The guidance informs that providers must update an incident report in CHRIS within 48 hours from initial submission or from the time that the provider is informed by the IMU of the need to update.  We object to this requirement as at times, all information may not be readily available to the provider.  There may be situations in which the provider is still actively engaging in needed follow ups with physicians, staff, and other care providers to ensure the immediate safety and security of the individual.  For example, there may be test results pending or a visit with a physician for follow up that must occur before the provider has a complete picture of the situation to share with IMU.  Furthermore, for an incident occurring on a Saturday afternoon that requires a hospital visit, it may not be until late Monday or Tuesday that any needed exams or follow up appointments with primary care physicians can occur. 

While it is imperative that providers provide requested information and updates in a timely and complete manner, we ask that the Department take into consideration extenuating circumstances that warrant a delay in order to prioritize the safety and wellbeing of the individual receiving care.  As these individuals have just experienced a level 2-3 serious incident, they are in that moment our most vulnerable population and deserve the prioritization of their needs.  As such, we ask that the Department allow flexibility in the update timing requirements for providers in circumstances that warrant such flexibility. 

We also ask that the Department clarify what circumstances would warrant flexibility and ask that the Department inform of the notification expectations and timeline for such situations.  A suggestion to the Department would be to require all requested information the Department does not deem critical to the immediate care of the individual to be submitted to the Department at the conclusion of Root Cause Analysis.  Doing so would allow providers to share complete feedback with the Department at a time when the provider has the full picture of the occurrence, the causation, and a means of future prevention.     

In addition, we would also ask that the Department make requests for information via the CHRIS system in order to provide for ease of access and eliminate risks for both Department and provider staff overlap in questions and responses.  At times, it may be that the Department contact for the provider is out of office or unavailable when a request is made for more information.  When requests are made via CHRIS rather than phone or email, the likelihood of a more timely response from the provider increases as another set of eyes filling in can attend to the requested information on behalf of the contact.  Furthermore, utilization of CHRIS ensures that all requests for information are in one location and easily followed up on by both the Department and provider.  Doing so would eliminate the risk of multiple requests of the same nature and allow both the provider and Department to streamline information in one location.  When it comes to reporting incidents, the wellbeing of the individual is the utmost concern for both the Department and the provider, by consolidating requests and the provision of information to one centralized location rather than in emails and phone calls it is the belief of this provider that the individuals we serve can be better cared for.