Unreported incidents affecting the health and safety of Medicaid home and community-based services (HCBS) beneficiaries put already vulnerable populations at further risk for injury, illness or even death. If left unaddressed, critical (abuse, neglect, exploitation), and even non-critical (medication errors, rights violation, falls), incidents cause further harm to individuals and raise costs for the system overall, as acute and chronic health spends will rise.
After close to two years of limited in-home contact due to COVID-19 restrictions, there are fears that too many critical and non-critical events went unreported and uninvestigated. Even in normal times, Medicaid HCBS waiver populations are at a higher risk of abuse, neglect and exploitation.
At the start of the pandemic, as many as 29 states modified incident reporting requirements due to the added demands and challenges presented by the public health emergency. Administrative bandwidth was needed to deal with the crisis. These types of allowances were granted by the U.S. Centers for Medicaid and Medicare Services (CMS) throughout the pandemic.
Late last year, the Government Accountability Office (GAO) released a report detailing the potential effects of the pandemic on incident management for Medicaid HCBS populations. The analysis from the GAO could not quantify how many incidents went unreported, but speculated that a significant number of events went unnoticed and uninvestigated at the height of the COVID-19 crisis.
The question remains: Where do we go from here?
The CMS requires state Medicaid incident management solutions to:
- Capture incident reports
- Track timely investigations
- Provide data for analytics to reduce risk of recurrence
New incident management information technology platforms are reducing paperwork and creating a digital trail for all incident-related activity. Robust reporting capabilities allow for thorough review of event details and contributing factors, so detrimental patterns can be identified and addressed.
It is worth noting, no amount of IT modernization will completely protect vulnerable populations from abuse, neglect and exploitation. The responsibilities fall to agency workers and support coordinators to identify, initiate investigations and strategize ways to prevent future incidents. But, armed with automated tools and comprehensive reporting platforms, proactively protecting Medicaid HCBS populations is possible.
As the world moves toward the ‘new’ normal, and public health emergency policies end, there will be an increasing need for identification and reporting of incidents and safeguards to keep beneficiaries safe. The recent GAO report noted, “Safeguards include minimum provider qualification requirements— such as licensing or education requirements—and incident reporting requirements to identify incidents that are severe enough to merit review and follow up.”
