An adult day care program – especially clinical model initiatives- are typically populated by people with limited cognitive function. As a result they may not be super verbal when it comes to complaints or airing grievances, no matter how trivial. For some operators this might mean they do not pay attention to the need to have an open dialogue environment where any grievance, even if seemingly trivial can be aired out.
Most areas where licensure is required insist upon some type of grievance or complaint procedure and this is necessary. However, this does not guarantee the operator will regularly review this with staff or take the time to solicit concerns from families or program participants on a set schedule in a pro-active way. The following is a summary of how your policy can look but more importantly is our making sure we use it:
Policy Statement: Participant Complaint Management Policy
In the event a program participant or their designated representative has a grievance relating to the services rendered within the center they will follow this procedure for reporting it and seeking resolution as follows:
a. Notify the Program Director immediately and request a meeting to discuss
b. During meeting outline the details of the concern/grievance
c. The Program Director will investigate any items that require verification
Program participants and their designated representatives shall be given the identity of the Local Ombudsman at admission and should be reminded to feel free to make any notifications to this agent as they so choose. The ombudsman for Our County is:
Care Advocacy Inc.
222 Main st.
Anytown, USA 00005 (Fictitious)
Reporting Requirements – Including Unusual Incidents
All incidents occurring in the Sample Adult Day Care Center must be documented in an Incident Report. This report is then placed in the applicable Program Participant/Personnel Files and in the control binder where Incident Reports are cataloged in a binder with alphabetical divides within the office of the program Director.
Please note the Pennsylvania statutory definition of unusual incident, requiring reporting for staff reference:
Unusual incident—An occurrence which seriously threatens the health and safety of a client. The term includes: Report to Licensing using this email address: email@example.com (Fictitious)
a. Criminal infractions.
b. Injury, trauma or illness of a client requiring treatment at a medical facility.
c. Abuse or suspected abuse of a client.
d. Violation or suspected violation of a client’s rights.
e. A client who is missing and presumed to be at risk.
f. Misuse or suspected misuse of client funds or property.
g. Outbreak of a communicable disease, as defined in Our State Code555.2222 (relating to specific identified reportable diseases, infections and conditions) to the extent that confidentiality laws permit reporting.
h. An incident involving a fire department or circumstances requiring police action.
i. A condition, except for snow or ice conditions, that results in closure of the facility for more than 1 scheduled day of operation.
j. Neglect or suspected neglect of a client.
These reports are to be completed by any staff with direct knowledge of any occurrence. If not on the property the Program Director is to be immediately notified of any incidents.
1. Notifications: (Written, of all incidents)
a. Family or program participant designated representative
b. Client family
c. Any agency responsible for managing this participant’s ongoing care, i.e. community mental health, Agents of Medicaid waivers
2. Notifications (oral) in the event there is: (Within 24 hours by phone)
a. Suspected abuse or neglect
b. Any incident requiring emergency services, i.e. Police or Fire Departments
c. Department of Aging of the State
d. Local county managed mental health personnel if the participant is jailed in a mental health program
3. Follow-up: Within 3 working days of an unusual incident the Program Director will conduct a thorough investigation and then using the form provided by the licensing department issue a thorough report to the Department
4. Storage: All reports are maintained by Sample for five, (5) years.
5. Reporting: (Deaths) To be handled by the Program Director
Using a Death Report on a form provided by the Department on Aging of the State notify:
a. Department of Aging of the State
b. Funding source, if public funds were used to pay for services
c. County operated mental health programs when funding from this source involved with this program participant
Of course this policy should be provided to the participant and/or their designated representative at admission but its value is heightened when it truly governs how we operate.