Below are RCA’s answers to questions from the Boston Globe and STAT about the three
investigations conducted by the state at Westminster and Danvers, and the employee complaints
contained within. Some names have been removed to protect privacy, and one question about an
open investigation was removed because the investigation was subsequently closed, and reporters
inquired about it separately. Questions not related to the DPH investigations have been removed.
The first line of question number 14 was slightly reworded to remove a reference to a page
number that does not exist in this file.
QUESTIONS ABOUT DPH INVESTIGATIONS
1. The state Department of Public Health began an investigation at Westminster after
receiving complaints from staff members. Investigators visited RCA on Feb. 1 and 2,
found many of the complaints to be substantiated, and issued a deficiency correction
order on March 9. The investigation was deemed closed on April 7. Can you comment on
this?
RCA cooperated fully with BSAS during the investigation and conducted its own internal
investigation. RCA refuted many of the findings during the interview with BSAS. BSAS took
the position that because certain documentation was incomplete, they had to conclude that
certain services were not provided. Subsequent to the BSAS inspection, RCA conducted
internal audits and confirmed that RCA did have adequate staffing and, in fact, had excess
staff hours over those required by BSAS during a period of time mentioned in one of the
complaint letters. This was confirmed through ADP payroll records.
In addition, RCA uses video cameras in its treatment rooms and a review of that footage
confirmed that RCA employees performed all required services and even more treatment
services than were required by BSAS. Nevertheless, because that information was not
readily available at the time of the BSAS inspection it was not considered by BSAS. RCA was
instructed by BSAS to respond to their finding in a specific manner and RCA followed their
direction and the matter was closed.
2. Included in the state’s investigative file (a public document) are six complaints from
employees. There are many detailed allegations made. We would like a response to the
entire file.
We have carefully addressed these issues above and below. Please advise if there are any
specific issues you believe were not addressed.

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DM2\8111653.6

 3. In a letter written 2/15, an employee who says he/she is the “financial analyst” says
he/she was told to “hide” when BSAS investigators came to Westminster. Is this true? If
so, why?
It is our understanding that the employee in question was given the opportunity to participate
in the meeting with the BSAS investigators. Our Corporate VP of Operations, Christina
Madeira, met with the employee and offered her an opportunity to participate. She declined
the invitation. In addition, all of the financial information was prepared by this employee
(who was extremely helpful in the process), and 100% of that information was provided to
Christina Madeira and the BSAS investigator. Further, RCA and this particular employee
enjoy a very good relationship and she continues to refer patients to RCA.
4. In a text message exchange between an employee and a manager, the employee asks
why they were told to hide for two days. In response, the manager says: “Haha bc what
we do isn’t legal.” The exchange is dated immediately after the state visited. What is
your comment on this? Did RCA tell employees to “hide” when BSAS came to visit the
site in early February? If so, why? If not, how do you explain both the letter in the
preceding question and this text message exchange?
Same as #3 above.
5. In the above-referenced letter, the employee writes that they grew concerned about
patient finances, fraud, medication diversion, staffing safety, patient safety, and general
operations of the facility including no heat, no hot water, no pillows, and no blankets.
The employee says they relayed their concerns to management. The employee states that
other employees have reported questions of unethical behaviors, patient safety, and
illegal behaviors to corporate and have been terminated or forced to leave. The employee
states that they began documenting and keeping detailed notes, copies of emails, and
collateral information regarding the activities this person deemed “suspicious.” Among
the concerns the employee lists: collecting out-of-pocket maximums, setting up payment
plans on claims that have not yet occurred, billing up front for services that have not yet
occurred, patient brokering, taking cash for patient referrals, and “warehousing of
patients” who were not suited to the facility. Patients refused to sign financial statements.
The employee reports that they were told to “dance around the financials.”
The Department of Public Health has investigated RCA on two separate occasions (both
unannounced) and as you will note, has never cited, or was able to substantiate any fraud or concern
around patient finances. In addition, RCA underwent a survey by the Joint Commission and is fully
accredited by the Joint Commission. The Joint Commission accredits and certifies more than

21,000 health care organizations and programs in the United States. An independent,
nonprofit organization, The Joint Commission is the nation's oldest and largest standardssetting and accrediting body in health care. To earn and maintain The Joint Commission’s
accreditation, an organization undergoes an on-site survey by a Joint Commission survey
team at least every three years.

