New policy summary – updated July 2017
New CIMS policy summary – Updated 1 June 20171
New CIMS policy summary – Updated July 20171
Introduction
The Department of Health and Human Services (the department) has developed a new client incident management system (CIMS) that focuses on the safety and wellbeing of clients.
The new CIMS supports a consistent approach to incident management, embeds transparency and accountability throughout the system, ensures client safety and wellbeing, and supports positive client experiences and outcomes.
The details of the new client incident management policy are described in the Client incident management guide (Final draft December 2016) (the policy). The following information is a summary of the policy and new approaches.
What is the new approach for client incident management?
The new CIMS comprises five stages:
Figure 1 Model for the new CIMS:
Identification and response
Identification is when an incident is disclosed to, or observed by, a service provider at any service delivery setting (for example, provider premises, outreach location, client’s home). This may include disclosure by a client, family member or other professionals, to the service provider.
Response covers the immediate activities undertaken to ensure the safety and wellbeing of clients, staff and visitors, preserve evidence and notify emergency services and family or other support people.
Reporting
Reporting captures specific information regarding the incident. As part of this stage, follow up is undertaken to ensure the information provided in an incident notification is accurate, and service providers and the department are assured that appropriate actions are being planned and/or undertaken to manage the incident.
Incident investigation
An investigation is a formal process of collecting information to ascertain the facts about an incident, which may inform any subsequent criminal, civil, disciplinary or administrative sanctions.
In the context of this policy, the purpose of an incident investigation is to determine whether there has been abuse or neglect of a client by a staff member, carer or another client.
Incident investigations may be carried out by service providers (including the department) or external bodies (including the department).
Incident review
A review is an analysis of an incident to identify what happened, determine whether an incident was managed appropriately, identify likely causes of the incident, and to apply subsequent learnings to reduce the risk of future harm.
Reviews may be carried out by service providers (including the department) or external bodies (including the department).
Analysis and learning
Analysis and learning includes monitoring and acting on trends identified through the analysis of incident information to enhance the quality of service and supports to clients.
Reporting, investigating, reviewing and analysing incidents enables service providers to review and assess the way in which an incident has been managed, to implement improvements, minimise risk and embed a continuous improvement approach which involves the client within service delivery. This in turn supports better client experience and outcomes.
What is the scope of the new CIMS?
The new CIMS will apply to the following department delivered services and funded organisations:
• alcohol and drug treatment services
• mental health community support services
• home and community care services (for people aged under 65 and for Aboriginal people aged under 50)
• community palliative care services
• aged care and carer’s support services
• sexual health prevention and community based care
• child protection
• out-of-home care services
• disability services
• public housing and homelessness assistance
Changes to scope since last update:
Community Health Services: The application of CIMS to registered and integrated Community Health Services has been deferred for 12 months from implementation to enable further consideration of the most appropriate incident reporting framework. This means that Community Health Services are not in scope for the initial implementation of the CIMS. Further advice will be provided to Community Health Services in coming months.
Public dental services: Public dental services are not in scope for the CIMS.
Please refer to Appendix C: Client Incident Management Guide (Final draft December 2016) for full details.
What is changing in the new CIMS?
The new CIMS is focused on incidents that have a direct impact on clients. This means that some events recorded as part of current incident reporting systems will be managed through case management, issues management, workplace health and safety and risk management systems in the future.
The table below highlights the key differences between the current incident reporting system and the new policy in relation to each of the CIMS stages.
Identification and Response Stage
Current systems / CIMS• Provide limited detail guiding service provider response to client incidents.
• Separate guidance in Responding to Allegations of Physical and Sexual Assault policy.
/ • Clear client-centred minimum standards will be identified for responding to all client incidents to ensure outcomes for client safety and wellbeing.
• Specific requirements will be identified for preservation of evidence and notification of police (if required).
• Response guidance will include immediate response and planning for ongoing support to ensure client centred focus and accountability to the client.
• Specific guidance for responding to allegations of physical and sexual assault will be included in the one document, with key actions identified in the body of the Client incident management guide (CIMG), and cross-referenced to Responding to allegations of physical and sexual assault appendix to improve clarity and consistency.
• The CIMG will include additional guidance relating to client incidents for children in out-of-home care.
Client Incident Reporting Stage
Current systems / CIMS• All incidents are individually reported to the department.
• Involves differing categorisation and incident types between health and human services.
• Separate protocols are documented for follow up between health and human services.
• No relationship between different categories of incidents, and no clear requirement to identify cumulative and escalating harm to clients. / • Revised incident categorisation and list of incident types to simplify and streamline classification across services, and ensure the system will be fit for purpose. Service providers select a primary incident type and secondary incident type for each client impacted.
• Two categories will be used: ’major impact’ and ‘non-major impact’. The service provider must exercise professional judgement in identifying the level of impact on each client involved in the incident, with guidance provided by the department.
• All major impact incidents will require specific information to be reported on an individual basis to the divisional office (Local Connections / Health Integration Partnerships for external service providers, Client Outcomes and Service Improvement (COSI) for internal services providers) by the service provider, within 24 hours of becoming aware of the incident.
