eSignature Legitimateness for Employee Incident Report in Canada

How to eSign a document: eSignature legitimateness for Employee Incident Report in Canada

good morning everybody this is Janelle pacano we do hi Department of Mental Health we're here to conduct this webinar this morning on the incident reporting changes for residential facilities and community mental health agencies I'm the chief of standards development and administrative rules for their high department of mental health and also on this broadcast this morning is Rob Nugent who is the community client Safety Manager for the Department of Mental Health many of you who have submitted incident reports are familiar with Rob he's a person who will read and review all community in residential facility incident reports and follow up as indicated either with email phone call letter or perhaps an on-site this morning we are recording this presentation in broadcast if technology works well this more ink that we intend to post this to the Department of Mental Health website later for people to who are not able to attend this morning or eight people that are here may want other staff to listen to this presentation we'd like to go over some of the logistics for today there is for the attendees you should see on your screen in a question function so there is the ability to send questions during this broadcast please be patient for us here it takes a little bit for the time for the questions to come through and to be able to read them but we will try to respond to those as best we can there is also the ability for attendees to raise your hand and if you raise your hand then we can unmute you and you can ask a question that way and everybody that is listening to the broadcast will be able to to hear you so those are the two different ways to communicate with us this is going to be we're going to be going over both a PowerPoint presentation but we'll also be reviewing the reporting instructions and the incident recording forms that have been previously sent out and hopefully people have had a chance to down load those forms and have them in front of you I think it'll be a little bit easier to follow the presentation this morning if you've done that although if not you can certainly listen and again this should be available in the future the PowerPoint presentation was also emailed last evening if people had the opportunity to download that please note that hopefully people will be patient there's going to be a little bit of switching back and forth here on the screens between PowerPoint and the incident reporting instructions if you haven't listened to one of my previous webinars this is the third one I've done so something I'm still trying to work with logistics also as an FYI we had this happen during one of the live webinars as well as during practice this week that the audio connection that I had was lost it was it was brief one was only 10 seconds and earlier this week it was a little bit longer than that I believe that people receive a pop-up menu when that happens it shows them the audio connection is lost but if for some reason if I stopped speaking for a period of time it is being reestablished or I would have to call it and in access the audio connection and in another another one okay so I think we have gone over I said some of the different the way the logistics how this webinar works go ahead and start the slideshow and today you know the goal of today's events we want to review the changes that affect the current reporting the revised forms although the forms basically follow the incident reporting construction so we'll be focusing there and also going to be highlighting the differences in reporting between community agencies and residential facilities I realize online that we're gonna have and are subject to both community mental health requirement and the residential facility requirements there really are not a lot of differences between the two so I thought it was a better use of everybody's time to just combine this into one webinar rather than queue to separate webinars and point out the differences I don't think for a community agency I don't think you're going to be spending a lot of time hearing about residential facility reporting and I think we can just knock this all off in one shot we're also gonna answer questions people had the opportunity to submit questions in advance to rob Nugent and those are incorporated throughout the PowerPoint presentation sometimes directly where we have some slides that say advanced questions on them and we've written the question out or paraphrased it especially if we got duplicate of the same or similar questions and other times just some of the information that we share throughout the PowerPoint should be answering those advanced questions as well so if you submitted something in advance you should hopefully see throughout this your answer is somewhere in the PowerPoint and again people can submit questions throughout do not feel they'll be at the end of the presentation we'll open it up for additional questions but if you have a question as we're going along please feel free to send that either in writing or by raising your hand and we'll try to catch that for you so want to talk a little bit about what what is what what is this about and why is this happening now we had set out in June 16th I believe it was a policy change and an advisory letter was sent out those were sent by email to agency executive director listservs and what we wanted to do is provide some regulatory reduction now if people aren't aware we have revised the incident reporting rules as well as the seclusion or restraint rules they have gone through what we call the Jake our process and that means we went through there was a committee and the rules were posted for draft comment we made additional changes we started the formal rule process will we filed those we held a public hearing and then there was also Jakob hearing they're clear Jake our jurisdiction which means the department can assign an effective date on these rules at this point any time that we want we and our decision has been to make that January 1st 2012 those rules we recognize there's going to be some different changes and staff training and perhaps updating internal forms or performance improvement tracking different things that agencies and residential facilities might need to do in order to implement those new change our intent is to provide training on that in the late summer early fall and give agencies the facilities time to train staff and make those own internal changes that they may need to do however there are also some categories that have been reportable of through June 30th that are not part of the new rules for example in the outpatient community mental health agencies suicide attempts and we wanted to make changes now to provide that regulatory reduction if we've already identified that providers do not need to continue to report these certain incident types we want to go ahead and make that change now rather than wait until January 1st these are official changes we have there your second bullet point the different paragraphs 5 1 to 2 26 13 is the incident reporting rule for community mental health agencies and then 5 1 to 2 - 30 16 is the rule for residential facilities those rules always gave us the authority by their wording to make changes to the incident form and reporting instruction the way those rules are written it's it's sort of Megan and up to us to define what is affordable we did not want to use that authority to make the changes for the rules that we took through the Jake our process we could have but that really those were those were different changes and we really needed to have that public process to get input to have external people serve on the committee and go through those processes so