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A Comprehensive Evaluation of Georgia’s State Hospital Services Requested by and provided to: Division of Mental Health, Developmental Disabilities and Addictive Diseases Georgia Department of Human Resources Submitted by: Peter F. Buckley, MD and Nannette M. Lewis, MPH Project Co-Directors Department of Psychiatry and Health Behavior Medical College of Georgia December 2007 2 TABLE OF CONTENTS 1. Executive Summary ................................................................... Page 3 2. Background and Context ........................................................... Page 6 3. Survey Method...........................................................................Page 9 4. Survey Team Composition....................................................... Page 11 5. Individual Facility Reports ........................................................ Page 15 Savannah .............................................................................. Page 15 Atlanta ................................................................................... Page 20 ECRH Augusta...................................................................... Page 31 SWRH Columbus.................................................................. Page 44 CSH Milledgeville.................................................................. Page 55 NWRH Rome ........................................................................ Page 75 SWSH Thomasville ............................................................... Page 87 6. System Report ......................................................................... Page 95 7. Limitations of this Audit .......................................................... Page 117 8. Concluding Remarks.............................................................. Page 118 9. Bibliography ........................................................................... Page 120 3 EXECUTIVE SUMMARY The Department of Psychiatry and Health Behavior at the Medical College of Georgia (MCG) began discussions with the Division of Mental Health, Developmental Disabilities & Addictive Diseases (Division) within the Georgia Department of Human Resources (DHR) in late 2006 regarding the delivery of inpatient mental health services within the state institutions. MCG was requested to conduct an audit of each individual facility as a quality improvement process and to provide feedback recommendations on the provision of care in each facility and in the state hospital system as a whole. Prior to initiation of the site visits, MCG and the Division worked together to develop an audit tool, outline needs and desired outcomes, and define survey methods. In addition, MCG met with consumer and advocacy groups to hear global concerns on the delivery of care in the state hospitals. Facility audits began in March 2007 and continued through September 2007, with a frequency of one site visit per month. The reports on each facility were summarized into major categories to include: Chart Organization and Content, Programming, Physician Documentation, Medical Management of Patients, Quality Initiatives, Treatment Team/Treatment Planning, Safety and the Environment of Care, Staffing, Utilization Management, Seclusion and Restraint, Patient and Family Issues, Training and Staff Development, Risk Management and Nursing Practices. Findings specific to each hospital were made available to each facility within 30 days of the site visit, and were included in the primary reports. While the summary reports on each facility are included in this final system report, the main purpose of this document is to identify consistent findings, examine system-wide challenges and opportunities for improvement and make recommendations for organizational enhancement and development in the provision of care. This final system report contains over 40 specific recommendations. Many pertain to areas related to staffing issues, including the recruitment, retention and training of mental health professionals, staffing mix and staffing levels. Other recommendations involve programming, risk management and quality initiatives, charting and medical record maintenance, medical management, centralization, standardization, and patient and family issues. For convenience in reporting, in this Executive Summary, the major recommendations are divided into categories of clinical quality, administrative structure, and system resources. 4 Clinical Quality 1. The Division should develop quality initiatives in collaboration with consumers and providers; these initiatives should be positive and proactive, with benchmarks established by national standards. Action plans should be implemented by providers, and supported and monitored by management. Quality initiatives must contain components of education, networking, and technology and be organized and orchestrated throughout the Division, to create a culture of quality. 2. The system as a whole needs to embrace the recovery model, employing both patient advocates and peer specialists for staff education and enhancement of treatment programs. 3. The Division should incorporate informed patient-centered decision making as a standard of care across the system. This will require a system-wide policy, sufficient numbers of trained and competent staff, and a standardized practice of communication, collaboration and the participation of patients and family members on an individual and Advisory Board level. 4. The Division should continue full implementation of the MANDT system, with ongoing analysis of the need for alternative/additional resources for safe and effective patient/milieu management in the absence of seclusion/restraint interventions. 5. The Division should continue efforts to insure that active programming is being scheduled and provided both on the units and in the Treatment Malls, with an appropriate balance between therapeutic and recreational activities. 6. The Division should encourage the development of facility Medical Staff Bylaws that set standards for the qualifications expected for the level and type of care provided, including general, forensic, and child/adolescent credentials; the bylaws should also include provisions for the supervision of residents who provide on-call services. This should also support the strategic use of expert consultants from the community. 7. The Division should develop a comprehensive program for drug/alcohol treatment, including the recognition and treatment of medical complications commonly associated with substance use. Drug/alcohol treatment/education should be made available to all patients hospitalized for psychiatric reasons. 8. The Division should develop or strengthen affiliations with state medical schools and universities to provide training and education about best practices in recognition, early detection and treatment of medical conditions, and especially to support recruitment and retention. 9. The Division should provide central office medical resources for expedited and thorough investigations of critical incidents. Analysis of trends and patterns of these incidents should lead to the design and implementation of risk reduction strategies based on the results. 10. The Division should continue to pursue best practices in the use of medications and in the monitoring of their effects. 5 Administrative Structures 1. The Division should create a positive culture and an affirmative work environment in the facilities through supportive supervision, constructive mentoring and a collaborative work relationship with hospital-level administrators and mid-level managers. 2. The Division should create 3-4 state-level associate medical director positions to focus on key areas such as forensics, medical oversight, risk management, developmental disabilities, child/adolescent, etc. 3. The Division should develop and implement a standard format and organization for all hospital medical records. This effort should be completed in a timely manner and be a joint effort between Central Office and the facilities. The Division should also investigate the use of new technologies and set a target date for the implementation of a fully electronic medical record. 4. The Division should adhere to a system-wide Policy and Procedure Manual that has been developed and approved by the Division and all Hospitals; this manual should provide broad guidelines for important areas and should not be highly detailed System Resources 1. The Division should conduct a comprehensive salary survey to determine current salary scales for all professional staff, followed by a restructuring of salaries to 70th percentile – 80the percentile within the regional market scales. 2. The Division should employ its own professional recruiters to attend national conventions and meetings to seek out and attract professionals whose interests include inpatient treatment. 3. The Division should conduct a thorough analysis of the salary, education, and training requirements of the Health Science Technician in order to make them comparable to the job responsibilities and risk factors associated with this position. 4. The Division should ensure that each facility have a sufficient number of qualified, board-certified primary care physicians, with at least one at each site, to provide consulting and routine medical care for psychiatric inpatients. In facilities with significant DD populations, primary care physicians may act as the primary attending for DD patients, with psychiatric consultation; these facilities will require additional primary care physicians to meet the demands of this challenging role as well as the more typical consultation role for psychiatric patients. The development, implementation, and delivery of this audit required the input, cooperation, and support of many individuals, groups and organizations. It is intended to provide a framework for many constituents to contribute to the successful improvement of the system, and to support the Division’s commitment to quality improvement and enhancement of the delivery of care to those in Georgia in need of public mental health services. 6 BACKGROUND AND CONTEXT The Georgia Department of Human Resources, Division of Mental Health, Developmental Disabilities, and Addictive Diseases (Division) is the provider for Georgians in need of public mental health services. Inpatient acute care is provided at seven facilities, which are geographically-based to serve the diverse rural and metropolitan population of the state. All facilities provide adult inpatient services, both acute and long term. Some facilities also provide acute inpatient care for disturbed children and adolescents. Furthermore, specialized services within some of these facilities include inpatient forensics, long-term care for individuals with developmental disabilities, and the management of complex dual diagnosis situations. The inpatient population served constitutes a disadvantaged sector of our community. Clinically, this population is characterized by severe mental illness, (predominantly psychotic disorders and mood disorders), inordinately high rates of co-morbid physical illnesses and poor psychosocial supports. Admissions to the state facilities are often precipitated by injurious behaviors to self or others and are frequently complicated by abuse/dependence on alcohol or illicit drugs. As a subgroup of all psychiatric patients who receive public mental health services, inpatients are a particularly challenging patient group. Clinical complexities of treatment include management of suicidal and aggressive behaviors, detection and management of co-morbid substance abuse problems, detection and management of co-morbid medical conditions, appropriate prescription and monitoring of psychiatric medications and appropriate prescription and monitoring of non-psychiatric medications. These same clinical complexities arise and are amplified further in the specialty populations of disturbed youth, forensics and developmentally disabled. Service complexities that are associated with the provision of care in such patient populations include the adequate assessment and support services for physical illnesses, the requirements for comprehensive multidisciplinary care with attention to both medical and psychiatric health needs, requirements for effective communication and skilled documentation among several levels of healthcare professionals, and the importance of integrated (medical-psychiatric), and coordinated (inpatient-to-outpatient) treatment planning. The seven state hospitals operate within their regions and each has its Medical Director and Hospital Administrator, with centralized oversight of services jointly through the office of quality assurance and the Division Medical Director's office. Ongoing discussions began in late 2006 with the Department of Psychiatry and Health Behavior at MCG, focusing on the advantage of a timely, independent and external evaluation of clinical care throughout the system. The goal of the evaluation was to carefully examine medical and psychiatric care in the state hospitals, as well as the processes for integrating and monitoring this care. An 7 audit conducted at each hospital would allow an evaluation of individual facilities, with immediate reports of observations and findings. The additional value of a seven-facility coordinated survey, however, would be the ability to make systemwide comments and recommendations, to identify strengths found within the system and to address common opportunities for improvement. Though part of a larger system, each hospital was unique, as each varied significantly in size, services, populations served and catchment areas. It is helpful to understand these variances to fully appreciate individual facility and system challenges and recommendations. Georgia Regional Hospital of Savannah is the smallest of the seven facilities, with approximately 100 beds, and is one of two state facilities that does not serve the developmentally disabled (DD) population. It has three distinct units, consisting of a short and long term acute adult mental health unit and a forensic unit. The facility had a very high census on the initial day of the audit, as the acute unit was over capacity and another 14 additional acute “boarders” had been added to the long-term unit. Georgia Regional Hospital - Atlanta has approximately 350 beds in eight distinct units. Approximately 120 Adult Mental Health beds are divided between three units, one of which is designated for longer-term stays. All of these units are typically over capacity. The Adolescent Acute Unit, one of only two in the state, has 28 beds. Two Forensic Units house 90 beds. The remaining beds are divided between two units serving the developmentally disabled (DD), one of which is a Skilled Nursing Facility (SNF). In terms of admissions, the Atlanta hospital is the busiest in the state. East Central Regional Hospital in Augusta, the second largest facility in the state, has over 600 beds, most dedicated to management of the developmentally disabled. The hospital is divided between two campuses, the Gracewood and Augusta campus. Gracewood beds are exclusively for the developmentally disabled and are located in three buildings, Birch, Redbud and Camellia. These are further divided into 5-6 units of about 20 individuals each. Patients are grouped by level of functioning and required care. Camellia houses those with the greatest physical needs in two Skilled Nursing Units. The Magnolia, Holly and Spruce Buildings on the Augusta Campus make up the 100 bed Azalea treatment center for developmentally disabled. The Forensic Unit adds 52 beds and the Adult Mental Health Unit has 64 beds. West Central Regional Hospital in Columbus has just under 150 beds and is one of two state facilities that has no beds dedicated to developmentally disabled patients. It is separated into four units: a 40 bed forensic unit, two short-term mental health units and one longer term mental health unit which also houses overflow forensic patients. On the day of the audit, the facility was over capacity 8 and was preparing to go on diversion if more admissions presented. In less than one month from the date of the survey, there were plans to expand forensic beds, reduce Adult Mental Health beds, and open a crisis stabilization unit. Central State Hospital in Milledgeville is the largest facility with over 800 beds. Approximately 200 Forensic beds are divided between two buildings: Freeman, a secured unit, and Binion, the only maximum security unit in the state. There are approximately 100 adult mental health beds located in the Powell Building, and approximately 30 child/adolescent beds in the Crittenden Building. The Craig Center is a long term treatment center with nearly 200 medically compromised patients, some receiving skilled nursing care, others receiving intermediate care. These patients may have a psychiatric diagnosis, may have dementia, or may be developmentally disabled, but their physical infirmities make medical/nursing needs their priority. The remaining approximate 350 beds are for the developmentally disabled and are divided between Allen Hall, Phoenix Center, Pecan Manor and Piedmont Hall. Northwest Regional Hospital in Rome serves three populations: Adult Mental Health, Forensic and the developmentally disabled. AMH beds number slightly less than 100 and are divided between two units. The Forensic population is on one unit of approximately 55 beds, and the remaining four units hold just over 100 beds for the developmentally disabled. Southwest Regional Hospital in Thomasville is primarily a facility for the developmentally disabled, with over 150 beds for this population. Approximately 50 of these beds are for higher functioning patients and are being phased out as placements become available in the community. Rosehaven treats those that have severe medical challenges, and some beds are designated as SNF (skilled nursing), while others are designated as an ICF (intermediate care facility). SWRH has a limited Forensic unit with only 19 beds, and another unit with approximately 50 beds for adult mental health. The census on these units is consistently at capacity. 9 SURVEY METHOD Prior to the initial hospital visits, several planning meetings were held with the Division to understand its needs, clarify the desired outcomes and define the survey methods. In collaboration with the Division, a comprehensive evaluation tool was designed that would be used by the team members to standardize the method and guide them through each hospital visit. The tool focused on certain aspects of patient care, particularly, assessments, the identification, treatment, and follow-up of medical issues, seclusion and restraint, treatment plans, the provision of care, quality improvement and patient safety management. Each survey team member was assigned specific items to evaluate in clinical documentation, through staff and leadership interview, and by review of other hospital records. To insure a broad view and to address the concerns of consumers, consumer families, and advocacy groups, pre-audit meetings were also held with representatives of NAMI and other consumer groups. Before each facility visit and survey, team members were briefed and reminded of the global issues that were identified by these groups. In addition, specific recommendations such as speaking directly with patients and meeting with staff members away from management were incorporated into the survey method. Prior to each audit, the survey team worked closely with each facility to obtain information and coordinate the schedule for the visit. Hospital staff members were extremely cooperative and helpful in providing a comprehensive packet of information, which included policy and procedures, chart forms and documents, staffing patterns, organizational charts, job descriptions and other specific information regarding hospital operations. The audit schedule at each facility was generally consistent in nature, but was customized to fit the unique structure, services and composition of each hospital. Most facilities received a two-day audit; Central State in Milledgeville and East Central in Augusta received three-day audits due to their larger size and complexities. In general, the survey process included: 1. Pre-audit information review. The information provided by the hospital prior to the audit was reviewed, organized, and copied for each team member. 2. A pre-audit team meeting. Team members discussed the pre-audit information packet and reviewed the audit tool. Updates and Individual surveyor assignments were also made at this time. 3. An opening day meeting. The survey team met with hospital clinical and management team for introductions and general hospital overview. 4. Daily Survey agenda, which included: A. Chart Review. Charts were reviewed on all units by at least two team members. Comprehensive reviews were conducted as well as cursory reviews related to certain issues or tracers. 10 B. Staff Interviews. Staff interviewed included Nursing Executives and Management, Physicians, line staff on units including Nurses and Health Science Technicians, Safety Officer, Patient Advocate, Peer Specialists, Human Resource Director, Pharmacist, UR Coordinator, Risk Manager and Performance Improvement Coordinator. In general, both front-line staff and management were supportive of the survey and were eager to provide information and receive comments and feedback. C. Patient Interviews. D. Further review of documents expanding to meeting minutes and Quality Improvement Activities. E. Treatment Team Attendance. F. Unit visitation to observe the treatment environment, milieu, and programming. The clinicians tried to spend as much time as possible on the units, actually conducting their chart reviews in the nursing station in order to observe staff-staff and staff-patient interactions. The Admissions area, 23-hour observation unit and the Treatment Mall were also visited. 5. At the conclusion of each day, a mid-survey summary was presented by the survey team to Hospital Management to report initial findings, plan the next day schedule and make mid-survey requests for additional information. 6. The survey team then met privately to review the day’s audit results, share general impressions, and refocus individual assignments based upon progress and findings of the day. 7. Wrap-up with Survey Team and Clinical/Management Team to review findings and give immediate feedback of significant issues. 8. Compilation of findings of individual surveyors into summarized report. 9. Submission of written survey report. The survey report of individual facilities submitted within 30 days of the visit served as an “Interim Report” or a component of the final analysis and report on the entire system. 10. In some cases, an action plan addressing the individual hospital findings and recommendations were submitted back to MCG Department of Psychiatry. 11 SURVEY TEAM COMPOSITION The MCG Department of Psychiatry policy and procedure team will be carefully selected to provide a depth and variety of experience and knowledge specific to this task. All members will be external to the system so that there will be no conflict of interest enabling them to provide objective appraisals of policies and procedures. The psychiatric physician on each hospital survey team was a Medical Director of an out-of-state hospital or system with added qualifications and experience pertinent to the specific population of their assigned hospital. Each site was visited by a team consisting of one to two board-certified psychiatrists with additional certifications in Forensic Psychiatry and/or Child Psychiatry, another physician board-certified in Family Medicine with additional qualifications in Psychiatry, geriatrics, and substance abuse, one to three Registered Nurses, one of which was also a Qualified Mental Retardation Professional (QMRP), and an Administrative Team Leader. The composition of each team to review selected policies will be proportionate and appropriate to the scope and focus of each policy. Project Co-Director Peter F. Buckley, MD Peter F. Buckley, MD, is Professor and Chairman of the Department of Psychiatry and Health Behavior at the Medical College of Georgia in Augusta. An expert in the treatment of serious mental illness, Dr. Buckley provides clinical care and conducts research on the treatment of schizophrenia. While previously Vice Chair at Case Western Reserve University in Cleveland, Ohio, he served as Medical Director for the adult state psychiatric services for Cleveland and Toledo. During his tenure as Medical Director, this system was voted Best Hospital in Ohio and received Joint Commission commendation with eleven Best Practices. Dr. Buckley is on the board of several professional organizations, is a member of the scientific Board of the National Alliance for the Mentally Ill, was a member of Georgia’s recent gubernatorial task for mental health, and is listed in Best Doctors of America. He is the recipient of several awards for his work, including an Exemplary Psychiatrist Award from the National Alliance for the Mentally Ill, and the Psychiatrist of the Year award from the Georgia Psychiatric Physicians Association. Dr. Buckley is also the recipient of the American Psychiatric Association Administrative Psychiatric Award for this work on state-university collaborations. Project Co-Director and Team Administrative Leader Nan Lewis, MPH Ms. Nan Lewis is a Senior Mental Health Administrator with over fifteen years of 12 leadership experience in public and private sectors of the mental health system. Ms. Lewis was Administrative Director for the Department of Psychiatry and Health Behavior at the Medical College of Georgia, transforming this service from a failing program to the major inpatient/outpatient service in Augusta. Prior to that, Ms. Lewis served as Chief Executive Officer at two private hospitals in North and South Carolina, and served in several administrative positions for Charter Behavioral Health System. In North Carolina, Ms. Lewis worked with the state to establish the first private inpatient unit for the developmentally disabled/mentally ill to divert admissions from state institutions. Also in cooperation with the State of North Carolina, she opened a residential treatment program for juvenile sex offenders to provide an alternative to incarceration. Ms. Lewis is on the Board of the Augusta Chapter of the National Alliance for the Mentally Ill. Prior to her mental health administrative career, Ms. Lewis was a Laboratory Technologist, and also holds a degree in Medical Technology. Team Physician – Family Medicine: Dean Harrell, MD Dean Harrell, MD, is Assistant Professor in the Department of Medicine at the Medical College of Georgia and is also an attending inpatient geriatric psychiatrist in the Department of Psychiatry and Health Behavior. He also provides expert consultation on physical co-morbidity among psychiatric inpatients at MCG. Dr. Harrell is board-certified in Family Medicine, with added qualifications in geriatrics. He is also trained and is board -eligible in Psychiatry. In addition to extensive experience as a geriatric internist with a subspecialty focus in psychiatry, Dr. Harrell has previously worked as a substance abuse counselor. Dr. Harrell is a Fellow of the American Academy of Family Medicine. Team Physician – Psychiatry: George P. Parker, MD George P. Parker, MD, is currently Associate Professor of Clinical Psychiatry and Director of Forensic Psychiatry in the Department of Psychiatry at Indiana University School of Medicine in Indianapolis, and Medical Director for the Indiana Division of Mental Health and Addiction. Before joining the Indiana University School of Medicine in Indianapolis, Dr. Parker was Assistant Professor of Psychiatry at Case Western Reserve University School of Medicine in Cleveland, Ohio, and Medical Director of Northcoast Behavioral Healthcare Systems in Ohio, the state hospital system that serves all of northern Ohio via three state psychiatric hospitals. He is a professional member of NAMI and is active with NAMI-Indiana. Dr. Parker is board-certified in General Psychiatry and Forensic Psychiatry. He has received certification by the National Board of Medical Examiners as a 13 Diplomate, and served as an examiner for the American Board of Psychiatry and Neurology. Dr. Parker also received a certification in Mental Health Executive Leadership from the Weatherhead School of Business Administration at Case Western Reserve University Team Physician – Psychiatry: Marion Sherman, MD, DFAPA, MBA Dr. Sherman is currently the Chief Clinical Officer of Twin Valley Behavioral Healthcare/Columbus Campus, and is on the clinical faculty of Ohio State University and Ohio University. Prior to her appointments in Ohio, she served as Clinical Director of Child and Adolescent Services at the University of Utah Neuropsychiatric Institute, and was on the clinical faculty of the University of Utah Medical School in Salt Lake City. Dr. Sherman is board-certified in general psychiatry, child/adolescent psychiatry, and forensic psychiatry by the American Board of Psychiatry and Neurology. She is a member of the American Psychiatric Association, NAMI and the Ohio Psychiatric Association, where she currently serves as President. She has been awarded the “Exemplary Psychiatrist of Ohio” by NAMI Ohio, and was featured in the 2004 Joint Commission “Spotlight on Success.” Team Physician – Psychiatry: Douglas A. Smith, MD Dr. Smith is currently the Medical Director of Northcoast Behavioral Healthcare in Ohio, which includes three psychiatric hospitals offering inpatient adult and forensic services and outpatient programs. He is also an associate professor at the University of Toledo and Case Western Reserve University School of Medicine. Dr. Smith is active at the Toledo Correctional Institute, where he performs assessments and treats the mentally ill. Dr. Smith is board-certified in General Psychiatry and Forensic Psychiatry. Dr. Smith received a certification in Mental Health Executive Leadership from the Weatherhead School of Business Administration at Case Western Reserve University. He serves as a Medical Advisor to NAMI of greater Cleveland. Team Nurse: Patricia W. Coppett, RN, BS, MBA Ms. Patricia Coppett is County Nurse Manager for Richmond County Health Department in Augusta, Georgia. Ms. Coppett has over twenty years of behavioral health care experience in the chronic, acute, forensic, residential and community settings. She has worked with adults, children and adolescents as a program manager and as a direct care provider. Ms. Coppett is a leading community advocate and has served on the Board of the Augusta Chapter of the 14 National Alliance for the Mentally Ill. Ms. Coppett is currently enrolled in the Nurse Practitioner program at Georgia Southern University. Team Nurse: Janis Krauss, RN, BSN, MSQA Ms. Krauss most recently served for six years as Clinical Decision Support Analyst in Outcomes Management at the Medical College of Georgia. Prior to that, she worked on the Behavioral Health Unit at University Hospital in Augusta for approximately 10 years, in both management and staff positions. Her nursing experience has also included medical/surgical care, including neurology, intensive care and emergency. In addition to her Masters Degree in Quality Assurance, Ms. Krauss received a Certificate in Health Care Evaluation in Health Services Research offered by the Department of Medicine at MCG. Team Nurse: Alicia Wright, BSN Ms. Wright is currently the Family Health Nurse Coordinator at the Richmond County Health Department in Augusta, Georgia. Her 20-year nursing career includes eight years in mental health and addictive disease caring for children and adolescents, adults and geriatrics in an inpatient setting. She has served in direct care and management roles, and has also performed as a healthcare educator for both patients and nursing students. Team Nurse: Linda Wright, RN, BSN Linda Wright has over thirty years experience in Mental Health with the majority of it in state hospital settings. While most of her experience has been with the developmentally disabled, Ms. Wright also has also worked with the forensic, med-psych and geriatric populations. Ms. Wright is a QMRP, and has performed in both direct care and management roles in state hospitals. Her management duties included nursing and service line supervision for the dually diagnosed mentally ill and developmentally disabled. For approximately five years, Ms. Wright served as Quality Accreditation Manager for the Division of Mental Health and Addiction in Indiana, where she was responsible for quality improvement, accreditation and certification, and outcome measures. Currently, Ms. Wright works for a pharmaceutical company as an expert clinical resource. 15 REGIONAL HOSPITALS - INDIVIDUAL REPORTS To better appreciate the scope and depth of the system report, both a brief description of each facility and their individual audit reports are included below. Some of the issues identified in the individual reports are significant and deserve attention, yet they are not referenced in the final system report as they were not found to be universal or consistent throughout the survey. It is worth comment that during the course of the audit, as changes in practices resulting from survey recommendations and accompanying corrective action plans were adopted, the system communicated these changes in practices to other facilities. This was evidenced by the shift in practices that was noted in subsequent hospitals as they incorporated previous survey recommendations into their operations. It was gratifying to see this beneficial effect occur from hospital to hospital. This was also a reason why individual hospital reports were readily available quickly after each hospital audit. Also of note is that a relatively standardized format for reporting was used to facilitate the comparison of the hospitals, enhance the communication of findings, and facilitate the compilation of the final system report. Findings are divided by general area, including chart organization and content, programming, physician documentation, medical management, quality initiatives, treatment team/treatment planning, safety and environment of care, staffing, risk management, utilization management, patient/family issues, seclusion and restraint, safety and the environment of care. Below is a synopsis of findings and recommendations from the audit of each facility. The individual audit report for the facilities covers each of these aspects in greater detail, including illustrative situations [this level of detail would be extraneous and unnecessarily duplicative to be included for this report]. GRH - SAVANNAH 1. Chart Organization and Content– Findings: Charts were inconsistent in order and content, making it difficult to locate information and follow patient progress. This could contribute to other noted problems below, such as follow-up of medical issues. Some forms seemed excessive and repetitive, making information voluminous rather than succinct and user friendly. Many required forms, such as consents for medication or treatment, Advance Directives, and HIPAA forms, were missing or unable to be located in some charts. Consent forms were improperly used, for example, competence of patient signing forms either not addressed or patient signing is clearly incompetent. Consent for medication forms allow multiple medications on one sheet, allowing the possibility of meds to be added after signature is obtained. Improper corrections of errors, such as white-out or blackout, or changes lacking date or initials, were also noted. Family involvement 16 was never noted anywhere in chart, from admission, through treatment, to discharge. Recommendations: a. Review standard chart forms, chart order and organization. b. Educate staff on proper correction of errors in the medical record c. Use one consent form per medication administered. 2. Programming – Findings: Although Program schedules existed, it was not evident by observation or by chart documentation that it was actually occurring. The Treatment Mall was beneficial in dispersing the patient population and providing another environment for them, but programming there appeared to be optional, and many patients were seen outside socializing rather than participating in structured activities. A new QI study tracking scheduled vs. actual activities had begun two weeks prior, and although results were positive, further investigation showed that scheduled activities may include recreational past times such as movies or bingo. Activity therapists provide the major component of programming, and although recreational activities are useful for patient management and can also be beneficial to the patient, they should not replace therapeutic or educational groups. Chart documentation typically tracked where patient was rather than activity they were involved in and participation in groups such as AA were not charted at all. Recommendations: a) Improve documentation to better reflect therapies, activities and level of participation of patients, taking credit for services that are delivered. b) Adjust audit currently in progress to separate therapeutic activities from recreational activities to better reflect care being delivered to patients. c) Maximize use of the Treatment Mall to address different population needs. 