Manual - Independent Living Inc. Pediatric Therapy Tampa FL
2009-2010
2007
iNDEPENDENT lIVING, iNC.- pEDIATRICS
Specializing in Home, Clinic, and School-Based Pediatric Therapy
Policy and Procedure Manual
Speech Therapy Occupational Therapy Physical Therapy
Policy and Procedure Manual
Independent Living, Inc.- Pediatrics
6508 Gunn Highway
Tampa, Florida 33625
Phone 813.963.6923 Fax 813.264.0768
Table of Contents
Chapter 1-Standards and Expectations
Mission Statement 5
Ethical Standards 5
Patient’s Rights 5
Licensure Requirements 6
Dress Code 6
Orientation Period 7
Ninety Day Reviews 8
Annual Reviews 8
Cancellations & No Shows 9
Supervision of Clients 9
Transportation of Clients 9
One-on-One Treatment 9
Supervisory Visits 9
Vacations & Time Off 10
Individual Provider Status 10
Clinic Procedures and Expectations 10
Communication 11
Chapter 2- Getting Started: Procedures, Documentation and Patient Care Policies
Getting Started 13
Referral Intake Sheets 14
Authorization Forms 14
Referral Procedures 14
Medical Consent Procedures 15
Authorization Process: Medicaid 15
Authorization Process: Medicaid Waiver, Medicaid HMO’s, CMS, Private Insurance (PPO’s) * 16
Early Steps 17
Timesheets 18
Time Reports 19
Pay Periods 19
Travel Logs & Part C Travel Logs 20
Evaluations / Re-evaluations 20
Daily Treatment Notes 22
Attendance Logs (Hillsborough County only) 22
Discharge Planning & Discharge Summaries 23
Wheelchairs & Wheelchair Clinic: Evaluation, Assessment and Modification 23
Authorization For Therapy Services (AFTS) Form 24
Chapter 3: Supply, Expense and Benefit Guidelines
PRN/Salaried Therapists and Office Staff:
Non-Reimbursable Expenses 26
Reimbursable Expenses 26
Continuing Education 27
Referral Bonuses 27
Medical and Dental Healthcare Plans 28
Consolidated Omnibus Budget Reconciliation Act (COBRA) 29
Employee Savings Plan– 401(k) 29
Other Available Benefits 30
Family and Medical Leave Act – FMLA 30
Workers’ Compensation 32
Change in Job Status 32
Contract Therapists:
Probationary Period and Annual Reviews 33
Reimbursable Expenses 33
Testing Materials 33
Benefits 33
Referral Bonuses 33
Chapter 4: School-Based Therapy
School-Based Therapy 35
Medicaid Policy Regarding School-Based Therapy 35
Policies and Procedures for School-based Therapists 35
Chapter 5: Office Staff Guidelines
Full Time/ Part Time Employment 39
Work Hours 39
Paid Holidays 39
Sick Policy 39
Paid Time Off (PTO) 39
Payroll 399
Annul Reviews 399
Office Equipment/Supplies Use 440
Email Policy 440
Customer Service 44
Forms & Letters 44
Chapter 6: Administrative & Program Management Policies
HIPAA Compliance Standards 474
Records Management 47
Medication Administration 48
Workplace Grievance 48
Non-Discriminatory Employment Policy 50
Anti-Harassment Policy 50
Fair Labor Standards Act – FLSA 51
Confidentiality Statement 51
Infection Control & Universal Precautions 52
Professional Office / Clinic Cleaning 54
Linens 54
Pest Control 54
Administrative Management 55
Governing Body 56
Program Evaluation 56
Personnel Policies 57
Progressive Disciplinary Action Procedures 58
Employment Termination Procedures 58
Reporting Incidents 59
Emergency Management and Disaster Preparedness Plan 60
Chapter
1
Standards and Expectations
Mission Statement
Ethical Standards
Patient’s Rights
Licensure Requirements
Dress Code
Orientation Period
Ninety Day Reviews
Annual Reviews
Cancellations & No Shows
Supervision of Clients
Transportation of Clients
One-on-One Treatment
Supervisory Visits
Vacations & Time Off
Individual Provider Status
Clinic Procedures & Expectations
Communication
Mission Statement
T
he mission of Independent Living, Inc. is to focus on the individual needs of every infant, child, and adult who will benefit from our team of skilled professionals. We will make every effort to provide therapeutic intervention in the most caring, natural environment.
