Illinois Department of Human Services
Division of Developmental Disabilities
This Information Bulletin addresses the requirement of providers and Independent Service Coordination agencies' use of the Critical Incident Reporting and Analysis System to report critical incidents. The bulletin also reflects a summary of the recent changes reflected in the revised CIRAS manual.
In accordance with the Home and Community-Based Services Waiver, the Division of Developmental Disabilities (DDD) must establish safeguards to assure the health and welfare of waiver participants. To align with this requirement, DDD must operate a critical incident reporting and management process. This is met via the following reporting requirements:
- ) Administrative Code Title 59, Part 50 "Office of Inspector General of Alleged Abuse or Neglect". This code requires the reporting of alleged abuse, neglect, exploitation, and deaths of individuals receiving services in settings that are licensed, certified, or funded by DDD.
- ) Critical Incident Reporting and Analysis System (CIRAS). DDD requires reporting of other critical incidents in the CIRAS system that are not considered to be alleged incidents of abuse, neglect, or exploitation.
This bulletin focuses solely on the other critical incident reporting via the CIRAS system.
Current guidance (remains applicable in revised manual):
Providers must report incidents within two (2) working days of discovering or being informed of the incident. ISC agencies should create reports for incidents they become aware of that have not been reported. Unresolved issues with CIRAS incidents should be reported to the Division by the ISC per the Problem and Conflict Resolution Protocol.
Critical incidents are defined below.
911 Call: All calls to 911 for emergency personnel response that do not fit into any other category. Calls for emergency response that are initiated by persons receiving supports from the provider agency should be included here, even if they are later determined to be inappropriate. A description of the reason for the call should be included in the narrative. Calls to 911 for medical emergencies should be reported as "Medical emergency".
Deaths: Deaths of participants that receive services while living in their own or family's home. Deaths of participants residing in residential settings are not reported as part of this data process since they are reported to OIG as per Rule 50.
Known injury: A known injury is any injury from a known cause that is not considered abuse or neglect and that requires immobilization, casting, five or more sutures or the equivalent, second or third degree burns, dental injuries, eye injuries, or any injury that prohibits the individual from participating in routine daily tasks for more than two consecutive days. In some cases, an injury may not be immediately recognized as requiring reporting. A known injury becomes reportable at the point where there is recognition that it fits this definition.
Law enforcement: Any incident that results in the individual being charged, incarcerated, or arrested. Calls to 911 for assistance that do not result in charges, arrest, or incarceration are not required to be reported in this category.
Medical emergency: Any incident where emergency medical intervention is required to save an individual's life (e.g., Heimlich maneuver, cardiopulmonary resuscitation, intravenous therapy for dehydration). Calls for 911 medical assistance should be reported as "medical emergency" even if the cause is other than the examples provided. A 911 call is not required for an issue to be reported as a "medical emergency". Issues that are resolved through intervention of agency staff that would have likely resulted in death if the action had not occurred should be reported.
Missing individual: An incident that is not considered neglect and the individual cannot be located for a period of time longer than specified in the personal plan; the individual cannot be located after actions specified in the personal plan are taken; the individual cannot be located in a search of the immediate surrounding area; circumstances indicate that the individual may be in immediate jeopardy; or law enforcement has been called to assist in the search for the individual.
Peer-to-peer acts: Acts committed by one individual against another when there is physical abuse with intent to harm; verbal abuse with intent to intimidate, harass, or humiliate resulting in emotional distress or maladaptive behavior; any sexual abuse; any exploitation; or intentional misappropriation of property of significant value. In some cases, such incidents may need to be reported to OIG as potential staff neglect or exploitation, rather than reported in CIRAS. If peer-to-peer actions occur due to failure of staff to intervene to prevent or stop the act, a neglect report is appropriate. In cases where one individual is clearly the aggressor, it is acceptable to make only one CIRAS entry in the name of the aggressor, listing the name(s) of the victim(s) in the narrative. However, if two or more people become involved in an altercation that meets this definition and the aggressor is identified as multiple individuals, a separate CIRAS report should be completed for each aggressor. Acts committed against staff should be reported in the "Peer-to-staff" option.
Peer-to-staff: Acts committed by one individual against a staff member when there is physical abuse with intent to harm or verbal abuse with intent to intimidate, harass, or humiliate.
Unauthorized restraint: Any use of restraint beyond the provisions outlined in Appendix G of each Waiver. Refer to Illinois Mental Health and Developmental Disabilities Code for details. (See 405 ILCS 5/1-125 and 405 ILCS 5/2-108 for details.)
