Main components of an abuse, neglect and exploitation prevention program

Formal framework for all other components (screening protocols, training, reporting procedures, investigations, and response

Reviewed and supported by provider leadership

Outlines training requirements for prevention and signs of ANE

Establishes reporting, investigation and resolution procedures

Identifies responsible parties

Incident File/Report Retention

Complies with regulatory and statutory guidelines

Reviewed by assigned and authorized personnel at regular intervals to maintain up-to-date procedures. Policy updates made when necessary

Reviewed by legal counsel

Persons served:

• Pre-admission screenings

Staff:

• Pre-employment background screenings, reference checks and verification
• Verify education, licenses and certifications

Volunteers:

• Background screenings

Vetting of 3rd party contractors and/or outside parties (always verify who is on site)

Provides staff overview of ANE prevention and reporting program

Initial hire and annual in line with internal written policy

Training includes:

• ANE indicators and symptoms
• Internal reporting procedures
• Reporting and resolution timelines
• Challenging behaviors and interventions
• Additional training and staff retraining per written policy

Training per internal agency/provider written policies for assigned program roles (varies per assigned position)

Safety and/or vulnerability assessments

Tracking for history of trends - if potential is identified, take action per internal policy

Indicators or symptoms

• Unusual patterns
• Suspicious or unexplained injuries (e.g., bruising)
• Inconsistent staff explanations
• Unusual resident behaviors around certain staff

Once notified and /or identified: report to proper authority in line with internal written policies

Reports made to proper authority (internal) per written company reporting policy and procedure

Triage of Potential Incident(s)

• Internal resolution and/or external reporting completed per written policy (assigned personnel review evidence, notes, observed incident reports or third-party reporting, witnesses, pattern, etc.
• Assessment of the incident (i.e., trauma, exploitation of persons served, injury, hospitalization, death)

Assigned personnel determine if there are indicators or absence of ANE in the incident based on assessment, leading to either further investigation or resolution per written policy

Prompt and thorough (within internal provider policy)

External reporting per statutory and/or funding agency (Medicaid, CPS, etc.) requirements

Assigned investigator

Root cause investigation/analysis

Assessment to determine if abuse, neglect, or exploitation claim is substantiated or unsubstantiated

Resolution per written policy

Prompt response to protect and care for person(s) served and corrective measures in line with internal written policies

Inquiries

Identify need for policy review, staff retraining, staff termination per written policy and staff review and / or change to screening procedures

Additional safety and/or vulnerability assessments

Interdisciplinary Team interventions

Address with Quality Assurance and Performance Improvement programs

Additional measures as necessary to protect person(s) served and prevent recurrence

Incident report retention per written policy and in line with statutory requirements