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 6-7, 2014 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Pennsylvania Associates, LLC dba Mount Pocono Medical was found not to be in compliance with the applicable chapters of 4 PA Code and 28 PA Code which pertain to the facility.
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Plan of Correction
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715.16(a)(3) LICENSURE Take-home privileges
(a) A narcotic treatment program shall determine whether a patient may be provided take-home medications.
(3) The narcotic treatment physician shall document in the patient record the rationale for permitting take-home medication.
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Observations
Based on the review of patient record documentation, the facility failed to ensure the physician document in the patient record the rationale for granting take home medication in two of three patient records. Another patient was admitted as a transfer patient with 6 take home medication bottles without benefit of a physician's order.
The findings include:
Eleven patient records were reviewed May 6-7, 2014. Three records were reviewed for take home medication documentation.
Patient # 4 was admitted April 26, 2013. The patient was granted 2 take home bottles October 17, 2013. However, the physician did not document in the patient record the rationale for permitting these take home medication bottles.
Patient # 6 was admitted October 19, 2012. The patient was granted a take home bottle October 21, 2013. However, the physician did not document in the patient record the rationale for permitting the take home medication bottle.
Patient # 1 was admitted February 27, 2014 as a transfer in patient from another narcotic treatment program. The physician initially ordered the patient be able to continue with the 6 take home medication bottles privilege granted by the referring narcotic treatment program. However, the physician then ordered that the take home medication bottles be revoked because the patient was to have turned in take home bottles from the referring facility and did not turn in all of the bottles as required. The patient reported he misplaced one of the bottles. There was no further medication order by the physician returning the patient's take home medication bottles to 6 bottles per week. Further clinical and nursing documentation revealed the patient is actually still receiving 6 take home medication bottles.
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Plan of Correction
The Facility Director conducted a training with the physician on 5/12/14. The 715.16 (a)(3) take home privileges was reviewed with physician. Moving forward all new physicians will be trained on this procedure. The lead nurse will review THB documents after physician signs off to ensure the rationale for the THB privileges is documented. The facility director will conduct inspections of patients records on monthly basis. |
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, the facility failed to restrict the reasons for involuntary termination to those reasons allowed by regulation in one of one patient records.
The findings include:
Eleven patient records were reviewed May 6-7, 2014. One patient record was reviewed for involuntary discharge. One patient record contained documentation of the patient being discharged for reasons other than those listed by regulation.
Patient # 9 was admitted July 18, 2012. The patient lost his medical insurance February 28, 2014. The patient record included documentation of a treatment plan dated March 17, 2014 requiring that the patient make a $100.00 payment by March 10, 2014. It further stated that the patient was $300.00 in arrears and must be caught up by March 21, 2014. There were no progress notes documenting any other interventions or financial help for the patient. The written notice dated March 27, 2014 described the facility's intent to terminate the patient for failure to comply with program guidelines and treatment plan goals. The detoxification was also documented as beginning on March 27, 2014.
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Plan of Correction
The facility director reviewed standard 715.21 (1)(i-v) patient termination. A training will be conducted with the clinical team on this standard by 6/6/14. The training will cover the key requirements for discharges and proper documentation. The lead counselor and/or facility director will have a meeting with counselor to review patient treatment plan and documentation slated for possible discharge. After the meeting the team will determine the course of action to ensure the standards is met. If the patient is to be discharged, the lead counselor and/or facility director will monitor discharge process. |
715.22(c) LICENSURE Patient grievance procedures
(c) Penalties may not be initiated prior to final resolution with the exception that penalties may be initiated against patients who have committed acts of physical violence or who have threatened to commit acts of physical violence in or around the narcotic treatment program premises.
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Observations
Based on the review of patient records, the facility failed to refrain from initiating penalties prior to a final resolution in one of one patient record reviewed.
The findings include:
Eleven patient records were reviewed May 6-7, 2014. One patient record was reviewed for grievance procedure documentation.
Patient # 9 was admitted on July 18, 2012. The patient was presented with a written notice, dated March 27, 2014, of the intent to terminate for failure to comply with program guidelines and treatment plan goals. The detoxification was also documented as beginning on March 27, 2014, not allowing an opportunity for the patient to appeal before the detoxification was initiated.
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Plan of Correction
The facility director reviewed standard 715.22(c) patient grievance. A training will be conducted with the clinical department reviewing the appeal/grievance procedure and documentation. The training will be conducted by 6/6/2014 by facility director. The lead counselor and/or facility director will ensure that all patients receive a copy of the appeal/grievance procedure. The grievance process will be followed. The facility director will review all of the appeals. |