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 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site inspection, Pinnacle Treatment Centers PA-V, Inc. was found not to be compliance with the applicable chapters of 28 PA Code which pertain to the facility. Deficiencies were identified during this inspection and a plan of correction is due on December 10, 2009.
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Plan of Correction
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715.14(a)(2) 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.
(2) If the narcotic treatment program determines that other drugs are abused in that narcotic treatment program 's locality or have been identified in the patient 's drug and alcohol history as being a drug of abuse or use, a narcotic treatment program may conduct a test or analysis for other drugs as well.
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Observations
Based on a review of patient records and policy and procedures, the facility failed to include drug-screen urinalysis testing for other abused drugs in three of nineteen patient records.
The findings include:
Nineteen patient records and the facility's policy and procedure manual were reviewed on November 2 - 3, 2009. Documentation in the patient record and policies regarding drug-screen urinalysis was reviewed. The facility failed to provide drug-screen urinalysis testing for three individuals who identified a history or current use of marijuana, patients 6, 10 and 11. The facility maintains a policy specific to an individual patient's drug history that indicated they would provide drug-screen urinalysis testing for other drugs known to be used by a patient.
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Plan of Correction
Although clients reported having used drugs of abuse, they were not always drug screened as a follow up. PTSA policy indicates that any patient who identifies having used or abused any substance shall be tested, at least on a monthly basis, for those substances. In this case, clients who admitted to marijuana use, either in the bio psych social history or during counseling, were not subsequently and regularly screened for the drug.
In order to correct this issue the Facility Director and the Medical Director will provide training to insure that counselors correctly identify and report all drugs being currently or previously used by clients. The counselors will be required to present a list of those clients and the drugs of abuse to the Facility Director on a monthly basis for inclusion in regular drug screening through urinalysis. The Facility Director will consult with the Medical Director related to this issue. The Facility Director will give the compiled list to the identified nursing staff to facilitate this process. The Facility Director will be responsible for ongoing compliance with this procedure.
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715.23(d) LICENSURE Patient records
(d) A narcotic treatment program shall prepare a treatment plan that outlines realistic short and long-term treatment goals which are mutually acceptable to the patient and the narcotic treatment program.
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Observations
Based on the review of patient records, the narcotic treatment program failed to document realistic short and long-term treatment goals in two of three patient records.
The findings include:
Nineteen patient records were reviewed November 2 - 3, 2009. Treatment plans with realistic short and long-term treatment goals were required in twelve patient records.
The narcotic treatment program did not document short and long-term goals that were individualized for the patient in patient records # 4, 7 and 13.
Patient # 4 had a current treatment plan to address "active opiate dependence". Drug-screen urinalysis results have indicated the patient had refrained from opiate use since induction into the methadone program (June 19, 2009). The treatment plan contained goals and objectives that were basic and similar to other treatment plans reviewed in other patient records and the treatment plan had not been updated to reflect patient progress in treatment.
Patient # 7 had a treatment plan that identified a goal to abstain from marijuana use. The action steps did not include any methods to verify that the patient abstained from marijuana usage nor were there treatment steps for the patient to follow.
Patient # 11 had a treatment plan that specified daily attendance in treatment. The patient had take-home privileges and reported one time weekly for dosing and had weekly take-home privileges.
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Plan of Correction
Counselors failed to document realistic short and long-term treatment goals in the treatment plans. In addition, there was a lack of individualization in some records and a failure to document progress related to the stated goals.
Currently, counselors use the Tower clinical system for treatment planning. Both the Project and Facility Directors have evaluated this tool and determined that it is insufficient to meet the needs of PTSA needs related to treatment planning policy.
As a result, PTSA will discontinue use of the automated treatment planning system and convert to a treatment planning form that is more conducive to individualization of the plan. The Facility Director will provide training related to this issue. Ongoing compliance with this requirement will be managed through direct supervision of counselors as well as through regular record review. The Facility Director will be responsible for consistent compliance and will provide additional training as needed.
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715.23(d)(1) LICENSURE Patient records
(d) A narcotic treatment program shall prepare a treatment plan that outlines realistic short and long-term treatment goals which are mutually acceptable to the patient and the narcotic treatment program.
(1) The treatment plan shall identify the behavioral tasks a patient shall perform to complete each short-term goal.
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Observations
Based on the review of patient records, the narcotic treatment program failed to document treatment plans that include support services in eight of twelve patient records.
The findings include:
Eighteen patient records were reviewed on November 2 - 3, 2009. Treatment plans, to include support services, were required in the twelve open patient records that were reviewed. The narcotic treatment program did not document support services in the treatment plan in patient records # 4, 5, 6, 7, 8, 9 10 and 11.
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Plan of Correction
The program inconsistently documented support services as part of the treatment plan.
Currently, counselors use the Tower clinical system for treatment planning. Both the Project and Facility Directors have evaluated this tool and determined that it is insufficient to meet the needs of PTSA needs related to treatment planning policy.
PTSA will discontinue use of the automated treatment planning system and convert to a treatment planning form that is more conducive to the inclusion of support services in the plan. The Facility Director will provide training related to this issue. Ongoing compliance with this requirement will be managed through direct supervision of counselors as well as through regular record review. The Facility Director will be responsible for consistent compliance and will provide additional training as needed.
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