Below is a copy of the letter sent to Cheryl Williams on January 16, 2003 regarding the October 2002 Licensing Alert "Staffing Regulations- Primary Care Hours and Detoxification Activities."
The primary problems revolve around the 11:00 p.m. - 7:00 a.m. shift, the definition of primary care hours in a detox setting as "primary care hours are 24 hours a day, seven days a week," and the new interpretation that states, "these designated staff may not have any duties other than the detoxification unit."
The letter to Ms. Williams outlines the work group's primary concerns, a request for additional information, and provides several recommendations. Questions can be directed to Lynn Cooper at the Association.
Cheryl Williams, Director
Bureau of Community Program Standards
Division of Drug and Alcohol Program Licensing
Department of Health
132 Kline Plaza, Suite A
Harrisburg, PA 17104
Dear Ms. Williams:
I am writing to you in regard to the Licensing Alert 3-02 on behalf of the members of the Pennsylvania Community Providers Association (PCPA). As you heard at the November PCPA D&A Committee meeting, a number of providers are experiencing significant problems with this Alert. As you know we decided to organize a small work group to discuss the problems in more depth and provide some recommendations. First and foremost, we too are alarmed by the deaths that have occurred and agree that some clarification of the detox regulations is necessary.
The work group concluded several things:
1. Detox programs are closing or being reduced.
2. Many programs are small (3 to 10 bed units) but very much needed.
3. The latest interpretation is too stringent.
4. Staff monitoring should be appropriate/proportionate to the census of the population.
5. A review of the assessment and screening process should be done to prevent inappropriate client placement.*
The work group has requested additional information about the recent tragedies reported by the Department that initiated this Alert. More information about the circumstances of these events may help us to provide further recommendations.
The primary problem revolves around the 11 pm to 7 am shift, the definition of primary care hours in a detox setting "primary care hours are 24 hours a day, seven days a week", and the new interpretation that states, " these designated staff may not have any duties other than the detoxification unit".
We suggest that the Alert read:
1. Appropriate professional staff must be onsite at all times.
2. Regular monitoring of detox clients must occur.
3. At no time may detox clients be left unattended.
4. A plan must be in place to appropriately respond to medical emergencies.
We look forward to your response to our recommendations.
Sincerely,
Lynn Cooper
Senior Policy Specialist
*Appropriate placing of clients is critical to successful outcomes. Obviously, individuals who present with major complications requiring inpatient diagnosis and treatment should not be placed in a medically monitored detox program. Individuals that require a higher level of care must be treated in a higher level of care program. Increasing the requirements on the lower level of care program is inappropriate. Examining the screening process may be most important.