3. Physician Documentation – Findings: Many physician notes were limited in length and detail, and generally uninformative. Physicians, including the Clinical Director, verbalized difficulty in meeting requirement of 5 notes/week/patient. It appeared that though the total number of attending physicians for the hospital appeared reasonable, the caseload of physicians on the acute unit seemed high, and may indeed contribute to this problem. This impression is supported by variability between units on quality of notes. Significant issues such as response to medication, rationale for medication changes, justification for seclusion orders and multiple medication use and patient progress on treatment goals, were sometimes absent or inadequately addressed. On-call physicians sometimes saw patients without documenting the visit. One physician routinely had PA students or medical students documenting for him, signing off on their note. 17 Recommendations: Suggest review and revision of statewide form for physician progress notes; as it stands now, there is little room for discussion of treatment decisions or for extended details of assessment. Need to investigate regulatory requirements and appropriateness of third-party documentation for physicians. Require documentation by on-call physicians. May also re-examine and evaluate case loads of physicians on the acute unit to determine if documentation and treatment expectations are reasonable. 4. Medical Management – Findings: Lack of follow-up of medical issues consistently appeared in charts. Most significant was the number of issues identified in just a sampling of charts, and although some of these issues were inconsequential, others had the potential to lead to serious medical complications. Included were such issues as lack of follow-up of patient status or conditions identified on admission (i.e. head injury, bandaged arm), results of lab and diagnostic tests (i.e. abnormal blood sugars, LFTs, CPK, thyroid studies, and mammograms), new diagnoses made without further work-up (i.e. dementia), positive reports on pain scales, and previous medical conditions left unaddressed. The problem was not attributable to merely oversight, as many conditions were originally documented or initialed by the physician. In addition to lack of medical follow-up, some established procedures (or lack thereof) were not best practice. For example, there seemed to be no clear established detoxification protocols, and risk of withdrawal/detoxification was not documented or discussed in charts of patients with substance abuse issues. Intramuscular (IM) PRNs are routinely written and administered without physician assessment. This could be interpreted as a procedure allowing an agitated patient to be “restrained” without physician notification. There did not seem to be routine review by a pharmacist for polypharmacy, contraindications or food/drug interactions. Polypharmacy did not appear to be widespread in charts reviewed, but where it was used there was little to no justification to support the practice. There is no place on the physician admission form for current medications on admission, and often this information was missing or not located. Having it on the physician admission form may also be a useful prompt for admission medication orders. Some practices were not consistent with established policy and procedure, for example, UR policy requires extended stay administrative and clinical review. Staff verbalized that it was happening in Treatment Team and in Administrative Daily Briefings, but it is not well documented. And although current Seclusion and Restraint (S&R) practice meets established guidelines, policy does not (staff stated that policy is up for review and will be changed). 18 Recommendations: Suggested methods include but may not be limited to: a) Keep this a priority issue when addressing chart organization recommendation (#5 below), as this may contribute to this problem. b) Consider redistributing caseloads of physicians. c) Examine role of primary care staff physician in coordinating patient care with the attending psychiatrists, clearly define performance expectations, responsibility as a member of the treatment team, and communication methods for handling both referrals to and recommendations from. d) Set up a check-and-balance system so that diagnostic test results are followed up on. e) Establish a QI study for continued monitoring and follow-up on action plan results. f) Use Treatment Teams to enhance communication and follow-up of patient care issues. g) Attempt to increase family communication and involvement in treatment to obtain a clearer picture of patient history, condition, and response to treatment. h) Review and revise as appropriate policies dealing with S&R and the use of PRN-IMs. i) Develop policies on detoxification protocols and establish guidelines for the identification and management of risk of withdrawal. j) Review and establish policies on pharmacist involvement in medication order review. k) Develop methods to insure obtaining a list of current medications at time of admission with physician review. 5. Follow-through on Quality Initiatives – Findings: The number of quality initiatives underway was impressive, with committees such as P&T, Safety, Client Rights and HR conducting studies as well as hospital-wide initiatives related to patient care. Data comparison with other hospitals was also evident, with benchmarks and goals recorded and tracked. Administrative support for these efforts was clear, with the Hospital Administrator participating on many levels in the initiatives. Some initiatives ended with data collection, however, and through further analysis, plans of action, and/or recheck of areas of needed improvement or identified problems were absent. Some responses and actions were able to be verbalized, but there was not a paper trail recording progress. For example, surveyor noted from medication error tracking that the predominance of errors was occurring on second shift, but this trend appeared to be unobserved. Many results, including client assaults, falls and injury rates, which did not meet benchmarks, had actions documented in minutes as “deferred.” Follow-through on significant problems or issues such as abuse complaints or sentinel events was not evident in quality documents. 19 Recommendations: a) Ensure that minutes of meetings that address quality issues flow from month to month, with action plan results recorded and addressed until closure. b) Avoid “deferred” as an action plan. c) Make sure that all data that is collected is analyzed, and not just recorded for the sake of recording. d) Remember that just as in chart documentation - what is not documented did not happen – so take credit for what has happened by documenting in meeting minutes and QI records. 6. Treatment Team – All treatment teams attended were organized, respectful and relaxed, with attendance by physician, staff and patient. Unit 5 had a very interactive treatment team. Unit 6’s treatment team was more physician driven, with limited input by other staff, and chart seemed to be passed around for signature with limited discussion. Orders and privileges were changed to reflect current patient status. 7. Physical Environment – Findings: GRH-S is challenged by being a smaller facility with a high census, and therefore has a mix of diagnoses, acuity levels and patient populations in a single milieu with limited space. The acute unit typically overflows to the long term unit. Consistently, there are developmentally disabled and substance abuse patients experiencing detoxification mixed with varying acuity levels of Mental Health Patients, making it difficult to meet all the needs of a very diverse population. Staff and physicians both expressed frustrations with both high census and patients with mental retardation (MR) or substance abuse (SA) as the primary diagnosis still being admitted. The physical environment was more challenging on the acute unit than the longer stay units, which were brighter, calmer and had better sightlines. With this consideration, the staff on the acute unit is to be commended for maintaining order on a very busy day. The security on the forensic unit was consistent and appropriate without being intrusive. With over census being a consistent issue, cots are routinely used for sleeping, creating both a privacy and comfort issue. A safety issue of removable telephone cords of potentially dangerous length was noted on every unit. Interviews with patients did not reveal any grievances. Recommendations: Remove telephone cords on patient units. Suggest replacing with short metal cords (as found in typical public telephone booths) which are not removable. 8. Staffing – Findings: All staff interviewed seemed to enjoy and be committed to their jobs. There seemed to be good staff attitude and morale. On a record high census day, line staff was not only managing very well on what could have been a very chaotic unit, but also took time to respectfully greet and welcome us. This was also evident on the unit in the interaction with patients and control of the milieu. 20 The impressive low utilization of Seclusion and Restraint also is a strong sign of awareness, involvement and skill in managing a difficult environment. When problems and “wish list” solutions were solicited from staff, most provided very productive responses and reasonable expectations for change. These suggestions included enhanced training for Health Service Technicians, improved programming on units, education on how to handle mentally retarded patients and training on methods to prevent/address client-client and client-staff assaults. Hospital Administration, management and staff and physicians were receptive to our observations and input, and seemed appreciative of our visit and comments. A sense of frustration was most evident from the medical staff, however, in attaining goals and expectations set for them. Nursing staffing seemed inconsistent, with what appeared to be extreme day-today swings in number of staff. Notably, weekend staffing appears to be significantly lower than weekday. As with physicians, the total number of social workers seemed adequate, but with perhaps a disproportionate workload on the acute unit. This may impact functions such as discharge planning, therapeutic programming, and family involvement with treatment, all identified as opportunities for improvement. Role/use of psychologists was not evident in chart documentation, observed programming or staff interviews. Recommendations: As with physicians, look at caseloads of Social Workers on Acute vs. the other two units, which could positively impact discharge process (and consequently readmission rates), family involvement in treatment and programming. 9. Training/Staff Development – The MANDT program is comprehensive and effective as evidenced by the low number of Seclusions and Restraints. The number of days spent in orientation for new employees allows for thorough review and training in hospital procedures. GRH - ATLANTA 1. Developmentally Disabled Units (DLC and SNF) – Findings: Impressions from both the RN and physician team members on these units were extremely favorable. The facilities were bright, appealing and very clean. Patients were dressed and well cared for. Staff members expressed job satisfaction, and were warm and caring in their delivery of care. Charts were well organized, documentation was excellent and included several specialized assessment tools. Medical problems appeared to be quickly addressed, including follow-up of abnormal lab values. Pharmacy completes a comprehensive medication review. The physician was commended as wonderfully dedicated to her patients, an extremely challenging and difficult population. Families were formally invited to participate by written invitation to quarterly nursing assessment meetings. These two units did not seem to share 21 the problems or concerns of the rest of the facility, or at least they were not as significant an issue, and are not included in most of the following notations. 2. Chart Organization and Content– Findings: Charts of patients with longer length of stays (East and Forensic) were routinely and completely purged prior to certain dates, and stored off unit in separate records. This process seemed random and not dictated by defined methods or policy. For example, some charts had all information prior to dates as recent as March 2007 completely removed, and information critical to patient care, such as the original history and physical examination, were no longer in the record. On the shorter term units, completed forms and/or documentation belonging in the chart were often not found, and staff had difficulty locating these in loose filing. In one case, a seclusion and restraint record was over a week old, but was not in the chart. The format of some of the preprinted forms contributed to excess paper in the chart, containing good informational prompts, but spread out more than it needed to be. On the Physician Psychiatric assessment, there is no “Formulation Section” which is where the documentation should support the treatment. Abbreviations were found in a physician order that nursing was unable to interpret. It was unclear whether staff was uninformed about approved abbreviations, or if these were not on the hospital approved list. Recommendations: a) Review and/or revise policies related to purging current records to insure that pertinent information remains on the active chart. This process should be defined and completed by Medical Records staff. b) Review loose filing responsibilities and practices, set timelines for inclusion of records in charts. For seclusion and restraint records, review forms the following day IN the record during treatment team to monitor compliance. c) Review format of preprinted forms to consolidate and better present information and reduce excess paper. Evaluate need for Formulation Section on the Physician Psychiatric assessment. d) Review hospital abbreviation lists, educate staff and physicians on approved abbreviations, and enforce compliance. 3. Programming – Findings: The activities building was visited by two survey team members, once in the morning and once in the afternoon. The schedule was posted on the wall and allowed for more than one activity to be occurring at any one time. A staff member was questioned about designations on the chart which appeared to be what discipline was leading each activity, but she was unable to interpret. In the morning, the surveyor noted a group of patients being led outside to participate in an activity, and though arriving in the middle of a scheduled group session, 22 another staff member appeared to be just getting started with another group of patients seated at tables. In the afternoon, the second surveyor noted a few patients playing basketball, but the majority of them were sitting around. Unit program schedules were reviewed, and a selection of activities was provided for most time slots throughout the day. In theory, this allows patients choice and also provides activities for patients with different levels of functioning. In practice, it appeared that patients elect the diversional activity more often than not. Patient on the Forensic Unit complained about inconsistency in program schedules, and that they changed frequently. Substance abuse programming was noted on the West and Central Adult Unit schedules, but the charts of patients with substance abuse listed as a diagnosis lacked substance abuse groups or treatment documentation. This could be due to patients electing not to attend, or due to poor documentation. Substance abuse groups were not noted as being offered on the adolescent program schedule. Structured classroom time appeared not to be offered on the Adolescent schedule, but rather optional “Independent Study” time, which may or may not provide adequate supervision for students to stay current in school work while hospitalized. It was not noted whether a teacher is employed by the hospital to oversee or coordinate school work. Activity Therapy does a good job with chart documentation of groups and activities, with forms being both informative and efficient for therapist to complete. Recommendations: a) Ensure that staff understands posted schedules, and that there is an expectation that groups begin on time. Evaluate the efficiency and effectiveness of providing multiple groups at one time, allowing patients to opt out for diversional activities rather than therapeutic. Chart documentation should reflect groups attended. b) Add substance abuse groups to the Adolescent Program schedule. Even if patients do not have diagnoses of substance abuse, adolescents could benefit from drug education and awareness. c) Adolescents are greatly defined and affected by their school performance, and educational interruption due to their hospitalization should be minimized as much as possible. Education and school coordination should be a priority during their treatment 4. Physician Documentation – Findings: Physicians were not meeting the stated new requirement of 5 out of 7 days daily progress notes (note that Medical Staff Rules and Regulations state two different standards). There was inconsistency in what type of progress note was being used, sometimes the computerized version, sometimes handwritten. 23 The form does not allow adequate space for complex problems when used manually, and therefore is often illegible. Many notes are also deficient in useful information on patient status and progress. Several forms requiring physician signature were found unsigned, including MD verbal orders, seclusion orders, seclusion and restraint review forms and involuntary commitment records. Physical examinations were found to be late, scanty, or blank in 50% of the charts reviewed by the psychiatric surveyor. Polypharmacy or comorbid psychotropics, were not always justified in documentation, nor were medication changes. Recommendations: a) Correct Medical Staff Rules and Regulations to be consistent in requirement of frequency of documentation. Evaluate the number of physicians by workload to increase numbers and improve performance. Impressions were that an additional psychiatrist could be added to cover Adult Central and West (½ FTE each), and if East is converted to a short term unit, another FTE there. Another medical physician was indicated as well. Physicians state they are seeing 30 patients in a 2 hour clinic for referrals for medical conditions. Adolescent may have adequate coverage, but when this physician is out, pulling psychiatrists from other units creates shortages there and disrupts continuity of care for the Adolescent Unit. Suggest some sort of regular cross coverage for Adolescents with the above mentioned FTE additions. b) Additional FTEs should help to address issues of inadequate notes, deficient documentation, and missing physician signatures, but also should set up a system to monitor compliance. c) Mandate use of computerized note, or provide an alternative form for handwritten notes that allows adequate room for documentation. d) Audit timeliness and quality of physical exams. 5. Consent Forms – Findings: Several issues were noted having to do with consents. On the Adolescent Unit, there is an apparent lack of understanding on legal issues related to consents. There was conflicting or lack of information in the chart regarding guardianship or custody, and thus the ability to give consent for a minor. In addition, it was noted in an adolescent chart that the “patient lacked capacity” to give consent, when the consent legally has to be obtained from guardian and patient’s capacity is therefore irrelevant. The practice of having multiple medications on one consent sheet was observed, and it was evident that new medications were added since the original patient 24 signature was obtained. On two occasions, informed consents for medications were not located. Consent forms related to transfer from involuntary to voluntary status were incomplete or absent. Recommendations: a) Conduct an in-service training on legal issues related to guardianship, capacity and consents. b) Revise consent forms for medication, requiring a patient/guardian signature every time a new medication is added. Suggest listing an anticipated range for medication identified on the consent, and therefore dosages can be changed without additional consents being obtained, while at the same time, patient is protected from significantly increasing dosages without additional informed consent. c) Monitor compliance for all consents 6. Seclusion and Restraint Documentation – Findings: In addition to the problems of absence of MD signatures on orders and forms and completed forms not being filed in the chart already noted above, multiple other problems were observed, making every Seclusion and Restraint chart reviewed deficient in at least one area. Omissions included documentation of routine observations such as circulation checks and vital signs, no bathroom breaks or water offered, or no RN or MD assessment documented. One order was written for a manual hold, seclusion, and restraint on the same order. Policies such as notification of family and debriefings following patient release were not followed or not documented. An “Administrative Restraint order” was noted on one chart, although staff stated that these were no longer used. Recommendations: Seclusion and Restraint deserves attention as a designated QI project or regular report of compliance to a quality team. This is always an area of scrutiny for JCAHO, and also a high risk procedure deserving of pristine documentation and records. Educate staff, monitor compliance, follow-through with consequences for non-compliance. Use treatment team to monitor documentation and timely inclusion in chart of completed form. 7. Medical Management – Findings: Multiple charts were noted to have documentation of “unable to assess,” or “refused exam,” and potential medical complications were left without appropriate follow-up. Even without a “hands-on” exam, patients’ condition can be somewhat assessed from a distance and documentation more helpful than “unable to assess” recorded in chart. 25 There was also a notation of a patient refusing labs two times over a week ago, but without further follow-up either changing the order or mandating compliance with treatment. The H&P form includes an area for listing medications, but the nursing assessment does not provide for medication list recall. Charting of current medications was inconsistent from record to record. A new JCAHO standard requires a “medication reconciliation” list which is especially helpful for longer lengths of stay. This insures that new medications added during the course of an admission do not interact or are contraindicated with other medications patient may be taking at home. Pharmacy did review medication orders, but called or emailed physicians with interactions or contraindications and notification did not always appear timely. For example, a Friday night case was noted where the drug-drug interaction notification was not found by the physician for 4 days, and another allergic notification was not identified by the pharmacy until the next business day. Inconsistency was noted in documentation of PPDs. The GRITS (Georgia Registry for Immunization System) is not utilized for tracking immunizations for Child/Adolescent or DD populations. Risk factors for withdrawal, increased monitoring for detoxifying patients or documentation of medical issues secondary to alcohol/polysubstance abuse were noticeably absent on substance abuse patients. There was some disconnect noted between the admissions unit and the receiving treatment unit. PRN antipsychotic medications were ordered, but since this was prior to the MAR creation, it was unclear to the unit physician and the nurse whether any PRNs were actually given prior to the patient’s arrival on the unit. One chart lacked appropriate follow-up and adherence to a physician order for constipation. The historical incidents and consequential developed and implemented action plans at this facility related to recording bowel movements and reporting constipation make this particularly significant. Recommendations: a) In physical exam documentation, discontinue the practice of allowing “unable to assess,” or “refused exam” as acceptable documentation for physical exams and assessments. Mandate at least an observational note of patient condition, with further documentation that the patient refused a more comprehensive exam. Define follow-up options for patients with potential medical complications, and timelines for repeat attempts to evaluate for all patients. 26 b) Add a prompt for recording current medications to the nursing assessment. Look into developing a policy for meeting the new JCAHO standard requiring medication reconciliation. c) Require Pharmacy to communicate directly with an on-site physician and to indicate interactions or contraindications at the time of the dispensing of the medication so that physician and nursing staff are aware before medications are administered. d) Standardize documentation of PPDs, and adopt GRITS (Georgia Registry for Immunization System) for tracking immunizations for Child/Adolescent or DD populations. e) Develop policies to identify risk factors for withdrawal, and define monitors to assess detoxifying patients. Include documentation of medical issues secondary to alcohol/polysubstance abuse as part of the history and physical exam. 8. Utilization Review – Findings: The utilization management plan has been recently reviewed as it contained 2007 goals, however, it is still in need of revision. The UR Director, though relatively new in her position, could not explain some things contained in the plan such as reference to Adult Mental Health Program Redesign 2002 and Planning List Criteria, neither which are described in the policy but by which patients’ stays are supposedly reviewed. “Questionable malingering” was listed as an acceptable diagnosis. A list of 13 Focused Programs were included in the Plan, although the UR Director stated these are outdated. All of the mental health units, including East, are described as acute units, however, patient condition and pathology did not seem to reflect this, and in fact, in the opinion of the psychiatric physician surveyor, most of these patients could be discharged. The observation of patients ready to be discharged was also incongruent with the statistics that show an impressive trend line for decrease in unauthorized days since the inception of APS review, and leads to the question of what clinical criteria are used to authorize these patients for continued stay. Two of the top five discharge diagnoses for 2005-06 as provided by the hospital were Psychotic Disorder NOS and Depressive Disorder NOS, indicating a lack of through diagnostic evaluation. This was also reflected in individual chart reviews, such as where a patient carried an NOS diagnosis for over 2 years. Recommendations: a) Review and revise the utilization management plan and remove outdated or inaccurate data. b) Examine continued stay criteria of all patients on East Unit, and concentrate efforts on discharging these patients. Overcrowding on Central and West could then be addressed by transferring patients to these beds. This could also alleviate physician workload. 27 c) Review use of NOS diagnoses an indicator of incomplete diagnostic evaluations. 9. Quality Initiatives – Findings: GRH-Atlanta has an impressive presentation of minutes and data collection, including graphs tracking trends with segregation by unit. However, again, there is general lack of follow-through. Most notably, the threshold for action or concern seems to be set quite high, and there is no comparative data from other GRHs, statewide standards, or other benchmarks from which reasonable goals can be established or criteria for which action would be required to be taken. For example, in a month where there were 23 staff injuries, one of which caused an employee to lose consciousness and be transported to the hospital by ambulance, the report stated there was “No single incident that rose to the level of requiring a Performance Analysis,” and therefore no formal performance improvement actions are taken. This statement is commonly seen. Although medication errors committed by physicians were as high as 78 in one month, no actions were indicated. The extremely low number of med errors committed by nursing, sometimes none in one month, suggests that there may be an underreporting problem. The committee structure is confusing, with the Safety Committee being tasked with patient care indicator monitoring and enforcement, but with little clinical representation and no empowerment for follow-through. There is a system of review, including generation of memo to a clinical manager, sometimes with required response, sometimes only serving as information that a trend or a significant issue is emerging or has arisen. The Safety Officer is competent and invested in his duties. However, committee or organizational structure may have reduced the impetus in ensuring compliance. The Provision of Care Committee, which does have clinical representation, does not address issues of patient incidents including assaults, falls, elopements, contraband and injuries. As noted under medical management findings, there are continued problems with monitoring and reacting to constipation in patients. This indicates a failed action plan, and a disconnect between quality initiatives and quality implementation. The plan, and monitored compliance with it, was excellent, but there was clear evidence to the contrary. Recommendations: a) Set thresholds for action based on comparative data from other GRHs, statewide standards, or other established benchmarks. b) Examine barriers to reporting nursing medication errors to determine if current numbers are accurate. c) Revise committee structure to ensure that the proper disciplines and clinical management are involved in quality initiatives and data review. Make sure that there is appropriate follow-up, that people are empowered and also receive support in effecting change and hold people accountable for 28 performance improvement in order to eliminate disconnects between planning and implementation. 10. Treatment Team – Findings: Treatment teams were attended on the Adolescent Unit, and Adult West and Central Mental Health. Treatment Team schedules did not allow attendance on the remaining units. In general, treatment teams were well attended by all disciplines and patients. Central Unit’s team was well run, interactive and group oriented. Medical issues were discussed, and the point system utilized for patient management was addressed. Treatment Plans were generally complete, but sometimes unclear as to assigned responsibilities as names are used without indication of discipline they are representing. Recommendations: Indicate responsible discipline on Treatment Plans in addition to or in place of individual names 11. Staffing, staff morale and attitude – Findings: Probably the most significant issue identified in this survey was the morale and attitude of staff, which was a consistent theme from line staff through physicians and management. Some employees were reluctant, even fearful to talk, while others stated that they had tried to express their concerns to administration, but were unheard and felt unsupported. As a result, most staff have either become apathetic or very frustrated. Frequently stated was lack of teamwork and leadership. Though staff also articulated concern with staffing levels and turnover, issues related to leadership and teamwork were much more frequently and passionately expressed, and recognized by some as contributing to the staffing problems. The difference between GRH-Savannah and GRH-Atlanta was striking in this regard. Though GRH-S had their share of opportunities for improvement, their energy and attitude were markedly different, and this was felt by the survey team almost immediately. Another source of frustration seemed to be the mandated practice of sending employee performance write-ups “downtown” before the problem can be addressed with the employee, with a usual turn-around time of 2-3 weeks. Managers felt that their hands were tied in expediently handling performance issues. The difficulty in disciplining or firing long-term or “classified” employees was also expressed, with some employees therefore acting entitled and unwilling to respond to supervision. Nowhere else is there better evidence of the effects of poor morale than in the turnover and vacancy rates for Nursing. It is not surprising that the two short term Adult Units and the Adolescent Units have the highest turnover rates, as that is where morale is the lowest and problems are the highest. Agency and 29 PRN staff, who are typically paid a higher rate than regular staff, are responsible for the majority of errors observed during the audit. The physicians feel not only the effect of short nursing staff, but experience shortages themselves. A significant source of discontent for the physicians is with mandated call, and then they are paid less per hour than a PRN physician taking the same call. Recommendations: a) Take advantage of the recent Nursing Executive replacement and the imminent Administrator change to create a perception of a new environment and time for positive change for GRH-A. Solicit employee input, conduct employee opinion surveys, and re-institute exit surveys. Make employees feel they are part of the process of positive change. Pay particular attention to the effects of the media exposure and continued scrutiny of the hospital on the employees. It is very important to maintain open lines of communication at this time, and while setting an expectation of improved performance, be careful not to imply scapegoating or blame of individual employees. b) Identify what is working on the SNF and DD units and try to replicate on other units. Continue to move the acute units back to the Program Model to encourage teamwork and cooperation between disciplines. Remove hesitancies to discipline classified employees if they are problematic. Expedite the disciplinary process, if at all possible remove the delays involved in Division review. c) Concentrate heavily on retention of employees. Encourage middle management and supervisors to develop good relationships with their subordinates. Have upper management model this behavior. Address some of the major issues, complaints, and contributors to burn-out such as moving employees off their home units to cover other units, only to create shortages from where they were pulled. Assign onsite shift supervisors to relieve nurse managers of 24-7 call responsibilities. Explore setting up nurse mentoring program to allow new nurses to ease into shift responsibilities. Consider self-scheduling. Instead of mandating shifts, MOD, and OT, at least on a temporary basis, provide incentives to take call and additional coverage (for physicians and nursing) by pay rates equal to what is being paid to agency or PRN staff. d) Resist the urge to hire just to fill positions, sacrificing quality for quantity. To build momentum once change is evident and there is an upswing in morale, encourage community exposure by employees becoming involved in mental health, community, and professional organizations so that they can be the ambassadors for the hospital and become recruitment leaders. Once positive change has taken place, become a training site for nursing schools for their psychiatry rotations to encourage recruitment and create a learning environment. 