This is an issue really close to home for two reasons. First, this facility is truly in my neighborhood and second because I did some work for this agency in the mid 1990s. Over the last several years they have had their challenges, but this one is central to my realm of expertise. So, I will comment and hopefully shed light on this subject for others in similar situations.
One of our local social news sites, Noozhawk , has two articles about a recent CMS visit to the SB County Psychiatric Health Facility and followup on lax drug controls. I first have to say that I'm shocked the DADMHS administrators were surprised by a visit from CMS. Note to self - if you accept any Medicaid (MediCal), Medicare or other CMS funds for treatment of patients, you should be prepared for a visit at any time. It is really just that simple!
Yes, it is true that CMS over the last many years has delegated their survey/audit visits to the states, but they can and still will come out themselves to confirm state findings (its is part of their own due diligence). This can also occur when they receive a complaint (staff, patients, families or anyone else), they get word of other problems (such as billing or other agency sanctions) or because they happen to be in the area. It doesn't matter how big or small you are, if you accept their money you agree to comply with their minimum standards for the facility and patient care.
And, the CMS surveyors have a reputation for being the most strict. So, if you don't have a copy of the manual (regulations) and you have responsibility for any licensed acute care facility, get a copy and start reading. It is thick and you can't wait to do this when they are sitting in your waiting room.
My observations (and advice for others who may be new to their responsibilities) include:
How often did the PHF's administration conduct a safety and quality walkthrough of the Contractor's kitchen? How often did they conduct a walkthrough of the PHF and audit compliance themselves?
The technology is available to have more responsive pharmacy services and timely availability of medications for these patients. And, just because you have a contractor, you don't delegate responsibility for oversight.
The hospital administrator is responsible for ensuring the presence of an effective quality improvement program (including safety, patients rights, quality, etc). And, the Governing Body is responsible for oversight and ensuring that the administration is fully performing their responsibilities. (Hospital Administion 101)
The State Department of Mental Health is also an important inspection, however, their emphasis is usually a little different. CMS comes first from the general hospital world and that is the approach they take.
A hospital must have its own governance structure clearly delineated and followed. There are ways to address more system wide issues, but the hospital can't get lost in the system. Acute facilities (because of the higher needs of patients) are held to a higher standard and this should always be in the forefront. The County Board of Supervisors can delegate responsibility to department heads, but they can't delegate their responsibility for oversight. In Ventura County, the Board Of Supervisors has appointed two of its members to serve on an Oversight Committee with hospital leadership. This seems to work well and might be a good model for Santa Barbara County to follow or explore some of the other governance models of CA public hospitals.
There should also be a clearly written policy identifying the hospital administrator and who is responsible in his or her absence. This is also hospital administration 101 and if the other agencies weren't checking this, then that is a problem.
I'm sorry I have to be so blunt, but feel that the situation warrants it. At some point, people need to step up to the plate and make the decisions necessary to fulfill their responsibilities to the patients and our community. Being responsible for an acute care facility (no matter how small) is a big job and it must be taken seriously -- because the lives of our patients truly depend upon it.