1. Background and Registry Checks and Clearances
  2. CPR/First Aid
  3. Education
  4. Human Rights Issues
  5. Medication Administration
  6. Policy and Procedure
  7. Test of Reading Comprehension
  8. Training
  9. Contact for Assistance

Background and Registry Checks and Clearances

  1. What are the training and background check requirements for volunteers?

    The Health Care Worker Background Check Act (225 ILCS 46/70) specifically excludes physicians and volunteers as individuals that have "direct access" to residents and thus exempts them from the requirements of the Act. This means the law does not require them to have a fingerprint background check or clearance. Nonetheless, it is strongly recommend that providers run HCWR, DCFS State Central Register (CANTS), Illinois Sex Offender and HFS OIG Sanction List clearances on volunteers.

    Also, CILA Rule 115.320(e) delineates "Volunteer training" requirements: "The agency shall provide an orientation and training program for volunteers specific to volunteer duties and shall provide supervision as necessary. Volunteers with responsibility for care of individuals served must complete and demonstrate competency in the training areas specified in subsection (d) above.

  2. It is my understanding that anyone hired as a DSP/DD Aide or a CNA in a program falling under DDD regulation should have a fingerprint background check run. Is this correct?

    Yes, all new hires (not just DSPs or CNAs) must have a fingerprint criminal background check (CBC), unless they already have a fingerprint CBC reported on the HCWR. These are designated as a "Fee_App" on the Health Care Worker Registry.

  3. How about in scenarios where volunteer or temporary hires would be filling the role of a DSP/DD Aide or CNA?

    • First I am sure you remember that none of these people can work alone with individuals supported without a DSP designated as a DD Aide on the HCWR on-site.  Please see examples below:
    • Intern paid by the agency - In most cases yes, he/she would need a fingerprint Criminal Background Check (CBC). Exception: the intern is a student in a licensed health care field (e.g., student nurse, physical therapy student, respiratory care student, etc.). Exception to this is if the intern is employed in a position with duties involving direct care for clients, patients, or residents or when duties involve or may involve contact with residents or access to living quarters or financial, medical or personal records of residents in which case, yes they need a fingerprint CBC too.
    • Temporary staff hired through another agency. Yes a fingerprint CBC is needed. Anixter could also only contract with temp agencies that have workers that are already on the HCWR with a fingerprint CBC.
    • Volunteer. No CBC needed. This group is defined by the HCW Background Check Act as not having direct access to consumers and therefore does not need a CBC.
    • All other employees ranging from respite workers, job coaches, administration (including secretaries and other support staff) are exempt.
  4. If a DSP's fingerprints come back rejected from a vendor, will the agency need to send them back for a reprint?

    Yes, per the Illinois Department of Public Health (IDPH), the agency will need to do the following:

    • Log into the IDPH Health Alert Network (HAN) Web Portal.
    • Click on the "Exception" tab.
    • Find the DSP's rejected print there and perform a screen print as proof of rejection so he/she can be re-fingerprinted.
    • The DSP should take that rejection letter back with them to vendor to get reprinted at no cost to agency.
      If prints come back the second time rejected, a name based criminal background check will need to be done instead.
  5. What does the "Certification Code" on the Health Alert Network (HAN) mean?

    The Code Field on the HAN contains the last three digits of the agency's Public Health Number and the first digit tells you if they are a DSP or a CNA. If first digit starts with a "6" the person is a DSP and if the first digit is a "0" the person is a CNA.

  6. If an individual is on the registry showing they have a waiver, must the organization maintain a copy of the waiver?

    No. They do not get a copy of the waiver, only a letter indicating "Granted" or "Denied". Since letters can be forged or revoked, it is best to only look at the person's profile page on the IDPH Web Portal which will show the Waiver status as "Granted." If the person gets another disqualifying conviction, the waiver will automatically be revoked. Your documentation should be a print screen of the either the IDPH Health Care Worker Registry or Health Alert Network registry showing the Waiver status as "Granted."

  7. Do we need to add DSPs to the registry under our agency even if they are already listed under another agency as a DD Aide?

    About a year ago I was told that if a DSP is listed on the Healthcare Worker Registry (HCWR) as a DD Aide that we do not need to add them because it would be redundant. Can you please clarify our requirement? 

    If you hire a person who is already on the HCWR as a "DD Aide", you are still required to add your agency and the date of hire to the person's "Training and Work History" section on the IDPH Health Alert Network within 30 days. You would go into their existing record to do this; you would not enter them "from scratch" as that would create a duplicate record.

  8. If we do need to add them under our agency, what documentation do we need to retain in their file, as by adding them as a DD Aide it would be indicating that we trained them in the full 6 modules in addition to medication administration?

    For your documentation, do a "print screen", indicating a date that shows the employee was trained at another agency has the "DD Aide" designation on the HCWR under "Programs."

  9. Can agencies use PDF copies of background check print screens instead of paper copies for proof of background checks?

    Agencies may use electronic documentation as long as it can be made available to IDHS reviewers in a timely manner. This policy also applies to completed On-the-Job Training (OJT) documents.

  10. How do I get registered with Illinois Department of Public Aid (IDPA) Web Portal?

    This is the direct link to the IDPH Web Portal. Click on the "Register for a Portal Account" link and follow the instructions. Additional information on Enrolling with the IDPH Web Portal is on the DHS website at: http://www.dhs.state.il.us/page.aspx?item=48125 or by contacting the Illinois Department of Public Health, Health Care Registry toll-free number 1-844-789-3676.

  11. While reviewing the Web Portal instructions, I noticed that there are registry checks beyond what are required for IDHS: IL Department of Corrections Sex Registrant, Inmate Search, Wanted Fugitives and National Sex Offender Registry. When were these added? 

    The Health Care Worker Background Check Act, 225 ILCS 46/15) Sec. 15 states that the Illinois Department of Public Health or its designee request a fingerprint-based criminal history records check; and transmit that information electronically to the Department of Public Health; conducting Internet searches on certain web sites, including: The Illinois Sex Offender Registry, the Department of Corrections' Sex Offender Search Engine, the Department of Corrections' Inmate Search Engine, the Department of Corrections Wanted Fugitives Search Engine, the National Sex Offender Public Registry, and the website of the Health and Human Services Office of Inspector General to determine if the applicant has been adjudicated a sex offender, has been a prison inmate, or has committed Medicare or Medicaid fraud.

  12. What is a FEE_APP background Check?

    This is a background check that must be requested by a government entity, in this case Illinois Department of Public Health (IDPH). This type of request allows Illinois State Police (ISP) to store the fingerprints in their repository. With this type of background check any future convictions associated with a person's fingerprints will prompt the ISP to send a notification to IDPH. This means that the background check is always up-to-date With a FEE_APP background check, the applicant will never need another criminal background check as long as they stay active on the registry.

  13. A certified CNA on the HCWR has a Fee-App Criminal Background Check (fingerprint background check). How do I go about adding him to the Web Portal for our particular agency so that I can send him for fingerprinting and move forward with the hiring process?

    Because this person has a fingerprint Fee_App Criminal Background Check reported he does NOT need to be fingerprinted again. Once a Fee_App is reported, no further fingerprint criminal background checks are required. When hired, you add the person to the Web Portal screen that records your current employees. As a CNA, he only needs an Abbreviated DSP training.  After training is completed, report that completion to the HCWR through the DSP Training Registry Portal like any other DSP that completes training link.

  14. Do all approved Livescan Fingerprinting Vendors charge the same amount?

    No.

