Critical Incidents and Incident Reports A&B

PHW EIM Information

24-Hour Reporting and documentation in Function Portal of any incident must take place, the best practice is for the SC to document as soon as they find out about the incident and have the necessary information.

Per the CHC Agreement, it is required to submit a critical incident report in EIM within forty-eight (48) hours of discovery of the incident, excluding weekends and holidays. The forty-eight (48) hour clock begins at the time that the incident was discovered. If the incident was discovered on a weekend or holiday the clock would start at 12:00 a.m. on the first business (day) following the discovery of the incident.  The Critical Incident Team submits the incident in EIM, after reviewing the SC’s documentation in FP and doing any necessary follow up with the SC.

Please remember to select the date and time of the discovery of the event upon case creation. 

Primary Reportable Category: Death

When a participant’s death is due to natural causes, an EIM event is NOT required. However, in circumstances when the demise of a participant is suspicious, or is unknown, or unexpected, please create the EIM event timely to allow for investigation. 

Per the OLTL instruction, when creating cases in EIM, do NOT use “Unexplained” as the secondary category in the Incident First Section. Instead, please select “Suspicious”. 

The option of “Unexplained” in the Incident Final Section Verification of Incident Classification Screen should only be used once it has been confirmed by the coroner that a cause of death could not be determined.

Trigger Events

Per the CHC Agreement:

• If a trigger event occurs, the Plan must complete a reassessment as expeditiously as possible in accordance with the circumstances and as clinically indicated by the Participant’s health status and needs, but in no case more than fourteen (14) days after the occurrence of the following trigger events:
  • A significant healthcare event to include but not be limited to a hospital admission, a transition between healthcare settings, or a hospital discharge. 
  • A change in functional status. 
  • A change in caregiver or informal support status if the change impacts one or more areas of health or functional status. 
  • A change in the home setting or environment if the change impacts one or more areas of health or functional status. 
  • A change in diagnosis that is not temporary or episodic and that impacts one or more area of health status or functioning. 
  • As requested by the Participant or designee, caregiver, Provider, or the PCPT or PCPT Participant, or the Department

From a critical incident perspective, we view all reportable critical incidents as trigger events. Per the CHC Agreement, a critical incident is defined as “An occurrence of an event that jeopardizes the participant’s health or welfare.” And as we review the trigger event definition, we can see that trigger events are those which impact the health or functional status of a participant. 

Here’s an example of how we make the connection: when we have a service interruption case, it likely indicates there’s either a change in caregiver or informal status OR perhaps there’s a risk identified in the home setting or environment causing the interruption (i.e., bed bugs and PAS agency suspends delivery of services until pest eradication can be completed). The example above is one where we would need to not only report the service interruption in EIM, but also conduct the trigger visit.

Incident Final Section

SC/MCO/OLTL Investigation Summary documentation expectations: OLTL expects the Final Section to be treated as a “working document” whereupon “real time” updates are to be entered to allow for true representation as to the status of the investigation, what barriers are identified, risks associated, and next steps. Remember: the documentation must paint a picture, who, what, when, where, how, why.

The Final Section should NOT be submitted until the Trigger Visit is completed and the participant either agrees to suggested changes/recommendations and/or the participant refuses assessment or suggested changes/recommendations. Documentation should also include the outcome of the Trigger Visit. If the participant refuses recommendations, which is their right, please ensure documentation demonstrates the fact that the participant understands and assumes risk (and that the SC held said conversation with the participant, we cannot assume).

Preventative Corrective Action: In this section there is a question as to whether an internal investigation was completed, some are indicating “yes”. This is ONLY appropriate when an investigation into the SCE and/or DSP respective agency was required. The question is not asking whether the SC investigated the event, that is the purpose of entering the event in EIM and providing the investigation details. In most Critical Incident events, the answer to the question should be “no”.

Additional Corrective Action: This section is extremely useful in detailing the risk mitigation efforts undertaken, please utilize this to enhance your documentation.

Below are the drop-down categories for both the Preventative and Additional Corrective Action sections:

Preventative Corrective Action Selection Options:

• Develop new policy and/or procedure, train appropriate staff and evaluate effectiveness
• Modify new policy and/or procedure, train appropriate staff and evaluate effectiveness
• Retrain new policy and/or procedure, train appropriate staff and evaluate effectiveness
• Introduced/added new service
• Introduced/added new informal support
• Adjusted Service Plan/Change in Amount, Frequency or Duration of existing supports and services
• Change made to living situation
• Added new or changed adaptive equipment
• Participant/Family/Caregiver/informal supports, education or training
• Participant Refused Recommendations and Assumed Risk
• SC reviewed PCSP and services were confirmed as appropriate, no changes at this time
• Primary Care Physician/Specialist Follow-up
• Other

Additional Correction Actions Selection Options:

• Change in PAS agency
• Change in Service Model; Agency to Participant Directed
• Change in Service Model; Participant Directed to Agency
• Change in Residence
• Diet/Food Modification
• Enhanced SC/MCO Monitoring
• Participant/Family Informal Support, Trained, Counseled
• Individual plan developed/modified (Service Plan, Behavior Support, Safety Prevention, Risk Management)
• Organization policy, procedure, protocol developed/trained
• Physical, behavioral health or substance abuse intervention
• Referred to law enforcement
• Right to Risk Form Completed
• Safety precautions taken
• Staff trained/retrained
• Use of assistive technology/adaptive equipment implemented
• Other 

Transition in Care Setting: 

If a participant transitions from an acute care setting to a SNF or Rehab, we can close the EIM event, as the participant is in a lower level of care, risk has been mitigated, and the SC will maintain contact with the SW at the facility to collaborate and plan for potential return to the community. 

If a participant transfers from one acute setting to another/different acute care setting for ongoing care, document the transfer in your note and in the EIM. We do not need to create a new case. 

If the participant discharges to SNF/Rehab and/or home and is then readmitted, a new EIM must be entered.

Protective Services Investigation Documentation: 

If there is no allegation of Abuse, Neglect, or Exploitation, and there is no protective service involvement, this section does not require documentation to be entered. On the contrary, if there is a protective service case, this must include documentation.