 RCA Westminster has never been cited for any concerns around medication diversion,
storage or handling. RCA Westminster has never been cited or found to have concerns
around basic operations including heat, hot water, pillows, and blankets. RCA Westminster
has never been cited for patient brokering or other concerns related to patients’ admission
into RCA programs. These accusations are being driven by a limited number of disgruntled
employees who acted in a coordinated manner by writing letters of accusation to BSAS
within the same twenty-four hour period. We dispute these accusations and the facts refute
these allegations.
Here is the RCA response to the following accusations:
 Rehabilitation facilities are required to collect patient responsibility payments.
o RCA routinely sets up interest-free payment plans to help patients afford their
treatment.
o Those payment plans must be set up in advance because we are required to
attempt to collect all patient responsibility payments.
o RCA collects co-pays and deductibles upon admission if financially viable for
the patient, the common practice in all healthcare. The remaining patient
responsibility balances are not billed until services are completed.
 Patient brokering
o RCA does not pay or receive cash for patient referrals.
o RCA does not warehouse patients who are not suited for the facility.
o RCA has a wait list that totals over 50 people regularly.
o RCA refers patients daily to competitors’ facilities as a free service to the
patient.
o RCA receives zero compensation for those referrals.
o RCA does not pay kick-backs to patients.
o If RCA has any questions about the integrity of a referent, we will stop
working with the referent immediately.
o RCA does perform detox services for “residential only” providers. When the
detox is completed, the patients return to those facilities.
 RCA does not discriminate against patients based on their ability to pay
o RCA has many in-network contracts that authorize length of stay based on
medical necessity.
o RCA admits patients every day regardless of their ability to pay
6. In another February 15 letter, a staff member sent along their resignation letter. In it,
among other complaints, they allege: “Patients have told stories of getting kickbacks to
complete detox. The human trading and promising of ‘We will send you 2 detox patients,
but you have to send us back 3 for our sober living facility and once they relapse we will
send them back to you for detox again.’ No one can tell me that this isn’t true. … This is
a fact and it is disgusting to be a part of it.” The employee also states that, “We are a
health care organization who forgot our promise to do no harm. Part of doing no harm is
not accepting patients who are inappropriate for our services, but we do so anyway
because they can pay.” The staff member also reports that people who run out of money

 are kicked out of treatment abruptly, but other “problem patients who have payment
methods (many who have stated that they were only there to get their money)” are
allowed to stay. The staff member describes “dangerously low staff to patient ratios.” The
staff member also says it is impossible to tell who actually gets clean because patients
“cheek” medication to pass them on for financial and physical favors.
RCA refutes all of these allegations. It has not and will never participate in patient
brokering or any form of paying for patients. RCA operates at nearly 100% occupancy, and
has a per shift patient to staff ratio that averages less than 1 to 4 and an overall staff to
patient ratio of 1.2 to 1. All payroll records are maintained in the ADP payroll system and
have been internally audited to verify staffing ratios. These allegations are also refuted in
the response to #5 above.
7. In another February 15 letter, a staffer writes that they were fired from RCA on Jan. 24,
and they believe it was retaliation for “advocating for my patients’ rights and dignity.”
The staff member writes that they brought numerous concerns to the attention of
leadership and nothing was addressed. Among the concerns the staff member lists:
“human trafficking of substance abuse patients.” The staff member says that numerous
patients told them that they were aware of the patient brokering and utilizing the situation
to tour the country. They would enter treatment with the support of the marketers with the
agreement that they would be “taken care of.” The staffer writes that staffing was a major
issue and at times it was unsafe. They also say that because of the low staffing, patients
engaged in sexually inappropriate behavior. The staff member said that once, drugs were
found in a patient’s room, but staff was ordered to disregard because removing the patient
would lose the facility money. The staff member also included a lengthy list of concerns
about a patient who later died, stating that he appeared overmedicated, was getting a large
dose of suboxone and appeared to be nodding out. The staff member also said that staff
were told “that he and his family had an endless supply of money and we were to do
whatever we had to to keep him in the facility although it was said numerous times that he
wasn’t clinical appropriate.”
RCA cannot and will not comment on protected health information or any other details that
may be related to a patient’s stay in treatment with us. The non-patient specific accusations
are responded to as follows:
 RCA’s mission is to advocate for its patients every day, which RCA does in many
ways:
o RCA maintains a fully staffed utilization review group which interacts with
insurance companies to ensure that RCA patients are receiving the treatment
that they need
o RCA answers its phones 24 hours a day, 7 days a week
o RCA provides for transportation if needed 24 hours a day, 7 days a week
o RCA is open and takes admissions 24 hours a day, 7 days a week
o RCA is writing legislation at its own expense to advocate for its patients
o RCA is building the finest facilities and believes it has the most extensive and
complete continuum of care model in the marketplace