  15. Is there a special fee arrangement with approved Livescan vendors?

    No. Each vendor sets its own price, but it is specified in its contract with IDPH.

  16. Do I have to settle on one vendor or can I use more than one to allow for location flexibility for applicants?

    You have the flexibility to use whichever vendors you want, in whatever combination makes the most sense (money and geography-wise) for your agency.

  17. What happens if an applicant doesn't make it to the vendor to get fingerprints done within the 10-day working time period?

    The consequence for the applicant not getting their fingerprints taken within 10 working days after they signed the disclosure and authorization form is that the agency suspends the applicant from working with the individuals served. YOUR AGENCY SHOULD REISSUE THE APPOINTMENT AS SOON AS POSSIBLE.

    You will need to generate another Livescan form but the process is much easier the second time. Go to the applicant profile page, click on the underlined date that should take you to a screen where you select "click here" to generate a Livescan form with a current date.

    Note:  The worker is withdrawn from the IDPH web application if worker fails to have them collected within 30 days.

  18. Are they mandatory?

    Yes, when adding a new employee to the Web Portal; they are required by Illinois Department of Public Health (IDPH).

  19. When I run annual background checks on existing staff that were hired using name-based (UCIA) criminal checks before Web Portal access, they do not have to have FEE_APP checks run as long as they work continuously here at our agency?

    They do not have to get a fingerprint criminal background check, but they must have the annual HCWR, CANTS, and IL Sex Offender Registry clearances run and print screen of such readily available for review.

  20. Is a licensed Psychologist required to have a CANTS clearance due their professional license?

    Yes, he/she must have one and be cleared due to the CILA's contract with DHS.

  21. What does CAAPP on the HAN refer to?

    It stands for "Criminal Activity Applicant". It can mean that there has been criminal activity since the FEE_APP. However, it can sometimes mean that IDPH had to add a FEE_APP to someone's profile on the HCWR and this can only be added as a CAAPP, even when there has not been any new criminal activity. So you need to look carefully at the profile to make sure there are no new convictions added or waivers revoked.  The CAAP designation was originally designed to indicate that there had been new criminal activity; however, that is not always the case. If Providers see a CAAPP designation for an employee, they should check the IDPH Web Portal to make sure their record does not display a "red flag" indicating a disqualifying conviction.

  22. DSP is on the HCWR and receives a hit at a later date. IDPH will notify the agency that has listed the employee as working at their agency. What if they work at 2 or more agencies?

    Any agency that has a Hire Date for that person will get notified. When they enter the Last Day Date, that facility is no longer notified via emails.

  23. What do I do if the applicant's fingerprints are rejected?

    Fingerprints reject either because they were not collected correctly or - and more likely - because the fingerprint ridges are not defined well enough to get a clear print. Many times fingerprints are processed the second time even when they rejected the first time, so they are done twice.

    • Rejected Once:Fingerprints that are rejected once must to be collected again. The applicant must take a copy of the email sent to the facility back to the same Livescan vendor (along with another copy of the Livescan request form) so that the application will not be charged the vendor's fee again. A $10 fee must be collected by the vendor to pay the Illinois State Police. They will not waive this fee but it is reduced from the original State police charge. If the applicant goes to a different Livescan vendor that vendor is allowed to charge the full price.
    • Rejected Twice:If the fingerprints are rejected by the Department of State Police a second time, the employer shall conduct a complete name-based (called UCIA); criminal history records check through the Department of State Police and mail a copy of the results of the background check to the Registry within 10 working days after receipt. The results of the UCIA criminal history records check shall have been issued by the Department of State Police no earlier than 31 days prior to hire. A UCIA name- based criminal history records check may be used only when there is proof that the individual's fingerprints have been rejected twice by the Department of State Police within the previous 12 months.
  24. If I hire a Certified Nursing Assistant (CNA), do they need to have a background check?

     CNA and Direct Support Person (DSP) training programs are required to conduct a FEE_APP fingerprint background check for any student that is not already on the Health Care Worker Registry with a FEE_APP background check. It does not matter how old or new a UCIA (name based) background check is; a new FEE_APP fingerprint background check is required.

  25. Where can my agency get fingerprints done?

    To do the fingerprint background check required by the Health Care Worker Background Check Act, agencies are required to use one of eleven (11) contracted vendors that are that are approved by IDPH. These vendors are set up to be able to send the electronic data files to the Illinois Department of Public Health. They assure that the background check is electronic from beginning to end.  A list of approved Livescan vendors can be found at: http://www.dhs.state.il.us/page.aspx?item=48125.

  26. My agency is a CILA and also has a DT. Are all staff that work within the agency from janitors, maintenance, receptionist and up required to have fingerprints?

    Your agency meets the definition of "Health care employer" under the Health Care Worker Background Check Act (225Â ILCSÂ 46/) as it is a provider of CILA and DT services. The Act specifically applies to individuals employed by health care employers as home health care aides, nurse aides, personal care assistants, private duty nurse aides, day training personnel, or persons working in any similar health-related occupation where the person provides direct care or has access to residents or their living quarters or financial, medical, or personal records. Beyond those occupying direct care positions, Section 10 of the HCWBC Act extends the applicability of the Act to ALL employees of Health care employers who have or may have contact with residents or access to the living quarters or the financial, medical, or personal records of residents.

  27. What background checks are now required annually for QIDPs working in a Home Based Waiver for people with developmental disabilities?

    All employees, regardless of job duties or title, must have 3 checks completed annually are: Health Care Worker Registry, Illinois Sex Offender Registry and DCFS CANTS.

  28. If someone has a criminal background from Wisconsin or any other state for that matter, will the IDPH Waiver Application assist them?

    If a person has a conviction in another state they still need a FEE_APP background for Illinois. Then on the waiver application it will ask if they have been convicted in another state. The waiver would be granted/denied based on that information.

  29. I do the background on all temporary workers at my agency. My question is about the "history" or "Work history" on the Web Portal. Do I add temps as "employees" (which they are not)?

    After checking with IDPH, temps are considered to be employees. You will need to add the 'temps' when hired and then remove them when they terminate as you would any regular employees by entering the last day date on the Web Portal screen. This will ensure you are notified immediately by email if they have a disqualifying conviction reported to Health Care Worker Registry.

  30. I am in the process of doing my annual DCFS Central Register/Child Abuse and Neglect Tracking System (CANTS) Background Checks on all of our employees. Last year we had an employee have a positive finding and we went through the Waiver Process. She was awarded a Waiver and is still an employee of ours. I assume it will come back again this year as a positive finding. So since we got the Waiver for her last year do I have to do anything for her this year or does the Waiver stand until the finding is gone?

    The waiver is finding specific and expires at the end of the Retention period reported on the "CANTS Background Check Information Form". You are still required to send annually another CANTS form to DCFS for such persons. If it is returned with only the previously reported finding, then another waiver is NOT needed. If it is a different finding, then another waiver would be required if your agency opted to pursue one.

  31. I have a question in regard to a new Illinois law on "Ban the Box." One of the exceptions for asking applicants about prior criminal convictions are employers subject to state or federal laws that require applicants with certain criminal convictions be excluded. I'm thinking that we should be able to continue to ask this question on our application?

    On Oct. 3, 2013, the Governor signed an executive order providing that applicants with a criminal record would no longer be asked about their criminal past when they apply for state jobs. The governor's order doesn't apply to private employers who are still free to inquire about criminal history on job applications. It is suggested that you also consult with your agency's legal staff about the "Ban the Box" law.

