CIRAS / CMA - Access Instructions and Frequently Asked Questions
On July 27, the Division of Developmental Disabilities (DDD) emailed information and instructions to community agencies on enrolling in DDD's two new systems, Critical Incident Reporting and Analysis System (CIRAS) and Capacity Management Application (CMA).
This notice includes more detailed instruction for completing the form Community Provider / External User I.D. and System Access Request (IL444-2022) and answers to the questions we received.
Completion Instructions For Community Provider / External User I.D. and System Access Request Form
Note this form cannot be completed and submitted until the community agency has obtained an external user I.D. following the Create Illinois.gov account steps.
- Action Requested - check the box, "System Access Only (ID Previously Assigned)"
- Community Provider Information -
- FEIN - input agency FEIN
- Agency Number - leave blank
- Provider Name - input Agency Name
- IGA/DSA No. (Required) - leave blank
- Medicaid ID Number - leave blank
- User Information - Complete information as requested for the designated CIRAS reporter. The IDHS ID will be the external user I.D. (for example, John.Doe@external.illinois.gov). This will be the email address assigned from the Create Illinois.gov account steps. If the CIRAS reporter has an existing external.illinois.gov email address, input that existing .gov address. An external I.D. must be obtained before completing and submitting the IL444-2022 Form.
- User System Access Requested: check the "Other" box and on the line provided, write "CIRAS_reporter, CIRAS_user, CMA user/update."
- Signature block: the designated CIRAS reporter should print and sign his/her name and add date.
Once completed, the form should be forwarded to: Sherry.Hinds@illinois.gov. After receipt and review, an email will be sent to the user confirming access to CIRAS.
Frequently Asked Questions
DDD has received several questions about CIRAS and CMA in response to the email of July 27, 2017. Below are the frequently asked questions with answers.
1. Question: Can agencies providing Self Direction Assistance (SDA) bill for the time it takes to enroll in and report through CIRAS?
Answer: SDAs may not bill for the time it takes to enroll in CIRAS. This is not an individual-specific activity. SDAs may bill for time spent preparing and submitting CIRAS reports specific to a Waiver participant, as long as the work is done by QIDPs per agency qualifications specified in the Waivers.
2. Question: We report through Reporting of Community Services (ROCS) software and so we currently have a .gov email accounts. Do we need to request a new .gov email account to access and use CIRAS?
Answer: No. If a community agency has an external.illinois.gov account, they must use it to gain access to CIRAS and CMA.
If problems arise establishing or accessing an external.illinois.gov account, please contact DoIT.HelpDesk@illinois.gov.
3. Question: How many CIRAS reporters does the Division require an agency to have?
Answer: Each agency must have at least one CIRAS reporter, however we strongly recommend having one or more additional reporters that can fill-in during an absence. Each reporter should enroll separately which would include obtaining his or her own external.gov email account.
4. Question: We are an Intermediate Care Facility for Developmental Disabilities (ICF/DD). Should we register for CIRAS?
Answer: No. CIRAS is a requirement for agencies that provide services through one or more of the three DD Medicaid Waivers. Because ICFs/DD do not provide services under these Waivers, ICFs/DD should not register for CIRAS. If a corporate entity provides both ICF/DD and Waiver services, it must enroll, but would report only for its Waiver settings.
5. Question: We are an ICF/DD, should we register?
Answer: We strongly encourage ICF/DD providers to register for and post their service capacities through CMA.
6. Question: What should we do with the Certificate of Understanding for CIRAS?
Answer: Once completed, the agency should keep the certificate on-site at the agency. The certificate is an audit component for MIS Security and CIRAS. It is not required that a copy be forwarded to DDD.
7. Question: Since community agencies have been required for years to have an internal critical incident review process/system in place, is it appropriate to assume CIRAS replaces it?
Answer: Attachment A requires agencies to have an internal critical incident review process. This will continue to be needed to ensure that, among other things, agency staff knows their responsibilities with regard to identifying, preventing, and addressing such incidents. It is up to each agency to review its internal policies and processes and determine what modifications need to be made given the release of CIRAS.
8. Question: When does DDD expect a CIRAS incident to be reported?
Answer: Agencies (and ISCs for individuals in the Home-Based Support Services Program) must report such incidents within two working days of discovering or being informed of the incident.
