Handbook on Reporting Abuse and Neglect of Adults with Disabilities

ILLINOIS DEPARTMENT OF HUMAN SERVICES

OFFICE OF THE INSPECTOR GENERAL


Pat Quinn, Governor
Michelle R. B. Saddler, Secretary
(Cover Letter)

April 2010


State Operated Facility
Training Coordinators


Community Agency
Executive Directors


RE: Reporting Abuse and Neglect of Adults with Disabilities

Dear Colleagues:

The Office of the Inspector General (OIG) of the Illinois Department of Human Services has revised this handbook, which addresses frequently asked questions relating to reporting abuse and neglect. The revisions include statutory changes made during the past year.

The more substantial changes include: no longer defining physical or mental abuse as an injury; extending physical abuse to cover indirect actions, such as directing another individual to abuse the victim; adding financial exploitation as reportable to OIG; expanding the neglect definition to include substantial risk of possible injury, harm or death; clearly prohibiting any retaliation against an employee for reporting; requiring employees to testify at Rule 50.90 appeals, when needed; and omitting the old Rule 50.80 appeal as redundant.

You can download a copy of Rule 50 from the Illinois General Assembly's website, which is: http://www.ilga.gov/commission/jcar/admincode/059/05900050sections.html

I strongly believe that one of the best ways of preventing abuse and neglect is to ensure that all persons in the position of caring for disabled individuals know what to report, when to report, and how to report. Accordingly, I request that you share this revised handbook with all members of your staff and strongly encourage them to become familiar with its contents.

Thank you for your time and attention to this very important issue.

Sincerely,

William M. Davis

Inspector General


TABLE OF CONTENTS

Role of OIG

Reportable to OIG

Abuse/Neglect Reporting

Initial Response to Abuse/Neglect

Duties After Reporting

Duties After Case Completion

Health Care Worker Registry

Written Responses

Other Issues


OFFICE OF THE INSPECTOR GENERAL

REPORTING ABUSE AND NEGLECT OF ADULTS WITH DISABILITIES

Role of OIG

What is OIG?

The Office of the Inspector General (OIG) is the only investigative entity within the Department of Human Services that is empowered by state law to conduct administrative investigations into alleged abuse, including financial exploitation, and neglect of individuals receiving services in any program that is operated, licensed, certified, or funded by the Department for developmental disability or mental health services and not licensed or certified by any other State agency (20 ILCS 1305/1-17/). OIG also investigates alleged abuse, neglect, and financial exploitation of adults with mental or physical disabilities in their homes (20 ILCS 2435/).

Where are OIG offices located?

OIG investigators are located throughout the state. Currently, OIG has offices in Anna, Chester, Centralia, Greenville, Alton, Jacksonville, Springfield, Champaign, Normal, Pekin, Kankakee, Chicago, Tinley Park, Hines, Waukegan, Elgin, and Rockford. OIG divides the state geographically into four bureaus: South, Central, North, and Metro (Chicago area). A fifth bureau investigates alleged domestic abuse of adults with disabilities.

How can OIG be reached?

All allegations should be reported to the OIG Hotline at 800-368-1463 (Voice and TTY). The fax number, which is to be used for follow-up documentation only, is (217) 786-2171.

What programs are required to report allegations of abuse/neglect to OIG?

State law and administrative rules require staff of programs licensed, funded or certified by DHS for mental health or developmental disability services to report allegations of abuse to include financial exploitation, neglect and deaths to OIG. This includes staff of: State-operated mental health centers and developmental centers, CILAs (Community Integrated Living Arrangements), developmental training programs, and outpatient mental health centers.

What domestic abuse/neglect allegations are in OIG's jurisdiction?

OIG is statutorily authorized to investigate alleged abuse, neglect, or financial exploitation of adults (persons 18 to 59 years of age) who have a mental or physical disability impairing the ability to seek help and who reside in a domestic living situation, such as private homes, unlicensed residential settings, and board and care homes. OIG works in coordination with local and state law enforcement agencies, DHS divisions, and other service providers to resolve issues leading to abuse, neglect, or financial exploitation.

