WHO IS ACCREDITED?

Private Organization Accreditation

CSS Healthcare Services provides Community based health services to the young, the elderly and to Individuals with Developmental Disability. Founded in 1997, we have the ability to offer a variety of quality community-based services to our clients, which has greatly contributed to our growth and success.
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ORGANIZATION TESTIMONIAL

Orange County Government, Youth & Family Services Division

Rodney J. Hrobar Sr., LMHC, CPP, Quality Assurance Manager

As the lead agency in Orange County, providing the safety net for children and families, it is reassuring that our clients can be confident that their needs will be addressed in accordance with the most stringent standards of public, as well as private, accountability as monitored and reviewed by the Council on Accreditation. 
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Purpose

The organization’s behavior support and management policies and practices promote positive behavior and protect the safety of service recipients and staff.

FOC
BSM 1: Philosophy and Organization Policy

The organization’s governing body and management promote a safe and therapeutic environment and provide necessary supports and resources to:

  1. keep staff and service recipients safe;
  2. enhance the service recipient’s quality of life;
  3. teach, strengthen, and expand upon positive behaviors; and
  4. minimize the use of crisis interventions.

Update:

  • Revised Standard - 05/07/18

Interpretation: For organizations that permit restrictive interventions, minimizing the use of interventions includes prioritizing a reduction in restraints/seclusions. For organizations that prohibit the use of restrictive interventions, this would result in reduction in the application of their crisis plans or “last resort” interventions (e.g. removing the individual from the program or calling the police).

Research Note: Research shows that leadership and organizational policy place a significant role in the reduction of crisis interventions and in creating more trauma informed-care. By developing policies that emphasizes a reduction in crisis interventions and using pre-identified, individualized means of de-escalation a more therapeutic environment can be developed.

Rating Indicators
1
The organization's practices fully meet the standard, as indicated by full implementation of the practices outlined in the BSM 1 Practice standards.
2
Practices are basically sound but there is room for improvement, as noted in the ratings for the BSM 1 Practice standards.
3
Practice requires significant improvement, as noted in the ratings for the BSM 1 Practice standards.
4
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the BSM 1 Practice standards. 

Table of Evidence

Self-Study Evidence On-Site Evidence On-Site Activities
    • A description of the organization’s BSM philosophy in BSM Narrative Question 1 including:
      1. programmatic and preventive approaches
      2. the spectrum of BSM interventions
      3. procedures/ interventions prohibited by the organization
    • Aggregate of the two most recent quarterly reviews of incidents requiring restrictive behavior management interventions
    • BSM policy and procedures
    • Incident review procedures
    • For organizations using restrictive behavior management interventions, provide documentation of clinical director notification of restrictive behavior management interventions
    • Documentation of compliance with applicable laws or regulations
    • Interview:
      1. Clinical or program directors
      2. Supervisors
      3. Personnel
      4. Persons served
      5. Parents/legal guardians

  • BSM 1.01

    The organization’s behavior support and management policies and practices comply with federal, state, and local legal and regulatory requirements.

    Update:

    • Added Research Note - 05/07/18

    Interpretation: The Public Health Service Act, as amended by the Children’s Health Act of 2000 and the Use of Restraint and Seclusion in Psychiatric Residential Treatment Facilities Providing Inpatient Psychiatric Services to Individuals Under Age 21 are federal regulations that govern the use of behavior management in the United States. Organizations serving youth involved with the juvenile justice system may be subject to different laws and regulations.

    Note: COA recognizes that the laws or regulations governing organizations serving youth involved with the juvenile justice system may sometimes authorize practices that conflict with the standards to which COA holds other organizations, and has addressed some of the potential discrepancies throughout the standards in BSM.

    Note: The organization is required to comply with the more stringent standard or regulation.

    Research Note: Per the federal standards, deaths must be reported promptly. Facilities must also report to agencies designated by the Secretary of the Department of Health and Human Services each death that occurs while a resident is restrained or in seclusion and each death that occurs within 24 hours after the person has been released from the restraints and seculsion or where it is reasonable to assume the death was the result of the restraints and seclusion. The designated agencies are likely to include protection and advocacy systemes, which have unique federal authority to investigate and legally pursue instances of abuse and neglect in facilities. The notification must be provided within 7 days of the death of the individual.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • The organization generally complies with all legal and regulatory requirements, with only minor exceptions noted in reports.
    3
    Practice requires significant improvement; e.g.,
    • The organization does not comply with requirements in at least one major area and is remedying this under the direction of appropriate authorities.
    4
    The organization has a pervasive problem of non-compliance.
    • Implementation of the standard is minimal or there is no evidence of implementation at all.

  • BSM 1.02

    Behavior support and management policies address:

    1. practices used to maintain a safe environment and prevent the need for crisis interventions;
    2. the use of individualized, proactive interventions to identify challenging behaviors, their antecedents, and how to help the service recipient cope and de-escalate;
    3. safety measures to be taken when crisis situations arise, including whether isolation, locked seclusion, manual or mechanical restraint are permitted as emergency safety measures or, when prohibited, other crisis intervention strategies;
    4. other practices that may be used and under what circumstances; and
    5. prohibited practices, including chemical restraint when the organization is responsible for medication administration.

