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Provider Procedures
IMPLEMENTATION UPDATE #55
If you have not yet reviewed Implementation Update #55, please do! There are several changes to incident reporting requirements. These changes were effective April 15, 2009. The changes impact 5 areas:
- The definition of "under the care of the provider;"
- Incidents of consumer absences;
- Additional requirements related to a Level III death of a consumer;
- The reporting of abuse, neglect, and exploitation; and
- Additional reporting requirements for making a verbal report to the LME and DMH/DD/SAS immediately upon learning of an incident.
Please note that DMH/DD/SAS staff are working to update the manual for the "Incident and Death Response System," as well as revise the grid found at the last two pages of Form QM02. In the meantime, the new requirements contained in Implementation Update #55 override pertinent sections of the Manual and the grid used to determine the level of an incident. These are the changes included in the Implementation Update.
"Under the Care of the Provider"
According to the glossary found in the November 2004 edition of the Incident Reporting Manual, "under the care of" the provider was limited to times when the consumer is "actively engaged in a billable service." In practice, this meant that many incidents were not reportable if the provider was not present when they occurred (unless the facility was providing either ACTT or Residential services). However, the definiftion of a consumer "under the care of" a provider has been revised, and now refers to a consumer "who has received any services in the 90 days prior to the incident." This is a much broader definition, and will likely result in increased reporting from providers.
Consumer Absences
The change that has been introduced related to these incidents is the creation of a Level III category. Previously, when a consumer went missing, the incident would be classified as either a Level I or Level II (depending on the length of time the consumer was missing and/or whether the incident required police contact). Beginning 4/15/09, any incident of a consumer absence must be classified as a Level III when an Amber Alert or Silver Alert has been issued. As with any Level III incident, providers are required to report Amber and Silver Alerts involving consumers to the Host and the Home LMEs, as well as the DMH/DD/SAS Advocacy office. These reports must be made immediately via phone call, followed by the submission of Form QM02 within 72 hours.
Level III Death Reporting
In an effort to obtain accurate data regarding the cause of death for a consumer, providers must now obtain a copy of the medical examiner's report and/or autopsy report for any Level III consumer death (i.e. those deaths that result from suicide, homicide or violence; accidental deaths; deaths from an unknown cause; or any death that occurs within 7 days of the use of seclusion or restraint). These documents are considered public records, so they should be fairly easy to attain. If no autopsy was performed or the reports are unavailable, a copy of the death certificate will be accepted. Once providers have reviewed the autopsy report/death certificate, they will be required to submit an updated incident report, even if the cause of death does not change the level of the incident. To update the report, providers should draw a line through the cause of death (if it has changed) and check the actual cause of death. The autopsy report and/or death certificate should be attached to the incident report, which should be faxed to the Division and the Host and Home LMEs, along with a comment briefly describing the change. If the cause of death does not change, simply re-fax the incident report with a copy of the autopsy report or death certificate. You should include a comment that the information in the report did not change the cause of death.
Abuse, Neglect and Exploitation
There are several changes included in Implementation Update #55 with regard to the reporting of Abuse, Neglect or Exploitation. To begin, there had been no Level I criteria prior to April 15th. Now, any allegation of abuse, neglect or exploitation that occurred prior to a consumer enrolling in services is to be reported as a Level I incident. Remember that providers are not required to submit Level I incidents to the LME, but they must track these internal to their facilities. As for Level II incidents in this cateogory Implementation Update #55 requires that "any allegations of abuse, neglect or exploitation by anyone, including a caretaker, friend, relative, staff, or stranger, that occurred while [the consumer is] enrolled in services" be reported as a Level II incident. As in the past, any allegation of abuse, neglect or exploitation that may result in permanent physical or psychiological impairment would be classified as a Level III incident. In addition, if the allegation results in arrest or is an allegation of rape/sexual assault, providers are expected to report the incident as a Level III incident of abuse.
Additional Reporting Requirements
Finally, Implementation Update #55 requires that any incident that is likely to be reported in the media, or if the consumer is perceived to be a "significant danger or concern to the community," the provider is required to make a verbal report to the Host LME and the DMH/DD/SAS Advocacy Team immediately upon learning of teh incident.
Implementation Update #55 also includes a lot of important information unrelated to incident reporting, so if you have not had a chance to read it yet, please make time as soon as you can
Link to Implementation Update #55
INCIDENT REPORTING
Incident Reporting is a quality improvement practice used to assure a consistent statewide process for protecting the health and safety of consumers and to provide standardized data from across the state. It is so important that reporting is required in the North Carolina Administrative Code. The State provides the required standardized Incident Reporting Form, the chart of Definitions that includes criteria for determining the level of responses to incidents, and the description of the Incident Reporting Process.
Who is responsible for reporting?
- Providers of publicly funded mental health, developmental disabilities and substance abuse services licensed under N.C. General Statutes 122C, except hospitals.
- Providers of publicly funded, non-licensed periodic or community-based mental health, developmental disabilities and substance abuse services.
Failure to report incidents as required by 10A North Carolina Administrative Code 27G.0600 may result in DHHS taking administrative action against the provider's license or authorization to provide services.
The State defines three levels of incidents:
Level I incidents, Level II incidents and Level III incidents can be found in the State's chart of Definitions and listed on pages 5 and 6 of the State Incident Reporting Form.
WHEN is an incident reported?
- Level I Incidents must be reported quarterly to the Guilford Center's Quality Improvement Department.
- Level II Incidents must be submitted to the Guilford Center's Quality Improvement Department within 72 hours of learning of the incident.
- Level III incidents must be verbally reported immediately to the Guilford Center's Quality Improvement Department. A completed form must be submitted to the Guilford Center's Quality Improvement Department and to the State within 72 hours of learning of the incident.
HOW is an incident reported?
Level I Incidents must be reported on the State Level I Incident Quarterly Report Form.
Level II and Level III Incidents must be reported on the State Incident Reporting Form, following the Incident Reporting Process.
Level II and Level III Restrictive Intervention Incidents must be reported on the State DHHS Restrictive Interventions Details Report. The form should be completed and submitted with the State's Incident Reporting Form.
Incident Reports may be submitted by mail or fax to the Guilford Center's Quality Improvement Department:
Joel Leonard
Quality Improvement Coordinator
Phone: 641-4346
Fax: 641-8026
Email: jleonard@guilfordcenter.com
How to get assistance with incident reporting
The Guilford Center provides technical assistance to help providers understand incident reporting requirements. If you have questions, contact:
Joel Leonard
Quality Improvement Coordinator
Phone: 641-4346
Fax: 641-8026
Email: jleonard@guilfordcenter.com