According to the Centers for Disease Control and Prevention, one in ten elders and one in seven children have experienced abuse and/or neglect in the past year. Every individual receiving human services has a right to a safe environment which enriches their lives. One pitfall to achievement of this goal is the potential for Abuse, Neglect and Exploitation (ANE) with vulnerable individuals. Implementing a strong Abuse, Neglect and Exploitation Prevention and Detection Program is a critical step for every health and human services provider.
This starts with clearly defined written policies, includes thorough screening protocols enacted by the provider, and followed by thorough and consistent staff training for all key roles (persons served, company leadership, caregivers, custodial roles, mandated reporters, trainers, assigned investigators). These critical pieces are followed by monitoring processes, reporting procedures, incident investigations by assigned personnel, and response/resolution of any incident.
This high-level overview addresses the framework for an effective Abuse, Neglect, and Exploitation prevention and detection program. Every human services provider must develop and implement their own specific policies that ensure a safe place for the persons served and complies with all state and federal statutory requirements.
Written policies, screening protocols, and staff training are three critical components that must be established by health and human service providers. These foundational pieces provide the structure for abuse, neglect, and exploitation prevention and detection programs.
|Written policy||Screening||Staff training|
Formal framework for all other components (screening protocols, training, reporting procedures, investigations, and response
Reviewed and supported by provider leadership
Outlines training requirements for prevention and signs of ANE
Establishes reporting, investigation and resolution procedures
Identifies responsible parties
Incident File/Report Retention
Complies with regulatory and statutory guidelines
Reviewed by assigned and authorized personnel at regular intervals to maintain up-to-date procedures. Policy updates made when necessary
Reviewed by legal counsel
Vetting of 3rd party contractors and/or outside parties (always verify who is on site)
Provides staff overview of ANE prevention and reporting program
Initial hire and annual in line with internal written policy
Training per internal agency/provider written policies for assigned program roles (varies per assigned position)
Monitoring / identifying protocols, reporting procedures, and investigations provide continued oversight by health and human service providers to ensure prevention and detection of potential abuse, neglect, and exploitation per written policies.
Safety and/or vulnerability assessments
Tracking for history of trends - if potential is identified, take action per internal policy
Indicators or symptoms
Once notified and /or identified: report to proper authority in line with internal written policies
Reports made to proper authority (internal) per written company reporting policy and procedure
Triage of Potential Incident(s)
Assigned personnel determine if there are indicators or absence of ANE in the incident based on assessment, leading to either further investigation or resolution per written policy
Prompt and thorough (within internal provider policy)
External reporting per statutory and/or funding agency (Medicaid, CPS, etc.) requirements
Root cause investigation/analysis
Assessment to determine if abuse, neglect, or exploitation claim is substantiated or unsubstantiated
Resolution per written policy
Timely response by health and human service providers is critical in order to protect person(s) served and determine proper course of action.
Prompt response to protect and care for person(s) served and corrective measures in line with internal written policies
Identify need for policy review, staff retraining, staff termination per written policy and staff review and / or change to screening procedures
Additional safety and/or vulnerability assessments
Interdisciplinary Team interventions
Address with Quality Assurance and Performance Improvement programs
Additional measures as necessary to protect person(s) served and prevent recurrence
Incident report retention per written policy and in line with statutory requirements
This information is meant to provide additional insight in the development of abuse, neglect and exploitation prevention and detection protocols. Every specialty care program must stay diligent in their efforts. Our exclusive OthersFirst program provides a wide range of basic and optional coverages to help meet the needs of your industry. Specialized coverages and endorsements including Abuse or Molestation coverage are available. Visit Nationwide Specialty Care Services for more information.
Additional Loss Control Services Resources
Nationwide Loss Control Services offers additional documents to assist with your ANE assessment. Our Abuse, Neglect and Exploitation Flow Chart and Sexual Abuse and Molestation Prevention Checklist are available on MyLossControlServices.com.
Information in this article is based on the prescribed guidelines of the following:
- Centers for Medicare and Medicaid Services (CMS); 1915(c) Instructions, Technical Guide, and Review Criteria [Version 3.6, January 2019]
- Centers of Disease Control and Prevention (CDC); Violence Prevention
- Understanding Elder Abuse Fact Sheet, The Center for Disease Control and Prevention https://www.cdc.gov/violenceprevention/pdf/em-factsheet-a.pdf
- Preventing Child Abuse Fact Sheet, The Center for Disease Control and Prevention https://www.cdc.gov/violenceprevention/pdf/CAN-factsheet.pdf