we didn't want to do that but we are using that authority now to make these policy changes and reduce the requirements okay so we've um and at this time I'm on this next slide I want to point out in the highlight especially that last bullet point we're not adding any new incident categories at this time there are going to be new ones there's some references to that in the new revised incident reporting rules and that was put in there to really hopefully help agencies it's information that I think might be helpful to them and their long-range planning okay but because we have this Authority that I just talked about this changes extend to all required reporting in the respective rules you always have to report incidents to you know if it's goes to OD image it also goes to the mental health board there's a copy requirement for coffee to go to parents or guardians of applicable and then in residential facilities there might be if you're a type 2 or type 3 you need to send a copy of that to an affiliating agency and agency from which the resident is receiving services that also is usually only going to be applicable maybe in a type 2 or type 3 we do have some type ones where people are getting services some services in that mental health agency but they're also receiving services in their main services and another agency so I just want to make clear that this is there is not now separate reporting requirements through our administrative rules for reporting to the department and to the mental health boards it is all one and the same not going to read this to you these were contained in the Advisory letter that people hopefully have had a chance to read in an earlier slide did have the link to that advisory if you have and don't have that you can certainly download that after this event but those are some of the highlight of the changes that have been made and I also want to point out you see on this slide under the community agencies a couple of those the top two bullet points are in purple when there are differences between community and residential facilities I highlighted that in purple and I'll be pointing that out as we go along but hopefully that will help people see where those differences are one of the things that is new and we sent out is separate forms and reporting instructions historically there's been one form for that both community mental health agencies and residential facilities have utilized there's been some sometimes there's some confusion about that because categories exist on the form for both so residential facility might see a category that only a community mental health agency needed to report or vice-versa so they were sending in that information and reporting incidents that don't need to be reported now when an incident does come in that's not a reportable and so that we do submit it we do remove that from our system so you know it comes in there's the record of it here but it's not part of our incident reporting system we do take it out however incidents we are required by law to forward all reportable incidents to Ohio legal right services within 24 hours so even if it's not reportable they may get a copy of it before we before we determine it's not reportable so we're hoping that these separate forms help reduce that confusion and people can clearly see what they need to report based upon their setting after people have had the opportunity to review the different forms maybe implement that at the agency if you operate both if you're community agency and you have a residential facility we'd be very interested to hear some feedback on whether or not that seems to be helpful to you there are again the slide that shows where you can find these documents and want to point out as much as there was a lot of time and review that was spent in putting these together and the information and in my mind I was certainly hoping that everything was perfect but it is not we have identified a couple of revisions that need to be made in a correction we decided not to send this out in advance today because I know that we have you know probably over 100 people listening today and if there's any other Corrections or things that people point out if they send that to us you know we'll try to incorporate that we're not talking to changes about whether or not something is reportable or not but just some information on there that may be incorrect for example on the form the residential facility reporting instructions the suicide attempt is currently a reportable incident and it says that but then on another page it says that it should not be so we need to just fix that okay talk a little bit about the methods to report we are not we're not updating the weir system at this time the department's energy and focus about Weir's is updating it to reflect the new rules that are going to go into effect January 1st 2012 to be honest my understanding is that mirrors will not be ready by January 1st 2012 however we're going to be going ahead with the rules at that time and the training in the fall will address how to deal with that I think there is if I was to say now I think there's a very high probability that at that point the reporting will be all on paper for a period of time we have asked that the Weir's the new Weir system is should be very different than the Weir system that exists today it is it will be a more secure system we've asked for that we have asked for the ability to assign different levels of access to the system at the agency level so you can maybe have somebody who manages that people who can submit the information a save feature currently now if a week incident report is filled out online on Weir's one if you walk away for a period of time to get timed out and you lose all your work and we're quite familiar that people in this in this field we get interrupted so many times a day that's not an unusual event as well as some agencies prefer you know staff would fill it out and they have you know supervisor of some administrative staff that they want to review it you can't do that in where's right now you can continue to utilize where's to report the reporting instructions do have a column to address that reporting via Weir's you know but there are there are categories on there that no longer exist there are some questions that do not exist again these are highlighted both in the PowerPoint some and as well in those reporting instructions there's a new method of reporting and that is by email and there is the email address there and you can fill out these forms are in a Microsoft Word fill in function you can fill them out an email to us as well as fax or some people still mail them it's it's very rare but we do occasionally get them by mail that is a secure fax and at this point I want to do do a poll question here and and that speaks to weird it says sort of a not very scientific one we know that when we're Swiss first Lant launched and we did some training and explanation of it organizations some organizations never did start using it which is fine some have used it and continue to do so and others houston in stock so this poll question is for apologize I'm trying to watch the poll apparently if I don't I didn't do that correctly I apologize so everybody's a patient with me on that we just like to see if people want to participate this if your agency if you do not use Weir's just wanted to get some information about why and there so people should have that poll open and you can take some time and answer that in this is you can answer as many of those this might be accurate to you it's not you can have one two three or four your answer for that so and we are when we do the Weir's the first Weir's was done the Department developed it and we put the system in place we trained people on it and said you know here it is if you want to use it this is this is how it