Development Of A New Department Of Health And Human Services Client Incident Management System

The development of a new Department of Health and Human Services client incident management system Proposed new model summary (as at 30 May 2016)

1. Introduction The Department of Health and Human Services (the department) is developing a new client incident management system that focuses on the safety and wellbeing of clients. The development of a new client incident management system will ensure a consistent approach to incident management, embed transparency and accountability throughout the system, ensure client safety and wellbeing, and support positive client experiences and outcomes.

2. What is the proposed new model for client incident management? The new client incident management system comprises five stages:

Figure 1 Model for the new client incident management system

1. Identification and response Identification is when an incident is disclosed to, or observed by, a service provider at any service delivery setting (for example, provider premises, outreach location, client’s home). This may include disclosure by a client, family member or other professionals, to the service provider. Response covers the immediate activities undertaken to ensure the safety and wellbeing of clients, staff and visitors, preserve evidence and notify emergency services and family or other support people.

2. Reporting Reporting captures specific information regarding the incident. As part of this stage, follow up is undertaken to ensure the information provided in an incident notification is accurate, and service providers and the department are assured that appropriate actions are being planned and/or undertaken to manage the incident.

3. Incident Investigation An investigation is a formal process of collecting information to ascertain the facts about an incident, which may inform any subsequent criminal, civil, disciplinary or administrative sanctions. In the context of this policy, the purpose of an incident investigation is to determine whether there has been abuse or neglect of a client by a staff member or another client, in relation to an allegation in a client incident report. 4. Incident Review A review is an analysis of an incident to identify what happened, determine whether an incident was managed appropriately, identify likely causes of the incident, and to apply subsequent learnings to reduce the risk of future harm. Reviews may be carried out by service providers (including the department) or external bodies.

5. Analysis and Learning Analysis and learning includes monitoring and acting on trends identified through the analysis of incident information to enhance the quality of service and supports to clients. Reporting, investigating, reviewing and analysing incidents enables service providers to review and assess the way in which an incident has been managed, to implement improvements, minimise risk and embed a continuous improvement approach which involves the client within service delivery. This in turn supports better client experience and outcomes.

3. What is the scope of the new client incident management system? In general, the new client incident management system will apply to all department delivered services and funded organisations, except those that report through the Victorian Health Incident Management System (VHIMS), which includes hospitals and some community health services. A full list of services in scope for the new client incident management system, as well as those services that are not in scope, is provided in the Client Incident Management System Instruction, Appendix C Scope of this instruction. A high level summary of the services in scope includes: community health services (that do not report through child protection VHIMS) out-of-home care services alcohol and drug treatment services youth justice mental health community support services disability services home and community care services (for people aged public housing and homelessness assistance under 65 and for Aboriginal people aged under 50) aged care and carer’s support services community dental services community palliative care services 4. What is changing in the new client incident management system? The new client incident management system is focused on incidents that have a direct impact on clients. This means that some occurrences currently recorded as part of current incident reporting systems will be managed through case management, issues management, workplace health and safety and risk management systems in the future. The table below highlights the key differences between the current system and the new model in relation to each of the client incident management system stages.

Identification and Response Stage Current systems New System Provide limited detail guiding service provider response to Clear client-centred minimum standards will be identified for responding to all client incidents to client incidents. ensure outcomes for client safety and wellbeing. Separate guidance in Responding to Allegations of Physical Specific requirements will be identified for preservation of evidence and notification of police (if and Sexual Assault policy document. required). Response guidance will include immediate response and planning for ongoing support to ensure client centred focus and accountability to the client. Specific guidance for responding to allegations of physical and sexual assault will be included in the one document, with key actions identified in the body of the Client Incident Management System Instruction, and cross-referenced to Responding to allegations of physical and sexual assault appendix to improve clarity and consistency.

Client Incident Reporting Stage Current systems New System All incidents are individually reported to the department. Revised incident categorisation and list of incident types to simplify and streamline classification Involves differing categorisation and incident types between across services, and ensure the system will be fit for purpose. Service providers select one Health and Human Services. primary incident type per incident report. Separate protocols are documented for follow up between Two categories will be used: ’major impact’ and ‘non-major impact’. The service provider must health and human services. exercise professional judgement in identifying the level of impact, with guidance provided by the department. No relationship between different categories of incidents, and no clear requirement to identify cumulative and escalating All ‘major impact’ incidents will require specific information to be reported on an individual basis harm to clients. to the divisional office by the service provider. All ‘non-major impact’ incidents will require basic information (including identifiable details of people involved in the incident) to be reported at an aggregate level to the divisional office on a monthly basis. Service provider CEOs will be required to review their monthly reports and identify patterns of persistent non-major incidents for a specific client, which will trigger a major impact incident to reflect cumulative harm, or other patterns of concern. The service provider board (or equivalent) must also receive a quarterly summary of these reports. Dangerous actions that are understood and being actively case-managed by the service provider will be reported as non-major incidents, unless there is an escalation or abnormality in the behaviour that triggers a Major impact incident.