9. I have looked for the Data Sharing Agreement, Model Business Associate Agreement, and the Data Sharing Agreement Questionnaire which are required by the ISCs. Although, the manual indicates that "Examples of each form are included as attachments at the end of this manual" and DHS also has said attachments and/or links for the forms are found in the manual, I have been unable to locate either. The Manual indicates that a Data Sharing Agreement, the Model Business Associate Agreement, and a Data Sharing agreement Security and Privacy Controls Questionnaire will be provided to the ISC agency by DDD. Could you please indicate exactly where the forms are found or provide them with the answers to these questions?
Answer: Each ISC agency requires a unique identifying code to be included on the above forms. Division staff are in the process of preparing documents that are individualized for each ISC. Each form will be provided to the ISC agency by the Division.
10. Will all reporters from the same agency have access to the full standard reports through CIRAS or only for the incidents each one specifically reported?
Answer: Each agency reporter will be able to view all incidents reported by other agency reporters. In addition, CIRAS has the InfoView function which will allow agencies to create incident reports based on factors such as age, location, etc.
11. Can we get clarification regarding responsible party to do reporting? For example, if an injury of unknown origin is noted at home and DT, who is responsible to report to CIRAS? Will it appear that there are multiple incidents for one individual if both report? Also, if an individual is taken to ER from DT and later requires hospitalization, who is responsible to report? The examples of this could be numerous and it would help to have some guidance on this.
Answer: The Critical Incident Reporting and Analysis System (CIRAS) is designed to capture electronic reports from providers and ISCs. DDD will use this information to inform ISC agencies of potential issues involving waiver participants and complete an analysis for patterns and trends. Providers should complete reporting to CIRAS when they become aware that an individual has experienced a critical incident. If a provider and/or ISC becomes aware of a CIRAS incident that has not been reported , they should create a CIRAS report and complete the appropriate follow-up action. Situations may present which result in reports from multiple providers. (e.g., Injury of unknown origin identified by a DT and CILA provider.) DDD would prefer to have incidents reported multiple times rather than no report.
12. Reporting of deaths: Currently, reporting of deaths for individuals living in their natural homes goes to adult protective services through IDOA. The instructions indicate that those deaths should be reported through CIRAS, even though deaths of those living in a CILA would be reported to OIG. Earlier in the manual it states that incidents of abuse/neglect should still be reported to those entities. Why the difference in reporting deaths of those living in their own homes vs. those living in a CILA?
Answer: Per Rule and per Waiver, deaths in CILA's and DT's have to be reported to OIG while deaths in family homes do not. CIRAS will assist in tracking those not reportable to OIG.
13. The requirements indicate that we have two working days to report. However, the category of "known injury" is partly defined as any injury that keeps an individual from participating in routine daily tasks for more than two consecutive days. It is conceivable that we won't know this until the two days have elapsed.
Answer: Although the severity of some injuries may not manifest themselves immediately, once a CIRAS-qualifying incident becomes evident, the provider is required to create an incident report. In the case of these types of injuries, the 2 day clock does not start until the person is prevented from engaging in routine daily tasks for more than two consecutive days. This would comply with the reporting requirement.
14. The definition for "Unauthorized Restraint" is "Any use of restraint beyond the provision outlined in Appendix G of each waiver." I have searched far and wide and cannot find a document titled Appendix G. Where can this information be found?
Answer: Appendix G is the Appendix in the Waiver that discusses "Participant Safeguards". It describes the safeguards that the State has established to assure health and welfare of waiver participants in specified areas. In Appendix G, the below rule is cited in regards to restraints:
15. Under "Unscheduled Hospitalization, there is reference to made to conditions specified in the nursing care plan. Is this plan a document that we in DT should or will be using?
Answer: The reference to the nursing care plan is essentially the documentation of a process which describes the needed supports for the person. Through the provision of services, providers should have such information on specific individuals who may have a potential onset of specific symptoms and criteria that require hospitalization.
16. Why not make the timelines the same, either two days period or two days not including Sat/Sun period? As it is now... If an incident happens on Friday afternoon at DT - two working days to report is Tues. afternoon since the program is closed on Sat/Sun. An incident happens on Friday afternoon at a CILA - two working day to report is Sun. afternoon. The incident is the same in either case, no less important if it happens in one setting over another.
Answer: CIRAS does have a reporting time frames of two (2) working days. DDD is taking the view that working days are Monday through Friday. This reporting period would not preclude the implementation of safeguards that would ensure the individuals health and safety.
Upon entry of an incident into CIRAS, the electronic system automatically notifies the ISC agency of the report. ISCs will use this information to monitor the individual's well-being and ensure any needed actions are taken. DDD staff also receives notification upon entry of reports of missing person and law enforcement involvement. All reports are summarized and analyzed on a monthly basis by DDD staff.