We understand that family members and caregivers are an extremely important part in providing support for their loved ones. We will always include family members and caregivers in planning goals and activities.
Our goal is to help our clients overcome challenges and achieve personal victories.
t
Ethical Standards
T
he vision of Independent Living Pediatrics is to lead the region in pediatric therapy services. We emphasize responsible and ethical business practices and quality patient care. We hold our therapists to this same high standard and expect honesty and integrity in all aspects of the position.
Patient’s Rights
Independent Living Inc.’s primary focus is to provide high quality patient care. We are committed to seeing that our patients receive the quality health care they deserve and expect. ILI has a Quality and Utilization Management Program to build our patient’s confidence that they are getting the care they need from people who care about them. This is how our Quality and Utilization Management Program ensures that we deliver safe, effective, quality health care and services:
We honor our patients’ rights. All of our patients are entitled to be treated in a manner that respects their rights. We recognize the specific needs of our patients and maintain a mutually respectful relationship with them. This is our commitment to the rights of our patients:
✓ Our patients have the right to receive information about our services, our therapists, health care professionals and providers, and our patients’ rights and responsibilities.
✓ Our patients have a right to be treated with respect and recognition of their dignity and right to privacy.
✓ Our patients have a right to participate with their doctors and health care professionals in making decisions about their health care.
✓ Our patients have the right to a candid discussion of appropriate or medically necessary treatment options for their conditions, regardless of cost of benefit coverage.
✓ Our patients have the right to voice complaints or appeals about our outpatient therapy group or care we provide.
✓ Our patients have the right to make recommendations about our patients’ rights and responsibilities policies.
Patient Care Committee Members
Director of Physical Therapy, Occupational Therapy, Speech Pathology Services, & Clinical Coordinator
Meeting Frequency: Annually
Licensure Requirements
T
hose employees whose position requires licensure by the state and/or registration by a professional organization are responsible for keeping such licensure or registration current. This documentation must be provided to Independent Living, Inc. contemporaneously with an acceptance of employment. Copies of professional registration and licensure must be kept updated in the employee’s personnel file. Failure to do so may result in disciplinary action up to and including termination.
Dress Code
E
mployees must maintain a professional appearance when performing job duties. Acceptable attire includes scrubs, slacks, conservative jeans, Independent Living, Inc. (ILI) polo shirts, t-shirts without inappropriate logos or slogans, and knee length shorts. It is not appropriate to wear shorts if you are providing therapy in the school system. School system attire is required in these instances as stated in school system procedures.
Employees treating clients in the clinic or daycare setting must maintain a professional appearance similar to the school system.
Clothing that is unacceptable includes the following:
1. Revealing clothing including half shirts, belly shirts, or low cut shirts
2. Jeans that are ripped, roughed up, revealing, low rise or pants that show undergarments when sitting.
3. Clothing with writing/logos that are offensive or inappropriate in a professional setting.
4. Flip flops
5. Gym attire or shorts that are not knee length.
Orientation Period
N
ew employees and established employees who are promoted to new positions will serve an initial orientation period of 90 calendar days from the first day of treatment during which the employee and ILI may evaluate employment suitability in terms of knowledge, skill, ability, and other relevant considerations. This period is used to determine whether the employment relationship and/or the employee’s promotion are mutually beneficial.
Employment is at-will before and after the initial orientation period and neither the employee nor ILI is bound to continue the employment relationship if either chooses, at its will, to end the relationship at any time, with or without cause and with or without notice.
The procedure is as follows:
A. New employees will participate in an orientation that will be conducted by a therapy supervisor or clinical coordinator explaining the employee's position and minimum performance procedures as it relates to the overall functions of the company. The therapist will be reimbursed $15.00 per hour for their time after successful completion of the 90-day probationary period.
B. New employees will be provided a job description for the position they have filled. Job descriptions may be revised from time to time at the discretion of the supervisor and clinical coordinator. Employees are expected, however, to do any and all other tasks when asked.
C. Department supervisors normally will be responsible for the departmental training and evaluation during the employee's orientation period.
D. Upon satisfactory completion of the orientation period, employees move to regular status and are subject to standard performance appraisal process and other ILI policies.
E. If, during the orientation period, the employee’s performance is deemed unsatisfactory, the clinical coordinator will be advised, and the employee may be terminated.
F. All employees, regardless of status or length of service, are required to meet and maintain ILI standards for job performance and behavior.
