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 June 11-12, 2012 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, RHJ Medical Center, Inc./Vandergrift LLC 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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715.17(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 on June 11-12, 2012, the facility failed to ensure that the narcotic treatment physician is determining the proper dosage level for a patient in eight of seventeen patient records.
The findings include:
Seventeen patient records were reviewed on June 11-12, 2012. All patient records were reviewed for medication order and dosage change which shall be written and signed by the narcotic treatment physician. Patient records # 4, 5, 8, 9, 11, 12, 14 and 16 contained documentation of medication orders that were completed by someone other than the narcotic treatment physician.
Patient #4 was admitted January 28, 2011. A seven day detox schedule was completed on 4-30-2012 by the Physician's Assistant and was not countersigned by the supervising physician.
Patient #5 was admitted February 10, 2012. The Client Dosage Adjustment form was completed by the nurse on 2-11-2012, and was faxed to the physician on 2-13-2012, but the dated physician's signature was for 2-11-2012. The Client Dosage Adjustment form was completed by the nurse on 2-12-2012 and was faxed to the physician on 2-13-2012. The physician signed the Client Dosage Adjustment form, but did not include the date of the signature.
Patient #8 was admitted October 5, 2010. A physicians note dated 2-24-2012 indicated that the the physician's assistant determined a 5 mg decrease in dose. In addition, a twenty-one day detox schedule was completed on 3-12-2012 by the physician's assistant rather than the Narcotic Treatment Physician as required.
Patient #9 was admitted May 14, 2010. A seven day detox schedule was completed on 2-16-2012 by the physician's assistant rather than the Narcotic Treatment Physician as required.
Patient #11 was admitted December 2, 2011. The Client Dosage Adjustment form was completed by the nurse on 1-17-2012 and was faxed to the physician on 1-19-2012, but the physician's dated signature was for 1-17-2012. A Client Dosage Adjustment form was completed by the nurse on 2-12-2012 and was faxed to the physician on 2-13-2013. The physician signed the medication order, but did not date the medication order. Medication orders were completed by the counselor on 1-10-2012 and 1-13-2012 rather than the Narcotic Treatment Physician as required.
Patient #12 was admitted April 3, 2012. The physician signed the medication order, but did not date his/her signature.
Patient #14 was admitted February 16, 2012. The Client Dosage Adjustment form was completed by the counselor on 3-13-2012 and was faxed to the physician on 3-14-2012. The physician signed the Client Dosage Adjustment form but dated his/her signature 3-13-2012.
Patient #16 was admitted May 11, 2012. The Client Dosage Adjustment form was completed by the nurse on 5-13-2012, and another Client Dosage Adjustment form was completed by the nurse on 5-14-2012. There was no documentation of the Narcotic Treatment Physician's signature as required.
The findings were reviewed with the facility director and the clinical supervisor and were not disputed.
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Plan of Correction
The project director will meet with the medical staff to discuss this regualtion and the failures to comply with this regulation. The medical staff will be reminded that all dosage adjustments and detox or stabilizations must be approved by the physician prior to any dosage change and that only the physician can complete the physician area of these documents which records the actual dosage amount. The nurses will be further instructed to ensure that the physician signature and date are included on all dosage related forms prior to changing any client dosage. The nurses will also be instructed to complete a nurse's note for all verbal orders where the dosage is changed prior to the physician signature.The nurses will also be instruct to refuse any dosage adjustment that has been signed by the physician assistant and not countersigned and dated by the supervising physician prior to entry into the system to change the client dosage. The physcians were reminded of the importance of both signature and date being completed on the dosage adjustment form. The physician assistant was instructed to ensure that the supervising physician had signed off on and dated any document that he had completed. In order to ensure compliance random chart audits will be conducted and any difficienies will be addressed immediately by the director. |
715.20(1) 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.
(1) The transferring narcotic treatment program shall transfer patient files which include admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient.
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Observations
Based on a review of patient records, the facility failed to document that it transferred patient records which included the admission date, medical and psychosocial summaries, dosage levels, urinalysis reports or summaries, exception requests and the current status of the patient. There was no documentation of the written consent of the patient to release that information in one of three patient records reviewed.
The findings include:
Seventeen patient records were reviewed on June 11 -12, 2012. Three of the patients reviewed transferred to another narcotic treatment facility and required a transfer of patient records. There was no documentation that the facility transferred the required documentation in one of three patient records.
Patient # 11 was admitted on December 2, 2011 and transferred to another narcotic treatment program on March 16, 2012. There was no documentation that the transferring narcotic treatment program transferred the required patient records, nor was there any documentation of an informed written consent, from the patient, to release that information.
The findings were reviewed with the facility director and the clinical supervisor and were not disputed.
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Plan of Correction
The project director will meet with staff to discuss the importance of transfer documentation. The staff will be instructed to obtain releases from all transferring clients to enable us to obtain transfer documentation. The staff will also be instructed to document any and all attempts/failures to complete this task. The staff will keep all fax transmittal sheet to prove that documentation was sent when requested. Random chart audits will be conducted to ensure compliance with this regulation. |