CPR/First Aid

  1. Are American Heart Association accredited online courses acceptable for use as refresher courses where a DSP's classroom-earned First Aid or CPR credential has expired?

    Completion of the online AHA Heartsaver CPR-AED course is only one part of a two part training for the certification that is required. The second part that is required by AHA is to demonstrate skills in front of an instructor. These two parts must be completed before the AHA would certify the person in CPR and First Aid. The requirement is that DSPs be certified in CPR and First Aid; therefore completion of ONLY the online course would not meet DHS training requirements for DSPs.

  2. What is the policy for DSPs encountering an emergency situation where CPR seems to be in order but the consumer either has a DNR or it is not known whether the person has a DNR order?

    If an individual is in need of emergency CPR and the staff is not aware of any DNR order, then emergency aid should be rendered. If it is known that there is a DNR, then it is appropriate for staff to wait for emergency personnel. The main point is that staff should not wait to perform emergency procedures while "checking on the DNR status" of the individual. The staff will not be held accountable for rendering aid to an individual with a DNR, but if they DO NOT render aid to someone who DOES NOT have a DNR, then it would be a problem.

  3. If a DSP American Red Cross CPR/First Aid Card expires on November 17, do we have until the end of November to get the DSP recertified?

    Certifications do not extend to the end of the month in any circumstance for American Red Cross certifications.

  4. We received a CPR card from a new employee. It is not American Red Cross or American Heart Association. Can this card be accepted?

    The Division's policy is that we accept only CPR/First Aid certifications through the American Heart Association or American Red Cross or the person holds a current certification as an Emergency Medical Technician (EMT).

Education

  1. Recently I had an interview with an applicant who explained to me that they could not find their HS diploma and contacting the school would be impossible. They told me they received an Associate in General Studies and could provide that as proof of education. I have had conflicting information in regards to accepting an associate's degree due to colleges not verifying HS education. This is the first time I have been approached with an Associate Degree and I want to make sure this would be acceptable for proof of education for a DSP?

    A DSP with an Associate's Degree, but no high school diploma, does meet the DSP educational qualifications (for DSPs who will be passing meds or working in DT facilities). Be sure there is a copy of the Associates Degree or diploma in the DSP's personnel file.

  2. We are working on the verification of a foreign degree for one of our employees. However, the DHS web site lists multiple agencies and I've heard that some are better than others. Can you recommend an agency or agencies that you know BQM accept?

    We cannot recommend specific vendors. We accept the foreign education evaluations of any NACES member. They are identified on their web site at: http://www.naces.org/members.html.  Providers or the prospective employees can make their own choice among the NACES member providers based on the factors important to them, cost, submittal requirements, turnaround time, etc.  If educational degrees need to also be translated, then any of the four vendors listed on the DHS web site at: http://www.dhs.state.il.us/page.aspx?item=59198 are acceptable vendors for translating foreign transcripts into English and evaluating them for U.S. grade or degree equivalency.

  3. Would someone who successfully completed the McGraw-Hill developed high school equivalency test (called the TASC-Test Assessing Secondary Completion) be recognized as having a GED in Illinois?

    If an individual takes the TASC in another state, passes and is issued a GED credential in that state, the person is recognized in Illinois as having a high school diploma equivalency (GED). However, if the person takes the test in another state and passes, then moves to Illinois without having a GED credential issued by that state, Illinois does not recognize the test scores as a GED. In other words, Illinois will not allow the person to bring their test scores here for credentialing. Illinois only issues a GED credential based upon the GED test developed by GED Testing Services.

  4. TASC is not recognized in Illinois, unless the test is taken in another state and they have issued a GED credential?

    Your understanding is correct. Illinois only issues a GED to persons passing the GED test developed by GED Testing Services but recognizes GED credentialing of other states.

  5. Does a home schooling high school diploma satisfy the high school diploma requirement for the DSP?

    Under Illinois law, a parent (or guardian) is the sole determiner as to whether their child or children have met the graduation requirements of their private home school and are entitled to receive a high school diploma.

  6. I have an applicant and I am trying to verify High School Diploma or GED for a DSP position. The applicant states that she went to an American School on a military base in Germany. The military base is no longer standing in Europe. Where would I find verification of High School Diploma?

    The Department Of Defense web site should be helpful. Student records and transcripts may be requested from several different sources, depending upon the student's last date of attendance or graduation date. She will need to identify the source based on her situation.

Human Rights Issues

  1. Does a person need a behavior plan if they are on psychotropic medication, even if they do not pose a threat to themselves or others?

    The use of medications to address psychiatric/mental illnesses and undesired behaviors is included within the Rights Restriction section of the Adults with Developmental Disabilities Waiver and is considered "restrictive" and subject to all the requirements for use of restrictive interventions. A separate behavior plan is typically the method that most agencies use for documenting efforts to address the behavioral symptoms and the agency's efforts to reduce reliance on the restrictive intervention. However, a separate behavior plan is not required by the waiver. The plan could be a part of the Individual Service Plan (ISP). Because the use of psychotropic medications is considered to be a restrictive intervention, the service planning team must always consider positive strategies, ensure that the lowest effective dosage is used, and incorporate strategies to reduce the need for medications. For example, teaching coping strategies, counseling, etc. can help minimize symptoms and reduce reliance of medication.

  2. What about a person receiving DT services, where medication is not administered at the DT site and problem behaviors are not usually seen at the DT site?

    Day Training (DT) programs and psychotropic medications: it is the expectation that even if the DT program does not administer the medication, the systemic nature of the medication means that the person is never "free" of the restrictive intervention, so these must be reviewed by the agency Human Rights Committee. DT programs may not see the maladaptive behavior on a regular basis but still need to be prepared to respond in an appropriate manner, be aware of occurrence to assist the residential program in documenting the frequency, and may have a role in teaching adaptive skills needed to reduce the long-term need for medications.

  3. Do medical devices, such as a gait belt, need to go through the Human Rights Committee (HRC) since they are medical devices?

    There's really not a great deal in writing within the code/rules about rights restrictions as related to "restraint". Basically, anything that restricts someone's movements would be considered a restraint. It always becomes a bit cloudy when that "restriction" is due to safety reasons. This type of restriction should always be considered from the perspective of balancing the rights of the person with his/her safety needs. Because safety devices may be over-used and encroach on rights, it's in the best interest of the agency and the person receiving services to ensure a review by HRC so that they can ensure the right balance has been achieved.

  4. Is use of video monitoring in common areas of the home considered to be a rights restriction?

    Yes, use of a video camera is considered to be a restriction and needs to be mentioned in the individuals' ISP. Rights restrictions to all individuals and/or guardians would also need to be issued and need to be reviewed by the individual/guardian and HRC on an annual basis. In most cases the video monitoring is put in place for monitoring of interactions by staff, however, if the electronic monitoring is being done because of the behavioral issues for one or more individuals, you would need to be sure that behavioral programming is in place as well.

  5. We have someone that has aged from child to adult services.  The guardian requests that there continues to be daily body chart checks to check for bruising, marks, etc. Is this a restriction of rights that needs to be reviewed by the HRC?

    Such a check is intrusive and would need review by HRC. Also, the reasoning for such checks should be something more than "guardian request" if at all possible. The guardian must have a reason for being concerned. It would be prudent to keep data on a daily basis regarding the results of these checks. The data could then be periodically reviewed to determine if such intrusion is actually resulting in discovered injuries or not. If no significant findings are noted after several months, a gradual fading of the frequency of checks could be considered along with teaching the person to communicate injuries. If this person needs assistance with bathing or dressing, the check could be done at those times in an effort to make the process as unobtrusive as possible.

