Behavior Treatment Committee

1. Behavior Treatment Committee Bridget Avery

2. BTC Tracking Sheets • BTC Tracking sheets are to be used for all customers that have a behavior plan. • Summit Pointe provides a uniform tracking sheet staff should use if a specialized form has not been developed for an individual customer. • If an individualized form has been developed by the behavior specialist, you can use that form instead of the generic BTC Tracking Sheet. Reporting guidelines remain the same for the individualized form.

3. BTC Tracking Sheets Submissions • All tracking sheets are due by the 7th of each month to Bridget Avery. • Bridget continues to monitor submission of these forms to assist homes in assuring they are meeting these expectations. • If no forms have been completed due to an absence of problem behavior, please notify Bridget of such.

4. Plan Revision Requests • On occasion, the plan developed by the behavior analyst may require revisions to support implementation, or to reflect new information. • Requests to alter or modify the plan should go to the developer of the plan. The modifications should be made collaboratively. • If agreement cannot be made, a request for consultation from the BTC can occur to assist in navigating the barriers. This can occur via an email to Sean Field and Bridget Avery to place the customer on the next BTC agenda.

5. Requests for Restrictions • If there is a request to add a restriction to the plan, coordination with the plan developer must occur prior to contacting the BTC. • Recommendations for a restrictive or intrusive intervention must be supported by documentation including incident reports, and the targeted behavior must pose likely risk to the safety and health of the customer or others. • All restrictive and intrusive interventions must be reviewed by BTC prior to implementation.

6. Community Access • Unless a specific intervention is outlined within the customer’s treatment or behavior plan that restricts access to the community, it is assumed that the customer has full right to access the community. • Staff should work with customers prior to leaving the home to plan for their return and record their absence from the home.

7. Questions? • Sean Field: spf@summitpointe.org • Bridget Avery: bma@summitpointe.org

8. Divider slide For Providers Incident Reporting

9. 9 Types of Incidents Immediately Reportable Sentinel Homicide Suicide Accidental or otherwise unexpected death Death/Injury sustained from behavioral intervention, fire, elopement, loss of limb Sexual Assault/Rape Abduction Critical Death (natural) Emergency Medical Treatment Hospitalization due to injury or medication error Arrest Risk Actions taken by customers that cause harm to themselves Actions taken by customers that cause harm to others

10. Everything Leads to PI

11. Filling out an IR DO! • Submit IR to Performance Improvement within 24 hours or next business day • Fax 269-966-2844 • Use another sheet of paper if you run out of room • Fill out everything that you can! • Be specific • Type or print legibly • Provide customer number DON’T! • Do not put multiple occurrences on one IR (i.e., med refusal morning and evening), separate them out • Do not put more than one customer full name on IR, use initials of other customers • Do not completely scratch out a word. Cross it off with one or two lines through the word and initial

12. Physical Management • In addition to an IR, a use of Physical Management Form MUST be completed and sent to PI. • All forms can be found at summitpointe.org/forms

13. Click here for Critical events reported to PIHP (SWMBH) and State

14. Large Photo Slide 14 IR Examples - Matching RISK Event for both customers Sentinel Event Critical Incident Not a Reportable Event RISK Event for other affiliate member Reportable event-Risk Event Immediate Event Notification • Direct Care Worker calls police due to our member throwing a chair through a window and locking themselves in their room • Male running around specialized residential home with a knife chasing another resident (also a member of our affiliation). • Male cuts off own finger (Waiver customer) • Customer in specialized residential punches staff person, staff person has bruise on arm • Consumer punches another affiliate member in same setting • Member receiving outpatient services kills family and takes hostages. • Police called to CCI for our member due to our member’s behavior

15. Best Practices • If a particular behavior is persistent: communicate with the customer’s case manager to help incorporate into next (or create a new) behavior treatment plan • Share your BEST PRACTICES!!! 