What other services does OIG provide?

OIG is statutorily responsible for other functions: providing training in reporting and investigating allegations; conducting unannounced site visits to the State-operated facilities; reporting to the Department of Public Health's Nurse Aide Registry the names of employees substantiated to have committed physical abuse, sexual abuse, or egregious neglect; and following up on a sample of administrative actions implemented by facilities and community agencies in response to investigative findings.


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Reportable to OIG

What types of complaints need to be reported to OIG?

  • Physical Abuse: An employee's non-accidental and inappropriate contact with an individual that causes bodily harm.  "Physical abuse" includes actions that cause bodily harm as a result of an employee directing an individual or person to physically abuse another individual. (The bodily harm does not have to be a visible injury.)
  • Sexual Abuse: Any sexual behavior, sexual contact or intimate physical contact between an employee and an individual, including an employee's coercion or encouragement of an individual to engage in sexual activity that results in sexual contact, intimate physical contact, sexual behavior or intimate physical behavior. (Sexual contact between an employee and an individual must be reported whether it is allegedly consensual or not, as it is a Class 3 felony.)
  • Mental Abuse: The use of demeaning, intimidating, or threatening words, signs, gestures, or other actions by an employee about an individual and in the presence of an individual or individuals that results in emotional distress or maladaptive behavior or the deterioration of an individual's physical condition or mental condition; or places an individual's health or safety at substantial risk of possible injury, harm or death.  (Since this includes what "could" precipitate a reaction, alleged mental abuse is reportable even if the individual does not appear to respond to the words, signs, gestures or actions.)
  • Neglect: An employee's, agency's, or facility's failure to provide adequate medical care, personal care, or maintenance, and that, as a consequence: causes an individual pain, injury, or emotional distress; results in either an individual's maladaptive behavior or the deterioration of an individual's physical condition or mental condition; or places an individual's health or safety at substantial risk of possible injury, harm or death.  (Neglect that causes presumable mental injury is reportable to OIG.  Neglect allegations do not require an identified harm to be reportable.)
  • Financial Exploitation: Taking unjust advantage of an individual's assets, property, or financial resources through deception, intimidation, or conversion for the employee's, facility's, or agency's own advantage or benefit.
  • What are the requirements for reporting deaths?

Deaths that must be reported to OIG are as follows:

  • Deaths occurring on-site in any residential or non-residential program;
  • Deaths within 14 days of discharge or transfer from a residential program; and
  • Deaths within 24 hours after deflection from a residential program.

A death must be reported to OIG within twenty-four (24) hours of the staff becoming aware of it.  If the death is suspected to be the result of abuse or neglect by staff, however, the death must be reported within four (4) hours.

Must criminal activity be reported to OIG?

Allegations of crimes should be reported to the most appropriate law enforcement agency, especially if an immediate response is critical. However, the allegation must still be reported to OIG within the time required, if it involves a death or an allegation of abuse or neglect. If the agency or facility has not reported to law enforcement, OIG has a responsibility to report possible crimes to the appropriate law enforcement entity, or instruct the agency or facility to report it, whether to the Illinois State Police or local law enforcement. OIG may assist with local law enforcement agencies in investigating allegations of abuse or neglect of individuals with disabilities.

What is the relationship between OIG and the State Police?

By law and interagency agreement, OIG reports criminal allegations at DHS facilities to the Illinois State Police. State employees must report any alleged criminal activity on facility grounds or by a State employee, such as theft of State property, to the State Police. OIG has a responsibility to report these to the Illinois State Police if they have not already been reported.

Should all medication errors be reported to OIG?

No. Report a medication error only when it results in the physical harm or mental deterioration of an individual or places an individual's health or safety at substantial risk.

Are suspicious injuries to an individual reported to OIG?