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o RCA has introduced the neighborhood model to make treatment easier
o RCA is working with people of all economic means, including those who
cannot afford to pay for treatment
Human trafficking – This comment is absurd and has been answered above. We do
not pay outside referents for business and certainly do not “send patients around the
country.” Further, as stated above, if we found referents that are “patient
brokering,” RCA would immediately cease working with the referent.
Staffing ratios were addressed in the response above.
One instance was found where patients had sexual relations in the facility. RCA dealt
with the patients in a clinically appropriate manner, and has processes in place to
mitigate the opportunity for this type of behavior to occur in the facility. By
definition, individuals with substance abuse disorder exhibit poor impulse control.
RCA establishes and requires that patients comply with community standards
beneficial to their recovery. Also, in some instances it is possible that couples may
seek treatment together. Your question provides no information at all about the
alleged circumstances involved, and fails to consider the above facts.
It is possible for patients to get contraband into a facility, in spite of best practices
used at intake to check the patient and all belongings, and to check visitors when they
come to a facility to visit a patient. RCA addresses any findings in a clinically
appropriate manner.

8. In another February 16 letter, a staffer who was fired said the facility should be closed.
The staff member says other employees came to them with fears of patient brokering,
fraudulent financial reporting and activity, patient safety, mistreatment, and medication
diversions. The staff member says that licensing requirements for staffing are not being
met. The staff member alleges that RCA is accepting patients who are not medically
appropriate. The staff member also states that RCA was utilizing “an unlicensed part of
facility to warehouse a cash pay mental health patient alone.” Can you comment?
These accusations are refuted and many are addressed in the responses above. Additionally,
we do not fraudulently report our financials. We are audited every year by an international
CPA firm. Further, we have been audited by BSAS multiple times, and not one of the
accusations related to patient safety, mistreatment or medication diversions has been
substantiated by the State. RCA has never exceeded its licensed number of beds.
9. In another February 16 letter, a staff member writes that staffing is “unsafe” and training
is not sufficient. The staff member also writes that after telling the Vice President of
Human Resources that the staff member told the Department of Public Health of their
concerns, the VP asked, “Were you this honest when the DPH visited yesterday?” And
the staff member said yes. The staff member says they were fired less than two weeks
later, and says this is retaliation. Can you comment?
These accusations are refuted and are addressed in the responses above.

 10. The state’s investigation report shows that it substantiated many of these complaints.
Westminster was found to be understaffed. Not a single employee interviewed could
identify who the Program Director was for either ATS or CSS. Group notes were either
not being documented or groups were not occurring according to the schedule. It was
found that male and female CSS clients engaged in sex in one of the bedrooms “which
demonstrates a lack of oversite that ensures the health and safety of clients.” Case
management, individual counseling, and group were not occurring. And the state found
that a client was admitted who was inappropriate for that level of care “as evidenced by
the client’s need for private nursing aides.” Can you comment?
While the State made several findings based on the documentation requested at the time of
the inspection, it did not substantiate “many of these complaints”. During the exit interview
with the State, the RCA representative explained that although RCA had failed to keep
complete records, there should be no question that the required treatment services were
provided and staffing was proper. Further, as stated above, internal audits of our payroll
system and video footage of our treatment rooms confirm that the services were provided and
that our staffing was proper.
RCA acknowledges that it did not specify individual Program Directors for ATS or CSS.
This is only done in Massachusetts and is a process that RCA disagrees with. Our Chief
Clinical Officer Deni Carise, has written about her concerns that a complete segregation of
patients from staff they first met in detox is detrimental to therapeutic treatment (see below).
Ms. Carise has effectively advocated for BSAS to allow a waiver of the strict requirement of
separate staffing because she believes patients need to feel a “continuity of care” as they
transition from various points of treatment, including from detox to residential to outpatient
services. Nevertheless, RCA has complied with the BSAS requirement to have individual
directors for ATS and CSS services.
The statements concerning lack of services provided and sexual relations by patients are
addressed in other parts of this response.
Separating ATS and CSS Staff and Activities –
The Negative Impact on Therapeutic Alliance and Outcomes
By Deni Carise
Today, most patients admitted to residential substance use disorder treatment (SUD) have
dependencies on substances that produce severe (opiates) and sometimes life-threatening
(alcohol, and/or benzodiazepines) withdrawal symptoms. It’s rare, in fact, that patients are
admitted for care with a primary diagnosis for substances such as cocaine or marijuana
alone, where medically based detoxification is not needed.
Recovery Centers of America (RCA) views effective treatment as including a continuum that
typically begins with detox in which medical and psychological stabilization begins followed
by a seamless transition into residential treatment where patients medical needs are less

