Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/8/19  4:00 pm
Commenter: Citizen

Serious Incidents

12VAC-106-20: Definitions-  Serious Incident
12VAC-106-570 C: Root Cause Analysis

Very appreciative of clarifying regulations to remove the requirement for completing a Root Cause Analysis for all Level III's and limits it to only the ones happening during the provision of a service or on the premises of the provider.  

Also appreciative of some of the language change to the definition of a Level II incident that takes out urgent care visits.  "In lieu of a PCP" left it up to the provider to determine what a PCP could/should treat versus an emergency room.  And logically, an urgent care visit is always going to be in lieu of a PCP otherwise the urgent care facility will recommend the person goes to the ER anyway.  

Not sure if all areas have access to urgent care facilities as opposed to emergency departments thought.

All that said, there is still one issue that regulations have yet to help clarify.  Most providers have at least one (if not multiple) individual(s) who insist on overuse of the emergency room.

There's only so many times a provider should have to write the following on a root cause analysis: "staff took individual to the hospital because they didn't want to get in trouble when individual declared some combination of the magic words... (i.e. 'chest pains,' 'can't breathe,' 'danger to myself or others,' 'it's my right,' etc.)."

If an individual goes to the emergency room and is discharged with no changes there should not be a CHRIS report or a Root Cause Analysis. Nor should there be for an individual who goes to the emergency room and then leaves prior to receiving treatment.  

Both instances should be clearly documented in progress notes, but the CHRIS/RCA follow up is unnecessary.  


CommentID: 76537