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Critical Incidents / IRAS Incident Reporting and Analysis System A training for SAMH providers in Circuits 3, 4, 5, 7, 8 Presented by Lutheran Services.

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Presentation on theme: "Critical Incidents / IRAS Incident Reporting and Analysis System A training for SAMH providers in Circuits 3, 4, 5, 7, 8 Presented by Lutheran Services."— Presentation transcript:

1 Critical Incidents / IRAS Incident Reporting and Analysis System A training for SAMH providers in Circuits 3, 4, 5, 7, 8 Presented by Lutheran Services Florida Health Systems October 2014

2 Housekeeping Please mute your phone and monitor area – unless you’re speaking Hold most questions until the end of the presentation, but they are encouraged during the FAQ portion This PowerPoint will be posted on the LSF web site – https://lsfhealthsystems.org – under Resources tabhttps://lsfhealthsystems.org Staff training offsite; QI staff onboarding

3 Why We Care DCF’s mission: Protect the vulnerable and promote recovery and resiliency The State of Florida has developed an entire operating procedure around IRAS and critical incident reporting (CFOP 215-6). CFOP adherence = compliance The Department’s contract with the M.E. requires that we support and manage the critical incident reporting in our region. We are all held accountable contractually.

4 What IRAS Provides Timely notification of critical incidents to LSF/DCF 24 HOURS, 24 HOURS, 24 HOURS to Submit into the Incident Reporting & Analysis System Details of the incident and the immediate actions taken. Tracking and analysis of incident data.

5 YOUR REPORTS AND DATA IDENTIFY TRENDS AND CAN LEAD TO IMPROVEMENTS IN POLICY AND PROCEDURES. Reporting and Analysis

6 Type of IncidentJulyAugSeptOctNovDecJanFebMarAprMayJuneFY Adult Death Child Arrest Child Death Child-on-Child Sexual Assault Elopement Employee Arrest Employee Misconduct Escape Missing Child Security Incident-Unintentional Sexual Abuse/Sexual Battery Significant Injury to Client Significant Injury to Staff Suicide Attempt Other Monthly Total: Fiscal Year Total: 278 PROVIDER DATA – ACCURACY COUNTS

7 Contract Requirement: SUBMIT WITHIN 24 HOURS, including weekends and holidays or Date of Discovery

8 Don’t let the IRAS software system scare you out of your seat If you are new to IRAS, LSF, DCF and your IT Desk are here to troubleshoot problems you may have and provide guidance to help you master this reporting system.

9 Registration for Users: a Step-by-Step Process You must be registered before you can report online into IRAS. Follow the steps on programs/mental-health/iras/registrationhttp://www.myflfamilies.com/service- programs/mental-health/iras/registration Plan ahead; it can take several days/weeks depending on DCF data office’s workload. Aventail must be installed on your desktop.

10 72-HOUR WARNING! IMPORTANT REMINDER: Once DCF’s data liaison specialist (Janice McIntyre) sends you the Aventail and DCF Web Portal password to use IRAS, you must sign in with it within 3 days or that password expires.

11 Now that you’re registered… Provider contractual responsibilities Report directly into IRAS within 24 hours of the incident occurring or, in some off-site situations, within discovering that the incident occurred. This includes weekends and holidays. In addition, if a consumer death occurs on-site, providers must notify LSF by telephone within 24 hours. Calling also applies to three more categories of incidents: elopement of a child, elopement of a court-ordered adult and any incident involving active media involvement. CALL (the LSF Access to Care Line) and an LSF Clinical staffer will answer after business hours

12 Tools A helpful User Guide is on the DCF IRAS site. You can link to it once signed on. OR you can print it out and keep it near your computer. RECOMMENDED: A 38-minute video that takes you tab by tab through entering an IRAS report.

13 The proper use of Date of Discovery as Incident Date (above): Off-site only, within the last 30 days of treatment/service

14 This shows the order you enter information after the BRIEF DESCRIPTION on Face Sheet. Remember to add PEOPLE INVOLVED. When entering additional relevant data (diagnoses, last date of service, clinical response, who was notified etc) type in Comments box and SAVE COMMENTS. Then, in order to SEND this report to DCF/LSF, you must click on NOTIFICATIONS (highlighted above). If you don’t send, no one is notified by for review.

