All You Ever Wanted to Know (and more) About Residential Licensing
Bell’s Intellectual Disability Residential Services (IDRS) program, which manages more than a dozen community living homes in York County, is licensed and inspected by the Pennsylvania State Department of Public Welfare (DPW) [now known as Department of Human Services] annually.
Following the inspection visit in the Spring of 2014, Ray Bianchini, a Bell volunteer at the time, caught up with the IDRS team to talk with them about what licensing means, how they are involved in the process, and what it means for Bell and the individuals served in our residential living homes.
Here’s what he found out in speaking with staff:
Within the past couple years, DPW has started requesting preliminary information about all group home residents prior to the inspectors’ on-site visit —specifically, the names of each resident by home, admission date, any behavioral plan addressing social, emotional, and environmental needs, any restrictive requirements, use of psychotropic medications, self-medicating, any allowed unsupervised time, and whether they are 60 years of age or older. This preliminary information helps DPW to plan, facilitate, and streamline the on-site process, as well as to better address and focus on any potential issues or problem areas during the inspection visit.
Once the inspectors arrive, they start out by reviewing staff, client, and overall agency and individual home records, for accuracy and completeness. The bulk of the record review is done at Bell’s main office where the master records are maintained.
This record review is the critical first step in the licensing process from DPW’s perspective; without accurate and complete documentation, there is no way they can verify mandated items have actually been done. Typically, by mid-day or early afternoon on day one, they identify which homes they will actually be visiting. At each of the selected homes, they review the current month’s Medical Administration Records (MAR’s), client funds, and related records. In addition, they inspect all physical facility and structural items in the homes, fire safety systems, food storage systems, first aid kits, etc., and they also set off the fire alarm and observe staff and resident responses during the drill.
DPW’s primary, overriding concern is to ensure the health and safety of all home residents. Accordingly, high priority items include fire safety systems, fire drill administration, food storage systems, regular medical appointments, medication administration, staff training in emergency medical procedures, psychological visits, as needed, and maintaining appropriate staffing levels and resident supervision in the homes at all times.
There are some items that are very “black and white”: refrigerator and freezer temperatures, hot water temperatures in kitchens and bathrooms, etc. In contrast, there are other areas that allow providers room for creativity, for example, programming, activities, client choices, etc. DPW’s main interest and concern in these areas are that providers are doing these things, that they are centered on clients’ interests, that they are as individualized as possible, that they emphasize normalization and integration into the community at large, and that they do not adversely affect the health and safety of residents in any way.
What constitutes a “citation”?
Essentially, a citation is any breach of, or anything that is not in compliance with, the 6400 regulations governing the operations of group homes, or with Chapter 51 which regulates any fiscal or billing issues, for example, fiscal or billing records at Bell’s main office that do not correspond with or support the claims submitted to DPW for reimbursement by the State.
What is the process for “fixing” any citations, issues, problem areas identified during the inspection?
At the conclusion of the on-site visit, the DPW inspection team meets with Bell’s senior management team to review the results and to provide a summary of both the positive outcomes and also the items in need of correction. As soon as possible after completion of the visit, DPW sends Bell a written summary of the inspection results, including the items in need of correction.
Bell is required to send DPW a written plan of correction within 10 business days of receiving DPW’s inspection report. The plan of correction has to address each citation, indicating specifically how each item will be corrected, who will be responsible for making the correction, the time frame in which the correction will be made, documentation proving that the correction has been made, and the specific process and procedures that will be adopted and implemented to prevent this non-compliance from ever happening again.
In this scenario, DPW would issue the entire ID department (not just the home or homes that were not in compliance) a provisional license and would then return “unannounced” for a follow up inspection. If the inspectors find that the original citations have not been corrected or if they find additional, new citations, the entireprogram would receive a Directed Plan of Correction, with recommendations from the State to fix the area.
The question of what licensing looks like, feels like, and how it impacts day-to-day life in the homes, for clients and for staff, evoked a variety of responses—ranging from “sometimes it’s really helpful” to “it can be rather stressful as we’re being evaluated on a year’s worth of work.” The impact of licensing on day-to-day life in the homes varies—some clients and staff love meeting new people and welcome having the inspectors on site, while others find the inspectors’ presence is a noticeable break in routine
In contrast to these varied responses, there was complete consensus among all staff interviewed that 2014 was the smoothest licensing inspection in their collective experiences with Bell.
The main reasons were that they have learned from past years’ inspections, and have made the changes needed to streamline the overall licensing process, especially, in the areas of documentation and records required by DPW. Out of the seven homes visited by DPW inspectors in 2014, five homes received no citations and were therefore 100% in compliance with State regulations. The other two homes received only three citations, one of which was corrected immediately by staff while DPW was still on site, leaving only two citations that needed to be addressed in the final plan of correction.
Staff was also in agreement that these licensing inspections help Bell to recognize possible problem areas that may need correction or modification before they become bigger and more serious. The end result in Rhoda’s words is that “while Bell is not perfect, it is always striving to be better” and to improve and to make needed changes that are ultimately “good for the individuals served and for Bell’s staff.”
More from Ray
As an outside observer with experience overseeing a DPW-licensed adult training program, I am genuinely impressed both with the results of Bell’s 2014 licensing inspection and also with the attitude of Bell’s staff towards these inspections as learning and growing opportunities. KUDOS to all the staff responsible, KEEP UP THE GREAT WORK!