  6. The rules require 1/3 of the committee not be associated with the provider. Does that include persons such as Independent Service Coordination (ISC), DT providers outside of the agency (persons not on payroll but familiar with the provider and the DD population?) Are they allowed to be on the committee and be counted as that 1/3?

    Providers that serve individuals that are also served by your agency are considered to be "associated". Independent Service Coordination (ISC) representatives, Day Training (DT) providers and others who serve persons with intellectual disability but not persons served by your agency would be considered to be unassociated.

  7. How do we handle issues of confidentiality at our HRC meetings?

    Members of the HRC should receive training on confidentiality; perhaps even sign an agency developed 'contract' of sorts, indicating that they understand their responsibility in keeping matters confidential. This can be a very simple document which your agency can develop. Also, documents with personal information regarding medications, behavioral issues, medical conditions, etc., that are used at the meetings should not convey names, social security numbers, etc. Use initials and or case numbers for the meeting paperwork. Members should also be trained to leave all paperwork in the meeting room and then disposed of properly.

  8. A great concern is about the need for a behavior program when someone has "marginal" behaviors. The need for the behavior plan was addressed by the IDT and authorized there. The individual engages in property destruction, occasional physical aggression, and is on psychotropic medications. Since the maladaptive score on the person's ICAP was marginal, could a program goal addressing behavior suffice instead of a full blown BIP? Is this an option?

    Yes. Addressing maladaptive behaviors through a positive programming goal is acceptable. There is no specific requirement that a separate behavior intervention program be developed. Certainly all problem behaviors, and the strategies that are used to change those behaviors, should be included within the service plan. However, there is no prescribed manner about how to address such issues. Many providers chose to develop a separate BIP but that is not required. If you use a program goal to address inappropriate/undesired behaviors which are of low frequency or low severity, you just need to ensure that the reason for the program goal is clearly stated within the service plan so that a clear link to the problem behavior is established.

  9. My understanding is that if an individual is on psychotropic medications to control maladaptive behaviors, there is to be a behavior plan that includes a medication reduction plan, unless the prescribing physician indicates that there is no need for a behavior plan?

    The use of psychotropic medication is considered to be a restrictive intervention. As such, the service planning team must always consider positive strategies, ensure that the lowest effective dosage is used, and incorporate strategies to reduce the need for medications. Those plans must be reviewed by the provider's Human Rights Committee. Again, these may be included within the service plan or in a separate behavior intervention program.

  10. Does there have to be a psychologist as a member of the Human Rights Committee?

    A psychologist is NOT required to be on the Human Rights Committee.

  11. If an issue is brought to the attention of the Human Rights Committee for review about a potential rights violation and they vote as a Committee that it is indeed a rights violation, what are the next steps? Does the Committee need to report this to any outside agency? Or is it something that we address internally?

    Issues that are viewed as abuse or neglect should be reported to OIG. Otherwise, you would handle the issue within your agency. It's important to keep in mind that HRC will often find that interventions and actions are restrictive (i.e. a "rights restriction"). That, alone, isn't a problem. There is nothing within DD rules that automatically prohibits restrictive interventions. Requirements:

    • An effort to use the least restrictive methods possible
    • An effort to reduce reliance on restrictive methods through positive training
    • At least annual review of the restriction by HRC

    Thus, HRC's role isn't just to identify rights restrictions but to ensure that required protections are in place to reduce the need to use restrictive interventions. When such protections are not in place, HRC would take action within the agency to stop the use of the restrictive measure until protections/safeguards are in place. That's usually handled pretty easily based on the authority given to HRC by the agency's leadership.

    If, for some reason, the HRC is unable to resolve the issue internally and/or is unable to secure cooperation of the agency's leadership, the committee or individual members can report the concerns to the Division or to The Human Rights Authority.

  12. Our company discussed concerns for food in resident's bedrooms given they are unsupervised and risk choking as well as sanitation concerns. It was discussed that this might be considered a part of the lease/rental agreement. If the resident agrees to it as a portion of that agreement, is it considered a rights restriction and in need of review and approval by all as well? This includes individuals who do not have a need for swallowing evaluation, but simply may "over stuff" and risk choking as well as those who may have swallow concerns getting it from roommates, etc.

    If "no food in bedrooms" is a policy for everyone, then documenting it as a policy and having the HRC review it annually (for all) would be sufficient. In such cases, the policy would need to be explained to individuals well in advance so that if it is a major concern, the person could look elsewhere for CILA services. Nonetheless, providers really need to consider "why" such blanket policies are implemented. Things that are simply for the convenience of the agency or "it's always been this way" really aren't fair to the individuals. Based on the description you gave, it sounds as if the policy won't be for all, just for those who are messy or need supervision while eating due to choking risks. In those cases, the individual needs should be addressed as part of the reason for the restriction and then measures included to teach needed skills so that, eventually, the restriction is no longer needed.

  13. I need clarification on rights restrictions for individuals living in a 24-hour CILA.  Is it against the individuals' rights to have their medication and money locked up? All individuals were deemed by the Nurse Trainer as unable to self-administer medication. The agency has been appointed as payee representative on all the persons living in the CILA and have to account for all money. We are wondering if these issues would need to be presented to the Human Rights Committee because these two issues are a restriction of their rights?

    The Division has never required HRC review for medications locked up for persons who are not independent in medication administration. This issue has not been discussed because of expectations of Rule 116 (that requires access to medications only for those who have been deemed independent in self-medication) prevail. No additional review by HRC is expected.  Specific information on Rule 116 regarding locked medications or self- administration of medication (Sections 116.60 and 116.80).  As the agency has been appointed as "payee", it has not been considered a restriction for the agency to receive and use funds on behalf of the individual. However, funds paid directly to the individual (paycheck, gifts, etc.) that are not freely accessed by the person would be considered a restriction and would require HRC approval. This would include the monthly allocation from SSI which is given to persons residing in CILAs. A restriction on the access to that money would constitute a rights restriction and would need HRC review and approval.

  14. We have several individuals that are on medications for seizures (Tegretol, Dilantin, Depakote, etc.). Do these need to be discussed at the HRC?

    "Psychotropic medication" means medication whose use for antipsychotic, antidepressant, antimanic, antianxiety, behavior modification or behavioral management purposes is listed in AMA Drug Evaluations, latest edition, or Physician's Desk Reference, latest edition or, ask the physician or pharmacist.

    The emphasis on medication classification means that all such medications must be treated as psychotropic even if prescribed for another purpose. For example, Klonopin (Clonazepam) is classified as an antianxiety medication, but can also be used for seizures.
    Additionally, a common error is to believe that psychotropic medications used to treat mental illness are exempt from the expectations regarding restrictive interventions. Based on the Adults with Developmental Disabilities waiver, ALL psychotropic medications are considered to be a restrictive intervention. This includes psychotropic medications that are used to address maladaptive behavior as well as medications used to treat mental illness.

Medication Administration

  1. We have a newly certified DSP who took the 8 hour Medication Administration training class before completing all the basic health & safety related OJTs. Should he retake the 8 hour Med Admin Training class before being authorized to pass medications by the RN Trainer?

    The section of Rule 116 that discusses this is: 116.40 c) 4). This is interpreted to mean that the Module 6 of the DSP curriculum (Basic Health and Safety) must be completed before taking the class on Medication Administration. This means that the trainee needs to repeat the 8-hour training course after completing the Basic Health and Safety course.