15 If there are no notifications records, this report has not been sent to DCF/LSF. You must click on SEND INITIAL INCICDENT REPORT

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19 Important Reminder Take action to ensure the health, safety and welfare by all individuals involved in an incident. THIS IS NUMBER ONE Contact law enforcement or emergency responders when appropriate, and/or the Florida Abuse Hotline. THEN follow IRAS procedures that your facility and the M.E. have established. (Remember, within 24 hours of incident)

20 Reportable Critical Incidents Adult Death - 18 years or older consumer whose life ends while receiving services or when it is known that an adult died within 30 days of discharge or last treatment / visit / service received. Manner of Death. Suspected Overdose. Seclusion and Restraint – IRAS will prompt you for all of these. Answer as they apply.

21 NATURAL EXPECTED, NATURAL UNEXPECTED ACCIDENT – A DEATH DUE TO THE UNINTENDED ACTIONS OF ONE’S SELF OR ANOTHER HOMICIDE – A DEATH DUE TO THE DELIBERATE ACTIONS OF ANOTHER SUICIDE – THE INTENTIONAL AND VOLUNTARY TAKING OF ONE’S OWN LIFE UNDETERMINED – THE MANNER OF DEATH HAS NOT YET BEEN DETERMINED UNKNOWN – THE MANNER OF DEATH WAS NOT IDENTIFIED OR MADE KNOWN Adult and Child Deaths

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23 More Dropdowns for Deaths Suspected Overdose Non-prescription – illicit Prescribed – methadone Prescribed – buprenorphine (suboxone) Other – an overdose not mentioned above Unknown Drug Is Death Related to Seclusion or Restraint? Yes should be checked if any of these circumstances applies: Death occurs while a person is restrained or secluded Within 24 hours of release from seclusion or restraint Within one week after seclusion or restraint where it is reasonable to assume it contributed directly or indirectly to consumer’s death.

24 Q: Are methadone clinics required to report the death of an individual receiving outpatient methadone maintenance? A: Yes, all Substance Abuse providers that are licensed by the State are required to report in IRAS. Death FAQ’s provided by the Department of Children and Family Services

25 Q: Do the managing entities (MEs) have the right to access records on non-Department clients? A: No, ME's cannot access non-DCF funded client information. If a non-DCF client is receiving services at a facility and there is an incident involving that individual, the Licensed Substance Abuse Provider would have to enter the incident report, but they would NOT release non-DCF funded client information to their ME. Summary: Enter all SA critical incidents into IRAS. Enter Lutheran Services Florida when it is a state-funded consumer. For non-DCF consumers, pull down to your agency’s name for Provider and Subcontractor. For MH critical incidents, report to Lutheran for DCF-funded consumers. Do not report at all into IRAS for non-DCF consumers unless there is media coverage of the event. Do NOT enter names or PHI for these special cases.) Death

26 Q: Does reporting deaths apply to individuals who die while receiving outpatient services? A: Yes, if they are receiving outpatient services you would report their death (just as you would if they were receiving inpatient services). The difference between the two is that you would report the death of a client that left a residential program if they died within 30 days of leaving the residential program. The day a client discharges or walks out of outpatient services, you no longer have to report. Death

27 Q: If a provider hears a rumor of a death, what responsibility, if any, do they have for investigating or verifying the rumor? A: While they are receiving outpatient services, you are responsible for reporting a client's death. Most likely after a staff member receives information that a current client has died, "confirmation" would come from some type of case management follow-up; with a phone call or contacting the medical examiner. Death

28 Q: Is there a time limit beyond which a death should not be reported? A: Document the death of a current client receiving inpatient or outpatient services. If a client receiving residential services dies within 30 days of discharging from services, document it. If a client dies after receiving outpatient services, do not document. Death

29 Child-on-Child Sexual Abuse Any sexual behavior between children which occurs without consent, without equality, or as a result of coercion. This applies only to children receiving services from the Department or by a licensed contracted provider. For example: children in foster care placements or in residential treatment.

30 Q: Does this apply to SAMH case management services? A: This applies to any child receiving services. Child on Child Sexual Abuse

31 Q: Does this apply to SAMH outpatient services in general? A: This applies to any child receiving services. Child on Child Sexual Abuse

32 Q: If abuse is alleged, does it need to be determined whether it actually occurred in order to report under this category? A: Currently the way IRAS is set up as a notification system, you would enter allegations. You could enter follow-up information as soon as you receive it, indicating whether or not allegations were confirmed. Child on Child Sexual Abuse

33 Q: Is it possible for a minor to consent to sexual activity, as applicable to this definition? A: As a minor they cannot consent to sexual activity. Child on Child Sexual Abuse

34 Q: Is this limited to children receiving services from the Family Safety program? A: This applies to any child receiving services. Child on Child Sexual Abuse

