INITIAL COMMENTS
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This report is a result of an onsite licensure renewal and methadone monitoring inspection. The inspection was conducted on October 16 & 19, 2015 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the onsite inspection, Tadiso, Inc., was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during the inspection:
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Plan of Correction
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715.6(e) LICENSURE Physician Staffing
(e) A physician assistant or certified registered nurse practitioner may perform functions of a narcotic treatment physician in a narcotic treatment program if authorized by Federal, State and local laws and regulations, and if these functions are delegated to the physician assistant or certified registered nurse practitioner by the medical director, and records are properly countersigned by the medical director or a narcotic treatment physician. One-third of all required narcotic treatment physician time shall be provided by a narcotic treatment physician. Time provided by a physician assistant or certified registered nurse practitioner may not exceed two-thirds of the required narcotic treatment physician time.
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Observations
Based on a review of patient records, the facility failed to document that a physician assistant may perform functions of a narcotic treatment physician in a narcotic treatment program if the records are properly countersigned by the medical director or a narcotic treatment physician in one of two patient records.
The findings include:
Ten patient records were reviewed on October 16 & 19, 2015. Two of the patient records included physical examinations performed by the physician's assistant and required the narcotic treatment physician's countersignature, within three days, as per the state licensing body. Patient record # 3 did not include a physician's countersignature within three days.
Patient #3 was admitted on July 31, 2015 and the physician assistant performed a physical on July 31, 2015. A physician countersignature was due by August 3, 2015. The physician countersigned the document on August 6, 2015.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The Medical Director will review and sign all physical examinations completed by the Certified Registered Nurse Practitioner and/or the Physician Assistant, within 3 days of completion. The Nursing Supervisor will ensure completion of all reviews by the Medical Director. Tadiso will be in full compliance with this standard, effective today, October 27, 2015. |
715.9(a)(4) LICENSURE Intake
(a) Prior to administration of an agent, a narcotic treatment program shall screen each individual to determine eligibility for admission. The narcotic treatment program shall:
(4) Have a narcotic treatment physician make a face-to-face determination of whether an individual is currently physiologically dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenance treatment. The narcotic treatment physician shall document in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction.
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Observations
Based on a review of patient records, the facility failed to have a narcotic treatment physician make a face-to-face determination of whether an individual is currently physiologically dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenance treatment. The narcotic treatment physician shall document in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction. The physician did not document the patient's current and 1 year history of dependence in one of two patient records.
The findings include:
Ten patient records were reviewed on October 16 & 19, 2015. Two of the patients reviewed were new admits, that did not transfer from another treatment facility. Both of these patient records required the facility to have a narcotic treatment physician make a face-to-face determination of whether an individual is currently physiologically dependent upon a narcotic drug and has been physiologically dependent for at least 1 year prior to admission for maintenance treatment. The narcotic treatment physician shall document in the patient 's record the basis for the determination of current dependency and evidence of a 1 year history of addiction. The physician did not document the patient's current and 1 year history of dependence in patient record # 1.
Patient #1 was admitted on August 11, 2015. The narcotic treatment physician completed the intake physical examination on August 11, 2015; however, the current and one year narcotic dependence form was completed by the Certified Registered Nurse Practitioner (CRNP) on August 12, 2015.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
All patients will meet with the Medical Director or a staff physician prior to receiving the first dose of medication. At this time, the Declaration of Addiction will be reviewed and signed with the patient. The Declaration of Addiction documents the patients' current dependence and 1 year history of addiction. The Nursing Supervisor shall ensure completion by the Medical Director of staff physician. Tadiso will be in full compliance with this standard effective today, October 27, 2015. |
715.14(a) LICENSURE Urine testing
(a) A narcotic treatment program shall complete an initial drug-screening urinalysis for each prospective patient and a random urinalysis at least monthly thereafter.
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Observations
Based on review of the patient records, the facility failed to obtain a complete drug screen urinalysis prior to the administration of methadone, a narcotic agent, in one of two patient records. A complete drug screen includes receiving the results from the CLIA and Department of Health approved laboratory.
The findings include:
Ten patient records were reviewed on October 16 & 19, 2015. Two of the patients reviewed were new admits that were not transferred from other narcotic treatment facilities. Both of the new admit patient records were required to complete a drug screen urinalysis prior to the administration of methadone, a narcotic agent. A complete urine drug screen includes receiving the results from the CLIA and Department of Health approved laboratory. The facility failed to obtain a complete drug screen urinalysis prior to the administration of methadone, a narcotic agent, in patient record #1.