  2. What if the DSP doesn't get 80% or above on test?

    Administrative Code Section 116.40 Training and Authorized of Non-Licensed Staff by Nurse-Trainers states: "Any direct care staff person who fails to qualify as an authorized direct care staff after initial training and testing must, within three months, be given another opportunity for retraining and retesting. No employee shall be terminated for failure to qualify during the three month time period following initial testing."

  3. What if they fail a second time? 

    A direct care staff person who fails to meet criteria for delegated authority to administer medication, including, but not limited to, failure of the written test on two occasions, shall be given consideration for shift transfer or reassignment, if possible. Refusal to complete training and testing required by this Section may be grounds for immediate dismissal. [20 ILCS 1705/15.4(h)]

  4. I am a Nurse Trainer. One of the companies I am working for assists individuals with Disabilities in their home, or possibly foster homes. We currently only have one client who we have received approval from the state. Since I am a Nurse Trainer can I train the CNA hired to care for this person trained as a DSP?

    Your Nurse Trainer status does not give you the authority to teach DSPs other than for Medication Administration under Rule 116.

  5. Is it correct that no one can take the meds home on home visits, such as Mom, Grandma, Sister, Husband etc., unless they have been trained on how to administer the medications by the Nurse Trainer. I cannot seem to find anything in Rule 116 that says that directly, but I do have a side note that I had written during the class?

    Medications can go with the individual on a home visit if the Mom, Grandma, Sister, etc., take responsibility for safeguarding and administering the medication. It was never the intention of Rule 116 to prevent home visits. The medications have to remain in their original containers, which have the instructions for administration printed on the container, and be sent with the individual.
    Typically, the Medication Administration Record (MAR) remains at the agency and is marked by staff to indicate that the individual went on home visit. The staff cannot mark off that the individual has received the medication because they were not present when it was administered. Family training is not required in the common CILA situation. Family training takes place when an individual lives in a home with a family that is NOT their legally recognized family but rather a family that is caring for the individual. These are "Host families". Rule 116 applies there and the host family members that will be responsible for and administering the medications must be trained under Rule 116 which require being trained by an RN-Trainer.

  6. Does DHS require registered nurses to have first aid certification? That seems redundant.

     Nurses have, well within their scope of practice, First Aid training. Maintenance of their license indicates competency in First Aid.

  7. Does the American Heart Association's ACLS (Advanced Cardiovascular Life Support) Certification cover the CPR requirement?

    Yes, the ACLS will cover the requirement for CPR. For the first aid, you will have to take the Heartsaver First Aid course. To find a course near you, visit heart.org/findacourse.

  8. I am wondering whether the American Heart Association includes instruction (training) on the proper use of EpiPens in ALL its CPR trainings, only some of them or if a separate or other AHA course includes training on EpiPens?

    None of the AHA CPR classes offer training with an EpiPen.  See AHA Course Matrix to see everything offered in those trainings.

  9. I am inquiring about the specific requirements for DSP medication re-training. Can you please specify the re-training requirements?

    Rule 116.40(e) Training and Authorization of Non-Licensed Staff by Nurse-Trainers states: "Authorized direct care staff shall be re-evaluated by a nurse-trainer at least annually or more frequently at the discretion of the registered professional nurse. Any retraining shall be to the extent that is necessary to ensure competency of the authorized direct care staff to administer medication [20 ILCS 1705/15.4(c)], as judged by a nurse-trainer." Like the initial authorization, the annual reauthorization is also an individual-specific, evaluation by the nurse-trainer for each medication administered to each person supported by that staff. You must also maintain documentation of each reauthorization.

  10. There seems to be some confusion at out agency about medication administration for DSPs. Once a DSP is med trained, can they pass meds at any of our homes? Our nurse trainer says that they must only stay in the one home that they have been trained in?

    The DSP trainee must have successfully completed Basic Health and Safety OJT/CBTAs which are specific to the persons they will be working with. Please see Rule 116.40.  In addition, they must have successfully passed the Medication Administration Training. This training must be person specific and medication specific. In addition, the DSP must receive training for any new medication prescribed or any new individual moving in. For more specific information on this topic, please go to:

  11.  I'm the Regional Director for an agency in the Chicago area. I have a new RN that will be starting with us, and I'd like to get her into a class to be a Nurse Trainer (RN-T), but I couldn't find any upcoming classes on the website. Could you assist me with this?

    The Division of Developmental Disabilities can grant provisional status to the RN-Trainer that is new- she can supervise DSPs who are already trained in medication administration with provisional status, but cannot train new DSPs to become authorized until the class is taken. She also is ineligible to train on a new medication to anyone prior to becoming an RN-Trainer. Please see the IDHS web site for more course information at: http://www.dhs.state.il.us/page.aspx?item=45209.

Policy and Procedure

  1. Questions have been raised concerning use of gait belts or transfer belts. Is it correct that a doctor's order is necessary for the use of a gait belt with individuals receiving services?

    59 Ill. Admin Code 120.40 states: "Personal adaptive equipment shall be prescribed by a physician, or by a qualified health professional who meets State standards as an occupational therapist pursuant to the Illinois Occupational Therapy Practice Act [225 ILCS 75], physical therapist pursuant to the Illinois Physical Therapy Act [225 ILCS 90], or speech and language therapist pursuant to the Illinois Speech-Language Pathology and Audiology Practice Act [225 ILCS 110], as appropriate to the disability."

  2. Since each Agency is required to initiate a CANTS Background Check on the first day of paid status is there a turnaround time for results?

    No, there is not a standard turnaround time for An Authorization for Background Check Child Abuse and Neglect Tracking System (CANTS) Form 689. The DCFS form must be initiated but results don't have to be received before the employee begins work. Typically, results are returned within 2-3 weeks. When results are received, you must take appropriate action if there are any indications from DCFS.

  3. I was looking at the DHS website to try to find what the requirements are for someone to supervise DSP's but was having a hard time locating that information?

    There are no Department requirements for a supervisor of DSPs. It is most often a QIDP, but it can be House Manager, RN, Executive Director, or a more seasoned DSP. It is typically left to the discretion of the agency. We would recommend that the person have knowledge of DSP responsibilities and the skills needed to support properly a person with developmental disabilities.

  4. We completed fingerprint criminal background check, clearances, pre-employment physical, and drug screening on an applicant. The physical came back as not fit for the job due to high blood pressure. He received medical attention for the condition and is on medication, although the hospital through which we run our pre-employment exams would not release him until he had a regular physician and was stabilized on medication. He now has a regular physician, but is having difficulty getting stabilized. The hospital that does our physicals states all he needs to do is come in and have his blood pressure taken.  If it is stabilized, they will release him to work. He does not need a complete physical. Do I need to have a complete physical/drug screen to be compliant since it has been so long since he had the pre-screens completed?

    The Bureau of Quality Management only requires Livescan fingerprint criminal background checks and HCWR, CANTs, Illinois sex offender and Illinois OIG clearances but not physical exams and drug screenings. The Department of Public Health requires ICFsDD to do certain health screenings such as TB checks, etc. but if you are not an ICFDD, then it is up to your agency to determine whether to do another physical exam and drug screening on your job applicant.

  5. Questions are abounding regarding reporting requirements for our agency regarding 'concealed carry' and whether we may be exempt. Can you help us with this?

    Here is the guidance I received. As developmental disability facilities and services (e.g., CILA, DT), typically referred to as "Habilitation", are not clearly identified in Public Act 98-63 (Concealed Carry law), these providers do not have a reporting requirement. Only physicians, licensed Clinical Psychologists and other Qualified Examiners as defined in the law have a reporting requirement.