works part of the development this time will be it will be developed here at the department and then we will involve agencies in utilizing where's and get some feedback so before this goes live statewide there will be some test runs including different agencies in the system and again we've asked for a lot of different upgrades to what is currently in place and I may have mentioned briefly also the ability to generate reports we're told that might be a Phase two of this new Weir system but where agencies can generate their own reports and perhaps do some benchmarking reports off of Weir's themselves rather than wait for the department to post it I think going to go ahead and and appreciate information forgiving people for giving us the feedback on that it just helps give us you know we hear anecdotally here and there are some information from people I have lost my screen okay okay everybody should have the spring back apologize again for that all right okay so now here is uh here's my disclaimer I'm always interested in disclaimers the PowerPoint is used in conjunction with the other forms and I put this up there in part for people who may be accessing this after not listening to this line but after after the factor they've just got a hold of the PowerPoint so the first part we're going to go over is the fields that basically everything was the incident reporting category and those are the fields that we give the incident information time date provider and client resident fields I've gone too far so let me switch over now to I'm going to pull up the community mental health agency reporting instructions there is again as I said when there are differences between the two I will point that out and I'm not going to go over every different category here I you know I know that people have the ability to to read it and some of this information is self explanatory but again as you see there we talked about the index and those A's and B's that actually corresponds with the form itself each each form has just a under here and a a B and a C and that's what we're talking about in the indexes they there is you see the column with the weird instructions some of the information is automatically filled in where's sometimes there going to be some differences so we try to point that out for people I do want to highlight their index B date of discovery because this is one where people still sometimes people don't get that you know correct and that's the date you learned that an incident is reportable okay and that is what triggers also the the timing for the reporting within 20 four hours of date of discovery exclusive of weekends or holidays so if you if an incident happened three months ago six months ago two years ago this is when it becomes reportable is when your agency learns about the incident index see their provider generated incident number I think when we switch to that we had more providers who were submitting information that was not HIPAA compliant that still does happen on occasion so again I would caution people to make sure that this does not contain any client information that should not be coming in to us you know an incident that is submitted is a public record provider name we do ask that people put just the official name of your agency or your residential facility it should match the name on your certificate just makes it a little bit easier for us to make sure that we know what who this is about and on page two of this F index F the name of the Adam board that you report the incident to a few years ago there was even a committee that worked on this in terms of who just submitted to I think it was a bigger issue for residential facilities and it was submitted to a residential facility it's submitted to the county of residence and then after the county of residence its we submit it to the board in the county that the residential facility is located to so if it needs to go to more than one board by rule we take care of the second reporting an index I the name and title the person to contact regarding the incident and and that is whoever is the person at the agency or residential facility that we should speak to historically some organizations identify a single point of contact or a couple point of contacts and they speak for all incident reports other organizations have multiple staff who may do that the department does not dictate that we do not regulate that that is up to you we just like to know who it is that we should be speaking speaking with the incident date K or in index K incident date the reason I want to bring that up in in Weir's please enter nein nein nein nein nein nein nein nein unfortunately weirs requires you to put a date in there and organizations have just had to sort of some organizations have messed guest something around the time and I know that it can cause some internal consternation and we did not have this on our previous reporting instructions but you know that date at 99 guess all zeroes would serve the same function just to mean that it is unknown the same with incident time it's unknown you can write that on the paper form just leave that blank on where's index M notifications made and on the incident reporting forms that we'll talk about - please select all of them that apply and then there's a on the form there's a fill-in form where you can if it's other let me go over to my powerpoint here and we're going to be adding to the list of notifications that are made so this is one of the areas we're gonna make some changes to the forms that we just revised adding OD image that was originally on the form and perhaps I wasn't thinking with all my brain power on that time but didn't the intent was so that people didn't have to check odium age I know I don't want I don't think of in terms of oh it just takes a moment to check box because I know if suddenly you've got a lot of different boxes to check that becomes you know a few moments and we're all scrambling for time to get everything done however people also send copies of these forms to boards or the impairment Guardian if applicable so that's the reason we're going to reinstate the checkbox OD MH and then on the residential forms I need to add the agency from which the resident is receiving services I think I included affiliating agency on that PowerPoint slide but I did that actually is already on the form and there are and you'll see that there are fewer boxes and choices BHO which is are we all not call our regional psychiatric hospital you know Court dys there were a lot of different choices on there historically quite honestly I'm not sure where they came from but we want to narrow this to the information that we the information that we need to look at rather than just filling it out okay I am taking a moment here to answer some I see some questions are popping up here one this this I think goes back to the incident report email that says will we receive a confirmation if we choose this method and I guess what I can do we'll make a note of that and look to see if that can be set up is an auto-reply I think we can do that but to be honest I'm not quite sure what the answer is so we will have to look into that and we will provide that answer after after today's event and I need to paly apologize here I'm trying to okay manage that I've got a couple people that are unfortunately the pair like you are having trouble hearing me but em my control panel shows that they're connected to audio so I I'm not sure how to I don't know how to address that I think I noticed if somebody isn't connected to the audio how to try to reconnect them so I index em the again the notifications made and you'll see that slide just points out what are the differences between the community mental health agency and the residential facility reporting it's now when I switch back here to the community mental health