Observations Based on the review of administrative documentation and patient records, the facility failed to ensure that the narcotic treatment physician was determining the patient's dose and schedule.
The findings include:
A on-site complaint investigation was conducted on April 26, 2012. Following a review of administrative documentation, that included a review of facility policy, and patient records it was determined the facility is utilizing a policy that prevents a patient from dosing. The policy that is currently used by the facility indicates that patients can be refused medication for failure to attend group sessions.
Interviews with staff and patients confirmed this policy and indicated patients have been refused medication for missed sessions.
Medication as ordered is determined for each patient, the dose is determined to be medically appropriate and it is to be administered as ordered. Withholding a patient dose for nonmedical reasons is prohibited.
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Plan of Correction The Medical Director and/or the Narcotic Treatment Physician is responsible for determining the patient's dose and schedule.
All non medical staff will be trained by 5/15/12 regarding the fact that holding of doses must be made by the Medical Director and or Program Physician for medical reasons.
The Program Director is responsible for ensuring that doses are not refused for non medical reasons.
Dosing that must be suspended due to medical reasons will be determined by the Medical Director or Narcotic Treatment Physician.
All persons who miss scheduled sessions will be referred to a manager to ensure placement in a make up group, where dosing will be administered after completion.
Members will be able to choose a make up session that is beneficial to them. The member will be dosed despite missed primary group.
Members continually missing services will be placed on a behavioral contract and the issue will also be addressed as a part of the treatment planning process.
Those who do not meet the terms of their contract, or do not meet treatment plan objectives, may be considered for involuntary transfer to another program.
Procedure formerly in place stated that members would be dosed after completion of primary service on a given day. Did not state that the dose would be refused. Program was not aware of state regulation that specifically stated that doses could not be suspended for non medical reasons.
Program is now aware and will adjust procedure as mentioned above.
Program Director will communicate new process to staff by 5/15/12. |