  6. I am trying to find out how long we need to keep old OJT packets on file once an employee has left our agency. We are running out of space?

    Providers under contract to DHS must keep the training records we require for 6 years if the documents contain Protected Health Information (PHI) covered by HIPAA. If the documents contain no HIPAA info, then the retention period is 5 years from the date the person for which the record is created leaves the provider's employ or the agency closes, etc. Records have to be kept as long as the employee is an active employee. Providers can only dispose of closed records meeting the appropriate retention period regardless whether the records are paper or electronic copies.

  7. What is "PHI"?

    PHI is health information about a person held by health care providers (includes CILAs) and health plans. This includes: patient's medical record number, demographic information, images of the person, conversations a doctor has about care or treatment with nurses and others, information in a doctor's computer system or a health insurer's computer system, billing information about a patient at a clinic.PHI is any health information that can lead to the identity of an person or with which the information can be used to make a reasonable assumption as to the identity of the individual.  Providers can scan documents and then keep only the electronic (scanned) version of the document as long as the agency can assure that the electronic documents are retrievable (backed up) and can readily accessed in case of a review until the appropriate retention period expires.

Test of Reading Comprehension

  1. What is the most recent policy regarding DSPs taking the TABE Test? I went through training years ago to give the test, but can't remember how many times a staff member is allowed to take the Test of Adult Basic Education (TABE) test, and if/when the test can be given un-timed, etc. Also, we have had some recent staff changes at our organization and wondered if staff must still go through DHS training in order to administer the test?

    The policy on retesting using the TABE test is: If an individual scores below an 8th grade reading Level on the TABE test, the test cannot be re-administered for six months unless a different test book is used. For example, if you administer TABE 10 the first time, you could retest using TABE 9 within a few days. (or use TABE 7 and 8 if you still have the older versions too.) However, if the testee doesn't test out at an 8th grade reading level on different test(s), he/she would need to wait 6 months to retake the test. McGraw Hill allows two categories of accommodation for students having a formal diagnosis of a learning disability from a qualified professional that do not affect the validity of the test.

    • Category 1: Students may take the test alone or in a study carrel/cubicle.
    • Category 2: Students may use extra time when taking the test.

    These policies are published in the Computer-Based Learning (CBL) Module entitled "How to Administer Tests of Adult Basic Education Training TABE Reading Test."

  2. Our agency Human Resources Department asked if there is an "expiration" date on TABE tests. They have a candidate who took & passed the TABE in January, 2015, and is just now being considered for employment. Do they need to administer a new TABE?

    There is no expiration. All that is needed is the "original" test to document a passing score.

  3. Must I use the complete battery of the TABE when testing an employee? 

    The content areas that can be measured by the TABE tests are reading, language, mathematics, and spelling. Community agencies are only required to test staff on the reading component of TABE when conducting the test.

  4. The scoring sheets for the TABE test are very expensive. Can our agency just use Xeroxed copies?

    The content areas that can be measured by the TABE tests are reading, language, mathematics, and spelling. Community agencies are only required to test staff on the reading component of TABE when conducting the test.

    There are two types of answer sheets for scoring the TABE test: SCOREZE and COMPUSCAN.

    Your agency can decide which one use. However, if you don't use an original of one of these TABE test score sheets, the test will not be considered legitimate. 

  5. How do I document reading at an 8th Grade level?

    8th grade reading level determined by the Test for Adult Basic Education (TABE), Adult Basic Literacy Examination (ABLE) or Comprehensive Adult Student Assessment System (CASAS). The original test score sheet must be properly completed and document an 8th grade or higher reading score.

  6. Can I use an online reading test to document reading level at 8th grade?

    Online TABE, ABLE or CASAS reading tests are also acceptable verification of 8th grade education or functional literacy if the following conditions are met:

    • Online testing is supervised and test results are documented in the DSP's personnel or training file or other location accessible to Department staff.
    • Reading scores are printed from their respective web sites (TABE, ABLE or CASAS).
    • The printed test score is accompanied by a signed statement from a supervisor of the online test verifying the person for whom the score is printed actually the person who completed the test.
    • The signed statement identifies supervisor's position in the agency that employs the person or supervisor's relationship to the organization.
  7. Do staff that have an educational level above high school need to take the TABE test if they are going to administer medications only in an emergency situation?

    Yes.

  8. If a DSP fails the TABE twice after retraining can they be terminated if reassignment or transfer is not an option within the agency?

    The medication administration legislation (Rule 116.40) "direct care staff who fails to qualify for competency to administer medications shall be given additional education and testing to meet criteria for delegation authority to administer medications. Any direct care staff person who fails to qualify as an authorized direct care staff after initial training and testing must, within three months, be given another opportunity for retraining and retesting. No employee shall be terminated for failure to qualify during the three month time period following initial testing. Refusal to complete training and testing required by this Section may be grounds for immediate dismissal."

Training

  1. Who has to complete an approved DSP training program?

    Those individuals working in adult DD settings (e.g., DT, CILA, ICFs/DD) who provide direct support 20% or more of their time. Direct support may include:

    • Activities of daily living
    • Implementing behavior support plans
    • Documenting in individual records
    • Recognizing and supporting basic health and safety as well as assisting with medical needs of the individual.
  2. Do I need to submit resumes for individuals who evaluate OJTs?

    No. The Checklist I is for individuals who want to be classroom instructors.

  3. Do we need to have a written test for each of the DSP Training Modules?

    No.You need to tell IDHS how you are evaluating the informational competencies for each module. Most agencies choose to provide a written assessment (test/quiz) to evaluate knowledge of Informational Competencies.

  4. We hired some Certified Nursing Assistants (CNAs) to work as DSPs. Will they need to complete the 120 hours of DSP training?

    Certified Nurse Assistants (CNA), Licensed Practical Nurses (LPN) and registered Nurses (RN) that are hired to function as a Direct Support Persons (DSPs) may be added to the Health Care Worker Registry as DD Aides if they have:

    • Completed CPR and First Aid training (6 hours) or can document current certification in each. Trainees certified as an Emergency Medical Technician (EMT) via the Illinois Department of Public Health or National Registry of Emergency Medical Technicians meet CPR and First Aid training requirements.
    • Completed Abuse, Neglect & Exploitation Prevention, Recognition & Intervention classroom training (3 hours) and on-the-job activities (5 hours).
    • Demonstrated competency in all areas listed in the DSP Training Program Core Competency Area Checklist, or DSP Training Program: Core Competency Verification Form, or listed as DSP Required Classroom Competencies and DSP Required OJT Competencies.
    • Results of an Illinois State Police name-based or fingerprint criminal background check reported to the Health Care Worker Registry.
    • Have their name cleared by the Illinois Department of Children and Family Services (DCFS) Children Abuse and Neglect Tracking System (CANTS), Illinois Sex Offender o Registry and HFS OIG Sanction List.
  5.  Some of our QIDPs serve in DSP roles 20% or more of the time. Do they need to have DSP training?