Client Incident Investigation Stage Current systems New System Separate protocols are documented for follow up between Investigations will be the primary responsibility of the service provider (including the department health and human services. where it is the service provider). Involves separate policies on specific types of investigation The service provider will be required to consider what level of independence is appropriate for across services. each investigation; where the alleged incident involves the abuse or neglect of a client by a staff Some programs do not have documented process for member, some degree of independence will be required, for example an investigation by a investigations. separate business unit or an external organisation The department has a specific role in undertaking some types Includes minimum standards for an investigation, clear thresholds for when an investigation will of investigations, for example, quality of care concerns in out- be required, guidelines for when an external investigator should be commissioned, and of-home care. oversight/quality assurance. The department will also provide guidance and assist to build capacity as required The service provider will be required to have robust, documented processes for investigations and will be required to submit the investigation report to the divisional office for quality assurance In exceptional cases meeting strict criteria, including where the service provider has demonstrated a lack of capacity to conduct an investigation that meets the standards set out, the department may become involved in the investigation as joint investigation manager. Employment and carer schemes and screening processes such as the Suitability Panel and Disability Worker Exclusion Scheme will continue. Where there are concerns about a service provider’s performance more generally, beyond an individual incident, funded organisation performance monitoring mechanisms such as Service Reviews would be activated. These are to be distinguished from incident investigations. Existing investigation processes such as Quality of Care for concerns in out-of-home care will need to be assessed for relevance and alignment with the framework outlined above. Divisional office joint management of incident investigation if required to be signed off by the relevant divisional office Director Mandatory divisional office joint management of investigations in some incidents with specific criteria Client Incident Review Stage Current systems New System Separate protocols are documented for follow up between In general, the department will not perform reviews of individual incidents itself, except for health and human services. services it delivers directly. Involves separate policies on specific types of review across The purpose of a review will be to determine whether the management of an incident was services. handled appropriately, and to identify any learnings to apply in practice. Some programs do not have documented process for review. Every Major Impact incident must be subject to a review, either a Case Review or a more The department has a specific role in undertaking some types detailed Root Cause Analysis. of reviews. Includes minimum standards for an incident review, and clear thresholds for when each type of review will be required. In circumstances where there is a demonstrated lack of capacity of the Service Provider to undertake a Root Cause Analysis review that meets the minimum standards, the department will have an option to jointly manage the review, with the right to approve the Terms of Reference and select an independent reviewer. Where there are concerns about a service provider’s performance more generally, beyond an individual incident, funded organisation performance monitoring mechanisms such as Service Reviews would be activated. These are to be distinguished from incident reviews. It is noted that external oversight bodies also conduct reviews, and that some of these reviews occur pursuant to legislative processes. These types of reviews will continue in accordance with current approaches. Existing review processes such as Quality of Support Reviews, operational debriefs, and Promoting Better Outcomes reviews will need to be assessed for relevance and alignment with the framework outlined above. Divisional office joint management of an incident review to be signed off by the relevant divisional office Director. The divisional office may opt to jointly manage if there is a demonstrated lack of capacity by the service provider to conduct a review that meets the standards. The Director will apply a risk- based approach based on the severity of the incident and capability of the service provider to determine whether the divisional office involvement in managing the review is required. 5. What are the next steps for the development of the new client incident management system? The draft Client Incident Management System Instruction will be distributed to all in-scope service providers for final consultation in June 2016. In July 2016, the department will also send all in-scope service providers another survey request: this time to gauge sector capability and readiness for implementing these changes over time. The information received from organisations will help the department create a capacity building strategy to support the implementation of the new client incident management system.

6. Where can I find more information? Find out more about the development of a new department client incident management system at: If you have any questions about the project please contact CIMS enquiries at [email protected]

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Except where otherwise indicated, the images in this publication show models and illustrative settings only, and do not necessarily depict actual services, facilities or recipients of services. Authorised and published by the Victorian Government, 1 Treasury Place, Melbourne. © State of Victoria, Department of Health and Human Services May, 2016. Available at DHS.vic.gov.au