agency reporting instructions so we're now on client information index and and I guess before I was talking I already talked about that HIPAA compliant information I think I confused that with the provider generated incident numbers so I apologize that it's actually indexed and that I was referencing and in our queue race ethnicity and there's select one okay queue is race race ethnicity we've added by or multicultural to provide a choice and that was basically done at the request of other providers over the past that they felt that the previous selections didn't match what match people's the best description or designation of them and go back to our is was the client the victim or perpetrator and they're in the reporting instructions it talks about if that's the role they have something happened to them you coded as a victim if they cause something to happen including to him or herself you coded as the perpetrator and so we eliminated that other category as a choice then that does still show up on Weir's again we can't eliminate that but because of the change in the reporting requirements then we feel that victim or perpetrator clearly covers every every incident that is currently reportable and we did have an advance question on that if they commit suicide attempt suicide cause the self inflicted injury is do we mark the client a resident is the perpetrator and the answer to that is yes back here to another client was involved index t2 please list a provider generated incident number of the other incident notification and this is a change previously you had to answer yes or no to every incident report that you selected and thus there's one of those examples I was talking about there was a box that you're checking and now if it is true then you just need to fill out that information if they did not involve any other clients and that you don't need to check any boxes I'm gonna do anything further you just skip that you additional information and it's a brief description of the incident you're reporting we if we need additional information we will request it and they're in the reporting instructions as a couple of examples of that one of the I know in where's one of the feedback now that I think about it might been one of the whole questions of pull options that they was very limited in the number of characters that were typed in there the fill in forms you should be able to type in and pretty much fill up fill in that box should run over you might want to check to make sure that it doesn't run over and everything that you type shows up on the screen or on the form if you're utilizing that to send it to us and the X the name of person completing report if different than index I and why the date report is completed is different than the date and index a we've had some internal discussion here about even and concluding those fields and maybe we'll continue to look at that that we change to the name of the person rather than the signature it was always okay for just to be printed but some in terms of emailing the incident forms in the past some providers felt because ask for signature you couldn't email a signature those boxes are there perhaps as much for agencies asking about information that they want so that internally they can track who is the person that's filling out the incident report and we're gonna be following up with the person who's identified as the contact person and there again talking about the signature okay there is a data field in these sections that's no longer included on the paper forms again it still exists in Weir's and that asked with staff injured as a result of this incident that is not something that people need to be filling out lost my question function apologized for this has it's gone away I'm gonna go ahead and try to keep on speaking and at the same point try to find what happened there and I'm not back here okay so again thank you for your patience here so the next thing I want to discuss is the incident reporting categories first one is use of abuse and neglect by staff reporting instructions so there you see and at this point on for all the categories everything is an index v so the different categories themselves or incident types do not have their own have their own index number there has been no changes in this reporting however in the instructions down where the use of force we've changed the language over and we have the language that's in the seclusion or restraint rule and this is the language that's also used in the new incident reporting rule that's going to go into effect in in January 1st 2012 so we put that language in the reporting instructions there's no there's been no change to what constitutes use of force and reporting under this category we thought in some places where the it didn't change the intent didn't change the reporting anything that was expected of the agencies that we could go ahead and put some of that new language and now and you know help providers as they transition over to what the changes in January 1st 2012 ok and I want to point out and that's a it's again later in this presentation but there has been no change or I'm sorry just said that this use of force is only by staff this is not use of force by law enforcement you'll see later that that has been changed and that is no longer a reportable incident the death of a client and again this is the this is the agency instructions that I have up on the screen and for community mental health agency report the death of a client if it's an accidental death that occurs on the grounds or during the provision of care and in a residential facility you also all residential deaths are reportable that's how it was before and so there has been no change of that so residential facilities also need to report homicide of resident death by a natural cause or if it's an unknown cause again going back to your reporting requirements need to occur within 24 hours of discovery of an event so at that time you may not know what the what the cause of death in that residential facility was so here there were some advanced questions that were submitted on the homicide or death of a client a community agency it is not included in the new reporting instructions is it still reportable and then it's no and actually it was not a reportable incident prior to July 1st 2001 so one of the things and we do hope on the new reporting instructions that we put out there that they are more clear and they make it easier to identify what is is not reportable and apparently we had some people who believe that before homicide death of a client the community agency was reportable when it was not however a homicide or death in a community agency by a client is a reportable incident it was before and it still is the next question there's a natural death on premises or during the provision of care in a community agency still reportable no it might be an event the agency wants to review QA or PI but it's not reportable and that might be and the reason I also put that for something where an agency wants to review that is the same for many of the incident categories that are no longer reportable and we've changed the level of reporting they may be significant events for an organization but the department doesn't need to know about every everything let me just everything that goes wrong and provider agency whether it's a community agency or whether it's a residential facility and just to give an example here you know natural death if somebody is on their way to your agency and they have a heart attack on the public sidewalk outside your agency not inside it's not an agency grounds and they have a heart attack you might have somebody who runs in and says oh please call 9-1-1 your organization might have a nurse who goes out and tries to assist the person provide CPR they may be hospitalized they may