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The Tuberculosis Epidemic: Legal and Ethical Issues for Alcohol and Other Drug Treatment Providers
Treatment Improvement Protocol (TIP) Series 18

Chapter 2 -- Summary of Recommendations

Substance abuse providers are obligated by Federal and State laws (and their own ethics) to provide or arrange for TB screening and followup for their patients, to report communicable diseases, including TB, to local or State public health officials, to protect the confidentiality of their patients, and to provide a safe workplace for their employees and others. This TIP makes a number of recommendations that will help providers reconcile (and comply with) those potentially conflicting obligations. Those recommendations are summarized below.

Collaboration Between the AOD and Public Health Fields

The alcohol and other drug (AOD) and public health fields should collaborate with each other to prevent the transmission of TB in the AOD setting. Collaboration would benefit shared patients, the public at large, the public health field, and AOD treatment providers. The Federal confidentiality laws do not prevent the two fields from collaborating with each other. To promote a good working relationship, the AOD and public health fields should:

  • Use patient consent and qualified service organization agreements to share patient-identifying information
  • Develop cooperation agreements that describe the roles and responsibilities of each with respect to TB screening, treatment, and followup
  • Cross-train each other's workers
  • Develop mutually beneficial propaganda (e.g., brochures and posters)
  • Collaborate on record keeping procedures
  • Develop lists of useful contacts.

Providing TB Services for AOD Patients

AOD programs are required to provide or arrange for TB-related services for their patients. Those services must include mechanisms for screening, evaluating, treating, and following up patients with active disease or patients in treatment. In providing those services, AOD programs should:

  • Be sure to detect, isolate, and treat patients and applicants with active TB
  • Take care not to discriminate against those with TB who are not infectious and pose no threat of transmitting TB to others
  • Use intake questionnaires that focus on the signs and symptoms of TB and on past TB involvement including treatment, if any, and preventive therapy, if any
  • Provide purified protein derivative (PPD) skin testing for all high-risk applicants
  • Ensure that applicants and patients with positive PPDs receive proper medical evaluation
  • Report suspected and confirmed cases of active TB to local or State public health officials, as mandated by State law
  • Remove or isolate patients with active disease
  • Ensure that patients in need of TB treatment receive it
  • Use directly observed therapy to promote patient adherence to recommended treatment or preventive therapy regimens
  • Monitor patients in treatment or preventive therapy for adherence, efficacy of treatment, and side effects
  • Screen patients periodically for TB
  • Educate patients about the risk of TB in the facility, the signs and symptoms of TB, TB treatment, preventive therapy, and the side effects of TB medications
  • Keep careful records of PPDs, evaluations, x-rays, diagnoses, etc.
  • Collaborate with public health officials and others to ensure appropriate screening, evaluation, treatment, monitoring, and record keeping.

Toward a Safe Workplace

To promote a safe workplace, AOD providers should collaborate with public health officials and workplace safety specialists. Providers must be sure to exclude from the workplace any patients and employees who have active TB disease. In general, AOD providers should:

  • Develop a site-specific TB risk assessment
  • Develop a written TB-infection control policy based on that assessment
  • Employ a hierarchy of controls to prevent the spread of TB in the facility, placing particular emphasis on administrative controls
  • Screen new employees for TB
  • Counsel employees about the risk of TB at the facility
  • Arrange for annual or more frequent PPDs, depending on the risk of TB at the facility, for all employees
  • Analyze all PPD conversions
  • Try to determine the source or sources of TB exposures at the site, if any
  • Train employees regarding the facility's TB-infection control policy
  • Arrange to review safety practices at regular intervals or whenever there is reason to believe that TB may have been transmitted on the premises
  • Take care not to discriminate against employees with noninfectious TB
  • Respect employee confidentiality

 



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