Annual Reviews
A
nnual reviews will be completed on the anniversary of the therapist’s actual start date. The therapist is required to submit updated information requested by the Human Resources department in order to process their review in a timely manner. A chart audit will be performed at this time. A sample of the therapist’s current clients will be contacted and surveyed for quality assurance. ILI may give merit increases at the end of the employee’s anniversary month according to the therapist’s performance, as measured on the annual review. Merit increases will not be retroactive if therapist has failed to send in paperwork requested by the Human Resources department or has not made an effort to schedule review with their supervisor. Merit increases will be retroactive if therapist has complied with all requests in a timely manner or if delay in review was the result of scheduling difficulties on ILI’s behalf. ILI reserves the right to impose a salary cap based on the current rate of reimbursement for services. This pertains to both therapists and office staff members.
Cancellations & No Shows
W
hen a family needs to cancel or change an appointment, they are asked to contact our office or the therapist directly and give as much notice as possible. If a family is not home for a scheduled appointment time or cancels their appointment, the therapist should write “no show” or “cancelled by family” on their time sheet. ILI office staff will then mail the family a “No Show” letter. If a family chronically cancels or cancels at the last minute on multiple occasions, the therapy coordinator should be contacted and a request to send a chronic cancellation letter should be made. If the therapist cancels the session, “cancelled by therapist” should be documented on the timesheet for the scheduled appointment. ALL scheduled appointments must be documented on the timesheet, regardless of whether therapy took place. The office staff keeps track of all appointments and whether they are executed.
Therapists must also communicate with the family when they need to make schedule changes. The therapist must call the family if an appointment must be changed or cancelled. ILI has a strict no show/cancellation policy. Each therapist is required to obtain caregiver’s signature on the ILI cancellation and no show policy form. This form should be completed during the first evaluation or therapy appointment and a copy given to the family by the therapist. Please review and discuss the form thoroughly with each family.
Supervision of Clients
I
t is ILI's policy that parent/guardians be present throughout therapy. Please do not allow parent/guardian to leave the premises when providing therapy in the client's natural environment. This becomes a liability issue if something were to happen to the child while exclusively in the therapist’s care.
Transportation of Clients
Do not transport any client or their family members for any reason.
One-on-One Treatment
All therapists must provide one-on-one treatment, meaning that children cannot be seen in a group.
Supervisory Visits
W
hen a PTA or COTA is providing treatment sessions on a regular basis, all patients must have supervisory visits every 30 days. It is the PTA’s or COTA’s responsibility to coordinate supervisory visits and document supervising therapist for each client on each timesheet. If there is not a supervising therapist, then it is the PTA’s or COTA’s responsibility to contact their Supervisor or therapy coordinator for assistance. Whenever possible, supervisory visits should be completed by the PT or OT who wrote the evaluation.
The supervising therapist can co-treat** with the assistant ONLY when the patient has Medicaid. PT’s or OT’s: if you would like a few extra hours, please contact your service coordinator to pick up some extra supervisory hours.
Evaluations should state the frequency plus an additional monthly visit when a PTA or COTA will be seeing a patient on a regular basis. (Example: “PT is recommended 2x per week, plus one supervisory visit per month.”)
**For group insurance, other, or Part C- supervising therapist can not co-treat with the assistant, it must be done as an independent treatment.
Vacations & Time Off
I
f a therapist plans on taking a vacation, they must notify their supervisor and therapy coordinator at least 30 days in advance. This allows the therapy coordinators sufficient time to find coverage while the therapist is on vacation. If a therapist takes time off due to an illness, they must contact their families to rearrange their therapy appointments.
Individual Provider Status
Each ILI therapist (both employee and contractor) are required to maintain their provider status for the Early Steps program, Medicaid and other insurances. This includes following enrollment procedures, expectations and continuing education requirements and/or minimum training requirements. Failure to return paperwork mailed out and requested by the office within 10 days or to maintain provider status for any current or new programs/ insurance will reflect poorly on the annual review and may result in probation or termination of employment.
Clinic Procedures and Expectations
Therapists who treat clients in one of our outpatient clinics are required to schedule their clients with the receptionist. Each therapist must document their treatment sessions and evaluations on a yellow clinic timesheet. This should be turned in with their home based therapy timesheet following the same payroll schedule. PRN rates for therapy and evaluations provided in our outpatient clinic will be reimbursed at 80% of the therapist’s home-based rate.