 acute but where 24-hour care is still needed and where patients continue to build an
awareness of their disorder as well as the physical, emotional, and spiritual strength needed
to engage in recovery without the safety of 24-hour care. The continuum of care should be a
somewhat fluid pathway that meets individual patients’ needs at different points as they
navigate both acute and post-acute withdrawal symptoms.
The linear path then moves to outpatient care, which includes partial and intensive and
general outpatient treatment until the person can maintain recovery without ongoing
professional help. According to the National Institute on Drug Abuse, participation for less
than 90 days is of limited effectiveness for maintaining positive outcomes.
The more this continuum of care connects these levels of services, the more likely the patient
will continue in care for a longer duration and complete the full course of care. This in turn
leads to increased likelihood that the patient will maintain the gains made in treatment,
continue in recovery, and importantly, not have need for further treatment at an acute level
of care.
Numerous studies have shown that those who receive a minimum of 90-days of treatment
(this can include residential and various forms of outpatient) are much more likely to
maintain recovery and return to a productive life.
But the continuum of care is punctuated with many “break-points” - times when patients find
it easier than others to quit treatment. One of those breakpoints is during transitions
between levels of care – primarily from residential treatment to outpatient treatment. The
transition from residential to outpatient is a significant breakpoint as patients must “start
over” with a new counselor and a new group of patients after spending the prior 2-4 weeks
getting to know and trust their counselor in the residential program.
Currently in MA, there is a requirement that staff and services on the detoxification units
must be completely separate from staff and services delivered on the residential care unit. In
our case, these patients transition, literally across the hall to an entirely new set of staff new nurses, counselors, physicians and even case managers. This leads to an unnecessary
disruption in treatment and an additional “break-point” in treatment where patients have to
essentially start over, tell an entirely new staff about the problems caused by their substance
use, the psychiatric symptoms, family problems, etc. In addition to inserting a new “breakpoint” after just 5-7 days in treatment, starting over with a new set of staff profoundly
hinders the development of the therapeutic alliance. Two decades of empirical research have
consistently linked the quality of the alliance between therapist and patient with outcomes of
care. Additionally, a patients report of a positive connection with the treatment staff early on
in treatment seems to be the strongest clinical indicator of therapeutic alliance and positive
clinical outcomes.
When patients enter treatment, they submit to a battery of assessments: Intake/Admission,
Biopsychosocial, Medical and Nursing, to name four – all due in the first 24-72 hours. One
of their most resounding complaints centers on the fact that they must tell and re-tell their
story many times to so many people.

 Imagine for a moment that drugs or alcohol have become such a problem for you that you
must stop all your normal activities in life and check into a residential treatment program.
You have to put aside work obligations, family, and child care responsibilities, etc. You
enter detox and you tell the physician, nursing staff, counselors, and your case manager all
about your drug or alcohol behaviors and the problems that led you to treatment. You talk to
the psychiatrist about your depression or anxiety. Then, 5-7 days later, you have a new
nursing staff, a new case manager, a new therapist, even a new psychiatrist and you have to
repeat all of the things you just told the staff in the detox center. I think it’s clear how this
could lead a patient who may already be anxious and considering quitting treatment, to
decide that starting over is just too overwhelming for them.
Imagine too, never seeing another patient who has made it through detox and gone one to
improve in residential care, even if just in a seminar, workshop or at lunch. The benefit of a
patient seeing someone who was in detox like you just 2 weeks ago seem so healthy can’t be
underestimated.
It’s also clear how this works against the therapeutic alliance – one of the most essential
ingredients needed for treatment to be successful. Those staff-patient bonds become more
difficult to construct when an unbending line has been drawn between detox (ATS) and
residential (CSS) staff and services. It’s curious to RCA, then, that Massachusetts has drawn
a firm line between detox and residential care and have told us that staff members cannot
work in both the detox and the residential unite, that residential/rehab patients cannot be in a
seminar or workshop with detox patients, etc. The reality is that patients improve most when
there is continuity of care and caregivers, when they can develop trust in their helpers and
become familiar with them.
The RCA model of care emphasizes the immediate assignment of newly admitted patients to
the counselor, family therapist, case manager, psychiatrist, nurses and other staff who will
see them through detox and residential care and ultimately to discharge.
Additionally, with a nationwide shortage of psychiatrists, nurses, family therapists and other
healthcare providers, and a state requirement to have separate staff for CSS and ATS
services in the same building, RCA is hiring duplicate staff and often splitting desirable fulltime jobs into 2 part-time jobs when, in fact, greater continuity of care would result from a
full-time staff member who works with the patients for the duration of their stay, an average
10-28 days. Continuity of care also allows doctors and nursing staff to be more effective and
to deliver care safely, ensuring patients are medicated properly.
To be sure, CSS and ATS are distinct levels of care with distinct activities, goals and
requirements but from the patient’s point of view, it’s a continuous experience, with a set of
staff designed to help them get well. We hope BSAS will take this into consideration and
allow RCA to provide continuity of staff and services for the patients who have entrusted us
with their care.
11. The state began another investigation at Danvers after receiving a report of an alleged
sexual incident. Investigators visited Danvers on 5/10 and 5/11. The sexual incident