Yes, whenever an employee is suspected to have caused the injuries. The person calling OIG should state that abuse or neglect is suspected.

If OIG does not accept an allegation to investigate, what should be done?

OIG's decision not to investigate a complaint does not mean that nothing inappropriate occurred or that nothing should be done by administrators of the community agency or State-operated facility. Rather, these administrators are responsible for following up matters when a complaint does not meet the statutory or regulatory definitions governing OIG.

What is the relationship between OIG and the Illinois Department of Financial and Professional Regulation?

The Illinois Department of Financial and Professional Regulation has the legal authority to investigate allegations made against licensed professionals, such as doctors and nurses. The law allows disclosure of OIG's Rule 50 investigative reports to that department for use in its investigations.

The law also allows verbal disclosure of OIG's domestic abuse investigative findings, as well as any subsequent referrals, to a licensed professional who made the initial allegation to OIG. Thus, for example, if a nurse reports an allegation of the abuse, neglect, or exploitation of an adult with disabilities in that adult's private home, OIG is allowed to tell that nurse the findings of the investigation.

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Abuse/Neglect Reporting

What is the time requirement for reporting abuse or neglect to OIG?

An allegation must be reported to the OIG Hotline within four (4) hours after it was initially discovered by staff. Even if a policy of the community agency or State-operated facility requires reporting through the chain of command, OIG must be called within four hours of the first staff becoming aware of the allegation.

How should reports be made to OIG?

Administrative Rule 50 does not prohibit State-operated facilities or community agencies from establishing internal reporting policies as long as the four (4) hour reporting requirement has been met. Facilities and agencies are encouraged to use the time to obtain basic information about the allegation and the persons involved.

All reports made to OIG must be made by phone to the OIG Hotline (800-368-1463). A facility or agency "OIG liaison" may be named to make reports, but anyone who suspects abuse or neglect may report an allegation.

Who MUST report allegations of abuse or neglect?

While anyone may report allegations to OIG, anyone employed by a community agency or State-operated facility is by law a "required reporter." The employee does not have to have first-hand information and does not have to believe the allegation. Instead, the law prohibits "screening" of allegations; that is, no one may decide that an abuse/neglect allegation should not be reported.

Public Act 94-853, effective June 13, 2006, states that intentionally not reporting an allegation or reporting it late is a Class A misdemeanor, punishable by up to one year in jail and/or up to a $2,500.00 fine.  In addition, any employee who creates and transmits a false report to the Office of the Inspector General hotline is in violation of this Act.

Must required reporters report allegations that are clearly fabricated or made by habitual liars?

Yes. Individuals with mental disabilities may use unusual words or phrases to describe abuse or neglect. If an individual makes an allegation that appears impossible to have occurred, it is appropriate to ask further questions to clarify what he or she is alleging before reporting it.

Past credibility is not relevant either; an individual who has repeatedly made unfounded allegations is at greater risk of being abused. However, if an individual is merely repeating the same alleged incident, that incident does not need to be reported to OIG again.

Repeated unfounded allegations by an individual, as with any frequent inappropriate behavior, may be addressed clinically. However, care must be taken to avoid intimidation or punishment for alleging abuse or neglect.

What is the statute of limitations on allegations of abuse or neglect?

There is none.  OIG will accept allegations regardless of when they allegedly occurred, provided the location of the alleged abuse or neglect is within OIG's investigative jurisdiction.

How are callers making an allegation to the OIG Hotline protected?

It is a violation of Section 1-17(k)(3) of the Act for any employee or administrator of an agency or facility to take retaliatory action against an employee who acts in good faith and reports in conformance with his or her duties as a required reported.  Laws such as the federal Whistleblower Act may also apply.

OIG keeps the names of all callers confidential until a final report is completed and in accordance with the Freedom of Information Act (5 ILCS 140).  Any caller requesting to remain anonymous will not be named during the investigation or in the OIG case report as the caller. However, if a case proceeds to criminal or administrative proceedings, it is likely that anonymity will be lost.