16. THANK YOU Performance Improvement Team Performance Improvement Coordinator Bridget Avery Performance Improvement Coordinator Katie Larder 269-441-6056 269-441-6025 bma@summitpointe.org kll2@summitpointe.org

17. Compliance Updates

18. SWMBH Audit – Proper Documentation Policy 1.4.2 (Summit Pointe) 12.11 (SWMBH) 15.7 (Medicaid Provider Manual) Areas of concern from audit: - Signatures from service providers did not include dates - Improper error correction

19. SWMBH Audit - Documentation for services provided must be signed AND dated by the rendering professional. Error Correction: - Draw a line through the entry - Write “error” by the entry (state reason for the error in the margin or above if there is room) - Sign/initial and date the entry - Do NOT alter the original entry

20. New Documents • SPOT User Request Form • User Access Agreement Form • MDHHS BH Release of Information

21. Request Form Requirements 1. Request form must be submitted from the user’s supervisor. The form will not be accepted if it is submitted by the user requesting the account. 2. User’s name on the request from must be their legal name and/or name on their license. 3. Request from must be sent to Summit Pointe’s Compliance Officer for approval via scanned email to meq@summitpointe.org or faxed to 269-966-2844.

22. HCBS & Recipient Rights

23. Summit Pointe Office of Recipient Rights: Kent Rehmann Rights Director kar2@summitpointe.org; 269-441-5966 Technical Questions, BTC, Investigations, Site Visits & Training Barongiere J. Lovelace, Rights Investigator bjl@summitpointe.org; 269-441-6042 Investigations, Training & Technical Follow Up, Lindsey A. Saporito, Rights Support Staff lac@summitpointe.org; 269-441-6520 Training Registrations, Site Visit Compliance, Rights Checks, Complaints Recipient Rights Training Records Letter stating the following format (Excel only) is being sent out by Lindsey. Provider Site Location Employee Name Date of Hire Date of Initial Date of Most Recent Big AFC Provider 123 N. West St. Doe, Jane 10/10/2010 10/30/2010 05/07/2019 Smith, John 08/26/2018 09/14/2019 (duplicate initial date) Park St. AFC Jones, James 01/12/2019 02/14/2019 (duplicate initial date) Kwando, Ty 05/01/2018 05/19/2018 02/07/2019

24. State of Michigan HCBS Implementation Process Structure: MDHHS PIHP Leads CMH Leads Supports Coordinators Providers • Support Coordinators take the lead in updating the IPOS. • Any restrictions on the freedoms of HCBS participants must align with the modifications requirements set for by CMS • HCBS Rule Modifications Requirements: • Individual needs (Not for the convenience of the staff, but needs of the individual) • Prior Interventions and Supports including less intrusive methods (Documented, not just hearsay or History of) • Description of proportionate to assessed need (Health & Safety needs) • Ongoing Data Measuring Effectiveness of Modification (IRs, BH Tracking Forms) • Establish Time Limits for periodic review of modifications (not just annually) • Individuals informed consent (guardian cannot restrict based on preference, values or convenience) • Assurance that interventions and supports will not cause harm. • These restrictions may also be subject to behavior treatment plan review approval, and Supports Coordinators will follow CMH policy to utilize the BTRC.

25. The HCBS Final Rules requires that individuals have free access to their homes and communities and are empowered with the same degree of decision making as individuals who are not HCBS participants. • Any deviation from this standard requires that a person centered planning session occur and that specific conditions are met. • Overview of HCBS rights: • Individuals have access to food at any time. (locks on fridges…) • Individuals must be allowed to have visitors of their choosing at any time. (shared rooms?) • Residential settings must have bedroom and bathroom doors that are lockable by the individual. • Individuals must have the freedom to furnish and decorate their rooms however they choose. • Individuals must have their choice of roommates if possible. • Freedom to control schedule, activities and resources. • House Rules are not permitted. • Individuals must be able to control their personal resources. (cigarettes, funds, food, personal items, TV…) • Restrictive Intervention Requirements: • Any Restriction on an individuals’ freedom, must be identified and justified in the individuals’ IPOS according to the modification requirements by the CMH. • BTRC may not typically review all the type of restrictions that must be included in an IPOS. • CMHs will have a mechanism in place for the restriction, if it is not set forth by the BTC.

26. Example of Violations of MHC with the HCBS Rules • Right to Religious Practices (7044) • Visitation (7261) • Contact with Attorneys/others (7262) • Access to Telephone or mail (7263) • Written & Posted Limitations (7265) • Uncensored Mail (7266) • Ability to Spend or Use Money (7304) • Restriction/Limitation (7441) • Possession & Use of Personal Property (7281) • Exclusions (7286) • Limitation to Personal Property (7286) • Informed Consent (7003) • Choice of Physician or MH Professional (7130) • Least Restrictive Setting (7086)