Observations
The facility failed to complete an initial drug screening urinalysis for each prospective patient and/or a random urinalysis at least monthly thereafter in five of six patient records.
Ten client records were reviewed on July 12-13, 2016. Six of the patients reviewed were prescribed Suboxone. All six patients were required to complete a drug screen urinalysis prior to the administration of buprenorphine, a narcotic agent, and at least monthly thereafter. A complete urine drug screen includes receiving the results from a CLIA and Department of Health approved laboratory. The facility failed to complete an initial drug screening urinalysis and/or a monthly random drug screening urinalysis in patient records # 1, 3, 8, 9 and 10.
Patient # 1 was admitted on May 19, 2016. The patient received their first dose of buprenorphine on May 19, 2016. The initial urine screen had been completed by the facility on May 19, 2016 using the dip stick method. However, there was no documentation that the initial urine screen had been sent out to a laboratory for urinalysis. There was no urine screen documented for the month of June 2016.
Patient # 3 was admitted on June 16, 2016. The patient received their first dose of buprenorphine on June 16, 2016. The initial urine screen had been completed by the facility on June 16, 2016 using the dip stick method. The laboratory results were reported on June 21, 2016.
Patient # 8 was admitted on November 19, 2015 and discharged on March 1, 2016. The patient received their first dose of buprenorphine on November 23, 2015. The initial urine screen had been completed by the facility on November 19, 2015 using the dip stick method. Monthly urine screens had been completed on December 18, 2015 and January 11, 2016 using the dip stick method. There was no urine screen documented for the month of February 2016.
Patient # 9 was admitted on July 9, 2015 and discharged on December 8, 2015. The patient received their first dose of buprenorphine on July 9, 2015. The initial urine screen had been completed by the facility on July 9, 2015 using the dip stick method. Urine results from the lab were received on July 11, 2015. Monthly urine screens had been completed on August 20, October 14 and November 2, 2015 using the dip stick method. There was no urine screen documented for the month of September 2015.
Patient # 10 was admitted on April 22, 2016 and discharged on May 19, 2016. The patient received their first dose of buprenorphine on April 22, 2016. The initial urine screen had been completed by the facility on April 22, 2016 using the dip stick method.
These findings were reviewed with facility staff during the licensing inspection.
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Plan of Correction
715.14(a) Urine Testing
On 12/9/15, FCDAC had submitted an exception request on 715.14, Response to this request was received on 2/29/16, which indicated that DDAP was in the process of finalizing their procedures and protocol for drug free facilities. DDAP has requested that FCDAC re-submit the exception request. FCDAC will submit this request by 7/25/16. In the meantime, The Project Director, Clinical Supervisor, Medical Director and Lead Counselor met on 7/25/16 and developed a written policy regarding initial drug-screening urinalysis for each prospective client entering the narcotic detoxification program and random urinalysis at least monthly thereafter. As part of the initial assessment/intake interview for the narcotic detoxification treatment, an initial urinalysis shall be sent to a clinical laboratory that performs testing that is in compliance with Federal requirements. The results of the urinalysis will be reviewed by the medical director prior to the initial prescription of a narcotic agent. Clients who participate within the narcotic detoxification program will also receive random monthly urinalysis that will be conducted by a clinical laboratory. It shall be the responsibility of the Clinical Supervisor to issue a "memo" notifying FCDAC staff and prescribing physician of the policy changes regarding urinalysis drug screenings. Clinical Supervisor will ensure ongoing compliance with this regulation through weekly clinical supervision and review of admissions with Facility Medical Director.
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Observations
The facility's physician failed to adhere to the dosing protocol listed on the medication by ordering that single dose Suboxone film be halved, quartered and cut into eighths. The medication packaging identifies this as a single dose medication.
Patient # 1 was admitted on May 19, 2016.
The physician's medication orders, dated May 31 and June 6, 2016, documented- Suboxone 8 mgs 3/4 filmstrip QD SL.
