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 buprenorphine, in the residential detoxification from opioid dependence. This inspection was conducted on December 3, 2009 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Pyramid Healthcare Inc. Transitions 2, was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. Deficiencies were identified during this inspection and plan of correction is due on December 24, 2009.
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Plan of Correction
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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 urine drug screen urinalysis prior to the administration of Subutex, a narcotic agent in two of four patient records. A complete urine drug screen includes receiving the results from the CLIA and Department of Health approved laboratory.
The findings include:
Four patient records were reviewed on December 3, 2009. Four patient records are required to complete a urine drug screen urinalysis prior to the administration of Subutex, 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 urine drug screen urinalysis prior to the administration of Subutex, a narcotic agent in two of the four records.
Record #1 - Patient was admitted on 12-2-09. The urine screen results were not available during the record review on 12-3-09. The first dose of Subutex was given on 12-3-09 at 8:00 am.
Record #2 - Patient was admitted on 12-2-09. The urine screen results were not available during the record review on 12-3-09. The first dose of Subutex was given on 12-2-09 at 10:00 PM.
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Plan of Correction
The Director of Nursing will be contacting Quest Diagnostics to inform them of Transitions need to get quicker turnaround with our urinalysis results. The Director of Nursing will be submitting for CLIA approval for onsite testing. Transitions will then be able to perform dipstick urinalysis for suboxone clients.
Interim Plan: The contract between Pyramid Healthcare Transitions and Quest Laboratories was amendeded on 1-7-10. Urine drug screen results will be available to Transitions nursing staff by the following morninig, prior to the client medicating with subutex. |
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 narcotic treatment program failed to document the consultation between the narcotic treatment physician determining the initial dose and the narcotic treatment physician performing the physical examination in 1 of 4 records.
The findings include:
Four patient records were reviewed on December 3, 2009. Three patient records are required to document a consult between the narcotic treatment physician determining the initial dose and the narcotic treatment physician performing the physical examination in one of the three records.
Record #3 - Patient was admitted on 10-10-09. The Certified Registered Nurse Practitioner (CRNP) completed the physical examination on 10-10-09. The narcotic treatment physician determined the initial dose on 10-10-09, but failed to document the consultation with the Certified Registered Nurse Practitioner who completed the physical examination.
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Plan of Correction
The Narcotic treatment physician, caring for the client, will consult with the physician who completed the clients physical exam. The Narcotic treatment physician will document, in his/her progress notes, that they consulted with the physician who completed the clients physical exam. This task will be monitored by the Medical Administrative Assistant through monthly chart monitors. |
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 on patient records, the facility physician failed to document the time on the medication order in one of four patient records.
The findings include:
Four records were reviewed on December 3, 2009. Four of the patient records were required to have the physician communicate the initial and subsequent dose and schedule to the person responsible for the administration of medication. One record did not document the time on the medication order. Due to the time not documented on the order, it was unable to be determined if the medication order was written prior to the first dose being administered to the patient.
Patient record #2 - Patient was admitted 12-2-09. The order was written on 12-2-09 and the first dose was given on 12-2-09 at 10:00 PM.
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Plan of Correction
Each physician, who writes an order, will include the date and time in their documentation. This task will be monitored through monthly chart monitors conducted by the medical administrative assistant. |