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 buprenorphine, in the treatment of narcotic addiction. This inspection was conducted on March 18, 2014 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, New Perspectives At White Deer Run was found to not be in compliance with the applicable chapters of 28 PA Code which pertain to the facility and a plan of correction is required.
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Plan of Correction
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715.15(a) LICENSURE Medication Dosage
(a) The narcotic treatment physician shall review the dosage levels at least twice a year, with each review occurring at least 2 months apart, to determine a patient 's therapeutic dosage.
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Observations
Based on the review of patient records, the facility failed to provide documentation that the phsycian consulted with the medical staff who completed the patient physical prior to the determination of initial dose and administration of medication in one of one records reviewed.
The findings include:
Twelve patient records were reviewed on March 18, 2014. One patient record included documentation that medical staff, other than the physician completed a the patient's medical examination.
Patient # 1 was admitted into treatment on March 13, 2014. The physical examination was completed by the certified registered nurse practitioner (CRNP) on March 14, 2014. The physician met with patient # 1 on March 15, 2014 and signed the physical examination documentation completed by the CRNP but did not document that he had consulted with the CRNP, as required.
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Plan of Correction
Campus Director spoke with Medical Director on 3/24/14 and reviewed policy that documentation of consultation is needed when CRNP completes physical examination. Medical Director will note consultation on necessary documents when the CRNP covers.
Nurses' Meeting occurred on 3/26/14 to review policy with all nursing staff as well to ensure compliance moving forward. |
715.17(c)(4)(i-viii) 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:
(4) Method for control and accountability of drugs. A narcotic treatment program shall develop and implement written policies and procedures regarding who is authorized to remove drugs from the storage area and the method for accounting for all stored drugs. An agent or other drug prescribed or administered shall be documented on an individual medication record or sheet in a manner sufficient to maintain an accurate accounting of medication at all times and shall include:
(i) The name of the medication.
(ii) The date prescribed.
(iii) The dosage.
(iv) The frequency.
(v) The route of administration.
(vi) The date and time administered.
(vii) The name of the person administering the medication.
(viii) The take-home schedule, if applicable.
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Observations
Based on a review of the facility's administrative and medical records, the facility failed to maintain medication in compliance with federal and state regulations.
The findings include:
Medication records and storage was reviewed and examined on March 18, 2014. An examination of the facility's current supply of medication revealed that the narcotic medication Subutex was stored and labeled as a stock medication. This medication must be obtained in an individual's name, either the treating physician or the individual patient's name.
The issue was addressed with staff and it was confirmed that this practice was taking place.
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Plan of Correction
Acting Nursing Supervisor has reached out to Pharmacy to change label on Subutex from Stock Medication to Treating Physician's name.
Expected completion date is no later than April 15th, 2014 as we are simply awaiting a call back from the pharmacy.
Nurses' meeting was held on March 26th to review this policy and needed compliance moving forward. |
715.17(c)(7) 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:
(7) Drug reactions and medication errors. A narcotic treatment program shall report any adverse drug reaction or medication error to a narcotic treatment physician immediately and initiate corrective action. The narcotic treatment program shall record the reaction or error in the drug administration record and the clinical chart, and shall inform each person who is authorized to administer medication or supervise self-medication of the reaction or error.
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Observations
Following a review of administrative records, the facility failed to provide documentation that the narcotic treatment physician was notified of medication errors.
The findings include:
The incident report logs were reviewed on March 18, 2014. Documentation was reviewed pertaining to medication errors. The physician was not contacted, as required.
Patient # 6 received a medication dose on May 26, 2013 that was not indicated. The incident report was reviewed and there was no indication that the physician was contacted. Patient # 6's record was also reviewed for documentation of notification to the physician of a medication error. There was no documentation in the record.
Patient # 8 received a medication dose on June 3, 2013 that was not indicated. The incident report was reviewed and there was no indication that the physician was contacted. Patient # 8's record was also reviewed for documentation of notification to the physician of a medication error. There was no documentation in the record.
The findings were reviewed with staff and were not disputed.
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Plan of Correction
Acting Nursing Supervisor and Campus Director reviewed completion of Incident Reports with all nursing staff on March 26th, 2014 during a nurses' meeting as previous incident reports did not indicate the physician was notified at the time of a medication error.
Campus Director will be reviewing ALL incident reports with reporters to ensure full completion of document for the next 60 days or until CD feels that the training is complete.
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715.29(4) LICENSURE Exceptions
A narcotic treatment program is permitted, at the time of application or any time thereafter, to request an exception from a specific regulation.
(4) The narcotic treatment program shall maintain documentation of the Department 's approval of an exception.
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Observations
Based on a review of patient records, the facility failed to maintain compliance with an exception to dose patients. The facility has an exception to dose patients in accordance with Licensing Alert May 2012. This exception permits a patient to be dosed in urgent situations prior to a face-to-face with the physician.
The findings include:
Patient records were reviewed on March 18, 2014. In accordance with the above referenced licensing alert, registered nurses may assess a patient and contact the physician for orders pertaining to the administration and induction of buprenorphine. In the review of patient records, it was revealed that licensed practical nurses (LPN) were completed the task of contacting the physcian was a patient assessment and a request for medication orders and other directives.
Patient # 6 was admitted on May 25, 2013. The patient record identified that the patient was assessed by an LPN on May 25, 2013 and contacted the physician by telephone for verbal orders. The physican provided verbal orders that included an induction of Subutex.
A review of the patient record revealed that the documentation indicated the patient was dosed prior to a face-to-face examination by the physician.
Patient # 7 was admitted on February 9, 2014. The patient record identified that the patient was assessed by an LPN on February 9, 2014 and contacted the physician by telephone for verbal orders. The physican provided verbal orders that included an induction of Subutex.
A review of the patient record revealed that the documentation indicated the patient was dosed prior to a face-to-face examination by the physician.
Patient # 8 was admitted on May 13, 2013. The patient record identified that the patient was assessed by an LPN on June 1, 2013 and contacted the physician by telephone for verbal orders. The physican provided verbal orders that included an induction of Subutex. A review of the patient record revealed that the documentation indicated the patient was dosed prior to a face-to-face examination by the physician.
Patient # 12 was admitted on March 6, 2014. The patient record identified that the patient was assessed by an LPN on March 6, 2014 and contacted the physician by telephone for verbal orders. The physican provided verbal orders that included an induction of Subutex.
A review of the patient record revealed that the documentation indicated the patient was dosed prior to a face-to-face examination by the physician.
The finding was addressed with facility staff and not disputed.
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Plan of Correction
Acting Nursing Supervisor and Campus Director notified nursing staff via email on 3/18/2014 attaching the Licensing Alert from May 2012.
Acting Nursing Supervisor and Campus Director met with all nurses on March 26th, 2014 to review the policy again with department.
Acting Nursing Supervisor will audit 4 charts weekly beginning April 2nd through May 28th, 2014 to ensure full compliance of the policy/alert.
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