35 CHILD ARREST 5b. The arrest of a child in the custody of the Department

36 Q: Does this apply to children in the custody of other agencies, such as DJJ, who are receiving SAMH services? A: Yes, if they are receiving any services from SAMH and get arrested a report needs to be entered into IRAS. Child Arrest

37 Q: What is meant by "custody of the Department?" A: A child who has been adjudicated as dependent. Child Arrest

38 Elopement The unauthorized absence beyond four hours of an adult during involuntary civil placement within a Department- operated, Department-contracted or licensed provider The unauthorized absence of a forensic client on conditional release in the community Unauthorized absence of any individual in a Department contracted or licensed residential SA and/or MH program

39 Q: Can a minor consent to leaving AMA or is this automatically elopement? A: A minor cannot consent. Elopement

40 AMA vs. Elopement Voluntary clients in residential have the right to leave treatment against medical advice. Do not report. UNLESS they leave/disappear from the facility without notifying any one, when there has been no intervention or AMA discharge process. Or, for example, if a client deviates during a medical appointment and does not return to the campus. Court-ordered (diversion sentencing) or Marchman Act involuntary clients in residential who leave AMA must be reported into IRAS regardless of the funding source. Remember, pull down to Lutheran Services for a DCF-funded consumer; pull down to your agency’s name twice if non- DCF.

41 Q: How would we define a client absent in the community? Does this include outpatient? A: Don't track outpatient clients if they don't show up, they are free to roam. However, if you were concerned for someone such as an elderly person, you need to follow up with them. Elopement

42 i. Missing Child. When the whereabouts of a child in the custody of the Department are unknown and attempts to locate the child have been unsuccessful. “Missing Child” as identified in CFOP 215-6

43 Q: What is meant by "custody of the Department?" A: A child that has been adjudicated as dependent. Missing Child

44 Q: How long does a child have to be missing before they must be reported as missing? A: If a child in a residential program is thought to be missing, report it immediately after you have searched the facility and determined the child is in fact missing. Missing Child

45 Q: Does this include all children receiving services? (E.g., outpatient services?) A: No, this incident type refers to children receiving residential services (or a similar type of placement), not for outpatient. Missing Child

46 ESCAPE – The unauthorized absence of a client who is committed by the court to a state mental health treatment facility.

47 f. Employee Arrest. The arrest of an employee of the Department or its contracted or licensed service providers for a civil or criminal offense. “Employee Arrest” as identified in CFOP 215-6

48 Q: How is this different from “g. Employee misconduct?” A: If an employee is arrested, enter a report in IRAS under "Employee Arrest.” Although this could be considered employee misconduct, it should be entered as an Employee Arrest. Employee Arrest

49 Q: Does this apply to all employees or only those who qualify for a Level 2 Background screening? A: This applies to all employees. Employee Arrest

50 Q: What does "civil" mean? A: It means that the person was not charged with a criminal act. Civil involves legal remedies - such as injunctions etc. Employee Arrest

51 g. Employee Misconduct. Work-related conduct or activity of an employee of the Department or its contracted or licensed service providers that results in potential liability for the Department; death or harm to a client; abuse, neglect or exploitation of a client; or results in a violation of statute, rule, regulation, or policy. This includes, but is not limited to, misuse of position or state property; falsification of records; failure to report suspected abuse or neglect; contract mismanagement; or improper commitment or expenditure of state funds. “Employee Misconduct” as identified in CFOP 215-6

52 Q: Does this include any alleged incident or only those somehow verified to have occurred? A: Report the alleged incident and follow up with verified information. Employee Misconduct

53 Q: Regarding "policy" does this include DCF policy, provider policy, both or neither? A: In CFOP 215-6, under "Employee Misconduct", the term "Policy" refers to DCF Policy. Employee Misconduct

54 k. Sexual Abuse/Sexual Battery. Any unsolicited or non-consensual sexual activity by one client to another client, a DCF or service provider employee or other individual to a client, or a client to an employee regardless of the consent of the client. This may include sexual battery as defined in Chapter 794 of the Florida Statutes as “oral, anal, or vaginal penetration by, or union with, the sexual organ of another or the anal or vaginal penetration of another by any other object; however, sexual battery does not include an act done for a bona fide medical purpose.” This includes any unsolicited or non- consensual sexual battery by one client to another client, a DCF or service provider employee or other individual to a client, or a client to an employee regardless of consent of the client. “Sexual Abuse/Sexual Battery” as identified in CFOP 215-6

55 Q: Are all allegations included or only those that are somehow substantiated? A: Currently the way IRAS is set up as a notification system, you would enter allegations. You could enter follow-up information as soon as you receive it, indicating whether or not allegations were confirmed. Sexual Abuse/Sexual Battery