• All non-major impact incidents will require basic information (including identifiable details of people involved in the incident) to be reported in aggregate (batch) to the divisional office on a monthly basis.
• Service provider CEOs or delegated authorities will be required to review their monthly reports and identify patterns of persistent non-major impact incidents for a specific client, which will trigger a major impact incident to reflect cumulative harm, or other patterns of concern.
Client Incident Investigation Stage
Current systems / CIMS• Separate protocols are documented for follow up between health and human services.
• Involves separate policies on specific types of investigation across services.
• Some programs do not have documented process for investigations.
• The department has a specific role in undertaking some types of investigations, for example, quality of care concerns in out-of-home care. / • Incident investigations will be the primary responsibility of the service provider (including the department where it is the service provider).
• Every major impact incident where there is an allegation of abuse, neglect or unexplained injury must be screened by the service provider for incident investigation.
• The service provider will be required to consider what level of independence is appropriate for each incident investigation. Where the alleged incident involves the abuse or neglect of a client by a staff member, some degree of independence will be required, for example an investigation by a separate business unit or an external organisation.
• Includes minimum standards for an incident investigation, clear thresholds for when an incident investigation will be required, guidelines for when an external investigator should be commissioned, and oversight/quality assurance. The service provider will be required to have robust, documented processes for incident investigations and will be required to submit the incident investigation outcome report to the divisional office (COSI for both internal and external service providers) for quality assurance.
• In exceptional cases, including where the service provider has demonstrated a lack of capability to conduct an incident investigation that meets the standards set out, the department may become involved in the investigation as joint investigation manager.
• Where there are concerns about a service provider’s performance more generally, beyond an individual incident, funded organisation performance monitoring mechanisms such as Service Reviews would be activated. These are to be distinguished from incident investigations.
• Employment and carer schemes and screening processes such as the Suitability Panel and Disability Worker Exclusion Scheme will continue.
• The Quality of Care Guidelines will be superseded by the new CIMS.
Client Incident Review Stage
Current systems / CIMS• Separate protocols are documented for follow up between health and human services.
• Involves separate policies on specific types of review across services.
• Some programs do not have documented process for review.
• The department has a specific role in undertaking some types of reviews. / • In general, the department will not perform reviews of individual incidents itself, except for services it delivers directly. Incident reviews will be the primary responsibility of the service provider (including the department where it is the service provider).
• The purpose of an incident review will be to determine whether the management of an incident was handled appropriately, and to identify any learnings to apply in practice.
• Every major impact incident that does not meet the threshold for investigation, must be subject to either a case review or a more detailed root cause analysis review:
– Case Review: A case review is designed to identify what happened in the incident, and any process and system issues that might have contributed to the occurrence of the incident. A case review must be commenced within 72 hours of receiving confirmation from the divisional office (Local Connections / Health Integration Partnerships for external service providers, Client Outcomes and Service Improvement (COSI) for internal services providers) that it is the appropriate course of action to take, and must be completed within 21 days.
– Root Cause Analysis (RCA) Review: An RCA is a structured review for identifying the causal factor(s) that underlie an incident, in order to facilitate learning from that incident. In contrast, to a case review, RCA is more structured and resource intensive. An RCA requires experienced staff, appropriate resourcing and time. An RCA will only be required in a small number of cases; those involving the most serious and complex incidents. An RCA must be completed within 60 days of receiving confirmation from the divisional office (Local Connections / Health Integration Partnerships for external service providers, Client Outcomes and Service Improvement (COSI) for internal services providers) that it is the appropriate course of action to take.
• Includes minimum standards for an incident review, and clear thresholds for when either a case review or root cause analysis review will be required.
• In circumstances where there is a demonstrated lack of capacity of the Service Provider to undertake a Root Cause Analysis review that meets the minimum standards, the department will have an option to jointly manage the review, with the right to approve the Terms of Reference and select an independent reviewer.
• Where there are concerns about a service provider’s performance more generally, beyond an individual incident, funded organisation performance monitoring mechanisms such as Service Reviews would be activated. These are to be distinguished from incident reviews.
• It is noted that external oversight bodies also conduct reviews, and that some of these reviews occur pursuant to legislative processes. These types of reviews will continue in accordance with current approaches.
Updates to existing policy and procedures
A review and update of all existing relevant policies is underway. A number of existing policies, such as the Quality of Care, Quality of Support Review and Responding to Allegations of Physical and Sexual Abuse guidelines will be superseded by the new CIMS.
Where can I find more information?
Find out more about the development of a new department CIMS on the Client Incident Management page of the department’s Service Providers website <http://providers.dhhs.vic.gov.au/cims>.
If you have any questions about the project please contact CIMS enquiries:
To receive this publication in an accessible format phone 9096 2162, using the National Relay Service 13 36 77 if required, or emailAuthorised and published by the Victorian Government, 1 Treasury Place, Melbourne.
© State of Victoria, Department of Health and Human Services June, 2017.
Available on the Client Incident Management page of the department’s Service Providers website <http://providers.dhhs.vic.gov.au/cims>.
New CIMS policy summary – Updated July 20171