QI plan components

The example of the QI plan components seems to exceed the regulatory standards and for that reason should not be explicit.  There are current concerns that providers are being exposed to interpretations that are broad and exceed the regulation standards. 

Level II reporting while in care of AR or licensed provider

A Level II incident language is clear in that it states that "serious incident that occurs or originates  during the provision of a service or on teh premises of a provider...." It feels that the guidance example is overreaching and outside of the regulatory standard when it suggests that a provider must report incidents that occur when an individual is not on the premises or in the care of an AR or other provider.  This should be removed. 

Unplanned Medical Visits

The language about unplanned medical visits is unclear in the guaidance document as individuals can be seen by a PCP, urgent care or ER and may not be admitted at that time. Please indicate clearer language so avoid broad interpretations of this requirement.  It may be more appropriate to indicate that level II should be initiated if an individual is admitted for treatment.  

Level III sexual assault

Level III incident of sexual assault reporting is not trauma informed and negates the sensitivity of the client/therapist relationship. 

Duplicate Death Reporting 

This guidance still does not address the requirement for duplicative reporting.  

Requirement for 24 hour reporting for bowel obstruction and aspiration pneumonia

Diagnosis of medical conditions are not immediately known at the time of medical intervention.  This should be clarified that there is a 24 hour requirement after receiving a diagnosis.