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 22-24, 2013 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Center for Behavioral Health- HA Inc was found not to be in compliance with the applicable chapters of 4 PA Code and 28 PA Code which pertain to the facility. The following deficiencies were identified during this inspection.
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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 a review of patient records, the facility failed to document a random urinalysis at least monthly in two of eight patient records.
The findings include:
The monthly urine screen results for 8 patients were reviewed on May 23-24, 2013. All eight patients were required to complete random monthly urinalysis. Patient records # 4 and 8 did not include documentation of monthly urine screen results.
Patient #4 was admitted on February 26, 2013. There was no documentation of a completed urinalysis for the month of April 2013. A urine sample was provided on April 5, 2013; however, it was documented that the specimen spilled in transit. There was no attempt to complete another urinalysis for the month of April 2013.
Patient #8 was admitted on April 3, 2006. There was no documentation of a complete urinalysis for the month of April 2013. A random urine screen was requested on April 30, 2013; however, the patient could not produce enough urine to complete the urinalysis.
Interviews with the facility director, clinical supervisor and nurse manager took place on May 24, 2013. The aforementioned information was confirmed.
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Plan of Correction
Program Director met with the Nurse Manager and nursing staff regarding random monthly urinalysis and the documentation of random monthly urinalysis. The Nurse Manager will utilize the SMART Software during the third week of the month to determine whether a patient has or has not received a random monthly u/a. If the patient is due for a random monthly and the results are a UTO, the Nurse Manager will place a hard hold in the patients record and enter another U/A within a week. If necessary the Nurse Manger will contact the counselor for assistance. The Nurse Manager will also make sure she documents the appropriate information in the patients record. Program Director contacted the laboratory that is used to test initial urinalysis and spoke with the Director to discuss communication when there is a QNS during transit. Moving forward the identified laboratory will send a fax or place a call to the Nurse Manager informing her of the QNS. The Nurse Manager will follow up with the patient by entering a nurse force test. If the QNA occurs on site the Nurse Manger will have the patient provide a U/A upon return to the clinic. The Nurse Manager will be responsible for documenting all information in the patients record. The Program Director will be responsible for overseeing the completion of this process. |
715.14(a)(1) 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.
(1) Each test shall be for opiates, methadone, amphetamines, barbiturates, cocaine and benzodiazepines.
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Observations
Based on a review of patient records, the facility failed to complete an initial drug-screening urinalysis for each prospective patient which tested for opiates, methadone, barbiturates, cocaine and benzodiazepines in one of six patient records.
The findings include:
The initial urinalysis results were reviewed in six patient records on May 23-24, 2013. All six patient records required documentation of a complete urinalysis which tested for opiates, methadone, barbiturates, cocaine and benzodiazepines. Patient record #2 did not include documentation of a complete urinalysis which included testing for all of the required substances.
Patient #2 was admitted on April 29, 2013. The initial urinalysis dated April 29, 2013 only tested for buprenorphine. The urinalysis did not include testing for opiates, methadone, amphetamines, barbiturates, cocaine and benzodiazepines. This is the only urinalysis testing that has been completed for this patient to date.
Interviews with the facility director, clinical supervisor and nurse manager and PA-C were conducted on May 24, 2013 at which time the aforementioned information was confirmed.
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Plan of Correction
Program Director met with Nurse Manger and Physician Assistant to discuss the initial urinalysis. Upon intake the Nurses will keep a carbon copy of the initial drug-screening urinalysis form to insure that the proper testing was requested. Upon receiving results of test the PA will review the hard copy of the results prior to admission to make sure the patient was tested for the methadone profile panel. If an error was made after reviewing the panel results and noticed that all panels were not tested, the nurse Manager will immediately contact the laboratory to inform them of the error and inform them which test is to be added. The Nurse Manage will notify the program director of the error and how the error was corrected. The Program Director will be responsible for overseeing the completion of this process. |
715.16(d)(1-3) LICENSURE Take-home privileges
(d) A narcotic treatment program may make exceptions to the requirements in subsection (c) relating to the length of time of satisfactory adherence to narcotic treatment program rules and number of days of take-home medication when, in the reasonable clinical judgment of the narcotic treatment physician, which is documented in the patient record:
(1) A patient has a permanent physical disability.
(2) A patient has a temporary disability.
(3) A patient has an exceptional circumstance such as illness, personal or family crisis, or travel which interferes with the patient 's ability to conform to the applicable mandatory attendance schedules. In all cases, the patient shall demonstrate an ability to responsibly handle narcotic drugs.
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Observations
Based on a review of patient records, the facility failed to ensure the physician completed the exceptional circumstance documentation in one of one patient records.
The findings include:
Nineteen patient records were reviewed on May 23-24, 2013. One patient record was reviewed for exceptional circumstance take home medication request. Patient record #3 did not include documentation of the exceptional circumstance and that the patient demonstrated an ability to responsibly handle narcotic drugs.
Patient #3 was admitted as a new methadone patient on April 25, 2013. The patient was given two take home bottles for May 18 & 19, 2013 and three take home bottles for May 25, 26 and 27, 2013. There was no medical note documenting the reasons for exceptional circumstance or any explanation as to the patients ability to responsibly handle narcotic drugs.
Interviews with the facility director, clinical supervisor and nurse manager took place on May 24, 2013. The aforementioned information was confirmed.
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Plan of Correction
Program Director met with the Medical Director and members of management to discuss 715.16(d) (1-3) LICENSURE
Take-home privileges. Program Director informed the Medical Director that his medical note needs to clearly identifying the reason for the written request, nature of the patients hardship, and whether courtesy dosing has been discussed as an option by the counselor and Clinical Supervisor. Program Director further explained to the Medical Director that his medical note needs to include his explanation as to why he believes the patient can responsibly handle narcotic drugs. Program Director informed the Clinical Supervisor and Senior Counselor that they will be responsible for documenting a clinic note prior to meeting with the Medical Director about the patient. A clinical note is to be documented in the patient record explaining why the written exception is needed for a patient who has been in treatment less then 90 days and isn't eligible for take home status. Clinical Supervisor will include in the written note whether the patients Counselor considered courtesy dosing as an option. Program Director will be responsible for overseeing the completion of this process.
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