What information should be provided to OIG when making a report?

Persons calling OIG to report an allegation or death should provide the following:

  • Information about the victim (birth date, diagnosis, medications, etc.);
  • Information about the guardian, if any (name, address, phone);
  • Steps taken to ensure the safety/health of the individuals involved;
  • Information of potential witnesses (names, work schedule, phone numbers, etc.);
  • Information about the accused (name, work schedule, home address, etc.); and
  • Particulars about the alleged incident.

How does the OIG Hotline function outside of regular business hours?

Reports may be made to the OIG Hotline 24 hours per day, 365 days per year. Intake investigators cover the Hotline during regular business hours (8:15 a.m. to 4:45 p.m. daily, except weekends and holidays).

If a call is received outside of regular business hours or when all Intake investigators are busy, the call will be routed to a contractual answering service of OIG. The answering services will take only basic information and then assess if potential imminent danger to individuals exists. If so, an OIG investigator will call back immediately. Otherwise, an Intake investigator will call back between 8:00 a.m. and 10:00 a.m. the next business day.

What requirements exist for notifying guardians?

The facility or agency is to notify the guardian of an allegation once it has been accepted by the OIG Hotline. OIG will later notify the guardian of the investigative finding and rights to request reconsideration or clarification of the finding. Thus, it is important to have the guardian's name and address when reporting an allegation to the Hotline.

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Initial Response to Abuse/Neglect

Who may take initial steps regarding an allegation of abuse or neglect?

All staff are responsible to ensure the safety and well-being of individuals under their care. However, the State-operated facilities have designated staff who are specially trained and assigned to take initial investigative steps. Likewise, some community agencies have adopted the OIG Investigative Protocol for Community Agencies and have been approved by OIG, which involves training and designation of investigators.

In any case, OIG has the authority to instruct facility or agency staff to take specific actions, as well as to cease actions that may hinder investigation.

What initial steps can be taken before reporting an allegation to OIG?

The State-operated facility or community agency should take all actions necessary to ensure the safety and well-being of individuals and the preservation of evidence, including:

  • Conducting medical exams of the alleged victim(s);
  • Removing the accused from contact with any individuals when credible evidence for the allegation exists;
  • Listing all persons present at the time, including visitors;
  • Gathering basic information necessary for reporting to OIG;
  • Separating witnesses before and during interviews; and
  • If so trained, collect and preserve evidence.

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Duties After Reporting

If an agency is requested to investigate, who may do the investigation?

A community agency will only be requested to investigate if it has first received approval to investigate. Approval requires that the agency:

  • Obtain a copy of the OIG Investigative Protocol for Community Agencies (available at www.dhs.state.il.us/page.aspx?item=10726);
  • Have at least one employee trained by OIG in Rule 50 and Basic Investigative Skills (or investigative Skills Refresher) within the past two years;
  • Ensure that the employee(s) has no conflict of interest in investigating;
  • Submit an application to OIG requesting authorization of the OIG-trained staff as agency investigator(s); and
  • Receive written authorization by OIG to investigate.

Approval is good for one fiscal year (July 1 through June 30).

Facility staff are not allowed to take primary responsibility for conducting an abuse or neglect investigation. However, trained facility staff may be asked by OIG to assist with investigative activity.

What identification will an OIG investigator have?

All OIG investigators are assigned a numbered badge and photo identification card. Anyone who is approached by a person identifying him or herself as an OIG investigator has the right to request to see his/her identification.

Are employees required to fully cooperate with OIG Investigators?

Yes. Employees are required to cooperate completely and truthfully with OIG investigations. Failure to do so could result in discipline.

Will talking to OIG violate HIPAA laws?

No. The federal Health Insurance Portability and Accountability Act (HIPAA) has a clause exempting investigations from its restrictions. OIG also has the right to obtain financial records from banks and other financial institutions, as well as from any person acting as a financial agent, during investigations into alleged financial exploitation.