 allegation was deemed not substantiated, but a deficiency correction order was issued for
other things. The issues the state found include: Danvers was not properly staffed.
Incidents that should have been reported to BSAS were not being reported to BSAS. No
staff person was able to identify the Program Director for the ATS or CSS unit. Many
clients were observed “walking freely through the building without staff oversight.”
Patients were allowed to hug and have other excessive physical contact.
As noted, DPH made an unannounced visit to the Danvers location to investigate an alleged
sexual incident. Like many other allegations, this one proved to be false. We have addressed
your questions related to the ATS or CSS Program Directors above. With respect to the
identification of Program Directors, RCA posts this information at Nursing Stations and it
has been emailed to all staff on more than one occasion.
100% of the efforts put forth at RCA are designed to prepare a patient for a life in recovery.
This requires preparing them to live their everyday life free from drugs and alcohol. The
freedoms RCA allows in its facilities are part of this preparation and the patient’s recovery.
RCA facilities are not locked facilities, and patients are allowed to walk from their unit to the
dining rooms or other areas without direct staff supervision. Our Chief Clinical Officer Deni
Carise has written a paper on this supervision issue and its therapeutic benefits. See below.
Despite RCA’s belief that patient freedom is beneficial to patients’ recover, RCA has added
additional staff supervision in order to comply with a BSAS request.
The Residential Experience – Allowing Patients the Freedom to Learn
By Deni Carise
Following the acute withdrawal phase, residential care for individuals with substance use
disorders –– is a period in which patients can try on new, healthier behaviors in preparation
for resuming life in the “real world” as newly sober people. Behavior in residential
treatment can be viewed as a dress rehearsal for the real thing. For example, if patients
cannot independently and regularly show up for a group meeting on time, there’s little hope
they will be able to show up for work or other important obligations when they return home.
Compared to a secure care facility or unit such as an acute psychiatric unit, it may seem that
individuals in substance use disorder treatment have a great deal of freedom in the facility.
Yes, patients have “responsible freedom” meaning they are permitted to navigate the facility
but there are limits to their movements. Importantly, they are navigating within specified
parameters under the watchful eye of trained staff.
Recovery Centers of America requires staff at all sites to conduct, at a minimum, hourly
rounds of all patients in their care. The process of hourly rounds is conducted 24 hours a
day, seven days a week, 365 days a year. A log is kept by staff showing that each patient’s
whereabouts are documented hourly. Additionally, attendance is taken at all groups and
meetings.
These hourly rounds and all other clinical interactions allow staff to identify patients
demonstrating increased cognitive, psychiatric, or medical impairment and identify them for

