Reports of abuse, neglect or exploitation of Medicaid home- and community-based services (HCBS) beneficiaries fell in 2020 as compared to prior years.
This, according to a recent report from the Government Accountability Office (GAO), was largely due to an absence of more routine in-person contact with case managers and creates “concerns that incidents of potential or actual harm to beneficiaries were going unreported.” Additionally, the GAO found, even if critical incidents were suspected or reported in 2020, further investigation into these events was often delayed or postponed.
Data is not currently available for exactly how many fewer critical incident reports were filed in 2020, as compared to the years prior. But the GAO study suggests the number is significant.
Medicaid HCBS beneficiaries are among those most vulnerable to abuse, neglect and exploitation, even in “normal” times. As such, the GAO recommends health and human services agencies institute changes to help them be better equipped to protect these individuals, especially in the event of future public health crises.
GAO Findings and Recommendations
Like so many other healthcare disparities exposed during the height of the pandemic, poor incident management for Medicaid beneficiaries pre-dates the public health crisis. While this latest report from the GAO was published in September 2021, the office has also previously reported on gaps in critical incident reporting in many state community assisted living facilities. The U.S. Department of Health and Human Services Office of the Inspector General (OIG) has also found several instances of non-compliance related to incident management for these populations.
When COVID-19 first began to spread around the U.S. in early 2020, all 50 states requested emergency authorization from the Centers for Medicare & Medicaid Services (CMS) to allow for remote visitation for their Medicaid members and clients, according to the GAO report. This would limit in-person contact and prevent the spread of the disease. Most states also requested permission for delayed or suspended background checks and other standard provider requirements, to streamline service provision under such unique circumstances.
The CMS has authority to approve temporary changes to state Medicaid programs during emergencies, and the agency allowed an unprecedented number of exemptions at the height of the pandemic. While the CMS put out repeated guidance and several crisis toolkits, there was no outlined protocol for monitoring these emergency changes, according to the GAO.
In addition, the CMS did not request states provide data on the effectiveness of these emergency measures as the pandemic continued.
“Agency officials confirmed that they did not have state data on critical incidents (which include incidents of abuse and neglect) and did not know if critical incidents had increased or decreased during the COVID-19 emergency,” according to the GAO report. As a result of their study, the GAO recommends the CMS develop procedures to monitor changes made during future crises. The authors also encourage the CMS to evaluate how the emergency response to COVID-19 impacted Medicaid HCBS beneficiaries, and address opportunities for improvement.
Incident Management for the Future
One of the biggest concerns noted it in the GAO report was the limited ability to understand the impact of isolation on Medicaid HCBS members without routine in-person visits during the pandemic.
State Medicaid administrators, case managers and providers benefit from historical case notes that offer insights into how incidents may have occurred. This data can also inform prevention efforts in the future.
The Blue Compass suite of health information technology solutions from FEI Systems includes a CMS-certifiable incident management module to assist with critical—and non-critical—incident reporting, investigation, follow up and prevention. Upon implementation, this module can house all incident-related data and case notes from integrated legacy systems for reporting and analysis.
The Blue Compass incident management module is designed to meet unique requirements for tracking and reporting critical (abuse, neglect, exploitation) and non-critical (medication errors, rights violation, falls) incidents across various programs and departments. The application can be implemented as a stand-alone solution, integrated into existing IT systems or included as a function-specific module within the Blue Compass comprehensive case management platform.
Ultimately, no software or health IT solution can replace adequate training in incident identification/reporting, investigation and management protocol. But with automated workflows and alerts built into our solutions, case managers, incident investigators, and state agency administrators are kept abreast of the next steps and requirements in reporting an incident and the path to resolution. Our incident management module easily guides all interested parties through reporting, investigation and follow up procedures to promote critical incident reporting compliance.