56 Q: Are incidents prior to provider involvement included in IRAS reporting? A: There is no time frame for this, however, incidents that occurred 1 year ago, 2 years ago or 10 years ago do not need to be reported in IRAS. Clients may disclose being sexually assaulted in their intake assessment or in a therapeutic session, which is an appropriate time to be disclosed. However, if it has happened since they have been receiving services, it needs to be reported. If that is the reason they are receiving services, it needs to be reported. Sexual Abuse/ Sexual Battery

57 n. Suicide Attempt. A potentially lethal act which reflects an attempt by an individual to cause his or her own death as determined by a licensed mental health professional or other licensed healthcare professional. “Suicide Attempt” as identified in CFOP 215-6

58 Q: What if it’s a drug overdose and we don't know whether it was deliberate? A: If you have credible evidence from which one could conclude that this was a suicide attempt, then document it as such. If there is not sufficient evidence that suggests a suicide attempt, but the client had to be taken to the hospital for immediate medical attention due to the overdose, then you would document the incident as a significant injury to client. Suicide Attempt

59 I.Significant Injury to Clients. Any severe bodily trauma received by a client in a treatment/service program that requires immediate medical or surgical evaluation or treatment in a hospital emergency department to address and prevent permanent damage or loss of life. “Significant Injury to Clients” as identified in CFOP 215-6

60 Q: What is meant by "serious?" Is it interchangeable with "severe?” A: An injury that causes great discomfort, damage, or distress, one that's serious, dangerous or harmful. Significant Injury to Clients

61 Q: Does this include medication errors? A: Yes Significant Injury to Clients

62 Q: Is there a distinction between inpatient and outpatient? A: No Significant Injury to Clients

63 M. Significant Injury to Staff: Any serious bodily trauma received by a staff member as a result of work-related activity that requires immediate medical or surgical evaluation or treatment in a hospital emergency to prevent permanent damage or loss of life. “Significant Injury to Staff” as identified in CFOP 215-6

64 J. Security Incident - Unintentional: An unintentional action or event that results in compromised data confidentiality, a danger to the physical safety of personnel, property or technology resources; misuse of state property or technology resources; and/or denial of use of property or technology resources. “Security Incident - Unintentional” as identified in CFOP 215-6

65 CFOP 60-17, Chapter 7 January 6, 2014 Establishes a uniform process for notification to the state’s HIPAA Privacy Officer, Office of Civil Rights Suspected or known breach is reported as soon as possible, in addition to submitting an IRAS report Call Privacy Officer at (850) Complete HIPAA - Privacy or Security Incident Reporting Form (available from DCF Forms on its web site) and fax to (850) (850) (850) The Office of Civil Rights’ Privacy Officer will review and may ask you to fill out a Risk Assessment to gauge the risk of compromise. This Office and LSF will guide you on breach notification requirements pursuant to the Florida Information Protection Act of 2014.

66 o. Other. Any major event not previously identified as a reportable critical incident but has, or is likely to have, a significant impact on client(s), the Department, or its provider(s). These events may include but are not limited to: (1) Human acts that jeopardize the health, safety, or welfare of clients such as kidnapping, riot, or hostage situation; (2) Bomb or biological/chemical threat of harm to personnel or property involving an explosive device or biological/chemical agent received in person, telephone, in writing, via mail, electronically, or otherwise; (3) Theft, vandalism, damage, fire, sabotage, or destruction of state or private property of significant value or importance; (4) Death of an employee or visitor while on the grounds; (5) Significant injury of a visitor (who is not a client) while on the grounds of the Department or one of its contracted or licensed providers; or, (6) Events regarding Department clients or clients of contracted or licensed service providers that have led to or may lead to media reports. “Other” as identified in CFOP 215-6

67 Q: If an incident is reportable to the Abuse Hotline, but doesn't fall into the definition of any IRAS critical incident, should it be reported as other? A: Without knowing specific examples, it is difficult to answer this question; however, if the incident is likely to have an impact on the client, provider and/or Department, report it. Other

68 Q: Should reports that clients have brought drugs into a residential facility be reported as OTHER? A: Yes Other

69 Q: What is meant by "significant impact?" A: If the event/incident posed any threat, harm or elevated concern for the client, provider and/or Department, report the incident. Other

70 Q: Regarding media reports, if a provider is mentioned in an article, but it's not problematic in any obvious way, is that reportable? A: No Other

71 Quality Improvement Is Ongoing. It Never Ends. For support, LSF Continuous Quality Improvement Specialist Bryan Mingle at or call direct at


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