not may not survive the heart attack but it you know before it never hit what was reportable but if that same event happened once they walk through the doors it became a reportable incident and natural death is not something that an organization really has control I mean it's you know in it as part of life people get sick people have illnesses it is different from an accidental death that is still reportable because an accidental death does denote that there might be something that needs to be reviewed looked at something that needs to be changed to reduce if there was some sort of risk that cost that accident last bullet point here death of an unknown hotline client still reportable and again this is sort of the unknown hotline client you may have somebody who calls in on a hotline they're also an open client to your organization and if they're an open client to your organization receiving other services you follow all the reporting instructions throughout if a hotline client does commit suicide law on the call then it would be a reportable incident and then I put in there technically we thought about if they died of accidental causes it would be reportable I can't imagine how that how that would happen but I'm sure it's possible so that's where reporting for a hotline client comes in you know if you have the situation where you just talked to somebody on the hotline and then you might read an article in the paper that seems to fit that that you know somebody that you talk to and I myself personally I mean I've worked on a hotline I trained people in a hotline a long time ago back in the 80s so I know that that happens there's phone calls that you feel pretty positive about there somewhere you know when that phone call terminates you know you're very concerned and about what the outcome is but to meet the reporting requirements that is that is the time when it is reportable I've got another question here we have one of the things that if you're not familiar these questions are come in to me like one line at a time so it's a one outpatient client attacks another outpatient client in the waiting room do we complete one incident reporter two one for victim one as perpetrator I'm not in terms of that of that question this is outpatient okay what's reportable is that the death of a client so if if a client attacked another client in an outpatient in the waiting room or something and somebody died it's one incident report because it would be we haven't gone we have in the screen hasn't popped up yet but homicide or suspected homicide by client that is what would be reportable you may put that information in in the instructions if it is an attack and it results in injury that is no longer reportable so serious bodily injury oh and I apologize I mean I'm getting ahead of myself okay physical assault injury it's reportable if it and we haven't got there yet if it results an emergency or unplanned medical intervention or hospitalization and again that would be reported as one incident I mention in the new rules in January 1st 2012 you will have the ability for everything even when it involves right now certain things trigger multiple reporting they involve more than one usually it's most common in a residential facility an event that involves maybe three residents or four residents right now you are required to fill out four different incident report forms the only exception to that is if it's sort of an occurrence where people have to be relocated a fire another disaster that will change in January first and at that point we are switching over to incident reporting one incident report per event next question that I have is well the mental health boards also accept emailed incident reports or is this an individual board decision at this point this would be an individual board decision we have we have talked about that not with the boards yet so the boards that are listening today we have talked about that with our Weir's people of weather that we can create a system in Weir's so that agencies can also utilize that system to send the incidents to the department and to the boards at the same time and perhaps even enter their other reporting but we're not far that we're not far enough along in the weir system to even have that discussion yet with the boards and what that would entail so that is something that we are looking at in the future do another question since Oh Team H now oversees a dog group homes as of July 1st 2001 do agencies need to report suspected abuse neglect by group home staff on this form this is thank you okay at this point the agencies their adult care facilities and residential care facilities that were previously licensed both by the Department of Health or the Department of Aging we'll continue to follow the incident reporting rules and requirements that they've had and are not this form is not set up for their use we do have some meetings scheduled here at the department to discuss the incident reporting and if that changes we will be advising people at that time so we're doing our best you know to get that information out next question we have how is a vehicular death classified no unusual circumstances for more clarification off site at time of accident okay if it is if it is an accidental death at that occurs and I assume that is the question for the vehicular death if is this an accidental death that occurs during the provision of treatment and it would be a reportable incident and I actually have a slide a little bit slide later to talk about now I'm serious bodily injury in that regard there are you know and we do recognize I mean there are some information there is some information or some incidents that still may be outside of the control of an agency or a facility they have to be reported we'll get that information and we'll file it but we do believe overall that these change in reporting instructions allows us to focus on the incident types that we really need to know about and we may want to do some follow-up and I also want to let you know and the question about emailing to the from the question about emailing to the board's currently organizations can email from Weir's but you have to work that out with their Adam board and I forgot about that but I believe there is some system within Weir's that allows organizations to do that [Music] next question that we had in advance about an individual in a residential facility it's reported as soon as occurs perhaps before cause of death you never need to submit a second incident report on the same incident if incident reports can be updated they can be changed if they need to be you know we would be following up on a residential death and we certainly know and recognize you may not know you know you may not necessarily know I mean if unfortunately if somebody went and they took pills you know they came in later in the evening had taken some pills and immediately walked in and maybe you want to sleep and unfortunately you know died as a result of that you're not going to know whether or not it's a natural death and they died during their sleep and find out during the coroner's report so we will get the additional information as part of the follow up and then the next category is homicide suspected homicide by a client or a resident and again that's now a separate category on the new form and if you if you're reporting it using Weir's then you use the death category and it has suspected homicide subtype back to the reporting instructions now of involuntary termination of treatment by an agency or facility this is a reportable incident only when the three things that are there in that middle third column over are triggered so it is not we we do understand there are times when agencies do need to terminate the treatment of a client or facility however in the client write rules this actually where this