regarding the fundamental characteristics of medications were mentioned. The management thus
suggested that the proposed finding and recommendation be excluded from the summary and that
only the initial issue be presented in the summary.
The NPM additionally explains that, regarding the comments of Idrija Psychiatric Hospital, the expert
clarified that the recommendation did not refer to the comment made by a person who mentioned
the administration of medications by intramuscular injection without his consent, but to the
established combination of antipsychotic Clozapine and a extended-release antipsychotic intended
for intramuscular administration. According to the expert, the aforementioned combination is
contrary to the description of the producer’s recommendations on the fundamental characteristics
of Clozapine, since extended-release antipsychotics intended for intramuscular administration can
no longer be removed from the body after application and their action cannot be stopped in the case
of agranulocytosis. The expert further stated that it was determined that the two antipsychotics
were prescribed outside official indications, and it would be necessary to provide the reasons for
such a combination in the documentation (e.g. inefficiency of other medications, non-cooperation
in the treatment etc.). The expert also determined that the simultaneous administration of
Leponex and Xeplion was advised in one case. According to the expert, the aforementioned was
not compliant with the producer’s recommendations, and such a combination should have been
justified in the medical documentation. He also determined that some other patients had been
prescribed antipsychotics without a more detailed definition of the reason for prescribing outside
official indications (e.g. inefficiency of other medications).
In the response to the NPM’s final report, the Ministry of Health stated that it could not take a position
regarding the content of expert issues, but it commended the fact that the application of individual
medications or therapies is being spoken about more openly. According to the Ministry, possible errors
or decisions on the use of less efficient medications/therapies were due to various reasons, but it
was certain that these did not include bad intentions. The Ministry thus advocates the practice that
doctor’s decisions and possible errors be spoken about openly in order to improve the system.
Complaint procedures
We recommended that Ljubljana University Psychiatric Hospital place the complaint form near collection
boxes or hand over a copy to patients upon their admission enabling them the possibility of making an
anonymous complaint without the knowledge of the ward staff. A document describing the complaint
procedure should also be displayed next to the collection box.
In their response to the preliminary report, the management of Ljubljana University Psychiatric Hospital
stated that the protocol of complaint procedures was displayed in all wards, and the complaint forms
were placed near collection boxes (the complaint was thus always anonymous), but without pens, which
could be used as dangerous weapons. The patients may obtain pens from the medical staff.
Relating to the NPM’s recommendation about complaint procedures and the response of the management
of Ljubljana University Psychiatric Hospital that patients could obtain pens only from the medical staff,
the Ministry of Health wondered if patients were able to contact mental health advocates. This question
was also raised in regard to the NPM’s recommendation that, after a while, patients should be given
the opportunity to again give their consent to their accommodation in the special supervision ward and
clarifications about their situation. The Ministry believed this to be the task of the advocate.
We recommended that the management of Idrija Psychiatric Hospital consider the possibility of
providing a pen to patients who might want to submit complaints anonymously, while observing the
safety aspect for the relevant and other patients.
In their response to the preliminary report, the management of Idrija Psychiatric Hospital explained
that collection boxes were installed in all secure wards where patients could anonymously submit their
complaints, commendations, suggestions and opinions relating to the medical treatment received.
Suitable forms (OB BPE/12 01) were placed next to the collection boxes, but no pens. One of the reasons
was that a pen could present an actual or potential risk of self-harm or injuries to someone else. The
management further added that informing patients in secure wards about where, when and how they
IMPLEMENTATION OF THE DUTIES AND POWERS OF THE NPM IN 2016
NATIONAL PREVENTIVE MECHANISM UNDER THE OPTIONAL PROTOCOL TO THE UN CONVENTION AGAINST TORTURE AND OTHER CRUEL, INHUMAN OR DEGRADING TREATMENT OR PUNISHMENT
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