30 12. Patient and Family – Findings: Several patients were interviewed and although most were generally satisfied with their care, others were vocal about overcrowding (Adult MH and Forensic), inconsistencies in patient schedules (Forensic), staff neither listening or working actively on their discharge (East), staff preoccupied with their own problems (all over), or fearful about being around other violent patients on their unit. There was little evidence of family involvement in any chart, and Social Work Services stated that they do very little family work. Recommendations: Family involvement in care will not only improve patient care, but will also help mend community image. Social work should make family communication a priority 13. Training/Staff Development – Findings: There appeared to be a commitment to training, with a dedicated training staff and building for this purpose. The orientation schedule appeared to provide sufficient period of time for training. Competencies appeared to be in order. However, staff commented that once orientation was complete, nursing staff was immediately immersed in the unit without additional on-site training or mentoring, and often felt overwhelmed. Some staff stated this contributed to turnover. There was a comment that training was often used excessively and inappropriately or inadequately to address employee performance problems, without accountability or performance expectations set before or after training was completed. Another staff indicated that they did not approve of the MANDT program, although it has seemed to be successful in reducing Seclusion and Restraint utilization. Recommendations: Establish a mentoring program as referenced above. Do not replace disciplinary action with training when performance problems are not related to education 14. Safety/Environment of CareFindings: While on the Adolescent Unit, it was noted that patients are allowed access to their rooms with door closures throughout the day; patient shoelaces of lengths found on high top sneakers were observed in patient rooms, and patient room doors are equipped with regular doorknobs, all contributing risk for patient suicide. There appears to be need of maintenance on many units, but especially the adolescent unit, with loose floor moldings and other general repair issues noted. On one of the exterior fenced yards for the adult males, it was noted that the smaller mesh screen that discourages climbing of fence by making the holes too small to fit fingers through was located at the bottom of the fence instead of the top. Staff members indicated that this had been done because patients had 31 been unraveling ties at the bottom of the fence that attached the links to the poles. This indicates lack of supervision in the outside area, as this would take some time and concentrated effort on the part of the patient to unfasten these ties. Recommendations: a) Look to replace doorknobs with slip knobs which will not support weight, restrict shoelaces on unit, and restrict patients in rooms unsupervised. b) Have Administrator do monthly walk-through inspections for general maintenance issues. c) Install small mesh to top of fence to discourage elopements. d) Suggest instituting a smoke-free hospital environment ECRH - AUGUSTA 1. Chart Organization and Content – Findings: On the DD Units, because these house generally long term, medically complex patients, records were very large. Perhaps in an attempt to make more manageable, information was divided into two charts; a health chart and a program chart. The charts were generally orderly, but sometimes as much as 23 years worth of documentation such as lab results, assessments, etc was still in the active chart, and the Medical Record policy for retention was not consistently followed. Surveyors were mixed in their report on ease of “tracing” problems through the chart, but when tracing was possible, results were reported as excellent. There was some inconsistency noted on where in the chart staff documented acute medical changes requiring physician notification, for example, there was a patient whose vital signs were ordered to be checked twice a day for one week. While this was being done, it was being documented in different places in the chart by different staff, making it difficult to track changes or significant readings. Charts were better organized and flowed somewhat better on the MH unit than on the Forensic Unit. For example, the MH unit used the computerized version of the Physician’s Progress note, which is awkward and provides insufficient space for required documentation when used as a printed form with handwritten notes. The Treatment Plan weekly update on the MH unit was also fully typed and has more text than the Forensic unit. Due to longer length of stays, the Forensic charts tended to be larger, and it was difficult to find current information. On these long term charts, the initial evaluations, such as the H&P and initial psychiatric evaluation, were often absent, though subsequent annual evaluations were present, indicating an inconsistency in thinning chart practices. There were various separate logs for 15-minute checks, I/O, S&R, etc., and there was inconsistency as to when these would be placed in the patient chart, so 32 sometimes it was difficult to locate information. When S&R forms were found in the chart, they were in the back of the physician order section, often in random order rather than chronological order. Recommendations: a) Records of long-term patients could be made more manageable by purging as defined by the medical record policy for retention. b) Require or at least encourage the computerized version of the Physician Progress note to provide adequate documentation of pertinent clinical information. c) When using separate log books for recording information, establish a policy and monitor consistency for the inclusion of these in the permanent medical record. d) Establish a consistent guideline for where patient information is recorded in the chart. This reference is specific to vital signs, crucial for medical monitoring and management 2. Programming – Findings: A wealth of programming seemed to exist for DD patients. Higher functioning patients participate in work therapy and vocational training, classes in independent living and social skills and functional academics. They are also provided off-campus trips and outings. A very impressive pseudo-store mimicking an actual grocery store was set up this month to teach shopping skills, including budgeting, money exchange and item selection. Patients were observed participating in these activities. Lower functioning patients receive occupational therapy such as personal care and domestic training, music therapy and social skill training. Large, bright areas for physical and movement therapy were observed, and patients were seen participating in all activities. Even patients unable to participate in structured programming were provided music, televisions or other sensory stimulation. By far, most patients were seen engaged in some kind of activity. For Mental Health and Forensic patients, individualized activity schedules are initiated by the RN, given to them at treatment team, and appear to be followed. As in the other facilities, the treatment mall offered most of the programming. Visits to the mall showed active groups and active participation from patients. From logs documenting group activities, all disciplines seem to be involved in providing programming, including psychology, nursing, social work and activity therapy. On the AMH Unit, reports show that nursing provides more groups than anyone, but they do not provide groups at all on Forensics. 33 An observed medication group consisted of interactive discussions on types of psychotropic medications, side effects and interactions. Another observed group for forensic patients educated them on court processes. Most consumers would benefit from SA programming, particularly on the MH units, where dual diagnosis is likely the rule and not the exception. One SA group is offered on the unit, but often consumers were at the treatment mall. Essentially no groups such as AA/NA/CA were noted. Recommendations: a) Enhance substance abuse programming, making it available to those clients with identified dependency, abuse, use, or those at high risk for abuse, which probably encompasses the large majority of consumers. b) As noted, nursing provides many groups on the Mental Health Unit, actually more than any other individual discipline. It was not determined if these were provided by professional staff (RN, LPN) or Health Service Technician’s. If Health Service Technician’s are providing the groups, the question of quality of group and training/competencies are an issue. If professional staff is providing these groups, a question of effective utilization of staff is raised. Due to acute nursing shortages, nursing responsibilities that can only be provided by nursing (assessments, medical monitoring, etc.) should not be compromised for provision of groups when perhaps other properly trained disciplines could provide these groups. Likewise, on forensics, nursing provides no groups, so this population may not be receiving medication education. This area deserves further evaluation. Treatment Mall vs. on-unit programming needs to be evaluated for those clients who are not able to go to the Mall, and therefore may not have access to therapy. c) Some consumers in DD groups anticipated rewards following active participation, but this was absent and their disappointment was evident. It may be beneficial to consider a reward system for participation in group activities. 3. Physician Documentation – Findings: The annual assessments on DD patients were very well done, thoroughly addressing numerous medical issues, but MD documentation was otherwise sparse. Interdisciplinary Periodic Health Reviews (PHRs) are conducted quarterly, but documentation tended to be rather repetitive and brief. One chart reviewed was missing a PHR. Other physician documentation consisted of short occasional progress notes, unless there was an active medical issue which required more detail. Sometimes physician documentation was contradictory. Physician documentation for the psychiatric conditions of DD patients was limited. This perhaps may be due to reliance on the psychiatric clinics operated by the Augusta campus physicians who come over once a week. Notes for these clinics were not observed in the chart. The surveyor may not have known where 34 to look or the clinic notes were filed separately. Psychiatric diagnoses were lacking supporting documentation, and justification for psychotropic medications used was often absent. This is a difficult population to treat because of the ability to evaluate effectiveness of medications. Identifying specific target symptoms for reduction or elimination would be useful in the consideration of initial use or adjustment of medication. This was not found to be present. Only one telephone order was noted to be not dated and timed when signed. Telephone orders are accepted, and “read-back” is documented. Some orders on Camellia were noted not to always be in compliance with policy of MD signing within 24 hours. There was sufficient documentation to support patient diagnosis on MH charts, but not as clear on forensics. The psychiatrist on the forensic unit was noted to use generic notes, some of which changed very little from note to note, which suggests minimal individualized assessment and documentation. Given the high number of patients followed by this psychiatrist, it is likely that content was sacrificed in the interests of efficiency. A stamp was used to prompt physician signature of telephone orders with inclusion of date and time, but this was not always completed. Recommendations: It is anticipated that most physician documentation issues would be addressed if workload was decreased to reasonable levels with the addition of staff. 4. Seclusion and Restraint (S&R) – Findings: Seclusion is not utilized for the DD population, and restraint use is rare, as de-escalation techniques are employed and are successful. Protective devices such as headgear and mitts to prevent self-injurious behavior were observed with appropriate documentation and physician orders. The low utilization of Seclusion and Restraint for the Mental Health and Forensic population is commendable. The use of PRNs is relatively common, however, and an intramuscular (IM) PRN is roughly equivalent to a hold/restraint episode. IMs are also usually used when patients are put in restraints. Physician documentation related to IMs is lacking, but nursing does document these well. A surveyor arrived on the unit just as a patient was being processed out of restraints. The patient was in restraints less than one hour. Chart documentation was complete, and a debriefing was held. This was impressive. Other charts reviewed did not show documentation deficiencies. The use of the term “Administrative Restraints” was used by staff and also noted in the chart, but not defined by policy. The policy is also unclear as to the role of security/police in the application of restraints, which leads to training questions. 35 Recommendations: a) Education on the reference to “Administrative Restraints” needs to occur, or this term needs to be defined in policy. b) If security and/or police are utilized in Seclusion/Restraint, their involvement needs to be defined by policy and competency records should reflect training appropriate to their level of involvement. c) As in the other facilities, the practice of PRN IMs should be be examined and addressed as a restraint, and policies developed to set guidelines. 5. Medical Management – Findings: The medical needs of DD patients are generally extensive and complex, and seem to be well addressed. The annual medical assessments are extremely thorough. The best diagnostic criteria to assess care in a long term facility for profoundly MR patients is skin integrity, and not one decubitus was noted on review or reported by nursing staff, however, the Medical Director did report one. In a population of 500 patients, this is a remarkable accomplishment and reflects attentive care. Nursing reported that patients on the SNF are routinely given two baths a day. Some polypharmacy was noted, for example Seroquel and Haldol were concurrently prescribed without much explanation. There was inconsistency in monitoring medication levels, for example Haldol levels were being checked, which is normally not done at all, yet a Depakote level was not checked for nine months, when six month monitoring is standard practice. The pharmacist does review medication orders for polypharmacy, contraindications, and interactions. One chart was noted to have a patient going twelve days without a bowel movement, however, staff seemed attentive with consistent documentation of monitoring and interventions. The MD was notified after all else failed and a fleet enema was administered on day twelve with results. Dental care and oral hygiene was assessed as very good. Dental appointments are at a minimum yearly, and identified problems have appropriate follow-up. Substance use/abuse/chemical dependencies were noted as diagnoses in four charts. Documentation regarding the diagnostic difference between the two, which would be important in differentiating treatment modalities, was lacking. There was no clearcut documentation regarding risk assessment for dedetoxification/withdrawal, and no standardized withdrawal treatment procedures (i.e. CIWA scales). It was noted that nursing assessments were not completed on several patients that had been admitted within the last 5-7 days. Nursing staff indicated that the patient had refused or was non-compliant, but this was not documented in the chart. 36 A few pain scales were either incomplete or were noted as elevated without pain source or interventions documented. Refusal of medical monitoring was noted in the chart, including a patient refusing blood draws for lithium levels and another refusing blood pressure checks when they were on blood pressure medications. Several patients had medical co-morbidities or positive diagnostic studies that lacked appropriate follow-up. For example, two patients had documented hepatitis without further liver studies or hepatitis profiles. One patient had six fasting blood sugar results above 126, which is diagnostic of diabetes, without treatment or follow-up. Another showed evidence of risk factors for Polycystic Ovarian Disease without follow-up. An EKG was lacking on a patient with documented irregular rhythm and gallop. Medication management seemed more problematic on the Forensic Unit than on Mental Health. Documentation of medication changes and/or dose changes on the forensic unit was limited in scope if it was present at all. Consent forms for medications were unclear and inconsistent regarding capacity to give consent. The potential for drug – drug interactions with polypharmacy was noted. Pharmacists did seem to work well and closely with the physicians and show compliance with formulary. Medication errors and Adverse Drug Reactions are so low that it suggests under-reporting. Recommendations: a) The medical management of substance abuse/chemically dependent consumers has been a consistent issue in the review of facilities, and is one to be addressed at ECRH. It is clear that there are educational, operational, and policy development opportunities related to the assessment and treatment of chemical dependency and substance abuse so prevalent in this population. b) Guidelines for interventions for patients who refuse assessment or medical monitoring need to be established, and caregiver communication regarding this is essential. At the very least, nurses need to be instructed to document noncompliance, and record observations that do not require hands-on interventions. c) Education on the reporting of medication errors and adverse drug reactions needs to be completed, as both appear to be underreported. d) The quality and thoroughness of medical follow-up would probably best be impacted by the expansion of the medical staff. Most co-morbidities or abnormal diagnostic studies that lacked follow-up were not complex, suggesting that it is not an educational issue, but rather a workload issue. Likewise, lack of follow-up of positive scales again may be impacted by staffing enhancements, but a check and balance system may also be necessary so not to ignore this indicator. 37 e) Physicians should be encouraged to better document medication and/or dosage changes, as well as the use of polypharmacy. For the DD client, it would be helpful to target specific symptoms to be addressed by psychotropic medications so that their effectiveness could be measured and documented by team members. 6. Utilization Management – Findings: Most patients who are long-term have very limited resources available in the community that could meet their complex needs, making placement difficult. There are a few “TIC,” Temporary and Immediate Care consumers that come from personal care homes because of disruptive behavior or circumstance changes, and these were observed to be reviewed for discharge planning appropriately. The admission wait list for Forensic is 20 days, with the evaluation wait time from one to two months. Resources or access to resources for patients who are discharged seem to be poor, as many re-admissions seem to cite this as the reason for readmit. Recommendations: The Forensic system seems to be backlogged, which may be alleviated by the addition of a Forensic Psychiatrist and additional community resources, particularly supervised housing, to allow for more prompt discharge planning. It was also noted that there were consumers Incompetent to Stand Trial that were in the system for an excessive amount of time related to the offense with which they were charged. This issue is large and complex, and may be under investigation, but the incidence of this happening should not be overlooked 7. Treatment Team – Findings: No treatment teams for DD were held at the time of the survey, but treatment team documentation reflected interdisciplinary participation. One chart’s team meeting lacked an MD signature, but staff reported that it is policy that an MD attend and it was more likely that he/she had just neglected to sign. Several treatment teams were attended on the Mental Health Unit by the surveyors. The Forensic Unit treatment team was not held on the days of the survey. All disciplines participated in treatment meetings, with the physicians leading the team. Consumers were actively involved in the meetings, reviewing their diagnosis, medications, activity schedules, medication compliance and goals, and verbalizing understanding of their treatment plan. Teams are only held once a week, so it is possible and not unusual for a consumer to be discharged before the first team meeting. 38 Recommendations: Treatment teams should be held more frequently than once weekly, as some patients may not stay long enough to attend a team meeting, or their first team may be on or near the day of discharge. This, again may be a staffing issue alleviated by the addition of physician and professional staff. 8. Patient and Family – Findings: Letters of invitation are sent to families approximately one month prior to team conferences for long term patients, and family involvement was evident in the chart for some clients. Appropriate notification was seen for reporting adverse events and/or medical emergencies to patient’s families. Only one chart was found to have inadequate charting regarding involvement of family in care. Visiting hours are somewhat restrictive, allowing only late afternoon or evening access. Recommendations: Consider expanding visitation hours. This would not only allow more contact for the patient, but feedback from family, friends, and significant others can be helpful in evaluating patient progress and changes. 9. Safety/Environment of CareFindings: A large and complex move was being conducted on the Gracewood campus with the relocation of many patients from other buildings to a more centrally located and recently renovated building. The move itself is noteworthy as it was meant to increase efficiency of a scarce and valuable resource – nursing personnel. Several safety issues were noted on the walk-through. These were primarily related to the move. Though perhaps understandable considering the scope of the job at hand, the staff was also cautioned that this was their most vulnerable time for an incident, so safety precautions should be intensified. Overall, the maintenance crew is to be commended for their attention to safety, and their teamwork in striving to meet clinical staff’s needs. The campus is also generally very well maintained, and the buildings and grounds present a pleasant environment. It is noteworthy that this population is smokeless, with an exception made for three long-term stay consumers who are smokers, for which accommodations have been made. Hand sanitizer dispensers for infection control purposes were noted in all group areas. Though effective for the control of contagious diseases, these can be an eye irritant and safety hazard as they are accessible to consumers. Several safety issues were noted on the walk-through of the Mental Health Units. Suicide risks included plastic bags in patient areas, and unlocked doors to closets and areas that clearly should have limited access. It was also noted that 39 the doorknobs to patient rooms seemed to be installed upside-down. The exterior knob, installed correctly, would result in slippage if anything was tied to it. The interior knob, installed in the opposite direction, would be able to easily hook and hold weight and pose a suicide risk. It was reported that suicide risk on the Forensic unit was usually not an issue, and it was confirmed that there were no patients on suicide precautions at the time of the survey. However, long removable phone cords in patient areas (these were removed immediately), electrical cords, long shoelaces in athletic shoes, and plastic bags being used in cans and stored in bulk in storage areas were accessible and could pose suicide risks as well as weapons that could be used in assaults. Other items that could potentially be used as weapons were noted, such as a glass pot of hot coffee and housekeeping items such as brooms and metal dustpans on sticks that were readily accessible in patient areas. The restraint/seclusion room was obviously being used as a patient room, with a chest filled with patient belongings and the bed made up for sleeping. Justification by staff was that S&R was rarely used, and records confirm only 5 instances of non-ambulatory restraints in the last 6 months with the most recent approximately one month earlier. When asked to show where the restraints were stored, the staff knew where to look and they were accessible, but were at the bottom of a drawer under other items. If restraint or seclusion were necessary in an emergency situation, all these factors would inhibit expedited administration. Further examination showed that the bed bolted to the floor in the seclusion room was not an acceptable restraint bed, as there were no holes in the bed frame where restraints could be securely attached to prohibit possible dangerous movement by the patient. Several interior doors were noted to open out into hallways or common areas. These doors did not provide clear vision to warn of someone standing or passing by on the other side, and so this could cause harm or injury. A surveyor actually observed a staff member being hit by one of the doors. On some of the units, red lines are drawn on the floor to delineate the hazardous area. This may be helpful, but does not eliminate this hazard. The Adult Mental Health Unit was separated into “pods.” One pod housed longer term patients, another pod was for males, another for females, and another was a mixed unit. Patient areas were small and felt somewhat closed in. The nurse’s station is completely removed from the patient area, not allowing direct observation from the work area. One nurse is often assigned two pods, and must rotate between the two. This configuration and staff assignment leaves Health Service Technicians routinely alone with the patients. “Panic buttons” were installed in most areas of the unit to summon help from additional staff and security in case of emergency. Lights on the wall indicated what area to respond to. 40 It is noteworthy that there is a smoke-free policy for this population, which seems to be working very well. Nicotine withdrawal is medically addressed with orders and application of nicotine patches. Staff states that this is beneficial in milieu and patient management and adherence to treatment schedules, not to mention a health/wellness benefit for the consumer. Recommendations: a) Reverse the installation of the doorknobs and install as they were designed so that they do not hold weight. b) Safety issues related to suicide/assault should never be compromised because of the absence of patients on those specific precautions, as patient mix can change instantly. Be quicker to react to identified safety issues; plastic bags as safety hazards were noted by both this survey and by Joint Commission, but were still on the units when we exited. c) Other identified risk items such as removable telephone cords, long shoelaces, glass, poles and sticks should be removed from patient areas. d) Although not much can be done to alleviate physical issues such as the isolation of the nurse’s station away from the patients, this needs to be taken into consideration in calculating staffing levels, both numbers of staff and composition (Health Service Technician/Nursing). e) Replace the bed being used for restraints with an acceptable restraint bed. f) Although the facility is to be commended on their Seclusion/Restraint Training and the low incidence of use, their ability to quickly implement the procedure is hampered by a lack of “readiness” on the unit, as evidenced in using the room as a patient room and inaccessibility of restraints. 10. Training/Staff Development – Findings: Competency files on the unit for employees were reviewed and appeared up to date and complete. 11. Staffing, staff morale and attitude – Findings: Nursing staffing was reported to have been a significant issue for a number of years, with a peak of 67% vacancy rate reached a few months ago. Use of overtime, agency and hourly (PRN) is the norm. The remaining staff’s tenures of 20, 25, 30 years provide a stable committed core and enable the facility to continue to provide basic care despite the challenges that vacancies, agency, and excessive overtime usage bring. Many of the deficiencies noted in documentation, patient monitoring, assessment, treatment planning, and medical management can be traced back to staffing issues, whether it be shortages or sub-optimal performance due to lack of core staffing (agency/PRN). Despite the staffing shortages, morale seemed positive and hopeful among line staff, management, and physicians. Clinical disciplines seem to work together well, despite the recent abandonment of the program model and the return to the medical model due to reported failure and deficiencies noted on Medicare surveys. This seems to be more due to leadership issues rather than the model 41 itself, which has since been addressed and corrected. Staff reported an improvement in operations with recent organizational changes, and overall, morale seemed to be on an upswing. Non-clinical and support departments also seem to be on–board with the hospital team, and work well with the clinical staff. Though understaffed themselves, physicians are generally satisfied, but are frustrated with increasing workloads, high nursing staff turnover, and what they consider inappropriate admissions to the short term mental health unit. The Forensic unit is particularly understaffed, with only one psychiatrist for 60 patients. Though they do tend to be longer term patients, this is still too high a patient-to-doctor ratio. As with RNs, the physicians have very long tenure; they know each other and work together well, which contributes greatly to maintaining patient care despite these deficiencies. The hospital plans to open a forensic transitional program which means this ratio will soon worsen. Physician staffing at the Gracewood Campus was adequate and stable, and every member of this group has a long tenure. It will be very difficult to replace such staff and management should begin to plan for recruitment well in advance of any planned retirement or departure. Staff consistently reported that they believe staffing, including both numbers and competencies is the most significant issue facing the facility. Human Resources is actively involved in recruitment activities, with a recent job fair being held. They also conduct exit surveys and track termination data by several variables to note and address turnover trends. It was noted that terminated employees (vs. those that have resigned) are also given exit surveys, which may skew data somewhat. HR provided data that showed ECRH lagged behind that of all other state facilities for average hire salary for RNs, LPNs, and charge nurses, and a proposal was being prepared to rectify that situation. Recent adjustments that had been approved for new hires are creating disparities for nurses that have been in the system for years, whose salaries now could possibly lag behind or be nearly equivalent to new hires. Though unlikely to leave because of their vested years of service, this could create morale problems among the very core group which is holding this facility together. HR was also addressing this issue with a proposal. Vacancy rates and turnover are discussed at Leadership Meetings in the facility. The effects of staff shortages were specifically noted by the surveyors during the survey in two significant areas. At least on some units, mandatory narcotic drug counts at change of shift are often done by only one RN or not done at all. This may be due to staffing levels or may just be against policy. Although a problem was not indicted with reconciliation, this practice would contribute to significant issues if discrepancies arise. 42 Recommendations: a) Staffing shortages for professional staff and physicians need to be addressed, not only for the obvious immediate need, but also for the long-term stability of the institution. The stable, experienced, tenured staff which is holding things together despite shortages will be due for retirement in a short time, so recruiting now to replace them with staff that will become seasoned and experienced by that time is essential. Salary issues seem to be obvious, and in a city with many other healthcare alternatives for professionals, this is even more significant. b) Recruitment is wasted effort without retention, and this needs to be addressed as well. Fortunately, morale seems very good. In addressing recruitment salaries, benefits, and bonuses, existing employee salaries should not be overlooked. c) Minimal requirements, experience, and training for Health Service Technicians has become a consistent issue in the review of each facility, and the quality of this staff which is tasked with the majority of patient contact needs to be studied, evaluated, and addressed in all facilities. d) Suggest eliminating giving exit surveys to terminated employees, if you don’t want them working in your system, their opinions on how it should be run are irrelevant. Their comments will tend to distort compiled data and dilute usefulness of the survey results. e) The Admissions/Observation Unit should be staffed with a nurse whenever a patient is present. f) Narcotic counts at change of shift should never be compromised or neglected due to staffing shortages. g) The medical staff needs to be supplemented, especially in Forensics. 12. Risk Management – Findings: One DD patient was observed with bruising on his face. Upon request, the surveyors were shown the chart describing the accident and indicating medical follow-up, and the incident report form recorded with risk management, detailing the account of the occurrence. Documentation was excellent. However, the patient fell during a physical therapy session and the incident may again indicate a lack of adequate staffing. Policies and practices for follow-up of abuse reports or allegations were examined and found to be thorough and appropriate. This included tracking of unsubstantiated claims to note possible trends related to particular shifts or employees. A clergy volunteer who provided individual and group spiritual services was interviewed, and made some statements that would suggest that volunteers be better trained as to appropriate boundaries with patients. He related discussions with patients regarding abuse allegations that may complicate rather than help resolve issues. Both staff and physicians conveyed some discomfort with what they report as overreaction to patient complaints. They feel that their ability to effectively treat 43 patients is sometimes compromised by a response to what they identify more as patient pathology than valid complaints, and the result is often treatment noncompliance. An example of this may be the nonperformance of exams and tests due to patient refusal. This impression of over-reaction was not reinforced, however, when talking to the patient advocate, risk manager, or human resources. Recommendations: Provide training and oversight to volunteers, including clergy, to insure appropriate boundaries in interactions with staff. 13. Quality Program – Findings: The March Leadership Team Minutes described Function Groups that will be formed for the analysis of clinical and human resource measures. These groups are to look at key issues, allow detail analysis, encourage staff participation and report back to leadership. As defined, this process is promising to effectively address and or prevent problems before they arise by effectively utilizing data. Results are not yet evident. Five QI projects that were currently in place were also reviewed, including three measures for MH and two for DD. These were very focused and limited in scope, but worthwhile projects that were well done. Because of the disproportionate number of long term DD clients at ECRH, any aggregate and comparative QI data could be difficult to interpret or misleading. It may be helpful to separate populations when collecting and examining information. Medical Staff Rules and Regulations still state that physician documentation is weekly for the first 2 months, then monthly, which is not consistent with current expectations. Recommendations: a) Continue with the Function Group plan to allow detailed analysis with staff and leadership involvement. b) Make allowances for the vast differences in ECRH patient populations when aggregating data to make findings more relevant and useful. c) Although the MH population is much smaller, those units seem more problem prone and high risk, so the number and focus of quality initiatives should reflect that. 44 WCRH – COLUMBUS 1. Chart Organization and Content – Findings: Charts were generally in good order. Two charts reviewed contained two abbreviations not on the approved list. Recommendations: Review acceptable abbreviations for the medical record with staff and/or make reference material readily available. 2. Programming – Findings: Programming occurs both in the Treatment Mall and on the unit. The programs in the Treatment Mall are essentially available only for the residents of the neighboring longer-term forensic unit. This mall offered a variety of programs and appeared to adhere to its posted schedule. Groups occurring on the units were not consistent with activity schedules that were posted. Except for Unit 9, schedules did not indicate what staff was responsible for providing a group, so when one was not occurring as scheduled, it was difficult to determine who to contact. A group on Patient Rights that was not occurring as scheduled was later determined to be the responsibility of the patient advocate. She stated that she was in treatment team, which extended beyond its usual time. Some type of group note was consistently seen in the charts, however it was not clear how many hours a day each patient was in active treatment. On each unit, surveyors noted that at least 5-6 patients were in their rooms, in their beds, or sitting unoccupied on the unit throughout the day. This was sometimes observed during on-unit activities or while other patients were outside. Substance abuse groups are offered three times a week, with one AA/NA/CA group offered per week in the Treatment Mall. Participation in these groups was not always noted in chart, so it was not clear if they were occurring, if patients were participating, or perhaps participation was just not documented. Facility reports of compliance with active treatment (scheduled vs. completed groups) showed that many groups were not provided in the two weeks reported. The Forensic Unit showed a much better compliance, while Unit 10 and 2, the acute units, reported as low as 28% completed in a one week period. Recommendations: With stabilization of staffing levels, provision of groups should improve to acceptable levels on all units. The hospital needs to increase number/type of substance abuse programming and ensure that staff who lead groups are trained and experienced in both the topic of the group and in group dynamics. The medical record should reflect the type, number, and level of patient involvement 45 in groups. Unless medically indicated, patients should not be allowed to remain in bed all day. Inclusion of the discipline or the name of the person providing groups on the schedule would assist supervisors in holding people accountable and adherence to group schedule. 