comes from you are required to let them know in advance of the termination you're to give them a reason and to offer a referral to the client or the residential facility if those three things and all of the three things need to occur so one of us to three things does not occur then it is a reportable incident okay if they all occur it is it is not and this really is something that should rarely be reported because I think organizations and facilities generally do a good job with this and they're not you know dumping clients and dumping residents so advance questions does that apply to a client that doesn't return they can't locate they don't respond to letter sent no you know in a perfect world every time a client or resident was going to terminate treatment they would let us know of that but we know that that's not really what happens so they stopped treatment without notification it is not an involuntary termination certainly and that question talks about you know they're trying to locate we realize this is a vulnerable population your agency facility might be trying to locate them send letters make some other phone calls whatever the organization feels is appropriate that's also true for residential facility generally as part of the residential agreement that somebody signs or is executed when somebody comes in it might address some information such as you know if you don't come show up for a day or two days or three days basically how long you may hold a bed for that might be part of the agreement did want to put a note of caution there you know we also have clients that you know aren't really good they miss a lot of appointments you know that's a very different situation with a client that has stopped showing up for treatment one that frequently misses appointments the next question we were getting isn't about how much advance notice of the termination is required we are also and address this and I suggest that and you know organizations have that in your policy you might want to discuss sort of that process who can make those decisions what kind of review is it you know in a outpatient mental health agency is that something that you review with the supervisor and just discuss with the person who's supervising the service is there a team that makes the decision the chief clinical officer again that is all information that it's up to your organization and you're going to look at the situation you know age what is the set what is your type of facility and there I give an example if you're you know a residential facility say you know for adults and you know somebody's been non-compliant with their treatment plan for months you I would expect and again this isn't a role I'm just sort of thinking sort of the common sense you know parts to it that you can give some more notice there then you have a resident who comes in and that resident has attempted to sexually assault other residents you might be an organization that you don't you don't generally take sex offenders perhaps it wasn't known because you know as another example the expectations for an organization a facility that does treat sex offenders should hopefully have some different things in place for supervision than one that that is not their focus of treatment there so again we want to offer that flexibility there you know if we unfortunately when you try to regulate everything to the nth degree then you will end up over regulating and hurting people so we want to have some flexibility within the rules hopefully that's helpful for people as they're trying to sort of figure that out but again I recommend address that in policy and in staffing there get out of this it does freeze up here a little bit on me medication error and adverse reaction is the next incident category there and you report that only when it results in permanent client harm hospitalization in a medical unit or death and there we do have the two definitions of a medication error and adverse drug reaction you know go back to the slideshow and the threshold for reporting reporting is higher and/or more clear because I think this is unfortunately an example of our previous instructions it it sometimes was hard to just to see whether something is reportable because we have that term likely to have occurred serious injury or death was likely to have occurred and that could be subject to different interpretations so that is no longer part of the instructions and again it has to result in the hospitalization and medical unit permanent harm or death and it's another thing to point out that it doesn't mean other types of medication errors and adverse incidents are not important they're not insignificant events they are there are things that the provider should review as part of its QAPI processes they just do not rise to the level of reporting that the department needs to know about it again we do not need to know about every time something goes wrong in an organization and I should just stay on my powerpoint here this one occurrence which necessitates temporary relocation of residents and emergency unplanned medical intervention it is not reportable in a community mental health agency and it is reportable in a residential facility there has been no change in the reporting of this this slide is just stopped again we wanted to point out where there are differences in reporting between the community mental health agencies and the residential facilities so serious bodily injury who an emergency or unplanned medical intervention or hospitalization is required and I want to switch back over because I also want to point out the definitions here okay this is another one there's differences between the community and the residential facilities in terms of the types of events where it is reportable but first we're start and the reporting instructions we have this definition emergency unplanned medical intervention and it I'm not going to go over all of it it's performed by a licensed assistant certified nurse practitioner it's basically medical treat that is not first aid and you see here includes other treatments not listed under first aid and then we have that first aid definition below hospitalization means inpatient treatment had a medical acute care hospitalization you do not need to report psychiatric or hospitalization in the psychiatric unit and then we also the an injury is an event that requires medical treatment that's not caused by physical illness or medical emergency and I think those are important because previously illness and medical emergency was a reportable incident both in the community and the residential facility and they are no longer reportable under both those settings so if somebody's gotten the flu somebody has a mad cold whatever it may be you don't need to report that to us so the injury definition is there because it's certainly again if you sort of think of you know the differentiate you know something happens somebody fell somebody hit somebody something happened - cause - cause that event that requires some type of medical treatment and then the definition of first-aid is included there because it ties up to what is not you know emergency unplanned medical intervention that first aid definition in and of itself there is at this time there is no level of reporting that is associated with an injury that requires only first aid that will change January 1st you'll learn all about that in the fall but I do want to make sure that that is that people are understand that and again want to point out here the slide where the differences between the community agencies and the residential facilities is in a residential facility a self-inflicted injury is a reportable incident both of them obviously report the physical assault and restraint or seclusion related injury and we're going to be revising the form itself to actually the form says