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January 13, 2023 Carrie McGregor Specialized Treatment Services, Inc. 1132 Central Avenue NE Minneapolis, MN 55413 License Number: 1063318 Licensing Investigation Number: 202203107 Dear Carrie McGregor: On October 10, 2022, the Minnesota Department of Human Services (DHS), Division of Licensing, received your request for reconsideration of both citations in the Correction Order (Attachment A) issued to you by the Department of Human Services September 28, 2022.
Citation 1. The correction order stated that one file reviewed for the requirements governing high dose requirements (client file numbered 1) did not meet requirements. The client was admitted to the program on September 5, 2019, with an ordered admission dose of 150mg methadone. The file did not contain documentation the client met face-to-face with the prescribing practitioner upon admission. Request for Reconsideration. The license holder indicated the citation was incorrect because the client was not admitted at a does that exceeds 150mg. Reconsideration Determination. Pursuant to Minnesota Statutes, section 245G.22, subdivision 4, a client being administered or dispensed a does beyond that set forth in subdivision 6, paragraph (a), that exceeds 150 milligrams of methadone or 24 milligrams of buprenorphine daily, and for each subsequent increase, must meet face-to-face with a prescribing practitioner. The meeting must occur before the administration or dispensing of the increased medication dose. After review of the documentation submitted by the license holder, the Commissioner has determined there is insufficient evidence to support the violation, and it is appropriate to rescind the citation. Citation 2. The correction order stated that one client reviewed for requirements governing criteria for unsupervised use (client file numbered 1) did not meet requirements in the following ways: a. The client was given their first take home dose of methadone on Saturday, September 7, 2019 for Sunday, September 8, 2019, when the clinic was closed. The review for criteria for unsupervised use was not completed until December 30, 2019; and b. The review for criteria for unsupervised use did not include the determination, including the basis of the determination documented in the client’s medical record. Request for Reconsideration. The license holder indicated they had been previously cited for the violation during a previous review and had corrected the violation. Reconsideration Determination. Pursuant to Minnesota Statutes, section 245G.22, subdivision 6, paragraph (b), a practitioner with authority to prescribe must review and document the criteria in this paragraph and paragraph (c) when determining whether dispensing medication for a client’s unsupervised use is appropriate to implement, increase of extend the amount of time between visits to the program. The criteria are: 1) absence of recent abuse of drugs including but not limited to opioids, non-narcotics and alcohol; 2) regularity of program attendance; 3) absence of serious behavioral problems at the program; 4) absence of known criminal activity such as drug dealing; 5) stability of the client’s home environment and social relationships; 6) length of time in comprehensive maintenance treatment; 7) reasonable assurance that unsupervised use medication will be safely stored within the client’s home; and 8) whether the rehabilitative benefit the client derived from decreasing the frequency of program attendance outweighs the potential risks of diversion or unsupervised use. Pursuant to paragraph (c), the determination, including the basis of the determination must be documented in the client’s medical record. After review of the documentation submitted by the license holder, the Commissioner has determined there is insufficient evidence to support the violation, and it is appropriate to rescind the citation. Disposition: The Commissioner has reviewed the license holder’s request for reconsideration and all of the information submitted in response to the correction order. The Commissioner finds there is insufficient evidence to support citations 1 and 2, and they are rescinded. This is a final agency decision. Sincerely,
Frances Simon Standing, Attorney Legal Counsel’s Office Office of Inspector General
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