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 20 & 21, 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 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 and a plan of correction is due on February 10, 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 31 patients with a counselor, while counselors with full caseloads were randomly assigned to conduct sessions for the 31 patients who had not been assigned to a counselor's caseload.
The findings included:
Patient census and caseload assignments were reviewed on January 20, 2009 and the Facility Director was interviewed. There was one vacant counselor position at the facility. Thirty-one patients were being seen randomly by counselors who already had full or nearly full caseloads, in order to ensure that the 31 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
Currently interviewing for the open counselor position. Plan to have position filled by February 16, 2009. Once counselor hired and trained will be in compliance with standard |
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 document that the physician made a face to face determination of current dependency and a one year history of addiction in three of eight patient records.
The findings included:
Twelve patient records were reviewed on January 21, 2009. Eight patient records were required to include documentation that the physician made a face to face determination of current dependency and a one year history of addiction. The physician's assistant completed the form in three of the eight patient records, specifically patient records # 3, 4 and 11. There was no documentation in those three patient records that confirmed that the Narcotic Treatment Physician made the determination of current dependency and a one year history of addiction, nor was there evidence that the physician had face to face contact with the patient.
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Plan of Correction
Director spoke with medical director on January 22, 2009 and met with medical director on January 26, 2009 to discuss this issue. MD is well aware of what duties the PA is able to perform at the facility. Medical director agreed to ensure that this would not happen again by performing all new admission physicals himself.
The front office staff who schedules all appointments were reminded to not schedule new admission appointments to our PA.
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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 consent to release information form signed by the patient, for patients transferring into the facility, in three of eight patient records.
The findings included:
Twelve patient records were reviewed on January 21, 2009. Eight patient records were required to document signed consents to release information forms. Information was disclosed from patient records # 2, 5 and 9, but the consents to release information forms were not signed by the patients in those patient records.
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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 26, 2009.
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