restraint related injury it doesn't have or seclusion on that so again that's one of those not only things a small technical change that will be adding to the form and okay I'm trying to go to trying to and I'm reading here and I guess I'm going to ask Rob I can not quite Robin Rob Nugent has sent me a message and Rob if you want to maybe explain what what you're trying to send over there because I'm not catching it and you should be able to speak yeah in the in the past agencies have asked if a client goes to the emergency room or is placed in 23 our observation which is just an observation bed whether they have to report report that in the past we've had them report only if they've received medical care greater than minor first aid or greater than first aid so it's just distinguishing between that definition where they're in a hospital bed versus you know they're admitted to the hospital verses 20 through our odds which is an outpatient service so I would think that would remain the same that if they receive care that you know is greater than first aid from a medical practitioner that would still be reportable but if it's just 23 hour obscene they're doing x-rays and things like that that would not be reportable okay and that's a good point and I've gone back here on on your screen to emergency unplanned medical intervention and there in the second line means the treatment required to be performed and treatment is a very important part of that definition it is part of also you know first aid and when we work when we worked on that so if somebody you know if if somebody goes for observation you know if you have to call 9-1-1 and ambulance comes and they decide to take somebody you know in but no treatment ends up being provided or it ends up being something that is very minor then it does not meet that definition of emergency unplanned medical intervention and I have to say these definitions these were they might seem very simple we spent a lot of time trying to develop them first aid I'll give a shout out to Teresa Lam pole with the Ohio Council spent a lot of time with me on that and again that'll kick in more as the level of reporting that's associated with that in January to make sure that we're clear about what we're looking for so again focus on it is on treatment not the setting so in conversely if it's you know something where it might be occur at your agency you may have a medical doctor that provides some of this treatment at your at your agency so then it would be a reportable incident I'm going to okay the next one is sexual assault and that's an allegation of one or more the following sexual offenses as defined by chapter 29 of seven of the Revised Code and I also want to point out here the where's instruction do not complete if type if sexual if type is sexual assault was minor involved and the reason for that is oh I I'm going to complete this and then I'm going to go back I missed my slides on serious bodily injury so I'll complete my thought here and then I'll go backwards and I apologize previous instructions required reporting of all consensual sexual activity involving minors and that is no longer reportable it is specific to when one of those crimes and those are crimes ing to the chapter 2907 of the Revised Code that there's an allegation of one of those crimes so consensual sex now if so there's a difference between and there are some legal differences between consensual sex between sexual activity between two 15 year olds or two fourteen year olds versus you might have consensual sexual activity between a four ten year old and a 23 year old well that may be consensual but that's going to trigger it's actually an allegation of a crime ing to chapter 29 of 7 a new high revised code so again we're looking at allegations of actual criminal contact and the reporting now between on sexual assault is actually the same so it's the same reporting for minors and adults there are no differences okay and you report it at this time only when the alleged victim is the client and that's another area I need to correct the reporting instructions to state this I wasn't when I was working on that part of it I misunderstood the previous reporting instructions another good reason why they were updating them that will change in 2012 but we will worry about that at that time and now I want to go back here apologize for the couple of the advanced questions on serious bodily injury due to physical assault and in that question here they talked about the draft rule that that be reportable if it happens on grounds during the provision of care and the new instructions don't specify this when is it now reportable it's reportable on a residential facility when the client is the alleged victim and that's consistent with the instructions prior to July 1st 2011 and that's going to be different when the rules that go into effect so so at other times when the other persons when it's staff or visitors or somebody else is the victim that will not be reportable until January 1st 2012 and then they're also talked about accidental injury has been oh and I typed that up wrong on that slide I apologize it says since accidental injury oh yeah that's right actually I apologize accidental injury has been eliminated under serious bodily injury and this isn't a commune mental health agency how would it be reported if there's a fire at the agency and it is it is not reportable in a community setting it is that's one of the things we when we did go through and eliminate some of the category we made the decision to eliminate serious bodily injury and emergency unplanned medical treatment kind of missed that so we are going to review it we can we can't make any revisions to the rule now we can't make them till after they go into effect so we'll be looking at it and but we're not going to plan to propose adding all events and I said you know if a client and staff are there sitting in a car at a red light they're hit my truck doesn't stop and Buster's hospitalized it's not necessarily one that needs to be reportable to the department suicide attempt community agency no longer reportable and it is still reportable in a residential facility and that that is a change that you know community suicided Townsend community agencies actually account for 30-something percent of our reportable incidents and community mental health agencies so we do believe that by eliminating that will certainly help reduce required reporting for organizations and then now there's another index now in the form as a result of the elected incident are criminal charges against a client being pressed by staff that occurs on your occurred on the old paper forms and that is not part of the new forms it's actually down this this area down here in the bottom right hand corner so again that's another one it is eliminated we can't take it out of where's but organizations do not have to answer back that question and we understand if people do answer the question if they put a filling in you're not doing anything you know wrong or anything like that it's just it's not something that you need to do it's up to every organization how they want to prefer to report if they want to use the paper reporting because the forms match up better or they want to continue to use Weir's that's entirely up to the organization's and that is that is sort of a review of all of the reporting instructions and the forms themselves do you want to do the reminder that their utter of other categories which are no longer reportable illness and medical emergency use of force by law enforcement and again we're not saying that those are significant events or events that an organization needs to utilize but they are not things that we think rise to the level of reporting and in part sometimes it's it's also because of the control and use of force by law enforcement