The physician's medication orders, dated June 6 and June 20, 2016, documented- Suboxone 8 mgs 1/2 filmstrip QD SL.
The physician's medication order, dated June 27, 2016, documented- Suboxone 8 mgs 1/4 filmstrip QD SL.
Patient # 2 was admitted on May 9, 2016.
The physician's medication orders, dated May 31 and June 6, 2016, documented- Suboxone 8 mgs 3/4 filmstrip QD SL.
The physician's medication orders, dated June 6 and June 20, 2016, documented- Suboxone 8 mgs 1/2 filmstrip QD SL.
The physician's medication order, dated June 27, 2016, documented- Suboxone 8 mgs 1/4 filmstrip QD SL.
Patient # 8 was admitted on November 19, 2015 and discharged on March 1, 2016.
The physician's medication orders, dated November 30 and December 7, 2015, documented- Suboxone 8 mgs 3/4 filmstrip QD SL.
The physician's medication orders, dated December 14 and December 21, 2015, documented- Suboxone 8 mgs 1/2 filmstrip QD SL.
The physician's medication orders, dated December 28, 2015 and January 4, 2016, documented- Suboxone 8 mgs 1/4 filmstrip QD SL.
Patient # 9 was admitted on July 9, 2015 and discharged on December 8, 2015.
The physician's medication orders, dated August 6, 2015, documented- Suboxone 8 mgs 1/2 filmstrip QD SL.
The physician's medication orders, dated August 10, 2015, documented- Suboxone 8 mgs, use as directed, #4 x 10 days.
The physician's medication orders, dated August 20, 2015, documented- Suboxone 8 mgs, use as directed, #2 x 4 days.
The physician's medication orders, dated August 24 and August 31, 2015, documented- Suboxone 8 mgs 1/4 filmstrip QD SL.
The physician's medication orders, dated September 3, 2015, documented- Suboxone 8 mgs, use as directed, #3 x 11 days.
The physician's medication orders, dated September 14 and September 21, 2015, documented- Suboxone 8 mgs 1/4 filmstrip QD SL.
The physician's medication orders, dated October 26 and November 2, 2015, documented- Suboxone 8 mgs 1/2 filmstrip QD SL.
The physician's medication orders, dated November 9, 16, 23, 30 and December 7 , 2015, documented- Suboxone 8 mgs 3/8 filmstrip QD SL.
Patient # 10 was admitted on April 22, 2016 and discharged on May 29, 2016.
The physician's medication order, dated May 9, 2016, documented- Suboxone 8 mgs 3/4 filmstrip QD SL.
These findings were reviewed with facility staff during the licensing process. This is a repeat citation.
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Plan of Correction
715.15(b) Medication Dosage
On 7/25/16 the Project Director, Medical Director, Clinical Supervisor and Lead Counselor met and developed a policy when prescribing Narcotic medication. The policy states that FCDAC physician(s) will adhere to dosing protocol when prescribing Suboxone or Zubsolv. Therefore, any Suboxone or Zubsolve prescriptions will be written to follow the manufactured quantities of 8mg, 4mg or 2mg, at no time are the prescriptions to be altered. The Treatment Supervisor and Lead counselor will ensure that the FCDAC physician(s) are adhering to the manufacturer's recommendations by conducting Quality Assurance checks on all written prescriptions during the medication visits prior to the client leaving FCDAC. The Clinical Supervisor and Lead Counselor will review dosing protocol with FCDAC's Medical Director to ensure that the physician(s) are adhering to dosing protocols for clients in the Detoxification program. The Lead Counselor will immediately notify the Clinical Supervisor, Project Director if dosing issues continue. Auditing of charts will be completed by the Clinical Supervisor and Lead Counselor to ensure appropriate single dosing is occurring. Any issues that are identified will be brought to the attention of the Project Director and prescribing physician.
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