3. Physician Documentation – Findings: Documentation by psychiatrists consisted of infrequent notes with limited content. Patients showed multiple medication changes, including type and dosage, within a few days with little MD documentation. Nursing documentation was generally good enough for the surveyor to ascertain the reason for the initial orders and for subsequent changes of medication. For example, several patients on two antipsychotics had consistently inadequate documentation by a physician as to the clinical reason for this practice, however nursing notes provided enough information to infer the reason for the use of the two medications. IM meds were also frequently ordered without justification or rationalization documented. MD signatures on verbal and telephone orders were often cosigned without the date or time of the co-signature. Verbal orders, which are different than telephone orders, are routine and accepted in non-emergency situations. There is no notation of nursing documentation of read-back on the order sheet, but nursing staff did state that it is their practice to do so. Recommendations: Physician documentation should improve proportionately with additional medical staff. The practice of verbal orders (that are not by telephone) should be discontinued except in true emergencies. Nurses are required to perform readback, and this needs to be documented. Changes in medications and/or treatment regimens need to be better documented by physician. 4. Seclusion and Restraint – Findings: Utilization of seclusion and restraint is very low, and many S/R rooms are in fact converted to closets or storage. When questioned where restraints were kept, staff often did not know or took some time to look for and find the restraints. The staff used the terminology of “administrative restraints,” but this is not defined in policy. Justification for S/R should only be because of threat to self and/or others. On some charts, this justification was not clearly stated on the orders. The practice of ordering manual hold/seclusion and manual hold/restraint was noted, implying a choice delegated by the physician. The use of both terms on one order is not necessary when the manual hold order is only for the purpose of the “hold” that may occur in the process of secluding or restraining a patient. 46 Recommendations: Either include definition of “administrative restraints” in policy, or educate staff to discontinue reference to this intervention. Evaluate the ordering practice of manual hold/seclusion and manual hold/restraint orders. The use of both terms on one order implies a choice delegated to someone other than a LIP. Step up MANDT training to complete and maintain 100% compliance. 5. Medical Management – Findings: Generally, patients get prompt physical assessments on admission and are adequately followed up on. Consults are ordered and promptly performed. The documentation for these, however, as indicated above in section 2, is very scant. Patients are allowed to refuse physical exams and diagnostic tests without follow-up or subsequent requests or attempts to do the exam or test. Medical staff attributed this to the workload of the internist, but the treatment team also failed to monitor and follow-up on the refusals. One patient was admitted on 5/14 without having an H&P completed for nearly one month until 6/10 due to patient refusal. Several patients were noted to refuse their annual H&P with no followup. Some patients also refused laboratory monitoring of the drug levels of the medications they were being treated with. Most changes of patient condition show appropriate physician interventions, and MD signatures indicate review of labs and consults. One chart, however, did indicate an obese patient with history of HTN who did not have a nutritional assessment or referral. Because of staffing shortages in pharmacy, concurrent reviews of medication regimens no longer occur, but they are present on some older charts. EKGs were not found on most patients who were on two antipsychotics. The chance of developing arrhythmias is significantly increased when on two antipsychotics, and therefore EKGs may be indicated in some circumstances. Polypharmacy in the use of antipsychotics was frequently noted. One patient was on three antipsychotics without reduction of psychotic symptoms. Pharmacy reported that use of two or more antipsychotics was very common. There seemed to be a reluctance to prescribe clozapine. Diabetic patients lacked appropriate management, for example, all diabetic patients should be placed on an ACE inhibitor or ARB2s for renal protection, whether or not they are hypertensive. Urinalysis for proteins to gauge renal pathology should also be routinely done. 47 In addition to the detailed chart reviews assigned to each survey team member, 20 random charts were scanned for substance abuse/dependence issues. Although approximately 75% had this listed as a diagnosis, establishing this as a prevalent problem, this medical condition is poorly addressed. For example, there was no documentation noted that differentiated drug dependence vs. abuse vs. use, which would dictate appropriate treatment modalities. Furthermore, there was no documentation of risk assessments for withdrawal symptoms, or evidence of withdrawal scales (i.e. CIWA) to objectively determine severity of withdrawal for medical intervention. No documentation was noted on medical problems commonly associated with substance use/abuse/dependence. Staff physicians stated that any patients with “serious” withdrawal symptoms are transferred out. The present detoxification regimen uses Librium, which has a very long half-life and thus can be detrimental to patients with liver disease. Librium has generally been replaced in detoxification protocols with Ativan, which is similar but safer drug with a much shorter half life, and thus can be used with patient with liver disease. Recommendations: a) Policies should be developed and expectations set to define procedures for when patients refuse assessments, diagnostic, or therapeutic testing, with a minimum of expected follow-up when this occurs. The Treatment team should monitor non-compliance and plan interventions. b) Procedures for the medical management and treatment planning for substance abusing/chemically dependent/substance using patients need to be better defined. Librium should be replaced with Ativan as the drug of choice for the detoxification regimen. c) Education or review of best practices in the use of polypharmacy, the prescription of clozapine, the monitoring of diabetics, obesity, and patients on antipsychotics is recommended. 6. Utilization Management – Findings: The UR Manager also performs as the Medical Record Director. UR meetings and reports only occur quarterly rather than monthly as defined in the UR plan because of staffing. Reports show that there were no inappropriate admissions between October and February, which is incongruent with the need to open a 24 hour observation unit and a crisis stabilization unit. This calls to question the validity of these data. The need to create these two services, which are normally outpatient services delivered by a community provider, reflects a deficiency in the total mental health delivery system, and creates a burden on a facility that is already struggling with providing inpatient services. Although hospital leadership again is showing responsiveness to patient need and overall system management, establishment of these new services with associated training, policy and procedure development including admission criteria and level 48 of care differentiation, and physical move and renovations, especially with the aggressive timelines set, creates more stress on a system that is struggling to provide current services. Legal status of some forensic patients was expired, and evaluations were overdue. This clogs the system and contributes to the need to expand the number of forensic beds. Recommendations: Ensure that defined criteria are established for the existing and new levels of care (acute IP, 23 hour observations, and Crisis Unit) so that accurate, effective and useful UR data can be collected and utilized 7. Quality Initiatives – Findings: Monitoring of important measures are in place, including readmissions, seclusion and restraint, medication errors, pain assessments, falls, elopements, and client injuries. Trending and relational factors are considered, for example re-admissions as related to length of stay (LOS), diagnosis, referral source, and discharge disposition were studied. Reporting to appropriate committees is occurring. Some indicators that are monitored by different committees may create some redundancies, for example, client injuries are monitored by a Risk Management subcommittee while staff injuries are tracked by Human Resources. These are related and may be impacted by the same variables, and probably should be tracked and monitored together with joint action plans. 8. Treatment Plan/Team – Findings: Treatment plans were very comprehensive and multidisciplinary. One chart had an initial physician order for substance abuse treatment that did not follow through to the treatment plan. Treatment teams are held daily and are well run. 9. Patient RightsFindings: Patients sign consents for medication by drug class rather than by specific medication. Medications within classes can differ considerably in risks, side effects, benefits, and outcomes, and medication education could not possibly be given for every drug within that class. These consents therefore, cannot be considered “informed.” Consent for clozapine, a complex drug, was completely lacking on one chart. Patient’s capacity to give consent changed quickly in some cases, without supporting documentation. 49 Forced medication procedures were unclear, especially for Forensic patients. Orders were noted that stated “If patient refuses medication, may hold to administer.” Recommendations: a) Immediately discontinue obtaining consents by drug class. Consents need to be medication specific, with thorough drug education completed so that it qualifies as informed consent. b) Procedures for “forced medications” need to be defined, and changes in patient capacity to give consent should be very well documented and supported. 10. Staffing and staff morale – Findings: By far, the most significant issues facing this facility relate to staffing. Staff vacancies and shortages are evident in every level of the institution, and include Physicians, Pharmacists, Psychologists, the Facility Administrator, Nursing, Health Service Technicians (Health Service Technicians), and transcriptionists, thus the delivery of care is affected on many levels. Some positions have been vacant for over a year. Once again, as experienced in Augusta, the ability to provide patient care can be attributed to a small core of long-tenured staff that are experienced and committed. Their morale seems to remain positive and hopeful, despite the significant challenges of running the facility with vacant positions, agency and PRN staff. Many employees seem to wear “more than one hat,” performing in interim or acting positions, or performing more than one job due to vacancies. Leadership stated that the beginnings of their staffing problems began with an announced closure of the facility several years ago, which was reversed, but then implied again at a later date. This created a sense of job insecuritywhich resulted in many good employees leaving and contributed to the difficulty in replacing them. Recruitment and retention have still not recovered from these announcements, but then are even further impacted by the salary issues facing this hospital, and all of the other hospitals in the system. The facility was currently very active in addressing the staffing situation. Agency and PRN staff were used as needed on the units and locum tenens physicians supplemented medical staff coverage. The facility was prepared to go on diversion the day of the survey to limit admissions after a busy weekend, but they were able to postpone this due to the number of discharges by the end of the day. An intense hiring effort was in progress with an abbreviated orientation scheduled for the new employees to quicken the elimination of vacancies on the units. Forty new hires had been made in the last month, with 34 of these being direct care staff. These efforts reflect responsive leadership to address an immediate crisis situation, but longer term issues of chronic vacancies and turnover remain. Most of these efforts are short term, and the use of agency, locums, and abbreviated training schedules only perpetuate problems as it 50 creates a sub-optimal work atmosphere and delivery of care. It was noted that approximately 1/3 of these new hires were for Unit 10, the most acute, active, and volatile unit. The day of the survey, leadership reported that the hospital was fully staffed on all units according to census and acuity levels that day. Surveyors noted situations where despite having adequate numbers, at times staff-patient ratios were still operationally stretched. For example, on one “pod,” there were 5 staff assigned to approximately 15 patients - 2 RNs and 3 Health Service Technicians, a very adequate ratio. However, when visiting the unit, one nurse and one Health Service Technician were off the unit, and the other RN was behind closed doors in the medication room. One of the remaining Health Service Technicians was assigned a 1:1, which left the other Health Service Technician responsible for monitoring and supervising all of the remaining consumers (14), some which were on line-of-sight and/or other precautions. On unit 10, two RNs were assigned to cover the entire unit for day shift. One gave medications and the other did everything else. The same staffing occurred on second shift. At change of shift, the first shift nurses handed off a number of tasks that she had not been able to finish during their shift. This staffing is insufficient, given the workload of this acute unit, without even considering precaution levels or the number of daily admissions or discharges. Physician shortages are reflected in the quality and quantity of chart documentation. There is one psychiatrist assigned to cover 40 Forensic patients, plus the Child/Adolescent crisis unit, and several acute patients on Unit 10. During the survey, this physician was not responsible for these acute patients only because a semi-retired physician had agreed to extend his usual duties in order to cover these patients. This is clearly excessive. Unit 7, with longer term AMH and Forensic patients, has one part time psychiatrist. This too is inadequate. Unit 10, with 40+ acute beds is currently being covered with one locum tenens, and was supplemented the week of the survey with the semiretired psychiatrist mentioned above. Unit 2, with 2 psychiatrists, was the most stable of the acute units, but was still understaffed for an acute population. A generally accepted ratio for acute units is 1 physician per 15 patients. The delinquency rate for discharge summaries is at 43%, although some of this is attributable to transcriptionist shortages. Psychology is also understaffed, and is reflected in a back log of community court evaluations and hospital reports. Pharmacy is understaffed, and has been for quite some time. Workload has been accomplished only through the use of contracts and agency pharmacists. Consults and concurrent reviews are not occurring at an optimal level. 51 Employees at all levels consistently report that recruitment, retention, and staffing issues are the most pressing problems for the facility. RN vacancy rates are as high a 40%, and turnover for Health Service Technician’s from December to April was over 100% (32 hired, 34 lost). Other issues expressed by line staff and middle management as problematic were shift to shift communication, lack of substance abuse treatment, and management of smoking privileges. Recommendations: Continue human resource staffing efforts by first eliminating the perception of facility closure. This should include but not be limited to open communication both internally and externally, filling key management positions, and improvement of the appearance of the facility. Continue aggressive recruitment activities, proceeding cautiously with the knowledge of the exposure and risks these very efforts can temporarily create by flooding the workforce with new, inexperienced and untrained employees. In recognition of the value the longterm employee brings to the facility, begin plans now for their replacement as they retire and exit the system, which will significantly impact the operations and stability of the institution. Begin efforts in retention to eliminate the 100% turnover in some job classes, or else the increased hiring efforts will only result in increased turnover. Ensure that abbreviated training is a temporary measure only, and that those who attended the condensed orientation eventually complete the entire training schedule. Examine salaries for all positions to remain competitive. Supplement medical staff to attain reasonable workloads and patient ratios. 11. Training/Staff Development – Findings: The facilities records show that MANDT training is only 43% complete, significantly lagging behind other facilities that have been surveyed. Because of multiple vacancies, staff is pulled to work units that they are not familiar with in order to meet minimum coverage. While visiting the units, surveyors questioned Health Service Technicians and nurses about unit specific issues, and found them uninformed about safety issues such as location of restraints and panic buttons. Some staff questioned also could not interpret abbreviations (HTN and DM) on the precaution sheets, therefore did not appear to fully understand the exact risks for which they were monitoring patients. Patient schedules on Unit 9 indicate that Health Service Technicians provide groups such as the Community Meeting and Adaptive Living Skills groups. It was not evident where or how they receive training on how to run groups or the content of their group. Recommendations: a) Complete MANDT training as soon as possible for all direct care staff. 52 b) Include training or resources on group dynamics and specific group topics to all employees providing groups, especially Health Service Technicians who are likely to have no background or training in these skills. c) If staff members are to provide cross-coverage on units other than their own, basic safety training on alternate units should be provided. Any staff providing monitoring of patients should be made knowledgeable of abbreviations used to indicate risks/precautions. 12. Safety/Environment of CareFindings: Grounds appeared unkempt and overgrown, buildings were in need of maintenance and repair, and patient furniture was worn and damaged. This is significant as it perpetuates the impression that the facility is closing, which is reported to be a continuing factor in recruitment and retention of staff. The patient units created a difficult environment for patient observation and management. Angles, alcoves, hallways, and corners allow patients to be out of line of sight. While the other units had closet doors removed in all patient rooms, Unit 2 did not. On this unit, shoelaces, belts, and cords were also present. These together create a suicide risk. Bathrooms also had grab bars attached to walls. Also on the admission unit is an enclosed patio area on the interior of the building that is unlocked and designated as a smoking area. The entire flooring of this area is a low wood deck, which is not in good repair and could present a fire hazard from cigarettes. Recommendations: a) Step up maintenance/repair of the facility buildings and grounds to eliminate perception that the facility is closing. b) Evaluate the potential safety hazard of the wood deck smoking area. Also evaluate suicide risks on the only unit where closet doors have not been removed and patients are allowed belts, shoelaces, and cords. Risks associated with bathroom grab bars can be eliminated by installing current bars at an angle that extends to close to floor level, or by purchasing new bars with continuous connection with the wall the entire length of the bar so not to allow tying or slipping something between the bar and the wall. c) The physical environment as related to difficulties in patient observation may be hard to correct, however, risks can be minimized by the positioning of observing staff and moving patient telephones out of alcoves. In the admission area, when patients have not been assessed or evaluated for risks, they should not be left in an unobservable area, and their access to potential hazards needs to be limited. 53 13. Risk Management – Findings: Quality studies done by the hospital showed non-compliance with reassessment of suicidal risk for continued stay or before discharge. Review of charts supported a significant weakness in this area. One chart’s H&P indicated suicidal ideation with plan, but the patient was not put on suicide precautions, only line-of-sight observation. The treatment plan also did not reference any intervention for suicide risk. Another chart on a patient preparing for discharge had a risk assessment completed, but did not address the suicidal history of the patient. This is a vulnerable area for the facility when coupled with other risk factors. As requested, a specific focus on issues related to patient and staff assaults was conducted on this survey. Once again, leadership is commendably active in addressing the problem of patient assaults in a crisis management mode. Daily morning meetings report potential hot spots and review census levels and staffing needs for urgent actions. Human Resource’s aggressive hiring and orientation schedules is addressing immediate staffing shortages. On a larger scale, creation of the 24-hour observation units and crisis stabilization units are meant to address census levels and appropriate levels of care to better manage and treat patients. Based on the current situation, these are appropriate management moves, but also will stress the system further. Adding a large number of new, minimally trained and oriented employees to the system carries its own risks, including increased chance of turnover and increased statistical odds of untoward events. The creation of new services, as mentioned earlier, presents additional challenges to an already stressed system. Client injury rate is also a performance improvement project. It has been monitored and trended. Action plans included closer monitoring of patients, requesting medical reviews by physician, and clients receiving anger management and coping skills training. No “root cause” has been pinpointed. The following issues related to assaults were identified during the survey process, with some deserving further analysis and investigation. a) There is a correlation between census level and patient injury rate. The following chart visually represents how, when census levels reach above 5000 DACE a month, the rate of client injuries proportionately increase. Although this clearly represents that patients are at greater risk of injury when census levels rise, this fact by itself is not conclusive, as other variables related to increased census should be examined. For example, is staffing appropriately adjusted for increased census, do groups still occur as scheduled with increased activity associated with increased census, do treatment teams and clinical oversight by the physician occur at the same frequency when census rises, or does simple overcrowding on units contribute to volatility leading to client injuries? 54 Client Injury Rate as Compared to Census 800 6.00 600 5.00 400 4.00 200 3.00 0 2.00 -200 JUL AUG SEPT OCT NOV DEC JAN FEB MAR APR 1.00 0.00 -400 Monthly Variance from 5000 Patient Days Rate of client injuries/1000 patient days b) There is an unlikely correlation between number of seclusion and restraint episodes and client assaults. Although the low utilization of S/R is commendable, appropriate use would be a more acceptable outcome in the management of volatile patients than patient and staff injuries and assaults. The reason for not using S/R for de-escalation and management of aggressive behavior should be explored - is it due to lack of training (MANDT training is only 43% complete), an inaccessibility of S/R rooms and equipment, or a reluctance to follow and perform the extensive policies and procedures related to S/R, including the paperwork, physician and family notification, patient observation, and debriefings which are staff/time consuming? c) Since MANDT training includes verbal de-escalation techniques and crisis intervention to prevent S/R, the delinquent training schedule may be contributing to uncontrolled situations resulting in patient/staff injuries. d) Vacancies, turnover, and agency utilization contribute to instability and chaos on the units, as evidenced by the milieu experienced by the surveyors on Unit 10 vs. Unit 2. Although both are acute units, Unit 10 experiences incidents greater in number and severity. This correlates with the lack of physician leadership due to excessive workload (1 fulltime psychiatrist for 40 acute beds), high Health Service Technician turnover and RN workloads on this unit. e) Group activities not only are a component of treatment, but are also conducive to patient and milieu management. Group activities were both observed and reported by facility to not always be occurring, 55 especially on the acute units. This can contribute to patient boredom and volatility. f) Medication management, or lack thereof, was not noted to be an issue contributing to patient assaults; however, high physician workload could possibly be linked to inability to quickly address patient needs without thoughtful and thorough assessment. This is evidenced again in the comparison between a more stable Unit 2, with two psychiatrists, and a more chaotic Unit 10, covered by one locum tenens and whatever additional help could be arranged for him that week. g) Minutes from the Safety/Risk Management Council indicate that smoking “causes disruption among patients.” Elimination of smoking, in addition to being a wellness initiative, may present an opportunity to reduce problematic behaviors on the unit. h) Incidents of client injuries are tracked by a different subcommittee than staff injuries. This data should be correlated with a combined action plan. Recommendations: a) This facility is potentially exposed for suicide risk with non-compliance of use of the reassessment tools. The Medical Director and Administrator should set expectations for 100% compliance. Quality should continue to monitor. b) Quality should drill down further with data to determine why assault rates increase with higher census levels. Care should be taken, however, not to set a threshold too high at any census level for numbers of assaults without action or intervention. MANDT training should be completed. The hospital should continue daily monitoring of potential hot spots, staffing, and census by upper management. Further investigation should occur relative to the appropriate use of seclusion/restraint to prevent patient assaults. The facility needs to be cognizant of the high number of new hires for Unit 10, in that a disproportionate number of inexperienced and untrained staff will now be providing care on this unit. Coordinate tracking and action plans for client and staff injuries. CSH – MILLEDGEVILLE 1. Chart Organization and Content – Findings: Long term clients had thick charts, some with very old information. However, pertinent information which should remain was removed from some charts, including admission H&Ps and comprehensive psychiatric evaluations. One patient’s chart noted a positive PPD in 1992 with a note not to give another PPD due to a protein reaction, but there was no documentation of whether TB had been ruled out and no chest X-ray or follow-up testing. Because of the 56 amount of time elapsed, this is probably due to chart thinning rather than lack of follow-up, but this can not be stated definitively. Chart order did not allow for ready identification of legal issues. Forms were found in different sections of the chart authorizing continued stay or habilitation. Charts generally were better organized on Forensics than AMH, so it was easier to follow flow of medical and psychiatric issues on the forensic units. Some Nursing documentation in longer-term charts appeared clearly templated, with monthly notes identical from month to month. This was also seen with some behavioral documentation on the DD units; the notes were identical month to month. Social Service assessment uses a relativity new assessment form with a recovery section. This section was inconsistently used in the DD units, with some completely filled out and others blank. The surveyor was told on at least one occasion that this section was not applicable on the DD units, although it was observed in the chart to be completed on more than one occasion. The psychiatric history tab in the charts was a blank section. Staff stated that this was due to the creation of two new forms which incorporates the history into the unified assessment. Forms and documentation were not found to be divided into helpful sections, so locating information was difficult and time consuming. Infection control stickers were noted on some charts to alert of necessary precautions, however, their use was inconsistent and it was unclear whether they are updated or renewed periodically. Recommendations: a) Develop and/or adhere to a medical records policy that defines chart content for long term clients. Remove older documents which tend to clutter chart and make location of relevant information difficult. Critical information such as admission H&P, initial psychiatric evaluations, etc. should be left intact. Consider centralizing and assigning this task to Medical Record Personnel rather than unit staff who, without adequate training, unknowingly contribute to an inconsistent policy implementation of chart content and order. b) Maintain a consistent order to charts to readily allow locating documents. Tabs that assist with organization should be updated along with the forms found within them. c) Documentation on long-term clients may start with a template, but should be individualized and updated with current condition and status. d) Infection control stickers should be applied consistently, updated, and supported by chart documentation. 2. Programming – 57 Findings: Programming on Hopeway and Freeway provided treatment options to adult mental health patients. Groups were observed to be well run and engaging, group participation and content were noted as positive. Most patients were observed to leave the units to participate in the programming in the treatment centers. On the Child/Adolescent Unit, each patient reviewed had only limited hours of active treatment scheduled per week, but did have four structured hours of education per day. The school is operated by Masters-level teachers, and attempts were made to coordinate with the home/community school in which the patient is enrolled. It was noted from sign-in sheets that patients are allowed to opt out of groups, and many sheets showed blanks or documented that patient “refused” or was “unable to attend”. Charts showed documentation of encouragement to participate in treatment, but there was lack of follow-up by the treatment team and the physicians to formulate an intervention for the refusal of therapy and/or non-participation in group or school. There was a daily disconnect between the needs (group assignments) documented on the individual treatment plans and the census sheet, and the provision of services (group attendance) documented on the sign in sheets. In the unit secretary’s office, there were large piles of sign-in sheets and other documents, not filed and in disarray, suggesting a lack of monitoring, coordination and oversight. The policy for active treatment programs/monitoring does define a process for addressing noncompliance, but allows for participation in only one treatment program daily. There was no substance use/abuse programming noted for C/A. A variety of off-unit activities were available for the DD population, including work and therapeutic programs. Groups were well run and started on time. Patients were encouraged to participate and staff interacted well with individuals. However, many groups, both on and off the units, did not seem to have specific goals. Others had goals, but they did not necessarily relate to treatment objectives. This was not due to the quality of the group, but rather a documentation/planning deficiency that could be readily corrected. For example, a patient may have a treatment objective to be able to pick up and hold specific objects such as a toothbrush, coins etc. This objective of improving patient’s grasping abilities could be assessed and monitored in group therapy if the treatment objectives were more generic and the patient was encouraged to hold pen, paintbrush, etc in the arts and crafts group, and their progress monitored and recorded there. The Powell building is designated as adult mental health, however it often contains a mix of patients. On the daily census, several patients were classified as “detox” and “A&D” (alcohol and drug). In addition, jail hold patients were often housed on Powell, disrupting the milieu and unable to attend groups in Hopeway. 12 step groups were not available, and there were only minimal substance abuse groups. 58 Recommendations: a) Define a procedure for addressing non-compliance with group attendance, such as discussion in treatment team, active interventions, etc., with chart documentation reflecting actions taken. b) Enhance substance use/abuse/addiction programming on all units. c) Particularly on the DD units, but relevant to programming everywhere, assure that goals of group therapy relate to individual patient treatment objectives so that group therapy providers can monitor, evaluate, and record progress that is useful in the overall evaluation of patient progress. d) Incorporate as much information as possible into the formulation of behavior plans, including progress notes, group therapy notes, treatment team feedback and discussion, and physician evaluations. Expedite the implementation of behavior plans to maximize benefit of interventions. e) Effectively use the model of treatment choice and options that have already been created on Hopeway and Freeway to address the mixture of populations/diagnoses on the units (particularly Powell). For example, if forensic “holds” continue to be housed on Powell, Hopeway programming could provide groups targeting this population. Powell patients with a primary diagnosis of substance abuse or addiction could opt out of mental health groups in the Hopeway Treatment Mall in favor of recovery programming if these were made available. 3. Physician Documentation – Findings: Special observation/ precaution orders were not consistent with admission diagnosis or initial assessments. Physician documentation supporting the use of antipsychotic medications was absent on several patients, and others lacked documentation of attempts to reduce the dose. On the Child/Adolescent Unit, physician progress notes were scanty and did not appear to be daily. One chart was noted not having a physician progress note for 7 days, and only 4 in an 11 day period. Rationale for medication use was absent in the physician notes of charts reviewed. Physician signatures were lacking on Treatment plans and telephone orders. Physician progress notes related to lab findings or diagnostic testing were rare. Use of abbreviations not on the approved list was noted, and staff was unable to interpret. Some sections of the Physician Admission Assessment forms were not always filled out, most notably the Risk section. Recommendations: 59 a) Improve documentation supporting the use of medications, including purpose, rationale, intended effects, justification for combination/dosage of drugs, and contraindications. b) Insure that admitting orders for special observation or precautions are consistent with admission diagnosis and initial assessment. Although this issue is addressed under physician documentation, this also could potentially be impacted by adding a nurse to the admission unit, who could assist the physician with the clinical assessment and alert the physician to special observation needs, requesting appropriate precautions to be ordered. c) Adhere to standards for progress note documentation set by the medical staff rules and regulations. On some units, this may take additional medical staff before this can be accomplished, on other units (C/A) it is a matter of monitoring and enforcement. d) Physician signatures lacking on treatment plans and telephone orders should be flagged for completion. e) Conduct an education campaign for the elimination of prohibited abbreviations and use of approved abbreviations. Make some kind of accommodation for agency staff to have access to this list (currently in the computer system to which they do not have passwords) so that nursing can assist in monitoring compliance. 