 increased surveillance, assessment and treatment. In some cases, the level of impairment
could trigger a patient transfer to a higher level of psychiatric or medical care.
If a patient is too impaired to be given this freedom but can be safely cared for in the
residential environment, the rounds or “check-ins” are increased until further assessment
shows that this is not necessary. This may take numerous forms from asking the patient to
check in at the nursing station every 10 minutes up to a 1:1 care contract where the patient is
always in full view of a staff member.
For the average residential patient, however, 1:1 contracts and transfers to psychiatric
facilities are rarely needed. Most patients can navigate freely and responsibly within specific
boundaries. This generally includes their assigned room, designated public recreation and
smoking areas, treatment and seminar rooms, dining facilities and counselors’ offices. The
patients are informed of areas within the facility that clearly are off-limits during treatment,
such as the admissions area, without staff supervision. And, importantly, staff are aware of
patients’ whereabouts. Within those parameters, patients are encouraged to work on projects
together and obtain recovery support from peers as a precursor to 12-step involvement upon
discharge. Additionally, they are taught to renew their commitment to personal
responsibilities, such as working within the boundaries or rules typically observed in society.
To be sure, there is a clinical impetus for the way residential facilities operate. Simply, they
are designed to assist newly sober people to learn or re-learn basic boundaries and
responsibilities within a structured, therapeutic environment. Patients, for instance, are not
permitted in each other’s rooms and, if found in another patient’s room, are subject to
disciplinary action by staff, including the creation of performance enhancement contracts
designed to help patients curb counter-productive behaviors and learn more pro-social
behaviors. That said, residential substance abuse treatment is voluntary, and patients are
deemed not to need the secure care reserved for inpatient psychiatric facilities because the
individual has been assessed to not be an immediate threat to self or others. They are,
however, expected to behave within social norms and when they do not, action is taken to
redirect them as noted earlier.
Residential treatment can be viewed as an experimental field for patients in which they try on
new behaviors and are positively reinforced for positive behaviors and need to account for
detrimental behaviors. In fact, one benchmark for discharge is the patient’s demonstrated
ability to function as a responsible, newly sober person. “Responsible freedom” offered to
patients within the confined space of the facility shapes those patients for discharge.
12. BSAS conducted a second site visit and review of programs at Danvers on or around July
11. RCA was sent a deficiency correction order by the state on July 20. The two
regulations cited as not being in compliance – 164.035: Required Notifications to the
Department and 164.048: Staffing Pattern – were also cited in the correction order
following the May site visit to Danvers. Can you comment on why BSAS found
recurring violations of two regulations during the second site visit and why those were
not corrected following the May visit?

 The investigation has been closed.
13. The most recent state report includes allegations from an employee that a patient on June
27 became intoxicated after ingesting large amounts of Purell taken from the nurse’s
station. Police records indicate 911 was called, and then someone subsequently called to
cancel the 911 response. The employee alleges the call to cancel 911 was made by two
BCAT employees en route to the facility to deal with the patient issue. Did this incident
occur? Was it handled properly by staff? Did an RCA employee call 911 or Danvers
emergency responders to cancel the original 911 call for help? Were employees
terminated following this incident, and if yes, how many and why?
As we have repeatedly stated, we don’t comment on individual patient or employee
matters for confidentiality and legal reasons. RCA medical protocols, including
emergency response protocols, are determined by RCA medical professionals who have
the requisite knowledge to make the proper assessment of a patient’s needs. It is RCA’s
policy that all non-medical professionals strictly follow the RCA medical protocols when
treating or engaging with patients. Any deviations from the RCA medical protocols may
put patients at risk or negatively impact their recovery. Any deviation from these
protocols may result in employee discipline up to and including termination.
Follow up question
14. Under the response to question #7, RCA notes “one instance was found where patients had
sexual relations in the facility” and “your question provides no information at all about the
alleged circumstances involved, and fails to consider the above facts.”
We would like to follow up based on that response. Does RCA believe that sex between patients
is detrimental to the recovery process, or does RCA believe there are exceptions? For instance,
are exceptions permissible for addicted couples seeking treatment together? Is the incident
referenced in the state report one between a couple seeking treatment together?
In the patient handbook for Westminster that was provided to state inspectors, there is a section
titled “Community Guidelines.” Among the guidelines, it states “Sexual/romantic relationships
are not permitted during your stay at Westminster.” Was this policy in place at the time of the
incident cited by state inspectors? Is this the current policy at Westminster?
Also, do all RCA facilities have the same rule about sexual relationships as stated in the patient
guide handed out at Westminster?
Was this also the policy at Danvers when state inspectors, in findings of non-compliance issued
last month, noted reports of several incidents of clients taking the elevator to the roof to have sex?
Also, do you agree or disagree with this particular finding from the state?
Draft response: All RCA facilities prohibit sexual conduct between patients and we also
encourage couples seeking treatment to go to separate facilities. Our clinical team views this as a
potential distraction for both parties during their course of treatment. While RCA prohibits this
behavior, if it is found that two patients engaged in any form of sexual contact, we clinically
evaluate each situation to determine the best course of subsequent action.