written on 3-25-2013 by someone other than the narcotic treatment physician. The findings were reviewed with the facility director and the nurse and were not disputed.
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Plan of Correction
Director met with medical director and discussed findings from inspection on October 2, 2013 and October 7, 2013.
Medical charts that we reviewed at our inspection were reviewed by MD, Project director and nurse supervisor on October 7, 2013 and it is understood by MD what he is required to complete in regards to documents and what the PA is allowed to complete.
Medical director and project director spoke to dispensing staff, nurse supervisor and PA on October 7, 2013 and discussed inspection results as well as medical activity that only the/a MD can perform.
MD will be the only staff member that will complete any new admission physicals/paperwork which should prevent this from occurring again.
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