4. Seclusion and Restraint – Findings: As in all previously reviewed facilities, use of seclusion and restraint was very low. C/A reports no restraint use in the past 10 years. However, increased use of “stat” or PRN medications could suggest the use of chemical restraints. Most charts on Binion were deficient in at least one type of documentation for seclusion and restraint, including family notification, plan of care, debriefings, revision in treatment plan, and signatures. Manual restraints reviewed on Phoenix were done well and very thoroughly documented. Complete documentation for the use of protective devices was not always present, including reasons for use, consents, and orders. Mittens on DD clients were observed to be appropriately ordered to prevent patient from licking medications off their hands. Other uses of mittens, however, could be interpreted as a restraint when used to keep a patient from “mouthing her hands”. In these cases, procedures for restraints were not followed and behavioral plans were not in place to address reduction of behavior. Surveyors were present on units during more than one code yellow, and staff responsiveness was very good, including physicians. The Nursing Assessment only lists four options for what patient can choose as interventions for “what would help you if you lose control” – 1. Go to my room, 2. 60 Go to quiet room, 3. Go to Seclusion Room, or 4. Be restrained. Patients need more positive options. Recommendations: a) Evaluate “STAT PRN” utilization to assure that medications are not being used as a chemical restraint. b) Expand options presented to patients on admission and recorded in the Nursing Assessment that are interventions that the patient can choose for “what would help you if you lose control.” Currently listing only “1. Go to my room, 2. Go to quiet room, 3. Go to Seclusion Room, or 4. Be restrained”, patients need more positive options to choose from. c) Treatment teams could be used as a method to monitor completeness of seclusion and restraint documentation. On short term units, this would be possible in routine treatment teams. On longer term units, the use of seclusion or restraint may be used as a trigger for an unscheduled treatment team, serving a dual purpose of documentation monitoring and providing an opportunity for treatment plan evaluation/change in response to the use of seclusion and/or restraint. d) Review policy and training for the use of protective devices on DD persons, clearly defining the difference between behavioral restraints and protective devices. Integrate behavior plans into the use of both of these interventions. 5. Medical Management – Findings: Of significance and certainly worth noting, the patients at CSH present with the most severe mental illness and medical complexities of those seen in the state system, and these two factors by themselves present significant challenges in the evaluation and treatment of these individuals. Additionally, when these factors are coupled together, issues of difficulty in diagnosis and treatment resistance and/or non-compliance in the management of their disease are also presented, and exhibit themselves in physical symptoms, status, and long term treatment success/failure rates. The surveyors were aware of the difference in acuity of patients in this facility, and recognized how this reflected in the overall evaluation of care. With this in mind, however, the lack of a staff internist or consulting physician to address patients’ physical needs becomes more striking, and was evident in the medical management of patients, especially of the more difficult or challenging patients. Notably, there were some charts with lengthy medical problems that were thoroughly addressed with appropriate consults with prompt follow up on all recommendations made. One chart showed excellent control of seizures in a patient with complex medical problems. Another chart exhibited excellent pain scales, with intervention and response with medication as appropriate until pain was resolved. A good relationship with the local hospital, Oconee Regional Medical Center, existed for emergency care. Difficulty referring for specialized consults to address advanced treatment needs before they rose to the level of emergency care, however, was absent. History and physicals are performed by 61 the admitting physician, and not by an internist or family physician, with no evidence of follow-up by consultation with a specialist even in cases of medical complications. Some of the specific issues that follow here in relation to medical management would be well addressed through the use of family physicians or internists on the medical staff serving in a consultation capacity. Several issues were noted related to diabetic care. The sliding scale approach is used throughout the organization, even in the long term population, and it is not consistently implemented or well documented. Scales and related dosages differed, patients were noted to frequently refuse finger sticks, scales were only done on alternate days, all contributing to less than optimal diabetic management. This was also evidenced by many diabetic patients having high hemoglobin A1Cs (>7%), and some patients consistently having fairly high fasting blood sugars, indicating inadequately controlled diabetes. Orders were frequently seen to notify a physician only if blood sugars were <50 or > 400, so routine glucose levels of 300 on long term patients often went unnoted by a physician without a change in insulin therapy. Abnormal glucose levels obtained through bedside testing (fingersticks) were not always confirmed through laboratory testing even when values were above reliable readings on the glucometer. In addition to refusals of glucose monitoring, there were refusals of medication documented. Non-compliance with medical care is challenging and poses a real dilemma to optimizing care for this patient population. Monitoring of glucose levels and documentation of medical issues frequently associated with diabetes was frequently absent in the charts reviewed. One diabetic patient had blood sugars ordered monthly, but no value could be located for May or July, and the value for June was high at 171. Multiple other reports on the chart dating back a year made it difficult to locate current data. Diabetic retinal care and foot care was not well documented. There was also a lack of nutritional correlation with glucose levels; diet content was not recorded as per nursing policy. Another general area of care which was problematic was in the treatment and management of hypertension. Orders were noted to “hold blood pressure medications” when a systolic pressure fell below parameters, generally below 100, however, there were no further blood pressures ordered later in the day to reassess the effect of holding medications. There were occasions noted where blood pressures were elevated later in the day and the medications were still held. Most of these incidents involved the holding of more than one medication. When medical consults or additional diagnostic testing were ordered, prompt follow-up on consults/testing was not always present. Several charts with abnormal tests or monitoring of drug levels had no further documentation of a recheck, or follow-up in progress note or physician orders. Pharmacy and 62 neurology recommendations of checking therapeutic drug levels and performing an annual review were not completed. Standing lab orders to periodically check medication levels were noted not to be always done in a timely manner. Some diagnoses were inadequately supported by discussion or formulation. Patients with the diagnosis of “dementia” had no documentation of MMSE or any other instrument to evaluate cognitive function. There was no documented metabolic work-up found in the charts to assess the reversible causes of this illness. Other DD patients with psychosis NOS and autism had no supporting documentation as to why patient was labeled with this diagnosis. On Phoenix, several charts showed repeated diagnostic conflicts between chart forms. No documented pacemaker checks were found for patients with pacemakers. Substance abuse assessment and treatment was weak, as it has been consistently throughout the surveyed Georgia hospitals. This diagnostic category was not specific or consistently related to clinical presentation. Diagnosing substance use vs. substance abuse vs. substance dependence is important in deciding treatment modalities and in the end, good recovery. There was an absence of risk factors associated with withdrawal documented in the chart, and medical issues commonly associated with substance abuse were also left unevaluated. Surveyors noted increased incidence of decubitus ulcers on Craig. (Also addressed under PI sections and Staff Training section) Nutritional assessments do not appear to address nutritional considerations as related to skin integrity. No standing orders were found for PRNS, which was commendable. Use of multiple antipsychotics simultaneously was observed, and there was no documentation to explain the purpose of the medication combination or dosage. Supporting documentation of justification or rationale for use was noted to be lacking in several charts. Medication reconciliation, a recent JCAHO initiative that assures accuracy of medication tracking from prior to admission (“home list”), through hospitalization, including transfers between units or facilities, to the discharge of the patient was not noted. The practice was not observed in the charts, nor were there forms or policies that supported the process. Routine checks and performance of Fleets enema for prevention of bowel impactions were observed in chart documentation, but no notes reflected attempts at evaluation or alleviation of the problem by medication adjustment or diet changes to relieve constipation. 63 STD testing on patients with high-risk sexual behavior was absent on several charts. On other charts, patients who tested positive for syphilis were not further tested for other STDs such as HIV. Recommendations: a) CSH could clearly benefit from the addition of family physicians, internists, or perhaps other specialists to practice at CSH in their specialty; currently they are used mostly to substitute for attending psychiatrists on the units. At the very least, executed contracts for family physicians/internists or specialists for routine and advanced medical consults or treatment would expedite proper medical care for complex situations. b) Several recommendations are made in the management of hypertension. When medications are held due to low blood pressure readings, reassessment should occur at least once per shift and findings relayed to the physician if abnormal. If blood pressure continues to be low for more than two days, then re-evaluation of medical regimen and/or status should occur. This can become especially crucial when using beta-blockers and centrally acting anti-hypertensives because of their potential adverse effect caused by abrupt withdrawal. Overall, anti-hypertensives are complex agents requiring skilled medical direction, direction that is beyond the routine skill set of most psychiatrists. This again suggests the need for staff physicians or contract specialists who manage the medical needs of the patients. c) Some of the behavioral problems associated with dementia could be addressed by the prompt use of a combination of a cholinesterase inhibitor and a NMDA receptor antagonist (i.e. Aricept and Memantine) instead of adding a neuroleptic. d) Protocols for the management of the diabetic patient need to be established and/or followed. This should include but not be limited to foot care, retinal care, frequency of Hgb A1C testing, interventions for refusals of both testing and medication, and more specific procedures to follow for abnormal test results (both glucometer and lab results). Use of the sliding scale approach should be limited and not applied to long term management of diabetes. When the sliding scale is used, the facility should standardize its use. The use of a flowsheet or the establishment of a diabetic care team may be considered to address this problem. e) Procedures for the diagnosis, medical management and treatment planning for the substance abusing/chemically dependent/substance using patient need to be better defined, including identification of risk factors for withdrawal and the medical complications commonly associated with these diagnoses. f) The increase of decubitus ulcers on Craig should not be dismissed with the recent QI study conclusion, and efforts should continue to reduce the occurrence of bed ulcers. g) A procedure and associated training for “Medication Reconciliation” needs to be established and implemented. 64 h) STD testing should be done routinely on patients with high risk sexual behaviors, or if already testing positive for one STD, additional testing for others should automatically follow. i) Although bowel management seems to be effective through the use of routine/regularly scheduled enemas, evaluation of causative factors of constipation should occur and be documented along with the interventions taken to prevent bowel impactions. Alternatives to routine Fleets enema should be considered. j) A method to ensure follow-up of diagnostic tests, abnormal labs, and consultation recommendations must be established. This could be addressed in a variety of ways, including a focused QI project, inclusion in Treatment Team discussion, assignment of duty to a specific shift/staff member, change in chart order to highlight new test results, etc. 6. Utilization Management – Findings: For the DD population, de-institutionalization is appropriately proceeding, to help patients live in the least restrictive environment; however, the supports in the community for crisis intervention do not appear adequate to handle the normal behavioral variability of DD persons. This leads to premature and/or unnecessary admission to CSH, disrupts the lives of DD persons, and conflicts with patient’s rights to live in the least restrictive environment. Also, if individuals are no longer dangerous to self or others, justification may not exist to continue the level of care in an institutional setting versus a community setting. APS tracking data indicated an increase in unauthorized days from March – June of 2007. The UR Coordinator indicated that this was due to a data entry problem rather than a true issue. As in other facilities, APS data was not necessarily used for justification of the establishment of the 23-hour observation unit. The unauthorized admissions to inpatient units were not seen as the potential admissions to the 23-hour observation unit. Data from a Performance Improvement project on 30-day readmission rate was referenced as support for the creation of the 23 hour Observation Unit, and readmission rates are expected to decrease. The unit is too new to have data to support or refute this supposition. Criteria for differentiation between admissions to inpatient vs. admissions to 23 hour observation have been created. On the day of the survey, a patient was noted to have been in the observation unit for well over 24 hours, actually approaching 48. This was against policy. Though APS data are tracked and compared to other facilities, information such as number of unauthorized days or length of stay per physician is not used for internal utilization management. The usefulness of this data system is questionable in light of staff report that it is very labor intensive. Recommendations: 65 a) Many patients on the maximum security unit have been referred in by other psychiatric hospitals or prison systems due to out of control behavior. CSH then takes responsibility for their discharge and is largely unsuccessful in referring them back to or placing them in their respective community system. A system should be developed whereby if CSH admits and stabilizes the patient, they must be accepted back to the referring hospital into a lower level of care or for pursuit of continued placement in their home community. b) Enforce compliance with no more than a 23 hour stay in the 24 hour observation unit. 7. Treatment Plans and Team – Findings: Treatment Teams were attended on Binion, Freeman, Crittenden, Powell and Piedmont. Forensic treatment teams are held on admission, every two weeks for two months, once a month for the remainder of the first year and then quarterly thereafter. Morning team on Binion was fully attended by all disciplines which were knowledgeable about the patients, including their diagnoses, clinical conditions and changes, and forensic status and plans. The team discussed patients’ complaints of pain with appropriate interventions. Patient’s participation in team discussion was minimal, and was not encouraged by active listening or response to patient comments. One patient appeared sedated, slow in movement and limited in responsiveness, so his involvement was minimal. The afternoon team was missing Activity Therapy due to staff vacancies. It too was well run, with the patient spending a considerably longer time in the meeting and participating at a much higher level. The team was very recovery oriented and provided individualized approaches to each patient’s care. Freeman’s team meetings were also done well with team and patient engaged in review and planning. Team on Powell was also well run with good patient participation. Nursing led treatment team on the C/A unit with good interdisciplinary input. Staff displayed detailed personal and clinical knowledge of the patients discussed, and they did an excellent job of individualizing each child’s plan. As discussed under programming, however, there is no defined procedure or system for establishment, monitoring, and response to minimum treatment hours/involvement either for the unit as a whole or per child. Treatment plans throughout the system were often lacking in inventory of patient strengths and needs. Although progress notes were generally good, there could be better correlation between the progress note content and the development or adjustment of the treatment plan, especially on C/A. Patient signatures were lacking on many plans. 66 The Piedmont Team meeting was well conducted and appropriate to the client. Family was notified but unable to attend. Staff indicated that they would be notified of the findings, and recommendations. On the DD units, treatment plans were not always consistent with the Client Centered Planning document, and staff confirmed that it was referred to on admission and then upon transitioning., indicating that it is not always integrated into the treatment plan while at CSH. Medication reduction strategies were not noted on any treatment plans reviewed. Behavior Plans were noted to not always be updated, reviewed, or implemented as directed. Treatment plans were noted that did address medical needs of terminal lung cancer and a fractured jaw. Pain assessments showed good follow-up and interventions. Recommendations: a) Coordinate treatment plans with client centered planning, so that this is not only referred to on admission and discharge, but all through the treatment process b) Use treatment team to address issues of non-compliance with medication and/or group therapy participation c) Use progress notes in the formulation of the treatment plans 8. Patient and Family – Findings: Medication consent forms listed as many as six different medications on one sheet with the patient’s signature. This would theoretically allow adding medications after the patient has already signed. Medication consents were also found unsigned by patients on Freeman and by parents on Crittenden. More significantly, the consent form provides no evidence that actual risks, side effects, benefits and alternatives were actually discussed with the patient, thereby confirming that consent is actually informed. Chart evidence of involvement of family in the treatment of Children and Adolescents was limited to signatures for consent for treatment and a medication change being discussed with one mother. Charts in Phoenix exhibited excellent involvement of family including informed consent and education of effects of medication, even when parents were not legal guardians. Visitation areas were observed on all units, providing privacy in a safe environment. Visitation times were somewhat limited, especially considering the state-wide referral base of CSH. The admission area for all patients was detached and “sterile”, with a separated glass viewing area with metal detector that all patients passed through before 67 being allowed staff contact in the building. This left an impression inconsistent with a recovery philosophy. By its own report, the facility lacked a “patient advocate” or “consumer specialist” position, although they did hire former patients and had employees acting in the capacity of responding to patient/family complaints. In staff interviews, the process of the investigation was explained to be mainly information gathering. If the result was the generation of a CIR (Critical Incident Report), the process continued through Risk Management channels. If no CIR was necessary, the information was given to the Clinical Director of the unit involved, who responded to the patient/family and was also responsible for addressing any problem identified. There appeared to be no closure to the loop to insure that appropriate actions had been taken to address the specific complaint, or to identify the problem as a quality issue that needed further follow-up. Recommendations: a) Revise the patient consent form for medications so that each medication entered has the date and signature only for that medication, and allows for evidence that patient was informed of the risks, benefits, side effects, and alternatives. b) Especially in light of the huge referral base for CSH, make sure that visiting hours are adequate to allow families time for visitation, or clearly communicate that accommodations can be made outside of posted hours if prearranged. 9. Training/Staff Development – Findings: Staff on C/A did not know what a “developmental assessment” was. Nursing staff on Phoenix believed it was a policy violation to leave the inner cabinet door in the medication room unlocked (as it was found). However, upon review of the policy, this practice was allowed. MANDT training has been progressing according to the planned timetable despite scheduling challenges created by staffing shortages which make it difficult for staff to leave units to attend training. Review of skin ulcers on Craig revealed a misidentification of a stage two ulcer. By chance, three of the five employee files reviewed involved staff that were or had been transferred between units. Training records were not observed and could not be presented that showed basic safety orientation had occurred. Recommendations: a) Retraining may be indicated in the identification of skin ulcers. 68 b) For staff that transfer between programs and for staff that regularly function on multiple units, namely “on-demand Health Service Technicians,” unit specific orientation should occur timely and be documented 10. Safety/Environment of CareFindings: Although this facility is older than the other state buildings, surveyors were impressed with the many safety and aesthetic factors that had been addressed to make the environment more safe, pleasing, and functional. A suicide risk assessment of all patient bathrooms had been conducted and many renovations had already occurred. This included plumbing, stall door, hinge and partition modifications. Other risk factors still existed, however, some in the same rooms where these other modifications had already occurred. These included such things as grab bars and tile soap dishes with handles in shower and bathroom areas. Less expensive measures such as discontinuation of use of plastic bags in patient areas and elimination of telephones with removable cords and wires had also not been taken. Belts, shoelaces, and cords were evident and still allowed on most units. On some units, TVs and other audio visual equipment were secured in response to a previous incident in order to eliminate breakage or tipping with resulting injury, however the use of carts with the same equipment was still being utilized by staff when bringing in videos to groups. All such equipment should be stabilized or eliminated so that this hazard is eliminated. Lightweight chairs were present in group areas of the Freeman unit, which could easily be picked up and used as weapons. In a group setting, this is even more dangerous as more than one patient could get involved and create and unsafe situation. With the exception of one unit visited, patient rooms were well kept, neat, and clean. Long term patient rooms were homelike and personalized. The exception was the 1st floor in the Allen Building, where rooms and bathrooms were disorderly and unclean. Some computers were noted to be over 10 years old. Agency staff cannot fully utilize computers (not given passwords), resulting in limited access to information such as approved/prohibited abbreviations, policies, etc. Much needed bathroom renovations on the first floor of Allen were in progress. Interim Life Safety Plans were in place. The newly renovated area still requires benches or chars for disabled clients in the shower area. Notably, this was the only area on the facility safety walk-through where an unlocked door which should have been locked was found. The unlocked door was a laundry chute that was open. This is remarkable and very positive, considering the literally hundreds of doors in this old facility and the frequency of this occurrence in the other facilities surveyed. 69 It was commendable that with the exception of a few long term residential clients, this was a non-smoking facility. Fresh air breaks had replaced smoking breaks, and patios originally provided for patients to smoke on had become outdoor porches. Recommendations: a) Evaluate the use of lightweight chairs in group settings due to the ability to be used as weapons. A short term fix could be attaching chairs together so they cannot be lifted. b) Easily removable hazards such as telephone cords that can be detached and plastic bags should be eliminated from patient areas. Belts, shoelaces, and removable cords should also be eliminated, limited and/or closely supervised. c) Review areas where physical renovations and safety modifications have already occurred to identify remaining hazards that create an unsafe environment. d) Secure TVs and/or eliminate audio/visual equipment on carts to prevent tipping with potential injury to staff and patients. Technology allows for remote access of equipment for videos if necessary. 11. Nursing Practices– Findings: There is no point of distribution system (Pyxis) for medications, although systems are in place to limit floor stock, monitor controlled substances, and prevent stockpiling. There is no pharmacist verification prior to med administration after hours (nights). The medication is verified by the physician, and the pharmacist on call can be contacted if necessary. Policy indicated that multi-use vials of insulin could be used till expiration date. This practice is questionable and deserves further investigation as most multiuse vials expire 28 days after opening. Multiple medication rooms and medication carts were inspected, and most bulk OTCs, controlled substances, and medications were in order with none expired. However, one medication room had a plethora of expired medications and food products, some with dates as old as 2005. These were removed immediately. New medication sheets are only printed every 90 days, so orders that are placed on the patient charts are not always reflected as current. Recommendations: a) Review policy of expiration of multi-use vials once opened to insure that it is consistent with manufacturers’ specifications. b) Establish a nursing policy and practice for inspection of expiration dates in medication rooms. No expired medications or supplies may be kept in the unit medication rooms. c) Consider printing new medication sheets more frequently than every 90 days to reflect current orders on the chart. 70 12. Staffing, staff morale and attitude – Findings: Staff morale is positive despite shortages in staffing on most levels and other challenges presented by the system. Generally, there seems to be a team spirit in addressing problems. There is an impression by staff that there is a commitment to improved quality, and in fact, they feel that patient care has improved over the last several years, with recognition that they still could do better. Genuine caring was exhibited by staff, and they generally appear attentive to the needs of the patients. The most frequent response by personnel queried to identify the facilities number one need was staffing, both in quality and quantity. Other concerns expressed by staff potentially affecting morale included excessive and inefficient paperwork, patients being admitted who were inappropriate and/or medically unstable, and old/outdated computers As in the other facilities, vacancies occurred throughout the institution on many levels. Human Resource data showed significant vacancy rates for Nurses, Techs/CNAs, Physicians, Psychologists and Behavior Specialists, Pharmacists and Social Service Providers. Also as in other facilities, a large number of employees have very long tenures, and their imminent retirement threatens to only exacerbate staffing problems in both numbers and by loss of these highly experienced, committed and skilled staff. Excluding supervisor, charge and management positions, data show that the facility operates with only 20% of their line staff nursing positions filled, with shifts covered either with agency nurses, through the use of mandatory overtime, or with supervisors performing clinical duties in addition to their administrative functions. Nursing shortages were evident in practice throughout the survey: the Admission unit was run by a non-nursing professional, there was only one RN assigned per building for 2nd and 3rd shift, staff complained of mandatory stayovers (overtime) to cover shifts, and supervisors being called suddenly to cover a shift due to an unexpected call-in. The position of “Team Leader” attracts nurses away from nursing positions due to higher pay scale, although a nursing degree is not required. This depletes the internal nursing pool and adds to the shortages. With a lack of forensic psychiatrists, the Clinical Director meets weekly with the medical staff consisting of a general psychiatrist, a neurologist, two surgeons, and an anesthesiologist, and a sole forensic psychiatrist for supervision and case review. While the non-psychiatrists had considerable institutional longevity, the lack of medical specialty expertise in Psychiatry and especially Forensic Psychiatry was striking. Child/Adolescent was the most adequately staffed with a C/A Psychiatrist and a general psychiatrist. 71 An “on-demand” Health Service Technician pool was created to readily provide staff as needed to cover scheduling needs created by acuity or call-ins. This is essentially a PRN pool that reports to work and is assigned as needed. Although this is a creative way to address staffing needs, it also points to the frequency and volume of unfilled shifts, call-ins, and increased acuity needs. The qualifications, experience and background of Health Service Technicians continue to be of question as the primary caregivers in this environment. All individuals with a DD diagnosis need to have a QMRP (Qualified Mental Retardation Professional) involved in the program design and implementation of their treatment. This is true whether they are in an ICF or Nursing Home environment. It was not evident that this was the case for patients in the Craig Building. The unit secretary on C/A was backlogged on filing and shredding duties due to other responsibilities such as greeting visitors, answering phones, entering computer data, and performing forensic and human resource paperwork. As noted earlier, this contributed to lack of treatment coordination in monitoring group participation and compliance. One psychologist for 192 forensic patients is not adequate and contributes to a backlog of evaluations and slows the legal process. Pharmacy staff members are operating with almost half of budgeted positions unfilled, and hiring is practically nonexistent (last hire 20 years ago). Pay and call requirements make recruitment difficult. Looming retirement schedules make existing staff relatively short term. Recommendations: a) Address staffing shortages in all areas with an aggressive recruitment plan, including examination of salary levels to remain competitive. Although all areas are in need of attention, physician staff, nursing staff, psychology and pharmacy appear to be the most critical areas. Awareness of the impending retirement and continuing loss of long term experienced staff is essential. The relatively rural location of the facility should also be factored into the ease/difficulty in recruitment. b) Consider restructuring the pay of Team Leaders so as not to attract Nurses out of staff/management positions depleting the nursing pool internally. c) Staff the admission unit with an RN will improve the admission process and eliminate potential risk issues. Facility data shows the average time spent by patients in the admission area is 94 minutes. This reflects 94 minutes without health professional assessment and oversight, and the inability to take orders from a physician. d) The scheduling pattern of only one RN per building for 3-11 and 11-7 shift is inadequate. 72 e) Consider letting the staffing coordinators who manage the Health Service Technician “on-demand” program also handle nursing staffing, relieving Nurses of this responsibility. This would be particularly helpful to Nurse Managers who perform administrative and line staff duties. f) Review staffing to insure that QMRPs are appropriately involved with DD programs and persons. g) Look for staffing efficiencies in the system. For example, there is an extra layer of supervision between the Nursing Manager and the Nurse Executive on the C/A unit. Considering the significant downsizing of institutionalized patients over the years, coupled with the number of long term employees, this suggests that some employees may remain in “layered” positions that are no longer needed. h) Create efficiencies with upgraded computers and technology, which also will contribute positively to staff morale, as this issue was frequently identified by staff as a frustration. 13. Risk Management – Findings: Treatment team on Binion was conducted with the patient sitting by the only door in the room, effectively preventing staff exit. Considering the violent histories of these patients, this is unadvisable. On the C/A unit, it was noted that there were two patients that shared the same surname. Policy for client identification requires “Name Alert stickers” be placed on stamp plate only, which is inadequate to prevent patient mix-up or confusion of charts themselves or other forms/documents. The safety system for patient observation and privileges did not always correlate with patient clinical condition or status. Clients on less restrictive levels were observed to still have documented high-risk behaviors. This disparity was also seen later in patients with longer lengths of stays, where privileging did not match level of behavior. For example, patients who were allowed to attend activities off the unit with minimal escort or supervision did indeed have these privileges granted, but this was inconsistent with their documented aggressive behaviors or levels of observation status. It was noted both by observation and by review of policy that staff who have regular patient contact are allowed to wear heels and open-toed shoes. In general, this is unadvisable for patient care areas and especially in an environment where patient-staff assaults occur. Issues related to patient assaults were encountered by surveyors frequently throughout the survey, as these were noted during discussions at treatment teams, documented in charts by medical conditions that were a result of an assault, seen in the review of incident reports, and one surveyor witnessed an attack on a physician. The issue of the lack of admission orders for special observation and precaution is relevant here, as sometimes precautions were 73 implemented after an event, which may have been prevented if orders had been issued earlier. Surveyors requested to review a sampling of CIRs (Critical Incident Reports) to include examples of incidents of patient-staff assaults, patient-patient assaults, suspected or alleged abuse, attempted suicides, falls, and medical conditions that escalated and required transfers or emergency care. An example of an RCA (Root Cause Analysis) was also requested to review. The intent was not so much to examine specific incidents themselves but rather the process in place for investigation, action-plan formulation, and follow-up. CIRs were found to be minimal in write-up of investigation of causative or contributing events or factors, or actions taken to address reoccurrence. Appropriate actions were taken when an employee disciplinary process was indicated, including suspensions and terminations; however, from a quality perspective, there appeared to be lost opportunities for improvement. On the DD units, a number of “unobserved” or unknown incidents were reported, and CIR reports were also noted to conclude that incidents were “unpreventable.” Incident reports deemed to need further review are sent to an IAT Team (Incident Analysis Team), however, it was not clear how these were identified and meeting records. Meeting records reflect only 7 meetings thus far this year, once in January, twice in March, then once again in April and June, and twice in July. Minutes reflect minimal review both in quantity and quality. Root Cause Analysis (RCA’s) were likewise found to be very scant in data, analysis, and outcome. It was apparent from examination of documents and interviews with staff that there is a disconnect between Risk and Performance Improvement. The closure of the loop in the investigation of incidents did not always occur, insuring thorough investigation and follow-up and evaluation of the implemented action plan. Another committee called “FMEA” (Failure Mode and Effects Analysis) conducts studies and tracks occurrences over a longer time period. Studies in progress through this committee include “hand-off communication,” patient falls and manual holds. Some of these data have been tracked for over two years. Staff is proud of the efforts of this committee, and cites good relationship with the local community hospital and decreased falls and manual holds as positive outcomes. Recommendations: a) Review policy for “name alerts” for occurrences of multiple patients with the same name to adequately prevent mix-up. b) When meeting with patients, either alone or as a group, advise staff to routinely position themselves so that they are not prevented exit from a room or area. c) Review dress code for appropriate footwear on units by caregivers. 