    Update:

    • Revised Standard - 05/07/18

    Interpretation: In regards to element (c), organizations that do not permit any of the restrictive interventions listed should address procedures for when de-escalation techniques do not work and the service environment no longer remains safe for the individual or others (e.g. removal from program or calling the police).

    Interpretation: In relation to element (e), chemical restraint does not include situations when a psychopharmacological drug:

    1. is used according to the requirements for treatment authorized by a court; or
    2. is provided using specified criteria in a person’s approved treatment plan as per a physician’s order to provide medical treatment for a specific diagnosis and known progression of symptoms, such as in cases of a PRN; or
    3. is administered in an emergency to prevent immediate, substantial, and irreversible deterioration of a person’s mental status when prescribed by a physician or other qualified medical practitioner.
    Medications are treatment for targeted symptomtology and should not be considered an intervention for challenging behaviors. Other prohibited practices include, but are not limited to, corporal punishment, behavioral control methods that interfere with the individual’s right to human care, etc.

    Interpretation: Organizations serving youth involved with the juvenile justice system may also be legally authorized to use restrictive interventions to prevent escapes, or protect property, in order to maintain safety, security, and order. However, they should still only employ restrictive interventions when absolutely necessary, as referenced throughout these standards.

    Note: For organizations that have resource parents providing restrictive interventions, those standards can be found throughout FKC, however the organization needs to clearly outline in the policy the interventions resource parents are permitted to apply and under what circumstances.

    Note: Refer to COA’s glossary for a definition of chemical restraint.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • One of the elements needs greater specificity or clarity in policy and/or procedures.
    3
    Practice requires significant improvement; e.g.,
    • Two of the elements need greater specificity or clarity in policy and/or procedures;  or
    • Policies and/or procedures are too vague to provide guidance to personnel.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.
    • One of the elements is not implemented.

  • BSM 1.03

    A committee comprised of all levels of staff conducts regular reviews of the use of behavior support and management interventions and:

    1. compare how organization practices compare with current information and research on effective practice;
    2. use findings from quarterly risk management reviews of crisis interventions to inform staff about current practice and the need for change;
    3. revise policies and procedures when necessary;
    4. determine whether additional resources are needed; and
    5. support efforts to minimize the use of crisis interventions.

    Update:

    • Revised Standard - 05/07/18

    Interpretation: For organizations that prohibit restrictive interventions, information regarding staff’s response to crisis situation should still be collected and reviewed, including the frequency of using last resort intervention (e.g., removal from program or calling the police). 

    Interpretation: Element (d) should include considerations for continuing staff training and education, when appropriate.

    Research Note: Agreement has been reached among experts that the best way to reduce injuries and deaths is to minimize the use of restraints to the greatest extent possible, with leadership creating a shared vision in order to adopt organization wide policies. Reductions in the use of seclusion and restraint can improve both staff morale and treatment outcomes by mitigating burnout, lower staff turnover, and avoid traumatization and retraumatization.

    Research Note: Using data on crisis interventions and their outcomes is helpful in monitoring the progress of organization towards achieving overall treatment outcomes and identifying when more supportive resources are needed. One form of analyses that may be effective to use during regular review is root cause analysis, a systematic process for identifying root cuases of problems or events and an approach for responding to them. It acknowledges that prevention is often not achieved with a single intervention and strives for continuous improvement. This form of analysis is particularly well-suited for behavior support management due to its complex nature and need for re-evaluation on both an individual-level and organization wide.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • One of the elements needs to be reviewed more regularly;  or
    • Elements (a) or (e) is not consistently done.
    3
    Practice requires significant improvement; e.g.,
    • Two of the elements are not reviewed regularly ; or
    • Reviews are not done sufficiently often to monitor practices.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g., 
    • Three of the elements are not reviewed regularly.

  • BSM 1.04

    The program or clinical director is notified following each use of a crisis intervention, including seclusion or manual or mechanical restraint, and each incident is administratively reviewed no later than one working day following an incident.

    Update:

    • Revised Standard - 05/07/18

    Interpretation: The review includes examining any preemptive measures taken to avoid crisis interventions, whether or not the individual’s behavior support and management plan was followed, and the measures’ effectiveness.

    Interpretation: For organizations that permit restrictive behavior management, this would include each use of seclusion or manual or mechanical restraint. For organizations that prohibit restrictive behavior management, this would include strategies utilized in response to crisis interventions, such as calling the police or removal from the program.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Notification and administrative review regularly occur, however procedures need clarifying; or
    • Notification has occasionally exceeded one working day.
    3
    Practice requires significant improvement; e.g.,
    • There have been instances where notification or administrative review did not occur; or
    • Procedures need significant strengthening.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • Notification or review does not regularly occur.
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