The proposed guidance for serious incident reporting creates an unwarranted, impossible and burdensome requirement for residential providers by creating a duty for residential providers to report level II serious incidents which did not occur during the provision of service or on the provider’s property; that can only be removed “if the provider verifies that the other provider reported the incident”.
24 hour reporting – this provision creates no exclusion for the residential provider from the 24 hour requirement if the residential provider were required to enter a level II serious incident report into the CHRIS system, due to the failure of the other provider to make the appropriate entry; given the possible lack of or at the very least guaranteed delayed awareness of the incident and the additional delays created by an attempted verification investigation (closed for the day, relevant staff not available, no answers/declined to comment etc.) it becomes probable that on many occasions the residential provider will not be able to meet the 24 hour standard which would result in a violation for the residential provider due to factors outside their control and despite their due diligence.
3. Onerous burden – this represent yet another example of an unfunded mandate being foisted upon the residential provider (investigation, documentation, reporting) and provides a basis for citing the residential provider for a violation when the residential provider has absolutely 0 control over the circumstances that created the violation and no way to prevent the violation from occurring or reoccurring – beyond unfair to a true injustice.
Recommendations: 1 – remove the requirement in its entirety from the guidance document;
2 – shift the requirement to the support coordinator, this is much more appropriate to their established role as the state already uses them as a policing agent and their primary responsibility is being aware of and coordinating across services; at the very least 3 – change the duty of the residential provider from verify to confirmation of the intent of the other provider to make the CHRIS entry and exclude the residential provider from the 24 hour requirement in this circumstance.