74 d) Patient’s level of observation and/or privileges must coincide with their clinical condition or status. This occurs both on admission and with continued stay. e) Process of Critical Incident Reports (CIRs) and Root Cause Analysis (RCAs) should be improved to reflect a thorough investigation of incidents from a more global perspective, one that would prevent similar incidents from happening again, rather than just an “at fault” investigation that addresses an employee performance problem or specific issue. Areas that should be addressed in all investigations include but are not limited to staffing levels and ability to observe the population at the time of the incidents, when and where incidents are occurring, whether precaution levels match patient status and whether they are being followed at the time of the incident, procedures and reporting measures that would identify injuries or harm immediately, and impediments to the reporting of incidents. Although investigations can be lengthy and time consuming, in the long run this could help to prevent or limit future occurrences and improve patient and staff safety. Better coordination between Risk Management and Quality Performance could lead to better system-wide management and outcomes. 14. Quality Program – Findings: Several Performance Improvement Committees and studies were in place with extensive data collection and tracking occurring. Nursing Performance Improvement operated with a calendar to rotate studies by month in several key areas. These included client ID, shift reporting, pain management, documentation, assessment and seclusion and restraint. Other key aspects of care were monitored monthly without rotation, including mediation administration and end of life protocol. Performance Improvement teams and focus groups addressed specific issues. The Client Safety Committee monitored other indicators. A plethora of data was contained in charts and graphs from various studies. Although most of these efforts were with merit and well presented, it was somewhat difficult to track how this information was channeled through Leadership, coordinated, acted upon, applied to the whole institution and followed up on. Data are appropriately tracked and cross-referenced with other variables to note correlations or impact of variables. One notable graph contained a comparison of seclusion and restraints against stat/PRN utilization and against staffing ratio by unit. No correlation was noted so no specific action was taken. However, there has been a notable increase of stat/PRN utilization over the last year. Recommendations: Quality does an excellent job at collecting and presenting data. The followthrough and action plans associated with these data are not always as well documented as the initial findings. The Quality program should analyze it’s own process of Leadership reporting, communication and coordination with Risk Management, and methods of follow-up on the effectiveness of action plans. Coordinated efforts can maximize the effectiveness of quality initiatives system- 75 wide. Because data collection can be time consuming, limit to high risk, high volume, and problem prone areas, and insure that the data are fully analyzed and utilized for improvement. Re-examine benchmarks or baselines for indicators of when investigations, interventions or follow-up is needed. NWRH- ROME 1. Chart Organization and Content – Findings: The organization of charts was inconsistent, with section dividers or tabs inserted in different order. In addition there were several charts where no information was found behind some of the tabs. There was an inconsistency in chart order, with physician orders in reverse chronological order, while progress notes were in chronological order. As generally found elsewhere, shorter-term patient charts were easier to navigate than longer-term patient charts. Some long-term charts were very large and contained old information that was unrelated to current patient status or care. This made it difficult to track clinical progress and find new and relevant information, especially current medications and medications on admission. Annual physicals, functional assessments, and psychiatric evaluations dated back to 2001, yet Social Work evaluations sometimes referred to previous assessments that could not be found on the chart. There was inconsistency between charts in what was kept and what was not. Paperwork on transfers from other facilities was located in various places and sometimes duplicated throughout the chart. In addition, there were a number of documents found in several charts that were questionable in their pertinence, for example, multiple photocopies of the same page from a telephone book. The DD units had two charts per patient, one designated as “medical” and the other as “legal.” This was found to be cumbersome in tracking patient progress and clinical care. For example, treatment plans were in one chart, progress notes in another. Forms were also inconsistently filed between the two charts. The monthly and/or the quarterly QMRP reports were not found in the chart on several DD units. While these were provided to the surveyor upon request, they were found in a stack of reports that were not filed rather than in the chart. Short-term charts were generally better organized, with the AMH charts being slightly superior to the Forensic charts. The Treatment Plan Problem List and the Interdisciplinary Education Record were found to be helpful. Peel-off and sticky forms were used for standard documentation, including refused medications and pain scales. These seemed to work quite nicely. It was noted, however, that on occasion, these notes were hole-punched after being completed and put on the chart. This made some documentation, including in some cases the signature, illegible. 76 There was some duplication of forms noted, both on the pre-visit document request and as utilized in the chart. It appeared that outdated or replaced forms were not removed from circulation when the new ones came out, and thus continued to be used. Vital sign sheets were one of these, where the newer one included waist circumference measurement and the older one did not. Some unapproved abbreviations were seen in charts, for example “QD” for once daily, and “RD” for redirection on a behavioral tracking sheet where RD was not given as an option in the legend. Recommendations: – a) Establish a consistent chart order throughout the facility and monitor compliance. Remove tabs/section organizers that are no longer in use, keep tab titles current. Charts need to be purged in accordance with Medical Record Policy to keep only relevant and useful information readily accessible in the chart. Having this done by Medical Records personnel is suggested so that the practice can be applied consistently. When specific prior reports are referenced in an update note or assessment, care should be taken to have that report readily available for review on the chart. b) Identify reasons why chart filing is lagging, and take steps to address to keep charts current and reduce loose filing. c) Eliminate hole punches through required documentation when using peel and stick forms. d) Remove old or replaced forms from circulation to prevent their utilization. e) Evaluate the utilization of two charts for DD clients in light of the misfiled information found in each chart and the difficulty in coordinating information between the two. f) Review approved abbreviation list, update as necessary, enforce compliance. 2. Programming – Findings: Programming for mental health occurred both on the unit and in the Treatment Mall. There were two Treatment Malls, one designated as acute and the other as rehab. The Acute Mall had a substance abuse track and a mental health track. Mental health groups and 12 step recovery groups occurred in the Rehab Mall. There was still patient inactivity on the units. At this time, there are two functioning Forensic Units, one designated as the admission unit and the other as a “step-down” unit. The criteria for movement of patients between the units is not established, and appeared to be somewhat arbitrary. The number of hours of actual active treatment and patient interaction and the reinforcement of training objectives throughout the day for the DD clients 77 appeared to be low. This may be a due to weak programming, but may also be related to the documentation on progress of objectives. Some clients showed only 3 or 4 times a week scheduled for work on objectives, with as little as 1-2 hours a day. What was not credited or documented is all the time that staff is working with the clients on bathing, dressing and eating. These did not have objectives and therefore were not counted as formal active treatment. Patients could have training objectives tied into these activities, maximizing active treatment, staff time and progress toward goals. It was also observed that all DD individuals had money management and self medication objectives. Even when the assessments indicated that some of the profound clients may have skills that could be developed in the areas of self help, bathing and dressing, these objectives and training needs were not addressed. Times around shift change and pre and post meals also appear to be loosely structured on the DD units. When no formal program is taking place, there needs to be a rotation of attention among all the clients. Recommendations: a) Review programming and documentation for DD clients to maximize both treatment opportunities and the capture of these in the record. Take advantage of routine daily activities for training and development, and cross reference goals and objectives between them. This may also be beneficial in allowing the client more opportunities to complete activities related to treatment objectives. Review “downtime” activity to assure clients receive adequate attention and supervision. b) Establish criteria for movement between the Forensic Units, if indeed one is designated and functioning as a “step-down” unit, rather than arbitrarily transferring patients due to bed need. c) Provide adequate treatment options for individuals not going to the treatment malls. 3. Physician Documentation – Findings: Although some charts had excellent documentation of rationale for medication and reasons for increase/decrease, many had none. Rationale was most frequently noted in the dictated psychiatric evaluation, which on the AMH units, included a section entitled “Medication Rationale.” Emergency medications given did not have a descriptive progress note by the physician. Admitting psychiatric assessments were thorough and well documented, and the suicide and violence risk section were observed to be valuable. The reason for special observation was not always described in progress notes, and orders were not renewed every 24 hours with documented justification. Admission orders for special observation status were sometimes found to be inconsistent with the practice for patients on the Forensic Unit. 78 Many telephone orders were not signed by the physician, or were signed late. Also, many were not noted to be “read-back verified.” There appeared to be a disproportionately high number of verbal orders. This may indicate orders were being given in person rather than the physician writing the order himself, as opposed to a verbal order given over the telephone. This is not advised, as related to JCAHO safety goals. The standard Admitting Physical Exam appeared thorough, but the form provided no section for conclusions and diagnosis. The “History” part of the H&P (History and Physical) could not be located in many charts, nor could the “Review of Systems.” On the DD units, it was noted that the Axis I diagnosis was not always consistent between court reports, assessments, and treatment plans even when they were completed roughly at the same time. Recommendations: a) Make the standard practice of observation level of new patients consistent with physician orders on admission. Physicians should be informed of this standard procedure, and if Nursing notes a discrepancy, they should contact the physician for a revised order. Likewise, reasons for special observation levels should be documented in the chart. b) Chart review should occur, perhaps at treatment team, to ensure consistency in diagnosis in the chart between forms, reports and other chart entries. c) Verify that the use of “verbal orders” is for telephone orders only, in accordance with Joint Commission safety goals. A quality initiative for readback verification and physician’s timely signature on orders may improve performance in this area, as this seems to be a long-term ongoing problem. d) H&Ps should be complete with “History” and Review of Systems included. e) Rationale for administration of medication and changes in dosage should be documented in every chart. 4. Seclusion and Restraint – Findings: A commendable low use of S&R was recorded for this facility. No seclusion rooms had restraint beds, and staff stated that if necessary, patient beds are moved and used for that purpose. This practice was questionable not only for the time necessary to move the beds, but as noted in Section 12, several types of beds are utilized in the facility, and not all are suitable for use as a restraint bed. The use of side rails on beds to prevent falling may be considered restraint when the purpose as documented is to keep an individual from getting out of bed. Staff stated that there were no incidents of manual hold or mechanical restraint used on the DD units. In some cases, it was questionable whether the failure to use a manual hold had a more detrimental effect on the patient than if one had been utilized. 79 A policy referenced the use of a Posey restraint vest for transport of patients, however staff stated this is no longer used. If this is not used, it needs to be removed from policy. If it is still used, the procedure needs to state how many staff members are to assist in the transport for safety purposes. This method can be a contributing factor to serious injuries when used for transport. Policies referencing the use of restraints dictated the need for “constant supervision” during restraints. This should be revised to state 1:1 observation since staff could be assigned other duties or patient observations and still provide constant supervision. Policy should also address client privacy during restraint. It was also noted that not all restraint polices stated the requirement for family notification. Recommendations: a) Review utilization and associated documentation for bed rails to attain compliance with restraint standards. Remove reference in policies to Posey restraints for transport if this procedure is no longer followed. If it is followed, the policy needs to be reviewed for safety considerations and precautions to prevent falls inserted, including requirements for close staff escorts. b) Although low use of restraint, manual holds and seclusion are commendable, ensure that patient safety is not being compromised in order to eliminate these procedures. When patient/staff are at risk of assault and or patient rights are being threatened, appropriate interventions should be made. c) Review policy terminology for patient observation during restraint, ensuring that patients are on 1:1 observation. Also review policies to assure compliance with family notification and patient privacy standards. d) Evaluate the usage of patient room beds as restraint beds, both from a safety perspective as well as from a patient rights perspective. Being restrained in one’s own bed can exacerbate mental health issues the patient may already have. 5. Medical Management – Findings: In general, medical management at this facility was improved as compared to other sites visited. The model of medical physicians acting as attendings for DD clients with the psychiatrists consulting, and visa versa for the MH patients, seemed to work very well. Patients who were medically ill were for the most part promptly evaluated with dispositions made. Communication between psychiatrist, nurse, and medical doctors appeared to be good. The use of the physician “communication book” on the units also seems to work well for notification and follow-up, despite creating some redundancy in documentation. Charts were specifically reviewed for diabetic management. Overall, patients were well managed. However, long term diabetic management through Hgb A1C measurement was inconsistently implemented. 80 Management of hypertension was also generally well addressed. However, a few patients were on three or more anti-hypertensives. Lasix was observed to be used in patients without a history of CHF and with normal renal functions, and many of these were also given KCl. Clonidine seemed to be used excessively, which is centrally acting and not recommended for patients who are already mentally compromised. Several patients with diagnosed dementia had no evidence of ever having a metabolic work-up or a formal MMSE. Bowel movement objectives were established for long term clients, and indicated that individuals would have various monthly objectives set, such as 15, or 18 BMs a month, or even an annual objective of 280 BMs a year. Setting an annual objective creates an extremely cumbersome system, and along with monthly objectives, does not allow accurate identification of potential problems. For example, an individual could have BM day 1-15 and then none for the rest of the month, and meet a monthly objective. While a surveyor was informed that patients also had orders for medication if they had no BM for three days, evidence was found in multiple charts on multiple occasions where individuals went for 4-5 days without further assessment. There were instances of “deferred” on physical exams were noted and seemed to be used inappropriately as they were never completed at a later time and were reasons were not documented as to why they were not. It was questioned whether this is a default entry that stays unless the physician enters something else. Several patients with substance abuse had medical issues that could be associated with ethanol use/abuse, but this was not noted or documented. Pain assessments, interventions and outcomes were generally well documented. However, they were recorded in several different places in the chart, so sometimes it was difficult to follow progression of a specific pain incident. Recommendations: a) Consider implementing a policy that defines long term diabetic management through the use of routine Hgb A1C. b) Eliminate “monthly and annual objectives” for the number of bowel movements for patients and establish a more practical and functional standard for monitoring that provides accurate and immediate alert if problems arise. c) Review default entries of “deferred” to determine if they are being inappropriately utilized. It may be advisable to not have a default entry if this leads to incomplete follow-up. d) Establish procedures for refusal of use of CPAP machines for patients diagnosed with sleep apnea. 81 e) Clients involved in incidents (patient-patient assaults) should be followed with assessments for pain. f) Review medication management of patients with hypertension to assure best practice utilization. 6. Utilization Management – Findings: UR minutes reflected good quality initiatives and tracking of information. Many monitors could be followed over a couple of years, with improved compliance being shown in response to the initiative, and with subsequent raising of the threshold for continued improvement. Consistent with surveyors’ observations on the units, there was low compliance with physician signature on verbal orders, and not much improvement has been shown over a period of time on this indicator. NWRH APS data on unauthorized days was very inconsistent with other facilities (high), but UR staff indicated that they felt this was due to other facilities skewing their data rather than reflecting a true comparative study. As in other facilities, APS was reported to be extremely labor intensive without much benefit derived. UR staff stated that 23-hour observation patients are not reviewed through utilization management. Recommendations: Consider a method for utilization review of 23-hour observation patients. 7. Quality Initiatives – Findings: It was difficult to track coordination and executive oversight of quality initiatives through different committees and up through management. It was noted that the Quality Manager does not attend the Risk Management Committee, the Patient Assessment and Care Function Team, Ethics Committee, P&T or the Discipline Chief Meetings. Mention of QI reports and initiatives, as well as follow-through of issues identified, were very brief in the executive minutes. Organization and execution of projects also seemed too weak, and did not always follow established QI procedures. For example, on FOCUS-PDCA projects, the “plan” and the “goal” for the project were listed as the same. One PI project was to decrease the serious injury and death rate by 50%, a goal that the surveyors were informed was mandated by the central office. The facility identified three areas to focus on that would contribute to meeting this goal: reduction of falls, addressing aggressive behavior, and obtaining accurate information on patient transfers. In practice, each area is so different and complex it deserves a separate FOCUS-PDCA plan. Lumping them into one muddies the process and makes a positive outcome more difficult to obtain. Another project identified as treatment planning addressed recidivism, substance 82 abuse assessment, and increased attendance at treatment teams, again, showing lack of standard QI structure, organization, and focus. The Director of Quality Management has only been in his position for approximately one year and has a limited background in mental health, which may be a contributing factor to the weak program. His immediate supervisor, the Director of Regulatory Compliance and Training, was not available at the time of the site visit for interview or comment. Recommendations: Review Quality Improvement representation on key committees and teams or attendance at the meetings to maximize inclusion of performance improvement activities. Review QI/PI process and procedures to make it more functional, useful, and consistent with Quality Management Practices. 8. Treatment Plan/Team – Findings: Treatment teams were attended on most units. On unit 408, treatment team was conducted by two psychiatrists, with coverage provided for one other who was on vacation. All patients were reviewed, some briefly and others in more detail. All staff seemed to know the patients well; a notebook of patients’ pictures was available if needed. One comprehensive treatment plan was completed with projection onto a screen and multidisciplinary input occurring in real time. Notably, no patients attended the treatment team. On Unit 406, treatment team was informative and patients were encouraged to actively participate. Patients interviewed were well informed. Generally, treatment plans were found to be thorough and complete. Groups did seem to match treatment plan goals. On a few of the DD Treatment Plans it was noted that target dates had expired, or that they had been extended as many as two times. There was no evidence, as required by ICF/MR standards, that there was change made in methodology of obtaining the goal or justification why the extension was necessary. Also noted in a DD treatment plan was the statement that a certain patient did not need a behavior support plan. Behavioral support plans are necessary for individuals on psychotropic medications to address specific behaviors, and this patient had been on psychotropic medication for years. Behavioral support plans that were indicated as a need in treatment plans were not completed in a timely manner. Recommendations: a) Treatment teams should not be held without access to patient charts. Patients should always be encouraged to attend and participate in the team meetings. 83 b) When target dates for goals are extended for unattained or incomplete goals, documentation should reflect a change in methodology, techniques, or interventions that will assist the patient in reaching these goals. The record should also reflect reasons why goals were not attained. c) All DD patients on psychotropic medications to address behaviors should also have a behavioral support plan. When recommendations are made to develop one, timely completion should be monitored. 9. Patient Rights – Findings: Procedure on the admission unit involved the typical search and confiscation of contraband. After this was done, the staff member retreated behind a glass window for the patient interview process. This seemed unnecessary, impersonal, and contradictory to a recovery model. Advance Directive Forms do not address a Mental Health Advanced Directive. There was inconsistency noted in the DD charts on whether the individual had the capacity to give informed consent. For example, the chart would indicate the person was unable to make choices or consent, but the same chart reflected the patient’s ability to make choices by turning their head. This may indicate a need for an assessment and documentation of the level of consent or choices the patient can make to avoid seemingly contradictory statements. All restrictions on personal property, which includes hygiene items, must have the restriction addressed in the treatment plan, approved by client/family/guardian and the human rights committee. The treatment plan also must indicate a plan to reduce the need for the restriction. This was not evident in one chart. The requirement for DD patients of annual updates for medication consents appeared to be met, however, some consents appeared rather methodical rather than relating to actual clinical care. There is not a filled Patient Advocate position at this facility, but there is a Peer Specialist whose role is to support the recovery of patients by encouraging their participation in treatment both while in the hospital and by following their discharge plans. It was commented that staff training on the “Recovery Model” would be beneficial to further support this. Recommendations: a) Patients treatment regimens should not be changed without a physician’s order, and denial of access to treatment should not be used as a consequence for undesirable behavior. b) Review current policy and procedure for Advanced Mental Health Directives, HIV testing, and restrictions on patient belongings, establishing or enforcing compliance with standards and regulations. Also suggest clarifying 84 documentation and policy on the ability to indicate choice vs. level of capacity to give consent. c) Provide staff training on the “Recovery Model,” and examine current practices from this perspective. d) Assure that there is consistency in the consent process when family or guardian is the one giving consent to make sure they are contacted for all consents. If attempts to reach the family or guardian are made and are unsuccessful, this should be documented. 10. Staffing and staff morale – Findings: Neither the Nurse Executive nor Human Resources were able to produce staffing data, including vacancy or turnover rates. The Nurse Executive stated he believed the nursing vacancy rate to be “about 50%”. Consistent with other facilities, the perception is that turnover is seen mostly with new hires. As in the other facilities, there are a good number of long term employees nearing retirement, intensifying the staffing shortage situation. Although there was a realization of this upcoming problem, it appeared not much was being done in anticipation of it. There seemed to be more stability in upper management, with fewer vacant positions than in other facilities visited. Although staff shortages were not readily apparent on the units visited and milieus were generally under control, surveyors experienced some problems in having staff and/or management available due to their being so involved in patient care activities or covering for others. Call-ins were a consistent problem, and a system of mandatory “holdovers” is in place that does not allow staff members to leave until a replacement can be found. As positive reinforcement for reducing holdovers, nursing has instituted a “unit of the month” highlighting the unit with the least call-ins. Overall, morale appeared to be good, and staffing issues did not come up as frequently as in the other facilities when staff members were interviewed. Comments instead included needs for computer/technology upgrades, improved communication, staff training, and enhanced programming for patients. The facility had a foster grandparent/senior companion program for the DD population that provided for emotional support and social interaction with the clients. Care should be taken to assure that staff members are also present in the area with these individuals to intervene and assure behavioral plans are implemented. On two occasions, the surveyor noted the grandparent in rooms with clients and no staff member present. During these observations a client was exhibiting a behavior addressed on his behavioral support plan. During the HR interview (the HR Director position is vacant), it was determined that clinical or discipline managers performed their own reference checks for new hires. In consideration of the shortages experienced in clinical staff and their first 85 priority being patient care, this seemed to be an inefficient use of their time and perhaps better performed by Human Resource professionals. In the review of employee file, it was noted that a nursing license that expired in January was not verified for renewal until March. Recommendations: a) As in other facilities, immediate measures to address acute staffing shortages need to be taken in light of pending retirement of long term employees. This includes recruitment issues such as examination of salaries and benefits, and retention issues such as training and qualifications of staff members. Utilization of measures such as agency staffing and mandatory holdovers must be seen as short term only, as they actually contribute to destabilization of staff, lower quality of care, and create additional turnover from staff dissatisfaction. b) Monitor the foster grandparent/senior companion program to assure that it is being used appropriately and not in place of staff. c) Review procedure of clinical staff members performing HR functions such as reference checks. Non-clinical departments should act as support departments to clinical care personnel, especially in light of the shortages and multiple demands clinicians already face. d) Nursing licenses and their verifications must be kept current. 11. Training/Staff Development – Findings: The Director of Training and the primary trainer for MANDT were not at the facility at the time of the survey, and a substitute who was knowledgeable about these processes was not available. MANDT training was reported to be on schedule, however, data or reports supporting this claim were not made available. 12. Safety/Environment of CareFindings: The facility is located on a large campus, with a mixture of occupied and empty buildings. Some treatment buildings were grouped while others were spaced apart. Security fencing around units was aesthetically pleasing rod iron, rather than institutional chain-link. Grounds were impressively well maintained and groomed. The interiors of the buildings were clean, but not as well maintained as the exterior. Physical repairs were needed on several units. There were a mixture of beds observed in patient rooms, including metal, wooden and the typical hospital bed which can be adjusted for height and angle. Hospital beds can be dangerous, as they can be raised to upright positions to present a suicide risk by hanging. Several other suicide risks were noted including doorknobs and exposed hinges in patient rooms and baths, bathroom grab bars and plumbing 86 fixtures and window screens in patient rooms with mesh. Patients were allowed shoelaces and belts. There were some safety inconsistencies noted: locked trash cans which prevented removal of plastic bags were located just feet from other trash cans with removable liners and plastic shower curtains in patient showers. Patient phones with short non-removable cords were across the room from a “staff telephone” with long removable cords and wires. Other facilities visited had already removed closet doors in patient rooms, recognizing the risk that these present. Louvered closet doors with doorknobs and hinges were observed in many patient rooms. Even with the retained closets, rooms were still observed to be cluttered. No doors that were supposed to be locked were found unlocked, the first facility where this was experienced. The facility is to be commended for being a non-smoking hospital. Staff in the 23-hour observation unit stated that this actually helped them control malingering. Recommendations: Conduct an internal suicide risk assessment to identify the greatest safety hazards and implement a schedule of modifications to reduce these threats. Interim safety measures should be implemented until the modifications are complete, including increased observation levels and/or limited access to areas where these risk factors are present. Evaluate need, location and risks of hospital-type adjustable beds on units. 13. Risk Management – Findings: Many doors which led onto units were solid with no windows, so the ability to see and assess who or what was happening on the other side was not possible before opening the door. On the DD unit, there seems to be a number of both “unknown” or “unobserved” incidents and client-to-client incidents. Documentation should include actions taken to deescalate and prevent further incidents, for example separating the clients involved, and/or clients being placed on a higher level of observation. These actions or similar actions should take place immediately, and not wait until an investigation is complete. Meanwhile, the incidents can continue to be investigated for elements to prevent future similar occurrences. It was reported that there was not a designated “Risk Manager” at the facility, but rather a staff member assigned to gather and log information. As a result, there is an identified weakness in trending and thorough follow-up of reports. Review of minutes and Critical Incident Reports revealed possible lost opportunities for improvement that may prevent similar incidents in the future. Recommendations: 87 Consider filling the vacant position of Risk Manager. Improve examination of data on individual incidents as well as trending. Include Quality on Risk Management Committee to use incident monitoring as opportunities for improvement and risk reduction. 14. Nursing Practice – Findings: No expired medications were found in any of the medication rooms. Recommendations: Review all medication rooms to assure that stop dates are not exceeded. Review the practice of look-alike, sound-alike medications being stored together to eliminate potential for mix-up. SWRH –THOMASVILLE 1. Chart Organization and Content – Findings: Charts were generally in good order. Long term charts were understandably thick, but had appropriate content and were organized. Forensic evaluations were kept separate and findings were not always evident in chart documentation. Recommendations: Results of forensic evaluations should be included in the chart. 