    Individuals listed on the state QIDP-Eligible Registry who have completed a DHS-approved 40-hour QIDP training program and spend 20% or more of their time providing direct support to persons with developmental disabilities may be added to the Health Care Worker Registry as a DD Aide (DSP) IF they:

    • Complete a 49-hour abbreviated DSP training program consisting of the following components of a DHS-approved DSP training program.
    • CPR and First Aid training, must document current certification. Certification as an Emergency Medical Technician (EMT): 6 hours.
    • Abuse, Neglect & Exploitation Prevention, Recognition & Intervention: 3 hours of classroom training and 5 hours of on-the-job training.
    • Basic Health and Safety: 15 hours of classroom and 20 hours of on-the-job training.
    • Competency Area Checklist, or listed as DSP Required Classroom Competencies and DSP Required OJT Competencies. The DSP Training Program Core Competency Area Checklist (pdf) (IL462-1286) or DSP Training Core Competency Verification Form (pdf) (IL462-1288).
    • Forms must be completed and signed to document competencies have been demonstrated to the employing agency. Either form may be used to document the QIDP has demonstrated competency in all DSP areas.
    • Have their abbreviated DSP training reported to the Health Care Worker Registry (HCWR) within 30 days of its completion to be designated as a "DD Aide" on the Health Care Worker Registry. See Illinois Health Care Worker Registry Instruction Manual (pdf).
    • Have the required results of all required registry and criminal fingerprint background checks, clearance through the DCFS Children Abuse and Neglect Tracking System (CANTS), Illinois Sex Offender Registry and HFS OIG Sanctions List.
  6. How long do providers have to complete DSP training?

    A DSP training program must be completed within 120 days of hire, or for current employees 120 days from the date they are assigned DSP responsibilities.

  7. What should agencies do if training OJTs are not applicable to the persons served at that agency?

    The OJT activities must cover the 81 interventional competencies that can be found in the DSP Training Program Approved On-the-Job Training (OJT) Activities and Competency-Based Training Assessments (CBTAs).

    • Each of competencies listed on these pages show the OJT/CBTA(s) that cover the training for that competency.
    • You can eliminate OJTs that are not applicable to the person(s) supported by your DSPs.
    • You do not need to sign off on eliminated ones as long as the competency is covered by another OJT. N
    • Note: OJTs 7, 13, 30, 37, 38, 39 cover a core competency that is not trained in any other OJT and therefore, cannot be eliminated, but can be modified, with Division of DD approval.
    • There is a blank template in the packet that can be used by agencies to design or modify any of the OJTs to better meet the needs of the individuals they serve.
  8. Can you blend classroom and online training?

    The SIUC online classroom curriculum is structured exactly like the DHS-approved curriculum. For that reason, providers using that online curriculum may blend online and instructor-led classroom curricula for DSPs to meet the 40 hour DSP classroom training requirement. However, The College of Direct Support and Relias Learning online classroom curricula are NOT structured like the DHS-approved curriculum. For that reason, Providers may NOT mix online and instructor-led classroom curricula for DSPs to meet the 40 hour DSP classroom training requirement. The College of Direct Support and Relias Learning online curricula must be used in their entirety.

  9. Do I complete both the Core Competency Verification form and the Core Competency Checklist, or just do one of them?

    You are only required to complete only one of these forms.

  10. When we hire new staff and they are already on the HealthCare Worker Registry we assess them using the Core Competency Area Checklist which then goes in the individual training file for when DHS surveys the agency. In it, it shows that the new staff is competent in those areas. If we switch to the Core Competency Verification- Summary Table how can we assess the new staff coming into the agency that are already in the Healthcare Registry? And what goes in their file for DHS review?

    There are no specific DSP retraining requirements or training program for persons in this situation. However, the employing agency must ensure that:

  11. A person was trained at our agency as a DSP and training completion was submitted to Southern Illinois University but it is not showing up on the HCWR. What should I do?

    If the employee's name and/or Social Security Number (SSN) used for the Criminal Background Check (CBC) were NOT REPORTED CORRECTLY to the HCWR, Providers must take the following actions depending on whether it has access to the IDPH Web Portal:

  12. Are there any guidelines of what needs to be included in the classroom assessment? Does it need to be approved by IDHS at all?

    Classroom assessments are used to determine the trainee's understanding of the Informational Competencies . These competencies can be used as a guide from when developing the assessment questions.  The assessment does not need to be approved by IDHS.

  13. Can DSP Instructors Train DSPs at a different site using Skype or videos?

    This type of training is approved with the following caveats:

    • Competencies would still be assessed objectively through testing.
    • Skype (or video) training would be limited to the Informational (Classroom) information.
    • DSP instructors would ensure trainees' questions are not inhibited by this process.
    • Instructors would ensure there is interaction with the trainees during classes so the process does not rely exclusively on testing for assessing progress and understanding.
  14. Must CNAs working in SNF/PEDs serving children with developmental disabilities complete the abbreviated DSP training and be designated as DD Aide on the HealthCare Worker Registry (HCWR)?

    No. It is optional. CNAs can support developmentally disabled children in SNF/PEDs without having to complete the additional, abbreviated Direct Support Person training program and be added to the Health Care Worker Registry as a DD Aide.

  15. Do bus drivers need to complete DSP training before they can be alone with an individual?

    No. community services contractual language provides for exemptions to the Direct Support Persons (DSP) training requirements which include being left alone with the individuals. These exemptions include respite workers, job coaches, secretaries, and other support staff. The Division includes bus drivers in the "other support staff" category. Bus drivers are therefore not required to complete DSP training. However, should an individual require programming during transportation (to and from developmental training, for example), these needs must be documented and addressed by the individual's service plan.

  16. What are the training and background check requirements for volunteers?

    Volunteers will need Rule 50 training on abuse and neglect.  The Health Care Worker Background Check Act (225 ILCS 46/70) specifically excludes physicians and volunteers from being required to have a fingerprint background check or clearance. Nonetheless, it is strongly recommended that providers run a clearance from the HCWR, DCFS State Central Register (CANTS), Illinois Sex Offender and HFS OIG Sanction List. Also, CILA Rule 115.320(e) delineates "Volunteer training" requirements: "The agency shall provide an orientation and training program for volunteers specific to volunteer duties and shall provide supervision as necessary.

  17. Can Training Period Be Extended for Part-Time Staff?

    The 120 day training period applies; however, we understand the difficulty in meeting this requirement in training part time DSPs. If the agency makes a concerted effort to complete training of part time DSP as soon after the 120 days as possible, we would likely waive that requirement. Depending on the particulars of each situation and the time span taken to complete the training, additional refresher training may be required.  Please see Waiver Form IL462-1291.  For additional information, please see DSP Waiver Request for Delay in Meeting Training Requirements.

  18. What trainings are required for DSP's on an annual basis?

    The Completion of OIG Rule 50 Training is required for all provider employees, including DSPs, at the time of hire and every two years thereafter.DSPs must also remain current with their CPR/First Aid certification.

  19. How long are training records required to be kept after the employee leaves?

    Providers under contract to IDHS must keep the training records we require for 6 years if the documents contain Protected Health Information (PHI) covered by HIPAA. If the documents contain no HIPAA info, then the retention period is 5 years from the date the person for which the record is created leaves the provider's employ or the agency closes, etc. Records have to be kept as long as the employee is an active employee. Providers can only dispose of closed records meeting the appropriate retention period regardless whether the records are paper or electronic copies.

  20. What is "PHI"?

    "Personal Health Information" is health information about a patient/consumer held by health care providers (includes CILAs) and health plans. This includes things like:

    • Patient's medical record number
    • Patient's demographic information (e.g. address, telephone number)
    • Information doctors, nurses, other health care providers put in a patient's medical record
    • Images of the patient
    • Conversations a doctor has about a patient's care or treatment with nurses and others
    • Information about a patient in a doctor's computer system or a health insurer's computer system Billing information about a patient at a clinic.
    • Thinking about it another way, PHI is any health information that can lead to the identity of an individual or the contents of the information can be used to make a reasonable assumption as to the identity of the individual.
  21. I know that IDHS will accept American Heart and Red Cross CPR and First Aid, but are there any online courses that are acceptable?