while an organization can control when they call police or law enforcement to the to the agency or the facility there are other times that police or law enforcement come they might be bringing a client there for another reason and they may get involved in regardless of whether the organization has called or requested the presence of law enforcement the organization does not have control over the actions by the law enforcement officers which is the reason that we took that off the required reporting again reminder they'll continue to appear on Weir's until the new system is developed they already discussed that about first aid I'll go over some more reminders that again January first there's going to be some additional categories of incidents which we require reporting there's one we call medical events impacting agency operations when when you see that when the time is and the rule is out there again it's a definition we spent some time on to make sure that it's a very narrow reporting for the most part providers these new categories we don't think that they will frequently be reported don't think you know sexual assault by non staff of visitors or staff the agency residential facility grounds is it's not an event that happens this medical event that impacts agency operations it kind of you know that's going to be the time when the Health Department has wrapped your agency or facility three times around with yellow tape and you've had and you know nail a dead cat to the door to warn people to stay away that people are risk it's not minor things like you know everybody has the flu so the definition of that is very specific to again try to limit the reporting so we do not expect an increase in reporting and in the categories with the exception of the seclusion and restraint related injury categories so just to make everybody aware that again as I talked about we're gonna make some revisions to the reporting instructions and report forms and we will send another email to the executive director I also I'll add in here now we are in the past a few years back people used to have the ability to sign up to get alerted of information that we would send via email or mail to an executive director it was not a listserv it became a very unwieldy operation for me to manage with an excel file we are pursuing that again and hopefully we'll be hopefully here at OD image we can put up sign up in people who want a sign to get notified of things rule activity advanced communications like this so we'll provide that more information but we are we are trying to do it I myself if people haven't learned am NOT a technology whiz but hopefully roas staff can do that for us also again that incident report new into the report if people want to utilize that we will get back and get an answer to that auto reply email and that we're just not going to be updated I'm gonna put where you can find I've made reference to those rules which will go into effect January 1st 2012 let me see if I can switch over here we have this that certainly didn't work here is from the department's rules web page that and you can you can get this from the front page and you can see under their rules and effect draft rules and then pending rules there's a link there and that will list everything that we have pending with that's filed with the register of Ohio under here the incident notification rules 26:13 they talked about the special treatment and safety measure rules wanted to people to have a chance to look at that we also have from our webpage under licensure and certification some links there is the Weir's that's down here under incident reporting and to go under under certification of community mental health agencies at the bottom is the incident notification rules forms and reporting instructions and that same information is also there under the residential facility light so people can do that I have a question what do I estimate the time frame to be for the revisions to forms and instructions some of them I've already put them into the forms I think you know if anybody has seen something today did think up they want to send me an email or some Robin email but those will be done hopefully by next Wednesday I will say at the latest perhaps sooner if we don't get because like I said we've got all these people looking at it and reviewing the information and I like to think I can get everything right and unfortunately just didn't I did not get it this time so I apologize for that are there any more questions I think answered everything theirs if I ask this sensation available as a PDF file they are like I said the recording of this webinar will be posted and as well as the PowerPoint slides and I I cannot speak to how that is posted I did send the PowerPoint if I'm kind of learning we were up great we were upgraded here to the 2010 I know that not everybody has that so there's been some difficulty at times opening both Word and PowerPoint I hope everybody was able to open these I did go back and save them and in the prior format if you cannot if you cannot open something that I send you then please feel free to give me an email send me an email and I will get it to you in another format and also if and if you have questions after today you can always follow up with me about anything that relates to rules and then for incident reporting including the instructions the forms Rob Newton is your main point of contact for that and there's his phone number there's this email be more than happy to address any questions and I do want to also launch if I can do it one more poll I've talked a little bit about upcoming training for the incident reporting and our original intent for that was to do regional training and but now that I've done all of three webinars and we've gotten some response from people would like to get your feedback there whether you think whether a series of webinars would you prefer or regional trainings I know I personally I like going out and doing the training I like the opportunity to get to meet people face-to-face this is you know sitting here speaking into sort of the open space and not getting the opportunity to see you you know I just like to get to see people and talk to them and have some side conversations it's one of the things I enjoy about you know the karf and Joint Commission trainings that we do in CoA which we because of their process we don't hold this frequently however this is you know we want to utilize the format that we think people best is best for the organization's because you are you know you're the customer here and we want to meet you meet your needs the series of webinars because the training between the new incident reporting rules seclusion restraint will be if I were I'm going to guess depending on your organization if you needed to hear everything possibly up to six hours so we would not do one six-hour webinar I'm sure as witty as I can or cannot be that people would fall asleep but we would do it as a series of webinars so again I am one man one last check for questions I'm not seeing anything come in I think there's a another question about receiving an email confirmation for an mui we're going to get back with everybody on that sounds like it's a good question i think it's one of those where we think let's let's look into that and okay well this going to go ahead now i appreciate everybody who's provided their responses to the polls i appreciate everybody who's listened today and again we will make this recording available on the OU DMH website and we'll send a notification when that is available as well perhaps I can get all these things accomplished they're on the same time and send one email I know we all get lots of them and again please any further questions that you have please contact Rob or please contact me and I hope everybody has a great weekend thank you you