From: Isa Diaz
To:
Rosalind Adams, BuzzFeed
Subject: Your inquiry about Shadow Mountain Behavioral Health
Rosalind: The following is a statement from Universal Health Services in regard to your recent
inquiry about Shadow Mountain Behavioral Health:
Once again, UHS finds itself in the position of having to correct the record, provide appropriate
context and explain the realities of the mental health system as you continue to show more regard
for sensationalism than the truth. UHS is proud of the care it provides patients at Shadow
Mountain Behavioral Health, a facility in good standing with the State of Oklahoma. The facility
has been recognized for the care of patients with the most complex psychiatric issues with
positive clinical outcomes. As is typical of your reporting style, you focus on the small number
of unfortunate events or incidents to create a false narrative about the quality of care and staff at
Shadow Mountain, while ignoring and disregarding the thousands of patients whose lives have
been positively impacted and improved by the care and treatment they received at Shadow
Mountain. The facility’s success is also reflected in positive clinical, evidence based
performance metrics.
With regard to some of the specific topics raised in your email:
“Surveillance video” and Use of Restraint and Seclusion
UHS strongly condemns the use by BuzzFeed of video tape illegally taken from our facility by a
former employee. The video clips would be shown to the public without context or knowledge
of the patients and their specific diseases and trauma history, their required treatment, or
knowledge of the staff and their professional backgrounds. Such action demonstrates a careless
disregard for the truth and a willingness to sensationalize events. We also question the ability of
any “experts” to comment about the events in the video without such information – which they
do not have.
You assert that the UHS Corporate Compliance Office was offered the opportunity to review the
video by the former employee and declined the opportunity. This is false. Not only was the
UHS Compliance Officer not offered the opportunity to view the video, but when he learned that
it was taken from the facility, he requested that it be returned immediately. It was not.
With regard to restraint and seclusion (often referred to as restrictive interventions), these are
options of last resort when a patient is at imminent risk of hurting themselves or others. It is
utilized when all other tools have failed including verbal de-escalation.
All facility clinical employees are required to be trained in an accredited or certified program for
physical management. Verbal De-escalation is an additional component of that training. It is
always preferable that staff utilize those techniques to assist a patient in regaining control.
Federal and state guidelines govern the use of these interventions. Every facility has policies and
procedures that address the utilization of restraint and seclusion including the required training
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 elements. The majority of UHS facilities are mechanically restraint free, including Shadow
Mountain. 97% of UHS BH facilities have lower rates of restraint and seclusion than the national
averages as reported by CMS’ Inpatient Psychiatric Quality Reporting System (IPFQR) in 2015.
Shadow Mountain’s IPFQR measures related to restraint and seclusion utilization are
dramatically under the national average—which is our goal.
UHS endorses the Six Core Strategies for Restraint Reduction © developed by the National
Association of State Mental Health Program Directors as our guide for assisting facilities in
reducing the use of these interventions. These principles have assisted the Division in reducing
restraint use year over year by more than 10%. These principles include the establishment of a
philosophy statement, data analysis, patient feedback and leadership involvement. .
Unfortunately, restraints and seclusion must be used on occasion particularly in a treatment
program like the one at Shadow Mountain considering their specific patient population who
often act out their trauma histories through aggression or self-harm. When a patient is in
restraint or seclusion, they are subject to constant monitoring to ensure their safety. This
occurred during events in the video. At all times the safety of our patients and staff is our highest
priority. None of the patients depicted in the video suffered any injuries or bodily harm. External
reporting of restraint and seclusion is only required in the case of a significant injury.
Patient privacy laws prohibit UHS from offering detailed comment on the patients shown in the
video, their diagnosis and treatment notwithstanding your claims that you will protect their
identities. It is impossible for anyone to judge the content of the video without detailed
knowledge of case histories, and no credible health care professional would render an opinion
without such knowledge as it would be irresponsible. Appearance can mask reality. In each
situation, there was far more occurring which precipitated the hold and/or seclusion which are
not visible or audible on the tape. For example, in the case of a patient who appears to be hitting
himself while a staff member seemingly looks on, the viewer with no background or knowledge
would not understand or be aware of the underlying pathology and history of the patient which
includes escalation with any physical contact inciting further violence for a sustained period of
time. With such a patient, while the conduct is disheartening, observation to ensure that no
actual harm occurs is the best course of conduct as opposed to intervention which has previously
escalated and continued the behavior. In this specific case, if the patient was harming himself
our staff would have immediately intervened.
