INITIAL COMMENTS
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This report is a result of an on-site inspection for the approval to use a narcotic agent, specifically methadone, in the treatment of narcotic addiction. This inspection was conducted on July 10, 11, and 12, 2007 by staff of the Division of Drug and Alcohol Program Licensure. Deficiencies were identified and plans of correction are due on August 2, 2007.
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Plan of Correction
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715.6(b)(1-9) LICENSURE Physician Staffing
(b) A narcotic treatment program may employ narcotic treatment physicians to assist the medical director. A narcotic treatment physician 's responsibilities include:
(1) Performing a medical history and physical exam.
(2) Determining diagnosis and determining narcotic dependence.
(3) Reviewing treatment plans.
(4) Determining dosage and all changes in doses.
(5) Ordering take-home privileges.
(6) Discussing cases with the treatment team.
(7) Issuing verbal orders pertaining to patient care.
(8) Assessing coexisting medical and psychiatric disorders.
(9) Treating or making appropriate referrals for treatment of these disorders.
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Observations
The facility failed to include the required responsibilities in the narcotic treatment physician job description. Specifically, the following two items were missing: (8) Assessing coexisting medical and psychiatric disorders and (9) Treating or making appropriate referrals for treatment of these disorders.
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Plan of Correction
Medical Director's new job description was sent out and will be signed and dated by the medical director. 30 days for completion. Program Director will be responsible for implementation. |
715.6(c) LICENSURE Physician Staffing
(c) A narcotic treatment physician shall be otherwise available for consultation and verbal medication orders at all times when a narcotic treatment program is open and a narcotic treatment physician is not present.
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Observations
The facility failed to provide documentation that a narcotic treatment physician is available for consultation and verbal orders at all times.
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Plan of Correction
Medical Director will type a letter stating his availablility to the clinic and letter will also include the back-up coverage when he is absent. 30 days for completion. Program Director will be responsible for implementation. |
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
The facility failed to maintain the required patient to counselor ratio. Specifically, the ratio for counselor # 3 was 44:1. The overall facility ratio was 36:1.
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Plan of Correction
A new full-time counselor was hired 7/16/07. Ratios will meet state regulations of 35:1 or less for every counselor. 30 days for completion and on-going. Clinical Supervisor will be responsible for implementation. |
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
The facility disclosed information without the patient's informed voluntary consent to release information in patient records #1, 4, 7, and 14.
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Plan of Correction
All needed consents will be signed and an in-service training on releases and transfers will be given. 30 days for completion. Clinical Supervisor will be responsible for implementation. |
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
The facility failed to adhere to the regulations that permit only narcotic treatment physicians to prescribe methadone. Specifically, the Certified Registered Nurse Practitioner ( CRNP ) prescribed methadone for patient # 5.
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Plan of Correction
Individual training will be given to the CRNP on state regualtions regarding prescribing methadone. 30 days for completion. Program Director will be responsible for implementation. |
715.15(f) LICENSURE Medication dosage
(f) The narcotic treatment program shall develop written policies and procedures relating to narcotic treatment medication dosage which includes the requirements of subsections (a)--(e).
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Observations
The facility failed to develop policies and procedures to address the requirement that methadone be administered or dispensed in oral form only.
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Plan of Correction
Home Office has made necessary updates and changes to policies in question and these changes will be included in the next policy publication. 90 days for completion. Program Director will be responsible for follow-through. |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
The facility failed to provide the minimum requirement of 2.5 hours of psychotherapy per month for patients # 3, 12, and 13.
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Plan of Correction
Counselors will schedule all patients for counseling and will document all AWOL's, suspensions, transfers and discharges to show cause when hours are not met. 30 days and on-going for completion. |
715.20(1) LICENSURE Patient transfers
A narcotic treatment program shall develop written transfer policies and procedures which shall require that the narcotic treatment program transfer a patient to another narcotic treatment program for continued maintenance, detoxification or another treatment activity within 7 days of the request of the patient.
(1) The transferring narcotic treatment program shall transfer patient files which include admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient.
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Observations
The facility failed to send to the receiving facility the information required for the transfer of patient #19. Specifically, the only document that was sent was the discharge summary. All other required information was not sent.
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Plan of Correction
An in-service training on releases and transfers will be given. 30 days for completion. Clinical Supervisor will be responsible for implementation. |
715.20(4) LICENSURE Patient transfers
A narcotic treatment program shall develop written transfer policies and procedures which shall require that the narcotic treatment program transfer a patient to another narcotic treatment program for continued maintenance, detoxification or another treatment activity within 7 days of the request of the patient.
(4) The receiving narcotic treatment program shall document in writing that it notified the transferring narcotic treatment program of the admission of the patient and the date of the initial dose given to the patient by the receiving narcotic treatment program.
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Observations
The facility failed to document that they contacted the transferring narcotic treatment program to confirm the dates of admission and initial dosage for patients # 1, 3, 4, and 7.
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Plan of Correction
An in-service training on releases and transfers will be given. An addendum will also be made on the current form used to notify transferring narcotic treatment program that will include date of dose and date of admission. 30 days for completion. Clinical Supervisor will be responsible for implementation. |
715.21(1)(i-iv) LICENSURE Patient termination
A narcotic treatment program shall develop and implement policies and procedures regarding involuntary terminations. Involuntary terminations shall be initiated only when all other efforts to retain the patient in the program have failed.
(1) A narcotic treatment program may involuntarily terminate a patient from the narcotic treatment program if it deems that the termination would be in the best interests of the health or safety of the patient and others, or the program finds any of the following conditions to exist:
(i) The patient has committed or threatened to commit acts of physical violence in or around the narcotic treatment program premises.
(ii) The patient possessed a controlled substance without a prescription or sold or distributed a controlled substance, in or around the narcotic treatment program premises.
(iii) The patient has been absent from the narcotic treatment program for 3 consecutive days or longer without cause.
(iv) The patient has failed to follow treatment plan objectives.
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Observations
The facility's policy and procedure for involuntary termination failed to include illicit possession or sale of a controlled substance in or around facility premises.
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Plan of Correction
Home Office has made necessary updates and changes to policies in question and these changes will be included in the next policy publication. 90 days for completion. Program Director will be responsible for follow-through. |
715.23(c)(1-7) LICENSURE Patient records
(c) An annual evaluation of each patient 's status shall be completed by the patient 's counselor and shall be reviewed, dated and signed by the medical director. The annual evaluation period shall start on the date of the patient 's admission to a narcotic treatment program and shall address the following areas:
(1) Employment, education and training.
(2) Legal standing.
(3) Substance abuse.
(4) Financial management abilities.
(5) Physical and emotional health.
(6) Fulfillment of treatment objectives.
(7) Family and community supports.
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Observations
The facility's medical director failed to review and document by dated signature the annual evaluations for patients #10, 11, 12, and 13.
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Plan of Correction
A computer error that does not show Medical Director's signature on reviewed documents will be corrected. Counselors will also be required to follow-up with incomplete paperwork. 30 days and on-going for completion. Clinical Supervisor will be responsible form implementation. |