2. Programming – Findings: Patient inactivity was observed on the units, sometimes inconsistent with posted schedules. Programming for patients not able to attend the treatment mall or off-unit activities was light, and it appeared that many patients remained on the unit in fairly cramped quarters. Clear criteria for allowing patients to attend off unit programming was not available, and it was stated it was a clinical decision of the treatment team. Off unit programming offered many groups and activities. The Serenity Room was a creative approach to reducing patient stressors. Recommendations: Make adequate programming available for patients who are not allowed to leave the units, and then assure that the treatment schedules are followed. 3. Physician documentation – Findings: Physician notes for DD patients on Rosehaven and 501/510 appeared complete. Medication rationale and effects were documented, abnormal labs and other diagnostics were quickly followed up on. Annual and quarterly updates were present and complete. Results of interventions or failure of interventions were well documented. 88 On the Mental Health Units, admission dictations and annual updates were well documented. Telephone orders were occasionally not co-signed by the physician, and some were signed late. One seclusion and restraint order was signed outside the one hour window. Medication changes and responses were well documented in the chart; however, use of polypharmacy was not always well supported in notes. Progress notes were acceptable in terms of frequency, but were somewhat limited in content. With the adequate physician staffing on these units, notes would be expected to be more complete. Aggressive behavior documented in nursing notes was not always referenced or discussed in physician notes. Recommendations: An organized effort to sign telephone and verbal orders may be indicated. Physician notes should be complete to include discussion of polypharmacy, patient behavior, and treatment regimens. 4. Seclusion and Restraint – Findings: Seclusion and Restraint utilization is commendably low. No restraint beds were observed in any seclusion room. Staff stated that patient beds were used when restraint was utilized, however it was very infrequent. The facility stated that they documented manual holds as restraints, and some forms indicating this were found, but not consistently. Debriefings of seclusion and restraint episodes were not filed in the chart, but kept separate. The patient advocate meets with all patients following episodes of seclusion and restraint, and the episodes are also reviewed by the ethics committee. Recommendations: Review the use of patient beds for restraint from both a safety perspective and from a recovery model perspective, considering the effects of a patient being restrained in their own bed. Examine the definition and application of manual holds to assure compliance with standards. 5. Medical Management – Findings: The AMH unit 310 utilized a Team Nurse concept for care delivery. Each client was assigned an admission pair consisting of an RN and a physician who worked with them directly throughout their hospitalization. The RN in this pair had this as her primary role, and had a list of responsibilities assigned to him/her, including developing and updating the treatment plan, coordinating and attending treatment team, communicating with the charge and medication nurse 89 regarding his/her patient, educating patient and family on treatment and medications, review of 3-11 and 11-7 reports, and completing chart documentation including progress notes, quarterly and annual assessments, consent forms, and legal papers. The concept was implemented to improve continuity of care and communication with all disciplines. The team also included a social worker. This concept seems to work very well for both the patient and staff. Care of both the diabetic and hypertensive patient seemed relatively good. Hgb A1Cs to evaluate long term management of diabetes were seen on some patients with very good results. Histories were lacking in substance abusing patients in regards to last use, blackouts, seizures and DTs, and medical issues related to past or present drug use. Differentiation should be made between substance use vs. abuse vs. dependence. An up to date detoxification protocol, such as a CIWA scale, was absent. Phenobarbitol was currently being used as drug of choice for detoxification, which is outdated. Patients in Rosehaven and 501/510 generally had a detailed plan of care that seemed well implemented. Some had an array of complex medical and psychiatric issues that appeared to be more than adequately assessed and treated. Pharmacy regularly reviewed polypharmacy. Some laboratory tests were not followed up on. Recommendations: a) Substance abuse assessments should include history of black outs, seizures, DTs, past use, last use, and medical issues related to present or past use. Replace phenobarbital with Ativan as the drug of choice for detoxification. Adopt a detoxification protocol such as the CIWA scale. Diagnosis should reflect a differentiation between use/abuse/dependence. b) Hgb A1Cs should be a standard component of long term management of diabetes. c) It is recommended that patients who are hypertensive be placed on ACE inhibitors, especially if they are diabetic. 6. Utilization Management – Findings: As in the all other facilities, APS was identified as very labor intensive with limited use. Staff stated that at least now many of the problems of the system have been rectified and at least the reports are accurate. Though typically a community-based service, a crisis unit is operated by the hospital because of unavailability elsewhere. This was recently moved back on campus. The UR department does not track or review admissions and discharges from either this or the 23-hour observation unit to assure that services are delivered in the appropriate setting. 90 Staff members stated that patients can stay in the 23-hour observation unit up to 48 hours. This conflicts with hospital policy indicating that admission to inpatient would occur if the patient “has not stabilized within 23 hours” in that level of care. Recommendations: a) A clinical quality review should occur to ensure appropriateness of admissions to the crisis unit vs. 23-hr observation unit vs. inpatient. b) Review practice of keeping patients in 23-hour observation beyond 23 hours, and at the very least adjust hospital policy or practice so that they are in compliance. 7. Quality Initiatives – Findings: The Quality Council is part of the Leadership Team, which indicates strong administrative support for quality initiatives. The agenda for Quality Council is comprehensive, and includes such topics as client satisfaction survey results, HR data including turnover and vacancy rates, Risk Management data, staff development information and typical quality agenda items such as PI Teams and FMEA reports. Some quality goals such as reducing critical incidents and patient injuries reflect total numbers only and are not expressed as relative to census or volume, therefore decreasing trends may not accurately represent decreasing incidence if the hospital is downsizing and closing units. Recommendations: When tracking information that may be impacted by census or volume of patients, report numbers in relation to that number to accurately reflect changes. 8. Treatment Plan/Treatment Team – Findings: Several treatment teams were attended on the Mental Health and Forensic units. They were well organized and relaxed. All members of the treatment team were active in the treatment planning process. Patients were encouraged to participate. Patients seem to know their physician and clinical staff involved in their treatment, and indicated that they felt cared for and safe. Notes were written either during or immediately following the patient interview. DD patients had Individual Service Plans and Behavior Management Plans in charts and these were completed. 9. Patient Rights – Findings: The patient advocate, though new in his role, reflects the proactive attitude of the facility. He responds to patient/family complaints, leads recovery groups, is active in promoting the recovery model with staff and meets individually with all patients following seclusion or restraint episodes. He has developed an institutional advanced mental health directive for patients which he 91 completes with them prior to discharge when they have stabilized and which can be used if they are ever readmitted. These directives include physician choice, medication choice, and preferences regarding emergency interventions. It was noted that these emergency interventions only include seclusion, restraint, or medication. All seclusion and restraint episodes are also reviewed by the Ethics Committee. Informed consents for medications allowed multiple medications on one sheet. Recommendations: On the institutional mental health advanced directive, include something other than seclusion, restraint, or medication as a choice for an emergency intervention, or it may be helpful to include an additional question that addresses interventions that could be performed before the use of seclusion, restraint or medication. 10. Staffing and staff morale – Findings: Though facing many of the challenges the other facilities face in terms of salaries, retention and turnover, SWSH seems to have found some measure of success in staffing the facility. Commendably, no agency staff is used, turnover is very low, and vacancy rates are much lower than other facilities surveyed. Morale is generally very good, with management identifying some issues with transferred Bainbridge employees and those facing reassignment with the continued closing of DD beds. The facility seems to be proactive and sensitive to these staffing needs, which contributes to its success. It was evident throughout the survey that good communication, teamwork, true patient compassion, pride and leadership all contribute to staffing successes. The facility and staff also seem to be well connected to the community, promoting relationships that assist in recruitment. Linkages exist with Nursing schools, with students completing their psychiatry rotations at SWSH. Internally, staff is supported as well, contributing to retention. Mentoring programs are set up for new employees. An incentive exists to encourage continued education, and multiple examples of professional advancement were seen within the organization, including certifications of Psychiatry and Forensic Technicians, advancements from CNA to LPN to RN, and even to Nurse Practitioner, all with employer support and encouragement. A peer program exists for employees involved in patient assault incidents or falsely accused by patients to help support them with personal issues that remain from those events. When downsizing was indicated because of budget reductions, both management and staff reported that clinical or direct care staff was not impacted. Administration chose to cut middle management or administrative positions. This not only seems operationally appropriate, but was referenced by many employees as positively affecting morale and reflecting an organizational commitment to patient care. 92 Physicians also are well staffed with competently trained and board-certified physicians performing in their specialty fields. The physician treating the DD clients knows his patients extremely well, and has contributed to these very medically fragile patients living past their life expectancy. Pharmacy is well staffed with four pharmacists, two of whom are nearing retirement. They state that salary scales may make it difficult to recruit replacements, as pharmacists are not able to make over $100,000 in some settings. The pharmacists are involved in Performance Improvement activities, and monitor PRN and polypharmacy utilization. A foster grandparent program exists to provide 1:1 attention and emotional support for DD patients. This was noted to be implemented and utilized appropriately. Reference checks were performed and their presence with patients did not replace staff. The admission unit was not staffed with an RN, as noted in a previous facility. This presents a situation where a patient that has not been assessed is not under medical supervision while he awaits evaluation. Also, for some shifts in Rosehaven, only one RN is on duty for the entire building. A team nurse concept has been implemented and seems to work nicely. Recommendations: a) Continue efforts of recruitment and retention, with emphasis on areas facing shortages because of retirement and non-competitive salaries to attract replacements. b) Evaluate need for RN in admission unit and for adequate coverage in Rosehaven. 11. Training/Staff Development – Findings: Staff members stated that SWSH was one of the first to implement MANDT training, and reported that they are at 100% compliance with advanced training for all employees. As mentioned in the previous section, continuing education and professional advancement is not only encouraged, but supported. Competency files were reviewed by two surveyors, and were in order. 12. Safety/Environment of CareFindings: SWSH is located on an attractive and well maintained campus. The Treatment Mall located in the Administration Building and Rosehaven provide excellent environments for treatment. They are open, spacious, warm and light, providing a pleasing atmosphere for care and recovery. The Rosehaven building 93 was immaculately clean with no odor even on the skilled nursing facility. The Mental Health and Forensic buildings, 310 and 414, were not as architecturally outstanding, with limited space resulting in a somewhat crowded and closed in feeling. However, the buildings were well maintained and clean. The facility has also identified that the limited physical space can cause patient management problems, and have taken steps to address this issue. For example, on the acute mental health unit, a number of private rooms are available for patients who are potentially assaultive or do well with more personal space. They have also created a separate unit identified as “secure unit” in the Mental Health Building that can hold up to 6 patients who are high management or could be dangerous to other patients. This unit is rather stark and bare, but seems to serve its purpose well. Suicide risks identified on the units included interior patient room doorknobs that could support weight. Although patient telephones were modified with short nonremovable cords, other conventional telephones were still observed on the units in patient care areas that had long removable cords. Bathroom modifications had occurred with suicide proof grab bars and showerheads installed, but other plumbing hazards remained, such as the on-off knobs in the showers. Plastic bags were also noted in multiple patient areas, including some in areas where staff did not continually supervise. Shoelaces and belts were limited for patients on suicide precautions, however staff did report that other patients on the unit were allowed these items and it was difficult to monitor. There was a mixture of beds in the facility, including hospital beds which can be raised and present a suicide risk. Beds and other bedroom furniture are also movable and with patient room doors opening “in,” could be used to barricade and prevent entry. Most outdoor recreation areas were aesthetically pleasing without chain-link fences or obtrusive barriers. However, the brick patio for the mental health unit does not appear secure and would allow relatively easy scaling and elopement opportunity. This has been documented in the past, and the wall has been equipped with an alarm system to alert staff to patients attempting to jump over. The Safety Committee had excellent clinical representation, and with a combined environment of care and clinical focus, allowed complete reporting and action to safety issues or incidents. Recommendations: a) Continue to conduct suicide risk assessments to provide a safe environment for patients. Renew efforts to remove plastic bags from patient areas. b) Evaluate risks associated with movable furniture in rooms. c) Reduce elopement risk from bricked patio. 13. Risk Management – 94 Findings: The Risk Management Department was recently supplemented allowing more staff to complete investigations, reports and trending. The meeting minutes show good clinical and management representation, and also reflect review of individual incidents. Efforts to improve trending and identification of commonalties are underway. Risk Management staff also expressed their goal of a more thorough discussion of incidents in meetings. Recommendations: Continue efforts of quality improvement and risk reduction by closer examination of individual incidents, and trending analysis of collective incidents. 95 SYSTEM REPORT MCG would like to thank the Division for the opportunity to be a part of the performance improvement process for Georgia’s mental health delivery system. This work would also not have been possible without the effort, time and cooperation of management and staff at each of the facilities, and we would also like to express our appreciation to them for their support and contributions in this process. As we completed each audit and reported out our findings to faculty, and staff, we were impressed by their motivation for change and desire for quality improvements. Additionally, Division leadership requested that the individual reports of each facility be explicit and specific. Their “tell it like it is” approach was consistent with their response to the recommendations and their commitment to improve the hospital system. In this regard, this responsibility throughout the audit process itself contributed to an ongoing quality improvement process wherein some recommendations were implemented during the audit process. This local and central responsiveness during this audit was commendable. System Strengths: In general, the core staff at the facility level are committed to their jobs, and have continued to show compassionate care and dedication to their jobs in the face of staffing shortages, patient care challenges and, recently, exposure in the media. Many of these employees have worked in the state system for 20+ years, some as many as 30. Their experience and stability have enabled some of the hospitals to continue to function in the face of significant adversity. They also provide a core on which a better system can be built, and reflect an attitude that is receptive to positive change. For the most part, an optimistic morale seems to be sustained despite continued challenges. In addition to the strengths found in this long term employee base, other positive aspects were noted during the audit process. Probably the most impressive was the medical care provided to the developmentally disabled population. Severely medically challenged, these patients receive care that has allowed many of them to live far past their projected life expectancy. The complete absence or very low incidence of decubitus ulcers in the bed ridden portion of this population was very commendable. This is also significant as skin integrity is often used as an indicator of general health care and attention. In all the facilities, the environments of care designated as SNFs, or skilled nursing facilities, could be called pristine. Constructive efforts that have had positive outcomes were also noted in the review of the state system. This includes the elimination of smoking in many of the facilities, a health benefit which was also referenced by staff to assist in patient management as it eliminated potential fighting, “under the table” trading, and patient demands for smoke breaks. The institution of the MANDT program 96 to address the management of aggressive patients played a role in the reduction of the use of seclusion and restraint, in compliance with a national initiative in mental health care. The state system has been supportive of the use of new psychotropic medications for best practice treatment of serious mental illness. Generally, appropriate use of these medications in terms of indications and dosages was noted during the audit. Although all of the facilities are physically showing their age and environmentally present safety concerns, most hospitals have identified the hazards and have taken steps to address many of them, limited mostly by funding and the prohibitive costs of some revisions and modifications. By and large, treatment teams operated well with well documented and productive treatment plans. Facilities were proactive in opening programs that would decrease re-admissions, such as 23-hour beds and crisis programs, despite the fact that the hospitals receive no reimbursement for these services because they are outpatient programs. All facilities have tried to enhance programming and encourage treatment choice by patients through the creation of Treatment Malls. Some hospitals have established positions of patient advocates and/or peer specialists, and show interest and intent in moving toward the recovery model. Collectively, these represent considerable strategic strengths and personal resources upon which to build further. As noted, several initiatives for quality improvement have already begun on a system level. In addition to contracting with MCG to perform facility audits, the Division is utilizing other outside consultants to examine procedures and performance. Reports are immediately used to implement correction plans and conduct change. The Division is also meeting with advocacy groups and consumers to obtain direct feedback regarding the delivery of care and personal experience in the mental health system. This involvement of advocacy groups and consumers is a key step in moving forward. A Gubernatorial Task Force has been formed to study the system and provide recommendations. The Department of Justice investigation will also yield a report to which the Division will respond. The media also contributed to this positive momentum by providing ongoing coverage and to raise public awareness about mental health. Findings and Recommendations: The following findings and recommendations for system-wide implementation that are presented by MCG Department of Psychiatry and Health Behavior are those that were consistently identified as problematic in all or most facilities, are systems where a statewide plan would create efficiencies, improve overall patient care, and/or maximize the benefits of a multi-hospital system, or are issues that must be addressed at the state level. These findings are consistent with performance improvement recommendations of regulatory agencies typically involved in the review of care in healthcare organizations, such as CMS and Joint 97 Commission. These findings and associated recommendations are detailed below. Additionally, a selected bibliography of key publications and mental health policy documents is included in support of these recommendations. 1. System Resources and UtilizationThe consensus of all team members was that staffing resources, mix and utilization were the most urgent issues that must be addressed by the Georgia State System. Although the severity of the problem differed between individual facilities, without exception this was the most consistent and significant challenge at each facility. Staffing shortages were noted in almost every discipline, and employees consistently identified this as the major problem and top priority for attention and change. Some of the specific consequences of depleted staff are outlined below. Consequences of low staffing levels…… Incomplete initial assessments Diminished capacity to meet with families Incomplete or superficial documentation Reduced oversight of patients Increased number of verbal orders Reduced unit programming Incomplete discharge planning Mandatory overtime Use of management in direct care positions Which further results in…… Increased risk of suicide, assaultive behavior, elopement, unexpected detoxification symptoms and medical complications because of inadequate risk analysis Decreased collateral information gathering, limited discharge planning, lost opportunities for family education and support in the recovery process. Poor interdisciplinary communication, less than optimal clinical care Increased risk of assaultive behaviors, suicide attempts, elopements, unobserved or noted deteriorating medical conditions and de-compensating psychiatric conditions. Increased opportunity for errors Patient boredom, increased aggressive behavior, exacerbated depressive symptoms, lost treatment opportunities Patient relapse, readmission, treatment failure Employee burnout, increased turnover, decreased retention Decreased supervision of line staff, management burnout, neglect of management duties such as quality improvement activities, risk management, etc. 98 Increased use of agency/locums personnel Insufficient individual therapy time Incomplete charting Accelerated recruitment/hiring processes Increased turnover, decreased retention Increased time spent on staffing and scheduling to obtain necessary coverage for patient care Provision of care by temporary staff not fully trained and not invested in long term success of the program, staff frustration with unstable workforce resulting in more turnover, increased employee costs Lost opportunity for patient education, treatment and evaluation of patient response to treatment, Patient rights violations with lapses in informed consent documentation. Standard and regulatory deficiencies. Lack of follow-up on diagnostic testing. Lowered standards for hiring personnel, shortened orientation and training process, decreased retention Wasted recruitment efforts, wasted training and orientation efforts, increased labor costs, diminished community image Equivalent loss of time and resources spent on employee supervision, direct patient care activities, other management duties Staffing levels, mix and competencies impact multiple aspects of patient care and operations, and other identified quality issues either exist or are exacerbated by deficiencies in this area. Vacancy rates can be impacted by many factors, including salaries, recruitment efforts, retention practices, orientation and training, staff composition and organizational structure. All of these need to be addressed in order to reach the most effective level of staffing in the state facilities. RECOMMENDATION 1.1: A comprehensive salary survey should be conducted to determine current salary scales for all professional staff members. The salaries for the professional staff of the facility, namely nursing, pharmacy and physicians lag behind, and sometimes substantially behind, industry standard. Because of the diversity of the hospital system, this presents a different kind of challenge for each facility, however the effects of submarket salary levels are the same. Hospitals in more urban areas with multiple competing job opportunities, such as Atlanta and Augusta, lose prospective employees to other hospitals offering significantly higher salaries. Hospitals in more rural areas such as Milledgeville, Thomasville and Rome, have difficulty attracting professionals to relocate to the area. 99 RECOMMENDATION 1.2: Restructure salaries to be in the 70th – 80th percentile level for regional market scales. National market shortages of most health care professionals, coupled with the current suffering reputation of the Georgia State Hospital system, will require DHR to offer salaries at the top end of the scales to attract high quality professional staff to fill current and anticipated openings. A cost analysis of current expenses associated with agency utilization, overtime and turnover may show a less than expected financial impact if agency and overtime can be eliminated, and turnover reduced. Although raising salaries alone will not solve the staffing crisis, neglecting salary levels or insufficiently addressing them will significantly hinder the resolution of the critical staffing situation. RECOMMENDATION1.3: Collaborate with Georgia’s universities and training programs, as a resource for current and future staffing needs. Most facilities were active in recruitment efforts which included job fairs and advertisement of job openings. However, in a market where there is a shortage of healthcare professionals, recruitment needs to be more aggressive and proactive. Involvement in training programs such as nursing schools, medical schools, residency programs, and pharmacy internships allow opportunities to capture prospective employees before they graduate, and then offer enticements such as repayment of school loans in exchange for commitments to work in the state system. State university collaborations are used in many other states as a valuable approach to enhancing care and resources within the public mental health system. RECOMMENDATION 1.4: The Division should be supportive of professional networking to provide exposure, represent system and individual facilities, and promote recruitment activities. Professional networking provides exposure and promotes job opportunities within the state system. This should be done on a national, state, and local level. On the hospital level, managers should be encouraged to participate in state and community organizations and events as representatives of their own and other state hospitals. This not only supports recruitment activities, but has the additional benefit of providing professional development and training, promoting increased competencies, job satisfaction and retention. This approach, fostered over time, also builds greater professional alliance throughout the system. 100 RECOMMENDATION 1.5: The Division should employ their own professional recruiters to attend national conventions and meetings to seek out and attract professionals whose interests include inpatient treatment. Some positions, namely medical staff and pharmacists, will require the efforts of full time professional staff for recruitment. This will not only assist in providing sufficient numbers of staff to fill current and anticipated openings, but will assure the recruitment of highly qualified personnel who are the “best fit” for individual positions. This will stabilize and improve the workforce considerably. RECOMMENDATION 1.6: Retention and turnover rates should be tracked and monitored by hospital, by discipline, and by unit, with both local and state interventions for identified problem areas. All recruitment efforts are wasted without effective retention. Effective retention begins with awareness and knowledge of who is leaving and why. Knowledge of why people are leaving will help in developing an effective retention plan. RECOMMENDATION 1.7: Effectively administer employee surveys to determine key points of job “dissatisfaction,” and then employ successful interventions at both the local and state level to improve retention rates. Employee satisfaction and exit surveys are being conducted, but results are not fully utilized. Exit surveys are often are given to terminated employees as well as those who have resigned voluntarily. This can skew data and make it more difficult for appropriate administrative response for improved retention. RECOMMENDATION 1.8: The Division should create a positive culture and an affirmative work environment through supportive supervision, constructive mentoring, and a collaborative work relationship with hospital level administrative and midlevel managers. Studies have shown that employee’s direct supervisors can have the most impact on job satisfaction and retention. Employees must feel as if their supervisors are receptive to their input and value their opinion, and are sensitive to their needs. A collaborative working relationship is most effective for not only employee retention, but also optimal organizational functioning. For lower level 101 employees, much of this effort must occur at the hospital level by mid level and department managers. However, this can be greatly impacted by upper management, creating a trickle down effect, when a supportive and affirmative work environment is created with positive mentoring and supervisory techniques. This is also tied to creating a “culture of quality” (see recommendation 9.2). RECOMMENDATION 1.9: Invest in current employees by supporting professional growth, education and career advancement. Opportunities for advancement have also been shown to be an effective retention strategy. Career ladders can be established for most positions that create incentives for improved skill levels, increased responsibilities, and higher education. Support for continued education can be provided through tuition reimbursement, time off for class attendance, or even provision of classes onsite. Continuing medical education is an important aspect of ongoing staff development. Regular on-site and system-wide educational opportunities should be made available through the use of local resources, including universities. This approach can also foster greater connection with the community. RECOMMENDATION 1.10: Establish a peer support network for employees involved in traumatic incidents with available professional help as needed. Inpatient mental health care constantly presents difficult and demanding work challenges. Situations can arise daily that can be potentially life-threatening for both patient and employee. This creates daily a stressful environment for employees, but especially for those that have already been involved in traumatic incidents such as assaults, altercations, incidents of injury of death or unsubstantiated accusations of abuse. The mental health issues of these employees need to be addressed, providing professional and peer support both before and after returning to work. This action would also indicate recognition by management of line staff’s work environment, boosting morale and employee confidence in administration’s sensitivity to their needs. RECOMMENDATION 1.11: Conduct a thorough analysis of the salary, education and training requirements of the Health Service Technician and make them comparable to the job responsibilities and risk factors associated with this position. Patients presenting at state hospitals often have severe mental illness complicated by multiple co-morbidities. Not only do these present significant 102 treatment challenges independently, but when co-occurring make detection and monitoring of their conditions that much more challenging. Patients are not always capable of self-reporting symptoms or conditions, and therefore staff must be keenly aware and skilled at assessing patient status. This heightens the responsibilities placed on health care professionals for the monitoring of these patients. Furthermore, unexpected and unanticipated situations can arise where immediate intervention, either medical or psychiatric, must occur to avoid escalating problems. It is essential to be able accurately assess and appropriately react, even if that means simply calling for help, assistance, or consultation by a colleague, nurse or physician. The Health Service Technician job classification requires no prior health or mental health experience or education, yet Health Service Technicians are the primary attendants and care givers to patients. They are the least trained personnel, but have more patient contact and patient supervision responsibilities than any other discipline. Salaries for this position compete with fast food restaurants and housekeeping personnel. Increasing minimal qualifications for this position, along with adjusting the salary scale, would significantly impact the quality of this level of staffing, and greatly impact patient care, treatment outcomes, and risk management. RECOMMENDATION 1.12: Create a statewide standardized orientation program complete with extensive classroom training and a period of shadowing and mentoring on the patient care units before new employees are assigned a patient care load or allowed to act independently. For even the experienced health care professional, thorough orientation and training is necessary before accepting solo responsibility on patient units. This should not only involve formal classroom training, but shadowing and mentoring in patient care areas before the new employee performs independently. Turnover is highest among short-term employees, and adequate training can help to reduce this phenomenon. The increased cost associated with longer more intensive orientation and training would most likely be offset by a decrease in turnover. RECOMMENDATION 1.13: Provide a stable workforce by allowing creative and flexible scheduling, incentives for call coverage, and part-time or job share positions. Creative and flexible scheduling can sometimes offset lower salaries in recruitment and retention. Weekend options, 12-hour shifts and part-time positions, can attract professionals looking for schedules that fit their lifestyle. Enticing reimbursement for on-call schedules can encourage staff physicians, 103 those most familiar with current patients, to provide coverage rather than hiring residents or outside physicians to provide care. RECOMMENDATION 1.14: Establish scheduling guidelines with approved and accepted acuity scales appropriate to patient population and condition to determine adequate staffing levels. Utilization of existing staff resources based on acuity and patient mix was not standardized or well established. Procedures for determining staffing levels using established guidelines or based upon national standards should be utilized. Staff scheduling should consider patient population (i.e. adult, adolescent), census levels, acuity, precaution levels, admission and discharge activity, adjusting staffing levels accordingly. RECOMMENDATION 1.15: Examine organizational charts to find efficiencies and ensure that reductions in overhead and administrative costs have occurred that correspond with decreasing patient census and line staff. On the hospital level, an effective organizational structure can create efficiencies, best utilize existing resources, and cut salary costs while preserving clinical quality. It can also maximize the utilization of limited or expensive resources, such as nursing personnel that require higher salaries and/or are in short supply. Most facilities have experienced significant downsizing in recent years. This coupled with the existence of staff that have very long tenures and remain in positions that are no longer necessary and/or efficient may require administrative reorganization. RECOMMENDATION 1.16: Salary scales should support nursing retention in nursing roles. Positions which do not require a nursing degree but have higher salaries, such as program administrators, have attracted RNs out of nursing positions creating more nursing shortages. RECOMMENDATION 1.17: Review current numbers of Ph.D. psychologists, eliminating, reassigning, or restructuring positions for best utilization and cost effectiveness. 