Shadow Mountain’s Record for Quality:
Shadow Mountain Behavioral Health is fully accredited by The Joint Commission, a respected,
independent organization with a 60 year record of undertaking robust and comprehensive
evidence-based evaluations of health care facilities on behalf of the federal government.
The Joint Commission designated Shadow Mountain as a Top Performer in Key Quality
Measures during each year of the program’s existence between 2011-2015. To be a Top
Performer, BH facilities were required to achieve performance of 95% or above on multiple
evidence-based clinical accountability metrics, including appropriate use of restraint and
seclusion protocols. Only a small number of BH hospitals were eligible for the distinction given
the extensiveness of the reporting obligations and high bar to achieve 95% on all criteria. During
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 the Top Performer program, only about 30% of eligible hospitals nationwide ultimately attain
this level of recognition. Contrary to the isolated and misleading accounts in your article,
Shadow Mountain also enjoys a very low rate of serious incidents which in 2016was .007%
further attesting to the quality of care provided notwithstanding the complex acuity of our patient
population.
Shadow Mountain patients also report high levels of satisfaction with the care they receive based
on the results of anonymous surveys provided to every patient. Between 2013-2016, the
aggregate patient satisfaction score was 4.4 out of a maximum of 5 and so far in 2017 the
aggregate score is 4.5.
Meeting Unmet Need & Regulatory oversight by the State of Oklahoma:
Shadow Mountain Behavioral Health is a partner with the State of Oklahoma, and is recognized
as a facility specializing in caring for clinically complex psychiatric patients. Shadow Mountain
is providing important services and filling a critical and often unmet need. Currently in
Oklahoma there is a lack of treatment services for adolescents who exhibit psychiatric diagnoses
coupled with oppositional defiant disorders. These patients have experienced extensive trauma
and based on their trauma history are aggressive and engage in self harm. Shadow Mountain is
one of the few treatment facilities that will admit and provide treatment for this patient
population. On a regular basis, Shadow Mountain receives calls from state agencies requesting
admission for patients who have been denied admission to other treatment facilities. Over the
past 36 years, Shadow Mountain has developed a reputation for the treatment and positive
clinical outcomes for children and adolescents who have been deemed untreatable. For
residential treatment care services patient acuity is so complex that Shadow Mountain provides a
1:3 staffing ratio for our Specialty RTC programs.
Like any health care provider, Shadow Mountain is highly regulated. State regulators are
regularly at the facility to review the care provided and to ensure compliance with applicable
state laws. As at other UHS facilities, Shadow Mountain takes all feedback received from
regulators seriously and constantly explores how we can improve the services we deliver. There
are also times when we disagree with the findings of regulators and we will engage in dialogue
to resolve matters including the possibility of a formal appeal. We are proud of our record of
working with the State of Oklahoma to address any identified concerns. For example, in
November 2016, when we received a written communication from the Oklahoma Health Care
Authority (OHCA) notifying us of their intention to terminate our acute services contract due to
staffing issues raised earlier in the year, while we disputed the basis for this action, we worked
quickly to address issues and a new contract was awarded within 5 weeks. Shadow Mountain is
currently in good standing with the State, we have contracts in place for each of our programs,
and recent surveys have been essentially deficient free.
Employee complaints
UHS takes seriously any employee complaint against another employee or facility leader. The
company provides a Compliance Hotline and web reporting program as a confidential way for
employees to use to ask questions or voice concerns that they may have about suspected
violations of company policies or violations of the law. All complaints regarding improper or
unethical business practices, violations of the law or company policies, including harassment,
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 fraud, retaliation and discrimination are taken seriously, addressed promptly and handled in a
manner that protects the privacy of the caller.
