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 January 23, 2009 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Progressive Medical Services, Inc. was found not to be compliance with the applicable chapters of 28 PA Code which pertain to the facility. Deficiencies were identified during this inspection and a plan of correction is due on February 14, 2009.
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Plan of Correction
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715.8(1)(vi) LICENSURE Psychosocial Staffing
A narcotic treatment program shall comply with the following staffing ratios as established in Chapter 704 (relating to staffing requirements for drug and alcohol treatment activities):
(vi) Outpatients. The counseling caseload for one FTE counselor in an outpatient narcotic treatment program may not exceed 35 active patients.
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Observations
Based on a review of facility information and an interview with the facility director, the facility failed to provide 57 patients with a counselor, while counselors with full caseloads were randomly assigned to conduct sessions with the 57 patients who had not been assigned to a counselor's caseload.
The finding include:
Patient census and caseload assignments were reviewed on January 22, 2009 and the Facility Director was interviewed. There was one vacant counselor position at the facility. Fifty-seven patients were being seen randomly by counselors who already had full or nearly full caseloads, in order to ensure that the 57 patients were getting the minimum of 2.5 hours of counseling per month. As a result of this practice, the counselors each had an effective caseload that exceeded the 35:1 maximum.
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Plan of Correction
As of 2/4/09 one counselor position has been filled.
We are finishing interviews to add another full time counselor to the staff.
We plan to have this position filled by 2/23/09. By filling position we are in compliance with standard. |
715.9(c) LICENSURE Intake
(c) If a patient was previously discharged from treatment at another narcotic treatment program, the admitting narcotic treatment program, with patient consent, shall contact the previous facility for the treatment history.
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Observations
Based on a review of patient records, the facility failed to contact the previous facility for the treatment history in two of two patient records.
The finding include:
Fourteen patient records were reviewed on January 22 - 23, 2009. Two patient records were required to have the documentation that there was contact with the previous narcotic treatment facility for the treatment history. Two of two patient records did not include documentation of contact with the previous facility, specifically patient records # 1 and 14.
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Plan of Correction
Director updated our release of information that requests records of those individuals who have had prior methadone treatment. This form was reviewed with inspector on January 22, 2009 for feedback.
All staff met with director on January 28, 2009 to review the form and learn new procedures. New procedure was implemented that front office staff are to make this release part of the intake packet.
When clinical staff is reviewing treatment history with a potential client they will have that individual sign the consent for information at that time. The counselor will then make sure that the consent is sent to the treatment facility. Documentation by a fax transmittal sheet or/and proof of mailing request will be obtained and maintained in the client chart.
New procedure implemented as of January 28, 2009. |
715.11 LICENSURE Confidentiality of patient records
A narcotic treatment program shall physically secure and maintain the confidentiality of all patient records in accordance with 42 CFR 2.22 (relating to notice to patients of Federal confidentiality requirements) and § 709.28 (relating to confidentiality).
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Observations
Based on a review of patient records, the facility failed to document a release of information form for patients transferring into the facility in two of fourteen patient records
The finding include:
Fourteen patient records were reviewed on January 22 - 23, 2009 and all fourteen patient records were required to document signed consent to release information forms. Information was disclosed but the consents to release information forms were not signed by the patient in two of the fourteen patient records, specifically patient records # 11 and 13.
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Plan of Correction
Director revised documentation currently used to verify a client's admission to our program to the transferring facility.
The verification of transfer form now includes a written consent that the client will sign prior to sending the information to the transferring facility.
This revised form was reviewed with inspector on January 22, 2009 and form was reviewed with staff and implemented at location on January 28, 2009. |
715.16(c)(1)(i-iv) LICENSURE Take-home privileges
(c) A narcotic treatment program shall require a patient to come to the narcotic treatment program for observation daily or at least 6 days a week for comprehensive maintenance treatment, unless a patient is permitted to receive take-home medication as follows:
(1) A narcotic treatment program may permit a patient to reduce attendance at the narcotic treatment program for observation to three times weekly and receive no more than a 2-day take-home supply of medication when, in the reasonable clinical judgment of the narcotic treatment physician, which is documented in the patient record:
(i) A patient demonstrates satisfactory adherence to narcotic treatment program rules for at least 3 months.
(ii) A patient demonstrates substantial progress in rehabilitation.
(iii) A patient demonstrates responsibility in handling narcotic drugs.
(iv) A patient demonstrates that rehabilitation progress would improve by decreasing the frequency of attendance for observation.
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Observations
Based on a review of patient records, the facility failed to grant appropriate take home privileges in one of four records.
The finding include:
Fourteen patient records were reviewed on January 22 - 23, 2009. Four records were required to include documentation for patient take-home determinations, to include documentation of the physician's rationale and the review of the eight point criteria for take-home privileges. Weekend privileges were granted in patient record # 12, but the documentation in the record did not support the granting of weekend take home privileges based on the 8 point evaluation used by the facility. The patient failed to meet the minimum of 2.5 psychotherapy hours per month, had pending legal charges upon admission in October 2008, and the patient's lack of positive peer support as reported in a January 2009 case consultation was viewed as a problem for the patient.. Based on all of these factors, this patient did not meet all eight requirements used to assess take-home privileges and was not appropriate to receive take home privileges.
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Plan of Correction
Director met with Clinical supervisor and medical director to discuss this client's take home status on January 26, 2009. It seems that due to this client not having a primary counselor at the time and that a few counselors were monitoring the client a request for take homes was submitted sooner that it should have been. Staff did feel that due to the client following through with his legal responsibilities he should not have been refused take homes.
As of January 26, 2009 Client has been assigned a primary counselor, a counselor has been hired as of February 4, 2009 so unassigned clients have consistent monitoring and all staff will meet as a team, (as we do with bi-weekly and higher take home status) for the next 30 days, beginning January 28, 2009 to present each client take home request. This will refresh all staff on ensuring that the 8 requirements for any take home status are being met |
715.17(c)(2) 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:
(2) Drug storage areas. A narcotic treatment program shall develop and implement written policies and procedures regarding storage of medications and access to the medication storage area. Agents shall be stored in a locked safe that has been approved by the DEA under 21 CFR 1301.72 and 1301.74 (relating to physical security controls; and other security controls).
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Observations
Based on the onsite inspection of the dispensing area, the area was not secured.
The finding include:
On January 23, 2009, the dispensing area was not secured. The door between the dispensing area and the front office was open during the dosing hours.
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Plan of Correction
All staff are aware of the need for security and that the door should have been shut and locked.
Staff were reprimanded by director on January 23, 2009.
Nursing and front office staff had a written reprimand made part of their personnel file due to this security infraction.
Director will monitor to ensure areas remain locked at all times. |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on a review of the patient records, the facility failed to provide the required 2.5 hours of psychotherapy per month for the first two years of treatment in three of eight patient records.
The findings include:
Fourteen patient records were reviewed on January 22-23, 2009. Eight patient records were required to have the 2.5 hours of psychotherapy for the first two years of treatment. Three patient records, #11, 12 and 13, documented less than 2.5 hours of psychotherapy per month.
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Plan of Correction
Due to having open counseling positions a few clients did not receive their full 2.5 hours of counseling.
Director reviewed all unassigned clients charts with clinical supervisor to determine if counseling hours were being met. Director and clinical supervisor worked out a plan to meet with these unassigned clients to ensure they are receiving their required counseling time.
Since we have hired a new counselor as of February 4, 2009 and plan to have hired another full time counselor by 2/23/2009 all clients will receive required counseling hours. |