How long does an OIG investigation take?

OIG makes every effort to have an investigative case report completed within 60 working days. However, delays in receiving medical reports, unavailability of witnesses, and other situations outside OIG's control may extend the time required for a thorough investigation.

What if law enforcement accepts an OIG case for investigation?

Usually, OIG and law enforcement work together on these cases. However, OIG conducts administrative investigations while law enforcement entities conduct criminal investigations, those where criminal charges may be filed. So OIG and the law enforcement entity will proceed somewhat differently and will produce separate reports.

What should be in the case file if the agency is investigating?

Investigative case files must contain all relevant evidence and enough documentation to support the findings. This includes interviews and a final investigative case report summarizing the evidence and clearly stating a conclusion.

If the report substantiates abuse/financial exploitation/neglect or an administrative issue, the investigative case file should contain documentation verifying implementation of all actions listed in the Written Response.

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Duties After Case Completion

Who notifies the accused staff member of the investigative finding?

Once an investigation is complete, OIG will send a letter to the accused and the employer notifying them of the case finding. OIG may also notify the employer by phone; if so, the employer may notify the accused employee before that employee receives OIG's letter.

When can an accused employee on administrative leave be returned to work?

That is the employer's decision.

What is a "reconsideration request"?

The State-operated facility, community agency, accused employee, alleged victim, or anyone else affected by the outcome may ask OIG to reconsider the finding of an investigation. This request must be submitted in writing to OIG within fifteen (15) days of receiving the report notification letter. The request must clearly identify that it is asking for a "reconsideration." By Rule 50, OIG may grant the request only if the request provides new information not contained in the investigation report and if that new information could change the finding.

What happens if a reconsideration request is granted?

If OIG grants a reconsideration request, the investigative report will be carefully reviewed. OIG may re-open the investigation, potentially changing the finding, or simply revise the report to include the new information.

What is an "aggravating" or "mitigating" circumstance?

State law requires that, in each substantiated case, OIG indicates whether there are any "aggravating" or "mitigating" circumstances. 

  • An aggravating circumstance is a factor that is attendant to a finding and that tends to compound or increase the culpability of the accused.  An example might be repeatedly kicking an individual or using a weapon.
  • A mitigating circumstance is a condition that is attendant to a finding, does not excuse or justify the conduct in question, but maybe considered in evaluating the severity of the conduct, the culpability of the accused, or both.  An example might be self-defense or being placed in a situation beyond the employee's training or ability.

OIG investigators look for aggravating or mitigating circumstances in every investigation, but the report identifies them only if the case is substantiated.

What is "egregious" neglect?

State law also requires OIG to determine in each substantiated neglect case whether the act or omission was "egregious." Egregious means a finding of neglect that represents a gross failure to adequately provide for, or a callous indifference to, the health, safety, or medical needs of an individual and results in an individual's death or serious deterioration of an individual's physical condition or mental condition, as determined by the Inspector General.

What happens to the accused employee in a substantiated case?

OIG does not determine personnel action - it does not fire or discipline staff. The action taken would be decided by the employer and reviewed by the DHS program divisions. However, if the finding is substantiated physical abuse, sexual abuse, or egregious neglect, OIG will refer the employee's name to this Health Care Worker Registry unless the employee wins an administrative appeal. Listing on the Registry effectively forces the termination of the direct care worker, since State law prohibits State-operated facilities and community agencies from employing a person listed on the Registry (20 ILCS 1705/7.3).

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Health Care Worker Registry

What is the Health Care Worker Registry?

The Department of Public Health maintains a list of individuals who have been trained as nurse aides for hospitals, nursing homes, and other settings with medically involved persons. OIG is statutorily required, absent administrative appeals to the contrary, to report to this "Health Care Worker Registry" the name of any person who is substantiated to have committed physical abuse, sexual abuse, or egregious neglect in a State operated facility or a program licensed, funded or certified by DHS to provide mental health or developmental services ("agency or facility"). Agencies and facilities may not report employee names to the Registry, but may search the Registry, such as for names of prospective employees. The Registry is available on-line at www.idph.state.il.us//nar/home.htm  

What administrative appeals are available to prevent listing?