When a call is related specifically to a facility CEO, details are forwarded to the assigned
Regional Vice President and to the Corporate HR department for investigation. Any issues that
require further action, up to and including coaching or discipline are handled with the Regional
Vice President.
In the instance you raise regarding the CEO of Shadow Mountain, complaints were handled per
established company policy.
Shadow Mountain – attracting employees and compensation
We challenge the incorrect assertions from BuzzFeed with regard to Shadow Mountain’s ability
to attract qualified staff as well as the assertion that our pay scale is somehow deficient. Shadow
Mountain is proud to be an employer of choice in the community for those seeking employment
in behavioral health. The mere fact that a handful of staff members over our long history have
failed to meet our expectations for patient care does not equate to the false premise that our staff
are not caring, dedicated professionals committed to their patients and the goal of providing the
best possible care and treatment. With regard to the two specific employees you reference,
Tashia Taylor and Dale Allen, both were terminated. In fact, Tashia Taylor was terminated a year
and a half before UHS acquired the facility.
With regard to compensation, our pay scale is based on local market analysis with appropriate
adjustments made periodically as required to ensure market compatibility in order to ensure
recruitment.
Peer Assistance Program
The Peer Assistance Program administered by the Oklahoma Board of Nursing is a voluntary,
confidential program which assists licensed nurses in returning to the safe practice of nursing.
Participation in the program includes development of an individual plan of recovery, monitoring
of compliance, support and education. UHS and Shadow Mountain are supportive of programs
like this that offer a chance for impacted individuals to recover and return to safe and productive
employment.
We dispute the contention that “80% of the nurses were in the Peer Assistance Program.” A small
percentage of Shadow Mountain’s nurses are participants in the Peer Assistance Program. We
respectfully decline to give the exact number because that is at odds with the goal of a
confidential program and may cause pain and stigma to those participating. We feel strongly that
it is our obligation to assist professionals get their lives back on track in a safe and responsible
way.
Sharon Worsham
We do not comment on internal matters such as the one related to Ms. Worsham’s husband’s
partial ownership in real estate leased to one of Shadow Mountain’s sites. The lease arrangement
was initiated during PSI’s ownership of Shadow Mountain and UHS inherited it following our
acquisition. However, that situation is not a material transaction which requires public disclosure.
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 Regardless, this matter has nothing to do with the quality of patient care delivered at Shadow
Mountain.
Admission Practices
We dispute any claims that we are intentionally admitting patients who do not meet admission
criteria at Shadow Mountain. Shadow Mountain has written admission criteria and all patients
are assessed by a psychiatrist to determine if they meet that criteria.
We also dispute the contentions by the former psychiatrist that statements are written which are
not attributed to the patients and/or their parents. We previously confronted the former
psychiatrist who made this accusation and demonstrated the falsity of the claim. Additionally,
any contention that there was “increased scrutiny” on the discharge of patients when census was
down is inaccurate. Discharge decisions are made by the psychiatrists in consultation with the
treatment team at the facility and are respected regardless of census.
Police Calls
Your questions, again based on information without context, grossly distort and misapprehend
the issue of police calls associated with Shadow Mountain. It is exceptionally rare for police to
be called to our facility to intervene with patients. This is in large part because our highly trained
staff is best equipped to deal with psychiatric patients as opposed to police who are trained to
deal with law enforcement and safety.
Our facility’s interaction with police is often to meet our legal notification obligations for which
the police are required to investigate (most times resulting in unsubstantiated matters), to deal
with outstanding warrants, to follow-up on an investigation that is unrelated to our facility, or for
other reasons.
Multiple patients’ incident
You reference an incident that took place in February 2015 involving multiple adolescents.
These adolescents were being treated for a variety of trauma-related issues. The entire matter
began and ended in less than 20 minutes. While police were called, our facility CEO assessed
the situation and determined that they were not needed. We are proud of the way that our staff
responded, and how they were able to calm the situation and the patients in a way that everyone
was safe and returned to the unit. Subsequent to the incident, we terminated a manager who in
our view precipitated the entire situation.

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