Unknown injury: Any injury of an unknown cause that is not considered possible abuse or neglect and that requires treatment that only a physician, physician's assistant, or nurse practitioner can provide. If the cause of the injury is known, follow instructions in KNOWN INJURY or MEDICAL EMERGENCY categories.
Unscheduled hospitalization: Any hospital admission that is not scheduled in advance. Hospitalization admissions that occur as a result of a medical emergency or 911 call should not be reported in this category but should be reported in the appropriate category.
- Sections of the manual have been moved within the document to improve organization of the manual. For example, topics related to notifications of CIRAS reports have been moved to a section entitled "Notifications of CIRAS Incidents"; topics related to data reporting have been moved to a section entitled "Data Reports and Analysis".
- The following statement has been added: "At minimum, two (2) designated agency reporters must be registered for CIRAS per agency to assure staff are always available for timely reporting of incidents."
- Sample templates for completion of the following forms are now accessible in the manual:
- - Community Provider/External User I.D. And System Access Request (IL444-2022)
- - Request for MIS Hardware, Software and Services (IL444-4144) (The "Narrative Description of Request" section of this form has changed to improve communication with MIS.)
- (Instructions on how to complete the forms have been placed in a table for easier reference)
- (The manual reflects that these two forms need to be sent together, in one email, to DHS.DDD.CIRAS@illinois.gov rather than sending the forms separately.)
- The following statement has been added: "Note: an individual must be registered in the Reporting of Community Services (ROCS) system for the provider agency to enter incidents in CIRAS for the person."
- The following have been added in the Tracking Data Elements table to place greater emphasis on entering accurate data:
||Select the city where the incident occurred. Note: Attention should be given to providers with locations throughout the state to assure the correct city is selected. Do not include name of neighborhood.
|ISC Provider for Individual
||Select the ISC providing services for the individual. An automatic email notification will be sent to the selected ISC. Due to a priority response by the ISC for specific incidents, it is imperative to select the assigned ISC. Thus, appropriate actions and timely follow up can be initiated upon receipt of the email notification.
||Provide a narrative of the provider's response to the incident. It should reflect sufficient details to accurately describe the response, including date/time of response, staff name(s) (and working titles) of persons responding, action steps taken to immediately address the incident, and the incident status at the time of the report.
- The following has been revised in the Tracking Data Elements table to highlight the need for additional details in the incident description:
|Narrative Description of the Critical Incident
Provide a narrative of the incident including information on what happened, when (date/time) and where the incident occurred, outcome of the incident, and any staff name (and their working title) or other individuals that were involved. Include other applicable dates, where circumstances occurring on those dates had impact on reported incident.
Assure to include any pertinent information reflecting the current status (ex.: person has been discharged from hospital; missing person has been located).
The narrative should reflect sufficient details to accurately describe the incident.
- A change in provider FEIN numbers for users and individuals served have an impact on entering CIRAS reports. Thus, the revised manual reflects the necessary steps (shown below) to be taken by providers in the event of a FEIN number change.
|Change in provider FEIN number: Impact on CIRAS Reporting for Individuals and Designated Agency Reporters
|If the FEIN number for a provider agency is changed (example: due to new acquisition, merger), then the provider must complete the following steps to assure individuals served and designated agency reporters are associated with the appropriate provider agency in the CIRAS system:
- Contact DDD staff in the Bureau of Community Reimbursement and Program Support to determine the appropriate documents/forms to submit to the Division. The Bureau will provide guidance on updating the provider's information in the ROCS system.
- Update information of impacted individuals in the ROCS system to reflect the new provider FEIN number.
- Complete new forms (IL444-2022 and IL444-4144) for the designated agency reporters. For IL444-4144, add an appropriate statement to the "Narrative Description of Request" section of the form to reflect reason for submission of a new form. For information on how to complete these forms, refer to "Enrollment In CIRAS" section of this manual.
- The following statement has been added: "All CIRAS submission requires a follow-up entry by the ISC within 10 working days of the initial report. This follow-up should be entered in CIRAS for Division tracking. The Search function in CIRAS is to be used to locate the incident and then enter the follow-up notes. Use of another reporting system does not replace a follow-up in CIRAS."
- Note: If necessary, BQM staff will contact ISCs and/or the providers following receipt of the incident report to assess status of actions taken. Division staff will monitor the situation until it is resolved.
The Division encourages staff members of providers and ISCs to review and refer to the revised CIRAS manual.