Any person whose name may be sent to the Registry has opportunity to request review or appeal the referral, and this is described in letters OIG mails directly to the person. Initially, the person may request OIG "reconsider" the finding before finalizing the case; this reconsideration will be granted only if it presents facts or evidence not included in the investigation.

After OIG finalizes the cases, the person may "appeal" OIG's decision to refer his or her name to the Registry or the agency's or facility's decision to take discipline. The person may also have appeal processes available through the Department of Public Health, where the Registry is located. Finally, the person may file a formal complaint through any grievance or civil service procedure.  Again, when OIG substantiates a case, it sends the accused person letters detailing the reconsideration and appeal processes.

When is someone's name referred to the Registry?

OIG refers a person's name to the registry only when three conditions are met. First, the person must be or have been employed by a facility or agency under OIG investigative jurisdiction.  Second, the person must be substantiated to have committed physical abuse, sexual abuse, or egregious neglect of an individual receiving services in that agency or facility. Third, the person must have exhausted any appeal rights.

How does someone get off the Registry once on it?

Once every twelve months, a person listed on the Registry may file an appeal, requesting removal. The appeal must be sent to the DHS Bureau of Hearings and Appeals and provide evidence that the person has been rehabilitated and that it is now in the public interest to remove his or her name. OIG is mandated to conduct investigations and provide recommendations regarding the removal.

How often should an employer check the Health Care Worker Registry?

An employer must check prior to hiring a prospective employee and should consider checking periodically in the event that an employee has a secondary employer.

How can a background check be done on a prospective employee not listed?

The law's provisions mean that the Registry does not list persons who are substantiated to have committed mental abuse, financial exploitation, or non-egregious neglect. Further, as the appeal processes can be lengthy, a person may have been discharged by the community agency or State-operated facility but not yet be listed on the Registry.

Thus, an agency or facility may know that a prospective employee was substantiated to have committed abuse or neglect, but the person is not listed on the Registry. In such cases, the agency or facility may file a Freedom of Information Request for the case - it helps to have the OIG case number. The case report will have all names and other identifying information blacked out, but the agency or facility will thus know the actual finding in the case.

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Written Responses

What is a "Written Response"?

The law requires agencies and facilities to provide a: "written response...that addresses in a concise and reasoned manner the actions that the agency or facility will take or has taken to protect the resident or patient from abuse or neglect, prevent reoccurrences, and eliminate problems identified..." (210 ILCS 30/6.2(c)).

OIG has developed a standard form for a Written Response, which the community agency or State-operated facility must complete and return to DHS' program divisions for review.

When is a Written Response required?

A Written Response is required whenever "abuse or neglect is substantiated or administrative action is recommended" (20 ILCS 1305/1-17(c)). Therefore, in addition to whether the allegation was substantiated or not, an OIG investigative report may cite administrative issues - such as policy issues, procedural failures, structural problems, late reporting, or investigative improprieties. In all such cases, a Written Response is required.

What must a Written Response include?

The law specifies that the community agency or State-operated facility must include in the Written Response the actions they took or plan to take in order to protect individuals from abuse or neglect, to prevent recurrence, and to eliminate problems. For each action, the agency or facility must include dates of implementation and completion.

The Written Response form also requires the name of the administrative person responsible for implementation of each action and the signature of the authorized representative.

To whom is Written Response to be sent and when is it due?

OIG mails an initial Written Response form with the case report when appropriate, but requests that the agency or facility return the completed form to the relevant DHS program division (i.e., Division of Developmental Disabilities or Division of Mental Health). Those divisions are the Secretary's designee for reviewing and approving the actions listed in the Written Response.