Patient #1 was admitted on August 11, 2015 and received their first dose of methadone on August 12, 2015. The urinalysis results were reported by the laboratory on August 13, 2015.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
On October 5, 2015, Tadiso began contracting with Quest Diagnostics Laboratory. This laboratory is now providing the overnight urine screening analysis for all new intakes. Although the results from the screening will not be automatically downloaded into Tadiso's electronic health record, the results can be guaranteed within 12 hours, which is the goal. The new laboratory picks up specimens at the clinic and results are faxed to the medical department. We will have the results from the lab before the patient receives any medication. The faxed document is scanned into the electronic health record. Tadiso will be in compliance with this standard, effective today, October 27, 2015. |
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 a review of patient records, the facility failed to document that the narcotic treatment physician reviewed the dosage levels at least twice a year, with each review occurring at least two months apart, in one of six patient records.
The findings include:
Ten patient records were reviewed on October 16 & 19, 2015. Six of the patients reviewed required semiannual dose reviews. The facilty did not document a semiannual dose review by the narcotic treatment physician in patient record #9.
Patient #9 was admitted on February 2, 2010. The narcotic treatment physician completed a dose review on February 13, 2015. An additional dose review was completed on August 28, 2015; however, this was completed by the Certified Registered Nurse Practitioner (CRNP), not the narcotic treatment physician.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The Medical Director or the staff physician will provide a dosage review 2 times per year. The Nursing Supervisor will ensure compliance with this standard, effective today, October 27, 2015. |
715.15(b) LICENSURE Medication dosage
(b) The narcotic treatment physician shall determine the proper dosage level for a patient, except as otherwise provided in this section. If the narcotic treatment physician determining the initial dose is not the narcotic treatment physician who conducted the patient examination, the narcotic treatment physician shall consult with the narcotic treatment physician who performed the examination before determining the patient 's initial dose and schedule.
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Observations
Based on a review of patient records, the facility failed to document that the narcotic treatment physician determined the proper dosage level for the patient in four of ten patient records.
The findings include:
Ten patient records were reviewed on October 16 & 19, 2015. The narcotic treatment physician is required to determine the proper dosage level for the patient in all patient records. The narcotic treatment physician did not document the proper dosage level for the patient in patient records # 1, 3, 5 and 6.
Patient #1 was admitted on August 11, 2015. The initial order was written by the Certified Registered Nurse Practitioner (CRNP) on August 12, 2015 at 13:45. The patient's first dose was on August 12, 2015 at 13:57. The physician did not sign the order until August 13, 2015, after the patient had already dosed.
Patient #3 was admitted on July 31, 2015. The initial order was written by the Certified Registered Nurse Practitioner (CRNP) on July 31, 2015 at 10:38. The patient's first dose was on July 31, 2015 at 10:46. The physician did not sign the order until August 4, 2015, after the patient had already dosed. The CRNP also wrote a dosage increase orders on August 7, 2015 an August 24, 2015 that were not signed by the physician.
Patient #5 was admitted on July 16, 2015. The Certified Registered Nurse Practitioner (CRNP) wrote a dosage change order on September 10, 2015 at 6:17 and the patient medicated at the new dosage on September 10, 2015 at 6:22. The physician did not sign this order until September 10, 2015 at 7:11, after the patient had already medicated.
Patient #6 was admitted on July 13, 2015. The Certified Registered Nurse Practitioner (CRNP) wrote a dosage increase order on July 27, 2015 at 8:39. The patient was medicated at the increased dosage on July 27, 2015 at 8:43. The physician did not sign this order. The Certified Registered Nurse Practitioner (CRNP) wrote a dosage increase order on August 3, 2015 at 7:17. The patient was medicated at the increased dosage on August 3, 2015 at 7:21. The physician did not sign this order. The Certified Registered Nurse Practitioner (CRNP) wrote a dosage increase order on September 8, 2015 at 8:38. The patient was medicated at the increased dosage on September 8, 2015 at 8:47. The physician did not sign this order until September 8, 2015, after the patient had already medicated.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The Medical Director or Staff Physician will sign all changes in medication dose prior to the change being received by the patient. If the CRNP or PA recommends a change in medication dose, she will present it to the Medical Director or Staff Physician. Then the Medical Director or Staff Physician will review, and write the order. All this will occur prior to the patient receiving the dose of medication. The Medical Director and Nursing Supervisor are responsible for monitoring this correction. Tadiso will be in compliance with this standard effective today, October 27, 2015. |