Critical Incident and Management Policy

CRITICAL INCIDENT AND MANAGEMENT POLICY

Senior Assist Services implements written policies and procedures on the prevention, reporting, notification, investigation, and management of critical incidents.

If we observe or have cause to suspect abuse, neglect, exploitation, abandonment, or suspicious or unexpected death, we will implement the following notifications and actions.

1. Take immediate action to ensure the participants’ health and safety.  If the participant’s health or well-being is in imminent danger, notify emergency first responders (911)

• Make a verbal report to the state adult protective services hotline at 1-800-490-8505.

• Contact the participants’ Service Coordinator within 24 hours.

• Submit a written report within 48 hours to the OFFICE OF LONG-TERM LIVING. (If the incident occurs over the weekend a written report must be entered the first business day after the incident) Senior Assist will utilize the appropriate forms required by the Department of Health and OLTL.

• Senior Assist Office Manager will contact the SC to make them aware of the modifications/ precautionary measures attempted to prevent an incident.

• Once a report is submitted by a direct care staff, the office manager will visit the consumer to see if any modifications need to be made to ensure consumers’ safety.

• Senior Assist employees are trained to recognize and report any consumer changes that could jeopardize the consumers’ health and welfare to the office manager. The Office Manager will notify the appropriate agencies and departments.

• Senior Assist Services Office Manager will complete consumer surveys on a quarterly or yearly basis dependent on which program is utilized. Consumers may report critical incidents at this time. Consumers are given contact information for the OLTL and the Department of Health.

•  Senior Assist office manager will investigate every incident and apply the appropriate course of action. Notification to appropriate agencies and precautionary measures will be taken with each critical incident.

1. Senior Assist Services will provide the Department of Health, the OLTL and the SC of any and all follow up information to a critical incident that is requested for the safety of the consumer.

1. Senior Assist Services will attempt to reduce the number of preventable incidents. All Senior Assist personnel shall be trained on our Critical incident policies and procedures. 

Senior Assist Services Inc. has identified the following Critical Incident categories

1. Death (other than by natural causes)
2. Serious injury that results in emergency room visits, hospitalizations, or death
3. Hospitalization except in certain cases, such as hospital stays that planned in advance
4. Provider or staff misconduct, including all deliberate, willful, unlawful, or dishonest activities

The following descriptions include:

ABUSE, which includes the infliction of injury, unreasonable confinement, intimidation, punishment, mental anguish, or sexual abuse of a participant. Types of abuse include, but are not limited to:

1. Physical Abuse, defined as a physical act by an individual that may cause physical injury to a participant.
2. Psychological abuse, defined as an act, other than verbal, that may inflict emotional harm, invoke fear, or humiliate, intimidate, degrade or demean a participant
3. Sexual Abuse, defined as an act or attempted act, such as rape, incest, sexual molestation, sexual exploitation, or sexual harassment and or inappropriate or unwanted touching of a participant.
4. Verbal abuse, defined as using words to threaten, coerce, intimidate, degrade, demean, harass, or humiliate a participant.

NEGLECT, which includes the failure to provide a participant the reasonable care that he or she requires, including but not limited to food, clothing, shelter, medical care, personal hygiene, and protection from harm. Types of neglect include:

1. Seclusion, which is the involuntary confinement of an individual alone in a room or an area from which the individual is physically prevented from having contact with others or leaving.
2. Abandonment, which is the desertion by anyone who assumed caregiving responsibilities.

EXPLOITATION, which is an act of depriving, defrauding, or otherwise obtaining the personal property from a participant in an unjust, or cruel manner, against one’s will, or without one’s consent, or knowledge for the benefit of self or others.

RESTRAINT, which includes any physical, chemical, or mechanical intervention that is used to control acute, episodic behavior that restricts the movement or function of the individual or a portion of the individual’s body. Use of restraints and seclusion are both restrictive interventions, which are actions or procedures that limit an individual’s movement, a person’s access to other individuals, locations or activities, or restricts participant rights.

SERVICE INTERRUPTION, which includes any event that results in the participant’s inability to receive services that places his or her health or safety at risk. This includes involuntary termination by the provider agency, and failure of the participants back up plan. If these events occur, the provider agency must have a plan for temporary stabilization.

MEDICATION ERRORS that result in hospitalization, an emergency room or other medical intervention.

CRITICAL INCIDENT AND MANAGEMENT REPORTING REQUIREMENTS

1. Notify the SC immediately
2. Report the following:
   1. Participant’s full name
   1. Date of Birth
   1. Date and Time of incident
   1. Brief description of the incident
   1. Participant’s current conditions
   1. Actions taken to mitigate risk to participants
   1. Reporter’s name, agency, and contact information

CRITICAL INCIDENT AND RISK MANAGEMENT POLICY

52.17. Critical incident and risk management and OLTL critical incident Management Bulletin  05-15-02 et al.

(b) A provider shall report a critical incident involving a participant to the department or the SC, or both on a form prescribed by the department.

(c) A provider shall develop and implement written policies and procedures on the prevention, reporting, notification, investigation and management of critical incidents.

(d) A provider shall meet the risk management requirements as specified in the approved applicable waivers, including approved waiver amendments.

Within 48 hours, the SC or provider agency that discovers or has independent knowledge of the critical incident is to submit a report to OLTL. If the incident occurs over the weekend, a written report must be entered the first business day after the incident occurred. All SCs and providers are required to report critical incidents. Before reporting an incident, measures must be taken immediately to safeguard the participant. This may include calling 911, contacting APS (participants age 18-59), Older adults protective services (participants over age 60), law enforcement, the fire department, or other authorities as appropriate. Providers must inform the participants SC within 24 hours of an incident. If the participant is in need of immediate intervention, providers must immediately contact SCs if 911 is NOT called.

Critical Incident cases involving an agency employee may require the employee to be removed from all OLTL HCBS programs. This may include requiring that the employee have no contact with the participant or suspending the employee until the investigation is completed. If the employee works for an agency, suspension may be with or without pay based upon the circumstances of the alleged incident and the employment policies of that agency

EIM SYSTEM regarding UPMC

Senior Assist Services, Inc. will report all critical incidents via the EIM System.

If Senior Assist Services is unable to reach the service coordinator, a verbal report will be made to the UPMC Community Health Choices concierge team within 24 hours at 1-844-833-0523.

Notification will be made to the participant or the participants’ representative within 24 hours of filing an incident report.

Participants do have the right to not report or to decline further intervention. However, this does not prevent our agency from being mandatory reporters.

Employee-involved incidents require that Senior Assist Services make a written report within 20 days.

Mandatory reporting requirements include:

1. Senior Assist Services discovers or has firsthand knowledge of the critical incident.
2. Incident that occurs during the time that service is provided.
3. Incident occurred when Senior Assist was contracted to provide services but failed to do so.
4. Incidents occur at times other than when Senior Assist Services was providing services but Senior Assist Services became aware of the incident during their time of contracted services.