    Both American Heart Association and American Red Cross offer classroom or blended learning (online and classroom) for certification and recertification. Neither offers a strictly online class for certification/recertification. IN ALL CASES, HANDS-ON DEMOSTRATION OF THE PROPER CPR TECHNIQUE FACE-TO-FACE WITH AN ARC OR AHA INSTRUCTOR IS REQUIRED BEFORE CERTIFICAION/RECERTIFICATION.

  22. I have a question regarding the Direct Support Person Training Program: Core Competency Verification form. At the bottom there is a place for Signature of Executive Director or Designee. Who can the Designee be and how do we make that official?

    It would be up to your agency's Executive Director to decide who to give signature authority to. A logical choice for signing DSP training documents on his or her behalf would be the DSP Course Coordinator or DSP Instructor. As far as making it official, hopefully anyone reviewing documentation would assume that if the signatory was not the executive director, that they had been granted signature authority either verbally or in writing.

  23. Once a person is DSP trained, are they DSP certified forever or do they have to go through training again if they left the social service agency, worked in another field and then returned say after five years?

    Per the DHS Training Requirements Manual at http://www.dhs.state.il.us/page.aspx?item=64992, there are no specific DSP retraining requirements. However, your agency must ensure that:

    • DSPs have the required results of all required registry clearances and criminal fingerprint background checks http://www.dhs.state.il.us/page.aspx?item=48125
    • OIG Rule 50/Abuse Neglect training within 10 working days of first day of paid status. Current certification in CPR and First Aid training or current certification as an Emergency Medical Technician (EMT).
    • Depending on types of consumers served in previously, types of consumers to be served now, and the length of time the DSP was working in a different field.
    • It is recommended that you confirm the DSP can demonstrate competency in each area of the DSP Training Program Core Competency Area Checklist or all competencies listed as DSP Required Classroom Competencies http://www.dhs.state.il.us/page.aspx?item=59139 and DSP Required OJT Competencies http://www.dhs.state.il.us/page.aspx?item=59175.
    • If you decide that this DSP and the individuals the DSP will be supporting would benefit from retraining the DSP curriculum, your agency would qualify for training reimbursement as more than 5 years have elapsed since the initial training. 
  24. Is there any procedure for an employee who has experience working with people with disabilities out-of-state to be approved as a DSP without going through the Illinois DSP training?

    Unfortunately, there is no procedure for people with experience working as a direct support person in another state to be approved as a DSP without going through the Illinois DSP training, even if another state credentialed them as meeting that state's training requirements for direct support. Illinois requires DSPs to be trained in the areas and competencies it requires before a person's DSP training credentials can be added to their Illinois Health Care Worker Registry record.

  25. Does the DSP course section on "Vital Signs & Symptoms" need to be taught by an RN or can any person who is certified as an instructor teach it?

    Persons certified by our office as a DSP instructor are qualified to teach all classroom curriculum modules including Vital Signs & Symptoms. To qualify as an instructor shall meet at least one of the following criteria as listed on Checklist I:

    • Qualified QIDP
    • Listed on the IDHS QIDP-eligible database registry maintained by the Division of Developmental Disabilities
    • Completed a Division-approved 40-hour QIDP Basic Orientation training program
    • Have a valid Illinois teaching certificate with at least one year of experience with DD.
    • A community college or college instructor with at least one year of verified teaching experience and familiarity with DD.

    Special Content Instructors must be:

    • Qualified QIDP
    • Listed on the IDHS QIDP-eligible database registry maintained by the Division of Developmental Disabilities
    • Complete a Division-approved 40-hour QIDP Basic Orientation training program
    • Have a valid Illinois teaching certificate with at least one year of experience with DD.
    • A community college or college instructor with at least one year of verified teaching experience and familiarity with DD.

    Special Content Instructors must:

    • Qualified QIDP
    • Listed on the IDHS QIDP-eligible database registry maintained by the Division of Developmental Disabilities
    • Completed a Division-approved 40-hour QIDP Basic Orientation training program
    • Have a valid Illinois teaching certificate with at least one year of experience with DD.
    • A community college or college instructor with at least one year of verified teaching experience and familiarity with DD.
    • Special Content Instructors must:
      • Submit a resume verifying qualifications of the person teaching the special content area
      • Have at least one year of experience in the field of developmental disabilities
      • List field of expertise in which they will teach (e.g., RN teaching medically-related competencies or safety inspector teaching environmental health and safety competencies).
  26. I have a new agency and want to have an approved DSP training program, but I don't have anyone who qualifies as a DSP Instructor. What can I do?

    If the agency is unable to hire a person who is a trained QIDP, a certified teacher or community college instructor to be its DSP instructor, consider the following options:

    • The requirement that the agency submit a resume for its DSP instructor can be waived if the agency submits a statement that it will only be hiring fully-trained DSPs who appear on the Health Care Worker Registry as DD Aides. All the Division of DD criminal background check and clearance requirements would still apply to fully-trained DSPs.
    • You could send untrained DSPs to another DD provider agency with an approved DSP training program for the 40 hours of classroom training, You would need to make whatever payment arrangements you need with that agency and submit a statement with Checklist G.
    • Inform us your plan for having qualified staff supervise and sign off on the 80 hours of OJT/CBTA training with the individuals (HBS clients) you serve.
    • The OJT trainer could be a fully trained and well-qualified DSP or someone who understands How to Train the DSPs on the Interventional Competencies and could sign off on each of the Competency-Based Training Assessments.
  27. Can you receive CE's for attending a 2-day course "Professional Crisis Management" (PCM)? This course is close to CPI/Aggression Management?

    No. PCM is a job requirement for employees of that particular agency.

  28. We have a returning employee who completed the classroom DSP training in 2009, but never submitted a completed OJT/CBTA packet. Would a 120 day Waiver Request be considered appropriate for this staff? Her availability for training is limited (hired for part time), and I wanted to be ready to explain to our HR/Recruitment department her options?

    Since it has been 4 years she should complete the entire 120 hours of training again. You should then complete a training waiver request for the 120 day requirement.

  29. Should all of the classroom training occur before starting the OJT/CBTAs?

    No. This is not recommended since trainees need a context for what they are learning plus an opportunity to apply it as soon as possible after learning it in the classroom. Training schedules may be developed where half of the day is spent I the classroom and the other half OJTs or one day I the classroom and one day working o OJTs. The cycle is repeated until the training is completed. Agencies are given freedom to decide a training schedule that works best for them.

  30. Can we practice health and safety competencies in a lab?

    Yes, In fact you should practice them in the classroom before doing them on individuals you support. This is because you will have opportunity to clarify procedures with you trainer before performing the actual task on someone you support.

  31. We are planning on having our staff trained by another agency with an IDHS approved training program. How do we handle the OJTs?

    You will need to have your agency set up the OJT/CBTAs within your own agency since they need to be agency and individual specific. Therefore, your agency will need to have an approved training program, specifying where classroom information will be taught. Please see Getting Your Agency Program Approved for more information. 

  32. How many skill gaps are permitted before putting a DSP through the entire 120 hours of training?

    This is left up to the discretion of the agency.

  33. Do OJT activities supervisors need to be QIDPs?

    No, a peer can do the evaluation is they possess the competencies themselves.


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Contact for Assistance

If you have questions, or need assistance, please contact DHS.BQM@illinois.gov or (217) 782-9438.