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Pennsylvania Department of Drug & Alcohol Programs
Inspection Results

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THE CONSORTIUM
451 UNIVERSITY AVENUE
PHILADELPHIA, PA 19104

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Survey conducted on 04/26/2012

INITIAL COMMENTS
 
This report is a result of an on-site complaint investigation conducted on April 26,2012 by staff from the Division of Drug and Alcohol Program Licensure. Based on the findings of the on-site complaint investigation, The Consortium was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during this investigation.
 
Plan of Correction

715.17(c)(1)(i-vi))  LICENSURE Medication control

(c) A narcotic treatment program shall develop and implement written policies and procedures regarding the medications used by patients which shall include, at a minimum: (1) Administration of medication. (i) A narcotic treatment physician shall determine the patient 's initial and subsequent dose and schedule. The physician shall communicate the initial and subsequent dose and schedule to the person responsible for the administration of medication. Each medication order and dosage change shall be written and signed by the narcotic treatment physician. (ii) An agent shall be administered or dispensed only by a practitioner licensed under the appropriate Federal and State laws to dispense agents to patients. (iii) Only authorized staff and patients who are receiving medication shall be permitted in the dispensing area. (iv) There shall be only one patient permitted at a dispensing station at any given time. (v) Each patient shall be observed when ingesting the agent. (vi) Administering and dispensing shall be conducted in a manner that protects the patient from disruption or annoyance from other individuals.
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.
 
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.

 
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