Loss Control Learning Center

Main components of an abuse, neglect and exploitation prevention program

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	Persons served: Pre-admission screenings Staff: Pre-employment background screenings, reference checks and verification Verify education, licenses and certifications Volunteers: Background screenings 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 includes: ANE indicators and symptoms Internal reporting procedures Reporting and resolution timelines Challenging behaviors and interventions Additional training and staff retraining per written policy Training per internal agency/provider written policies for assigned program roles (varies per assigned position)

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

Persons served:

Pre-admission screenings

Staff:

Pre-employment background screenings, reference checks and verification
Verify education, licenses and certifications

Volunteers:

Background screenings

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 includes:

ANE indicators and symptoms
Internal reporting procedures
Reporting and resolution timelines
Challenging behaviors and interventions
Additional training and staff retraining per 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.

Monitor/Identify	Report	Investigate
Safety and/or vulnerability assessments Tracking for history of trends - if potential is identified, take action per internal policy Indicators or symptoms Unusual patterns Suspicious or unexplained injuries (e.g., bruising) Inconsistent staff explanations Unusual resident behaviors around certain staff 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) Internal resolution and/or external reporting completed per written policy (assigned personnel review evidence, notes, observed incident reports or third-party reporting, witnesses, pattern, etc. Assessment of the incident (i.e., trauma, exploitation of persons served, injury, hospitalization, death) 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 Assigned investigator Root cause investigation/analysis Assessment to determine if abuse, neglect, or exploitation claim is substantiated or unsubstantiated Resolution per written policy

Monitor/Identify

Report

Investigate

Safety and/or vulnerability assessments

Tracking for history of trends - if potential is identified, take action per internal policy

Indicators or symptoms

Unusual patterns
Suspicious or unexplained injuries (e.g., bruising)
Inconsistent staff explanations
Unusual resident behaviors around certain staff

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)

Internal resolution and/or external reporting completed per written policy (assigned personnel review evidence, notes, observed incident reports or third-party reporting, witnesses, pattern, etc.
Assessment of the incident (i.e., trauma, exploitation of persons served, injury, hospitalization, death)

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

Assigned investigator

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.

Response
Prompt response to protect and care for person(s) served and corrective measures in line with internal written policies Inquiries 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

Response

Prompt response to protect and care for person(s) served and corrective measures in line with internal written policies

Inquiries

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:

Government Resources:

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

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