104 Psychologists are necessary in the forensic population for court ordered evaluations and in the DD population for behavior plans, but psychological testing can be more cost effectively performed in an outpatient setting, and psychotherapy can be provided by master level therapists. RECOMMENDATION 1.18: Consider the formation of a case manager position within the Social Work Department to assist with discharge planning. The current role of the master’s prepared Social Workers in the inpatient setting is mainly discharge planning and placement. Creation of case manager positions to assist Social Workers could reduce salary costs in this department, or provide for additional resources without increased salary costs. This could also allow Social Workers to be utilized for more family work, recovery education, and therapeutic interventions with patients, such as group or individual therapy. Case management positions could also provide a career ladder for Health Service Technicians, a benefit aiding in retention. RECOMMENDATION 1.19: Examine job responsibilities and task assignments so that clinical disciplines are supported by non-clinical disciplines, and not visa-versa, maximizing the time and efforts of those with patient care responsibilities. Professionals that provide patient care should be supported by other hospital staff so that their focus, energy and time are spent on patient care. For example, Human Resource functions such as reference checks and license verifications should be performed by Human Resource Personnel. Medical Record functions such as chart purging and thinning should be performed by Medical Records personnel. Likewise, scheduling, an extremely time consuming function, should not be performed by nurse managers. All of these allow more direct patient care to be provided by nursing, as well as improved supervision of others providing direct patient care. RECOMMENDATION 1.20: Examine the prospect of statewide shared call coverage for Pharmacists. The possibility of statewide rotation and coverage of pharmacy call could reduce the frequency of call responsibilities for Pharmacists, reducing after-hour responsibilities and burden, and increasing job satisfaction. 105 RECOMMENDATION 1.21: Create 3 or 4 associate state level Medical Director positions to focus on key areas system-wide, such as forensics, medical oversight, risk management, the developmentally disabled population, child/adolescent treatment, etc. On the state level, organizational structure should also be one to support operations of hospitals. One Medical Director tasked with oversight of 7 facilities does not fully serve the needs of the physicians, patients and staff of each hospital. Policy design and implementation should not be purely administrative in nature, but created, supported and implemented by physicians and mental health professionals. RECOMMENDATION 1.22: Perform cost-benefit analysis of outsourcing services on a system-wide basis such as Laboratory and Pharmacy. Because of the difficulty in recruiting Pharmacists, supporting this function through contractual arrangement may be advantageous. Having such a large hospital system can provide negotiation leverage and make outsourcing financially beneficial. Laboratory tests are another outsourcing opportunity, and could not only relieve staffing problems, but also reduce the need for expensive technology and equipment purchases/leases, inspection preparation and fees and space requirements. 2. Chart content and organization – Inconsistencies in chart content and organization throughout the system point to the advantages of having a standard chart and chart order. Creating standard forms can reduce printing costs through volume production, ensure compliance with standards and regulations, and create efficiencies by facilitating access and transfer of information. All of these will ultimately improve patient care. RECOMMENDATION 2.1: Develop a statewide consistent chart, including standardized forms, content and organization with central office and hospital input and approval. There is a voluminous number of chart forms at each facility. Some are better than others, and through a statewide project, taking the best and/or best parts of forms and incorporating into standardized forms would benefit the entire system. At some facilities, several forms have been combined, making a continuous and cohesive process, assessment, or treatment record and eliminating excess paper. Conversely, there are some forms that have been implemented statewide 106 that are not user friendly. In the development of forms, it is essential to receive the input of the professionals that are using them. RECOMMENDATION 2.2: Assign the monitoring and maintenance of open and closed charts to Medical Record personnel. As addressed under staffing, the monitoring of chart content, organization and associated thinning and purging activities is best addressed by medical record personnel. The advantages to this are many, including expertise, consistency, and best use of staff. Medical Record staff members are trained to maintain records. They have the expertise to recognize what belongs on the chart and what does not. They are the most familiar with the medical record retention policy, and can implement it consistently. A consistent problem observed in the facilities was the use of old forms even though a new form had been created, sometimes as long as years ago. This was due to a simple error of old forms being tucked away in drawers or cabinets, and then reappearing and put back into use. Unit staff members, perhaps new or just unaware of the small changes or slight differences in the new form, do not recognize the difference and utilize the old forms. Medical Record personnel would be quicker to identify this issue on isolated units and correct it because they are monitoring chart content hospital-wide. When unit staff members are responsible for this function, turnover only perpetuates the problem, as medical record content is low on the priority list in training and commitment to memory. Finally, as mentioned earlier, patient care staff members are freed up to do patient care, rather than paperwork. RECOMMENDATION 2.3: Investigate the use of new technologies available and set a target date for the implementation of a user-friendly, fully electronic medical record. Ultimately, moving toward an electronic medical record will improve quality and coordination of care during hospitalization, but even more importantly, throughout the continuum. A secure, privacy-protected linkage with community providers’ computerized medical records will allow immediate access to current medications and pharmacological history upon admission. Discharge summaries and course of inpatient treatment would be available for outpatient providers for immediate aftercare treatment. This cost-effective strategy will improve overall patient outcomes. As recommended by the 2003 President’s New Freedom Commission on Mental Health, the electronic record can also incorporate technologies to include clinical reminders, tools for decision support, clinical practice guidelines, and patient 107 safety alert systems such as drug interactions, contraindications and allergies. This reduces medical errors or adverse incidents or events. 3. Statewide Policy and Procedures – RECOMMENDATION 3.1: Adherence to a system-wide Policy and Procedure Manual that has been developed and approved by the Division and all Hospitals. Currently, there is neither conformity nor consistency in policy and procedures for the state system. Manuals differ considerably in volume, content, and organization. The value of a Master Policy Manual is obvious: continuous compliance with standards and regulations, and consistent delivery of care. However, they should exist in terms of a template, with changes, deletions and/or additions made for individual facilities when their unique functions require modifications to the procedures. The changes should be made with Central Office knowledge and approval. 4. Medical Staff Composition, Bylaws, and Rules and Regulations – RECOMMENDATION 4.1: Medical Staff Bylaws should set standards of board certifications for the level and type of care provided, including general, forensic, and child/adolescent credentials, and include provisions for supervision of residents providing on-call services. The composition of the medical staff varied significantly between facilities, not only in number and associated patient care load, but also in credentialing and specialty areas. This was true for on-call staff, psychiatry staff, and consulting staff. At a minimum, the Georgia State System for mental health should employ board-certified physicians for the level and type of care they are providing. Psychiatrists treating children and adolescents should be board-certified in Child/Adolescent Psychiatry; those treating forensic patients should be boarded in Forensics. This is not to say that in some cases, currently employed physicians who are not boarded do not provide adequate care, but as a credentialing policy, as reflected in Medical Staff Bylaws, this should be the standard. Credentialing standards should also address on-call and after hour provider qualifications, and if residents provide this service, then procedures and requirements for their supervision should be clearly defined. 108 RECOMMENDATION 4.2: Medical staff bylaws and each facility should support the strategic use of consultants who can provide expert support to inpatient care. As has been readily acknowledged earlier in this document, the complexity of illness and comorbidities in many patients who receive care within the hospitals is a key consideration. Our earlier recommendation is that the Division recruit clinicians with speciality and certification (e.g. forensics) which are pertinent to the needs of this patient population. This effort can be complemented by the strategic use of local consultants to the hospital. This also has the advantage of enhancing the communication and connectivity between inpatient and outpatient providers. 5. Substance Use/ Abuse /Dependency Treatment – RECOMMENDATION 5.1: Develop a comprehensive program for drug/alcohol treatment, including the recognition and treatment of medical complications commonly associated with substance use. The prevalence of substance abuse as a dual diagnosis or high risk factor in the forensic and mental health population speaks to the need for development of a comprehensive defined treatment program for substance use, abuse and dependency. Treatment should include screening and assessments, withdrawal risk identification, medical detoxification procedures, drug education and recovery groups. Programs should address the physical, mental and emotional components of addiction. Job classifications, competencies and staffing requirements should be developed for substance abuse counselors. Policies and procedures need to be written and implemented for the treatment of substance abuse and chemical dependency. Physicians and other medical personnel should be trained in risk identification, detoxification procedures and medical complications associated with the use of drugs and alcohol. RECOMMENDATION 5.2: Drug/alcohol treatment should be made available to all patients, whether they are merely at risk for drug use or experiencing long-term dependency issues. The 2003 President’s New Freedom Commission on Mental Health indicated the need for integrated treatment programs overcoming the traditional separation between mental health and substance abuse treatment. Instead of patients 109 choosing or being assigned a treatment “track” or program focusing on mental health or substance abuse issues, drug/alcohol treatment is incorporated into all treatment programs. The long-term treatment success of psychiatric disorders will be positively affected by the added attention to drug/alcohol issues. 6. Medical management of patients – It is well documented that persons with mental illness have an increased prevalence of general medical conditions, including cardiovascular disease, diabetes, digestive disorders, hypertension, obesity and gastrointestinal problems. Substance use carries a high risk of serious illness and complications, including HIV, liver disease, heart disease and diabetes. The institutionalized, developmentally disabled population contains extremely medically fragile patients. Those that may not be as critically ill are challenged by a multitude of complications and long term medical issues that require constant and diligent care. Furthermore, mental illness can impair self-care of personal health and adherence to their prescribed treatment regimens. Psychiatric crises will only exacerbate these issues, so when patients present for admission, they are likely to be in compromised health or have deteriorating medical conditions. The treatment of psychiatric conditions presents health challenges in and of itself. Medication administration and side effects and complications associated with the use of psychotropic drugs present medical challenges of their own. So patients who may have long term, previously stabilized conditions, or may be completely free of co-morbid conditions can be also expected to have or develop medical conditions that need attention. RECOMMENDATION 6.1: Have a sufficient number of general practitioner physicians, at least one at each site, board-certified in internal or family medicine, to provide consulting and routine medical care for psychiatric inpatients. In facilities with both MH and DD populations, one model is to have psychiatrists as the attending physicians for mental health/forensic patients and internists or family physicians as the attending physicians for the developmentally disabled patients, with each acting as consultants for the alternate population. This provides on-site immediate and consistent coverage for both psychiatric and medical needs. The number of physicians still must be sufficient to allow adequate time for both attending and consulting responsibilities. The transfer of mental health patients from the Regional Hospitals to medicalsurgical facilities for emergent or specialty care is sometimes difficult and often 110 delayed. This only intensifies the need for recognition and management of both acute and long-term conditions to keep them from escalating into conditions necessitating transfer. For all of these reasons, having competent medical personnel as part of the staff of Regional Hospitals therefore is essential. Patient outcomes will include fewer medical complications, better general health and wellness and therefore improved response to psychiatric care, more rapid recovery and decreased length of stay. Patient transfers for emergent and specialty care will be reduced but not eliminated, so contractual arrangements for consultative services and formal service agreements with external providers will still be necessary. Over the course of the surveys, several general areas emerged as medical issues that are prevalent in the population and in need of better defined systems of care. The management of diabetes, hypertension, and medical problems commonly associated with long term alcohol and substance abuse were among these. This list is by no means comprehensive, as the incidence of physical comorbidities in this population is quite high. RECOMMENDATION 6.2: Use affiliation with Georgia’s medical schools and universities to provide training, education and best practice management for recognition, early detection, and treatment of medical conditions. Some of these problems can be traced to the absence of clinical practice guidelines, or guidelines that may not be considered best practice. Variations from known standards of care, variations of care because of lack of standards or lack of coordinated care not only constitute ineffective treatment environment, but also create situations of danger for patients. Ensuring that staff are well trained in the basic recognition and management of medical conditions is an important task. There should be ongoing educational opportunities that focus on medical issues relevant to this patient population. State University collaboration as well as local resources can also assist in this important, ongoing activity. 7. Utilization Management – Utilization review is a difficult process to evaluate, looking at only hospitalprovided services, since outpatient and community services and the criminal justice system play such a large role in overall utilization management. Likewise, data on re-admissions and length of stays are more useful when looked at in the context of the larger mental health delivery system. 111 RECOMMENDATION 7.1: Re-examine utilization management systems for cost-effectiveness, data relevance, accuracy and usefulness. Do not hold hospitals accountable for utilization data that is mainly determined or strongly impacted by external forces beyond their control.. In response to perceived needs in outpatient services that affected their performance measures, hospitals have established on-site programs that are typically provided in outpatient settings. This is provided despite the fact that sometimes there is no reimbursement for these services, as they must be provided by an outpatient facility to be eligible for funding. Examples of these are crisis programs, supported residential placement, emergency care and long term substance abuse programs. Although these services are needed, the provision of them by the hospitals is complicated. The facilities reported that the creation of the APS system of utilization management was supposed to provide data that supported the need of outpatient programs by identifying the impact on inpatient systems when these programs did not exist or were poorly delivered. Instead, what was consistently reported from hospital to hospital was that the result of the implementation of APS was time-consuming project for which they were held accountable for the data that was produced. Lengths of stay are out of individual hospital’s control when it is primarily lack of placement and aftercare keeping patients in the hospital. UR Managers had difficulty verbalizing how extended length of stays due to placement issues were distinguished from those that may be treatment resistant or treatment failures in need of second opinion or consultation. Data comparisons between facilities were also rendered difficult to evaluate by the fact that differences in patient populations were not taken into account when comparing indicators. 8. Critical Incident management – Risk Management is handled similarly at most facilities, with reporting, tracking and routine investigations occurring locally, and the more critical incidents being investigated by the central office. RECOMMENDATION 8.1: Provide central office medical resources for expedited thorough investigations of critical incidents and analysis of trends and patterns with subsequent design and implementation of risk reduction strategies based on the results. Although most individual investigations are handled appropriately, what is lacking is coordination with quality improvement and a big picture approach to identifying commonalties and implementing change that could prevent further incidents. 112 The number of incidents reported indicate that there is a good reporting mechanism and that employees are not reluctant or fearful to report events. However, the large number also makes it more difficult to thoroughly investigate each one to determine root causes or commonalties with other incidents. Sentinel events need immediate medical review from the state level, which again speaks to the need of more physicians at the central office to respond to these investigations. (see recommendation 1.21) 9. Performance Improvement and CQI processes – Quality processes should identify improvement opportunities and set benchmarks that are developed by direct healthcare providers through consultation with consumers and consumer family members. This is in contrast to conducting studies and collecting data in response to external sanctions, regulatory agencies, or imposed standards. High risk, problem-prone and high volume procedures should be monitored and tracked, but more importantly, analyzed and acted upon. RECOMMENDATION 9.1: Development of quality initiatives should be focused, positive and proactive, in collaboration with consumers and providers, and use benchmarks established by national standards. Action plans should be implemented by providers, and supported and monitored by management. Quality improvement processes should be closely tied into operations, and therefore requires the participation and support of management. Supervisors and administrators should not only be aware of quality reports and findings, but also actively involved in effecting change related to discovered improvement opportunities. Committee composition and defined committee reporting and information flow through the organizational chart can facilitate upper management involvement. RECOMMENDATION 9.2: Quality initiatives must contain components of education, networking, and technology, and be organized and orchestrated through the Division, to create a culture of quality. More important than the implementation and performance of quality studies and processes, even if coordinated system-wide, is creating a culture of quality. This concept must originate at the central office and disseminate throughout the organization. This is a difficult and gradual task. Mandates to reach goals or 113 objectives without providing the tools, support, and resources will not achieve this goal and it will require a comprehensive approach, including inclusive education and instructional activities. It will require seeking out best practices, utilizing networking and information transfer technologies, as well as the promotion and celebration of successes as they occur within and between each facility. This is another area of opportunity for collaboration with advocates and advisors. Promoting and recognizing these successes fuels a culture of quality. A sustained commitment to instilling a culture of quality in a system that is transformed in its workforce and operations will galvanize community, family, and advocacy support. Successes can also attract media attention, adding further to the momentum of improvement. At the present time, this report focuses more so on fundamental aspects of care and operations. However, as the system evolves and improves, creating a culture of quality should soon rise to the forefront in systems planning and prioritization. RECOMMENDATION 9.3: Data collection, for whatever purpose, should always be segregated by patient population: mental health (i.e. adult/adolescent), forensic and developmentally disabled. Methods of reporting also impact the effectiveness of quality improvement activities. For example, some processes looking at key indicators such as patient injury rates, elopements, hours of restraint and seclusion, readmission rates, length of stay are compared from facility to facility. However, quality data that compares hospital performances as a whole is invalid because of the vast differences in patient composition of each facility. Although all treated in the same facility, within the same system, and under the same Division within DHR, adult mental health, adolescent mental health, forensic, and developmentally disabled patient populations are different in their needs, outcomes, and risk factors. In addition, each regional hospital functions within its own unique local mental health system. Comparing client injury rates between a facility that has a high DD population to one that has little to none dilutes the usefulness of the data. Tracking separately the number of elopements from unlocked DD buildings versus elopements from locked secure units is more meaningful than evaluating total number of elopements between facilities. 10. Patient and Family – RECOMMENDATION 10.1: The system as a whole needs to embrace the recovery model, including the employment of both patient advocates and peer specialists for staff education and enhancement of treatment programs. 114 Clinicians and staff members must exemplify attitudes that consumers have the ability to participate in their treatment decisions. This need is further reinforced by the fact that most admissions to state facilities are involuntary. Therefore providers can actually diminish the capacity of consumers to take control and manage their own illnesses by not adjusting their mindset. The patients’ decision making ability must be expected, solicited, and supported. Although the State of Georgia is a leader in the development of the Peer Specialist Program, this position was not seen to be consistently employed and utilized throughout the hospitals. Because of the Division’s commitment and work in peer support, there is a real opportunity here to integrate and galvanize recover-based approaches and shared decision making. RECOMMENDATION 10.2: Incorporating informed patient-centered treatment and decision making as a standard of care across the system will require system policy, sufficient numbers of trained and competent staff members and a standardized practice of communication. Treatment teams were not always conducted across the system with the patient present. Therefore, the patient’s ability to participate in the design and implementation of their inpatient treatment was not always offered. Family involvement and support in treatment and the outpatient recovery plan is limited by the lack of family communication. Families are a tremendous asset and support in treatment planning. Families are so well attuned to the physical health of their loved ones that they can be of great assistance to the clinical staff in the assessment and care of medical conditions and pain. Similarly, their knowledge of their loved one’s mental health is a tremendous source of information and guidance in treatment planning. Georgia’s mental health system should make full use of this rich and willing asset. This partnership will greatly enhance patient assessment treatment planning and customer satisfaction. Staffing levels and responsibilities need to be addressed (as outlined earlier) in support of greater access to and involvement with family members in the care of persons who are hospitalized. Family involvement should occur at all stages of hospitalization (assessment, stabilization, aftercare planning) and should be welcomed in treatment planning. RECOMMENDATION 10.3: Participation with consumers, families and advocates should be encouraged through participation with current groups and organizations, and also through formation of Advisory Boards whose specific purpose is evaluating and providing feedback on services. Consumers, families and advocates have not had sufficient opportunity to provide feedback on and input into the design of treatment systems and the 115 delivery of care. The benefit of encouraging participation, soliciting comment, and incorporating the responses is not only an improved system of care, but relationship building with groups where strong affiliations are advantageous. This is another area of great opportunity. RECOMMENDATION 10.4: Continue full implementation of the MANDT system with ongoing analysis of need for alternative/additional resources for safe and effective patient/milieu management in the absence of seclusion/restraint interventions. The practical elimination of use of seclusion and restraint is commendable, however, this seems to have been done more by mandate than by elimination of need or corresponding development of other effective interventions. Where fully implemented, the MANDT system is evidenced to be very effective; however some facilities have lagged behind on the training schedule. The incidence of patient and staff assaults, some with serious injury or consequences, imply that the elimination of this procedure was not without some consequence since effective measures of patient and milieu management were not simultaneously employed. 11. Patient Treatment and Management – RECOMMENDATION 11.1: Physical modifications, renovations or other measures such as structured programming, improved staffing mix and levels, and creative patient management must be taken to address safety issues created by limited space. Units visited at many of the facilities were limited in space, and sometimes the patient area was isolated from the nurse’s station with 1-3 Health Service Technicians supervising patient group activities. Confining patients who may be agitated, delusional, detoxifying and/or aggressive to small, congested areas can provoke patient to patient and/or patient to staff altercations. In an ideal environment, patients should have common areas that are not crowded, and allow for personal space without isolation. Professional staff should be accessible and available for constant observation and quick intervention. RECOMMENDATION 11.2: Continue efforts to insure that active programming is being scheduled and provided both on the units and in the 116 Treatment Mall with an appropriate balance between therapeutic and recreational activities. Programming on inpatient units not only plays a role in active treatment, but is also an effective patient management tool. Patients engaged in activities are more easily supervised, less likely to be bored, and less likely to get into patient altercations. A central office report is submitted weekly from each facility that reports the number of hours of treatment scheduled and provided. This report reflects hours counted that can include diversionary activities, individual or oneto-one encounters, and treatment mall activities which occur simultaneously, thus providing information that is difficult to clarify on the quality and quantity of programming any individual patient may have access to or be involved in. Programming should include a combination of therapeutic activities and recreational activities, and should be provided not only in Treatment Malls, but also on patient care units when patients are not allowed to leave for off-unit programming. The Treatment Malls observed at most facilities allow for patients to attend offunit programming. The Mall also gives patients a choice of activities they can participate in. The advantages of the Mall are that patients are allowed to leave the crowded units for what is usually a more spacious area, have an opportunity to participate in a variety of activities, and can be active in their treatment choices. The disadvantages are that not all patients are allowed to leave, and the ones left on the unit were not observed to be offered many structured activities. Ironically, these patients are those that may be most in need of therapy. The Mall also allows patients to “opt out” of treatment for diversional or recreational activities. Both of these disadvantages could be addressed with stronger programming both in the Mall and on the unit. This is an area of great opportunity to enhance care with improved staffing levels and responsibilities, greater involvement of peer support specialists, and a revitalization of programming. Active treatment planning wherein patients and families are engaged and partnering in care will greatly enhance patient care and customer satisfaction. RECOMMENDATION 11.3: Continue to pursue best practices in the use of medications and the monitoring for effects In this audit, we observed generally appropriate use of psychotropic medications, both in terms of the indications for use of these medications as well as the appropriate dosages. These are important considerations, particularly given the patients served in Georgia’s public mental health system. The appropriate use and access to a wide range of medicines in these facilities is commendable. We also observed where medication response and side effects were not evaluated over time. This is an important area for improvement. Additionally, we observed 117 many instances of polypharmacy. This is a complex treatment issue, with national rates of over 1/3 of patients receiving 2 antipsychotics at the same time. Polypharmacy is a poorly understood yet common practice. Against this background, it is important that clinicians in Georgia’s facilities carefully evaluate over time the risk and benefit of polypharmacy. Additionally, the Division should continue to ensure best practices in the use of psychotropic medications. LIMITATIONS OF THIS AUDIT AND REPORT It is important to recognize that although this audit identifies many opportunities for change, it is limited in its scope. The audit focused on the state hospitals and did not address the care within the full delivery system. Community systems, outpatient programs, emergency and long term care options all play a role in the utilization and measurement of success of inpatient treatment. Inpatient systems are also dependent on the performance of and cooperation with the criminal justice system, and breakdowns within that system will also be exposed when looking at inpatient mental health care. Thus, the audit’s focus on hospitals does not give a comprehensive review of the continuity of care. Even with an excellent team of professionals, a detailed audit tool and full cooperation with each hospital, surveys were conducted over a time period of 2-3 days, and many details may have been missed. Certain aspects of care were not a focus. This survey was also not comprehensive in examining central office or even regional oversight, performance or interventions in the delivery of patient care, which are also critical factors in ultimate hospital performance. Our team did pay attention to environment of care issues during the audit. However, we did not assess capital planning and resources for buildings at each hospital. This is obviously and important aspect in considering treatment and service planning. 118 CONCLUDING REMARKS Georgia’s public mental health system provides care to patients who have complex needs, including (now more appreciated) substantial medical and substance abuse co-occurring illnesses. In conducting this audit we observed in each hospital, evidence of compassionate and quality care, given by committed staff. We also observed areas where care can be improved upon. In considering the improvements and recommendations outlined in this report, the commitment of the Division’s leadership and the support of the hospital staff are major resources to catalyze the momentum for future improvements. In this document, building upon the finding(s) and recommendations in 7 other documents which provide a comprehensive individual evaluation of each facility, we have provided specific recommendations for system-wide improvement. Although it is evident in the review of each hospital that they are a part of a bigger system, in many ways each facility operates independently. Benefits could definitely be derived from a coordinated and consistent statewide system. Many issues need to be addressed at the state level, as individual facilities are naturally unable to affect the changes needed. At the same time, the variances between facilities must be recognized, with acknowledgement of strengths, weaknesses and unique characteristics of each hospital. In some cases, statewide conformity, system compliance could dilute some of the inherent advantage to individual hospital performance. This dynamic tension is common to public mental health systems across the country. It is also important to appreciate that patients receive their care within the local system of care. Therefore, how well and in what manner each hospital integrates within its own system of care is a consideration key toward achieving a seamless continuity of care. These local relationships should continue to be fostered and developed. Finally, performance improvement is an ongoing process, and this report provides only a launching pad for change. Building upon the recommendations contained within this report, it is imperative that a performance improvement program is established that is comprehensive and continuous, developing a culture of quality within the system. Effective performance measures must be established to monitor, measure and evaluate system improvements that are implemented. The complexity and extent of findings speak to longstanding difficulties whose origins precede way beyond the current staff or leadership. 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