Written Responses are due within 30 days of the investigation's completion, unless a reconsideration has been granted - if the reconsideration request is denied, the due date is 15 days after notification of the denial. Written Responses thus may be due before the actions identified are fully implemented.

To whom must documentation of actions taken be sent?

Since DHS' program divisions review Written Responses, the divisions frequently require clarification or documentation of actions taken. However, the law also mandates that OIG conduct a random review of completed actions in order to monitor compliance with the requirements, so OIG may also request documents.

What are "implementation status reports" and when are they required?

Within thirty days of approval of a Written Response, the community agency or State-operated facility is required by law to submit to OIG an implementation status report if the actions are not completed. If these actions remain uncompleted, an updated implementation status report is required at least every other month. That is, thirty days after the Written Response is approved and then every sixty days thereafter until final completion, the agency or facility must send OIG an updated implementation status report.

What happens during a Compliance Review?

OIG has created a standard protocol for Written Response Compliance Reviews. OIG conducts an initial review of the Written Response and documentation submitted. Then, OIG may contact the agency or facility to obtain further documentation, such as training records, revised policies, and verification of administrative action against an employee. The OIG staff conducting the compliance review may make a visit to the agency or facility to review documentation, interview staff and observe operations. These visits are typically scheduled in advance with the authorized representative or OIG liaison. Upon completion of a review, OIG sends a letter to the authorized representative indicating whether the agency or facility is in compliance or not.

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Other Issues

What is the OIG Investigative Protocol for Community Agencies?

The a Rule 50 allows OIG to delegate responsibility for some abuse/neglect investigations to the community agency. However, the agency must first adopt OIG's investigative protocol and be approved by OIG. The protocol is available on-line at www.dhs.state.il.us/page.aspx?item=10726

How can an accused employee or a guardian get a copy of a case report?

Any person may request a copy of an OIG case report by submitting a Freedom of Information Act request (FOIA), but State law has three specific restrictions: reports may be released only after they are finalized; only substantiated case reports may be released; and released reports may contain no personal identifying information.  Therefore, released reports will have all names, birthdates, ages, addresses, job titles, and other such personal information blacked out.

What is an unannounced site visit?

The law creating OIG requires OIG to conduct annual site visits to each facility operated by DHS to provide mental health and developmental services. The law does not list specific expectations of the site visits, except that they be unannounced, but the scope of OIG's jurisdiction is the prevention of abuse and neglect. So, each fiscal year, OIG develops a site visit plan that identifies what issues relative to abuse and neglect prevention will be examined during the upcoming site visits and how these issues will be reviewed.

Two staff from OIG - a compliance reviewer and a clinical coordinator - conduct these unannounced site visit at each facility once per fiscal year. OIG sends reports to the facilities individually and discusses trends and patterns in the findings in OIG's Annual Report.

What training does OIG provide?

OIG currently conducts three training courses.

The first is on Rule 50 (formally called 59 Illinois Administrative Code Chapter I, §50), the administrative regulation governing the management of abuse and neglect in facilities and agencies. This training is aimed at training administrative staff at the agencies and facilities, so they are able to train their own staff. The second is a Basic Investigative Skills course, which covers the initial response to allegations, preserving evidence, securing the scene, taking statements, and interviewing.

The third is a single day training: Investigative Skills Refresher, which reviews Rule 50, the topics of investigations, report writing and courtroom testimony.

How do agency/facility employees register for training?

A description of the trainings, a Training Calendar, and a link to the Registration Form are available on-line at www.dhs.state.il.us/organization/Secretary/OIG/tta.asp   While any staff of a community agency or State-operated facility may register for Rule 50 training, there are specific restrictions on who may register for the Basic Investigative Skills course or Investigative Skills Refresher course. Contact OIG's Training Coordinators at the numbers listed on the Registration Form, should you have any questions. Completed Registration Forms should be faxed to (217) 786-6921 or mailed to: DHS-OIG, Bureau of Compliance and Evaluation, 901 Southwind Road, Springfield, IL 62703.