Therapists are expected to clean up after each session. This includes placing toys/materials back in their original location and disinfecting their area with the provided materials and/or chemicals. If a therapist is treating after hours, it is their responsibility to follow the closing procedures completely, which includes locking the doors properly and setting the alarm system. It is also their responsibility to coordinate access to a key.
Equipment will be assessed quarterly for safety by team leaders, clinical coordinator and/or appropriate vendor.
Parents and caregivers are allowed to leave during their scheduled therapy session for the clinic only. A medical release form must be completed and placed in the permanent file. The parent/caregiver is expected to return 10 minutes prior to the end of their child’s therapy session. They are also required to leave their cell phone number or an emergency contact number with the therapist prior to leaving. Review of the attendance policy is required including caregiver signature on the cancellation and no show policy form. Parents/caregivers who do not adhere to the above policy will no longer be allowed to leave during their child’s therapy session.
Communication
It is each therapist’s responsibility to have internet access, check their email on a regular basis (minimum 2-3 times per week), and return phone calls from the office within a 24 hour period. Please refrain from cell phone use while with a client.
Chapter
2
Getting Started: Procedures, Documentation and Patient Care Policies
Getting Started
Referral Intake Sheet
Authorization Form
Referral Procedures
Medical Consent Procedures
Authorization Process:
Medicaid
Medicaid Waiver
CMS/Other Insurance
Early Steps
Timesheets
Time Reports
Pay Periods
Travel Logs & Part C Travel Logs
Evaluations & Re-evaluations
Daily Treatment Notes
Attendance Logs (Hillsborough County Only)
Discharge Planning & Discharge Summaries
Wheelchair Assessments & Wheelchair Clinic:
Evaluation, Assessment and Modification
Authorization for Therapy Services (AFTS) Form
Getting Started
W
e have compiled a list of items that will help make scheduling your clients and getting started a smooth process. Please read the following hints and tips. If you have any questions or difficulty getting started, call your supervisor or therapy coordinator to assist you.
✓ Make a list of all of your patient’s phone numbers and office numbers…keep them with you in a convenient place.
✓ Utilize a schedule book or form in fifteen minute increments.
✓ Develop an organizational strategy that works for you, such as a 3-ring binder, file box etc…
✓ Utilize a program like Mapquest to help you locate families and determine how much drive time will be needed. When in doubt, give yourself extra drive-time allowance.
✓ Plot your caseload on a map with Post-It notes to give yourself a visual representation of your caseload. After realizing the “whole picture”, it will make scheduling easier and keep drive time to a minimum.
✓ Give yourself a window of time to be at a patient’s home, i.e. “I’ll be here to see Johnny between 3:00 and 3:15, depending on traffic”. Let families know that you will call them if you will be more than 15 minutes late.
✓ Keep good documentation of phone calls with families and write down any attempts to contact families.
✓ When leaving a message for families initially to set-up their appointment, let them know that the sooner they are able to get back to you, the better chance they will have at their desired appointment time.
✓ Inform parents when initially scheduling clients that they are required to cancel appointments 24 hours in advance by contacting either the therapist personally or the office.
✓ Call your therapy coordinator if you are having difficulty scheduling a patient or are experiencing frequent no-shows/cancellations.
✓ If you have a patient that frequently no-shows, let the family know that you will be calling them after leaving your previous patient’s home and if they do not answer the phone, you will not provide therapy that day and the visit will be counted as a “no show”.
✓ Provide your families with appointment cards with your phone number on it…you may want to post this on the refrigerator or somewhere they will notice it. Appointment cards are available in the office.
✓ If a family notifies you of a change in insurance or personal information (i.e. phone number’s, address, physician, etc.), please contact the therapy coordinator.
Referral Intake Sheets
T
hese forms are used to provide the therapist with information they need to contact the client's family to set up an evaluation or therapy appointment. Please refer to this form for identifying information such as: name, address, phone number, date of birth, diagnosis, insurance information, contact, physician's name and address, and any other pertinent information. Please use this form to keep notes such as location therapy will be provided, helpful hints and/or notes to help organize the client's information.
Authorization Forms
A
uthorizations forms are used to provide the therapist with their orders such as insurance information, type of service requested, frequency, duration, billing information, number of authorized visits, etc. It is each therapist's responsibility to track the authorization period and the number of visits approved for each client. Please document each visit on this form. When there are only 2 or 3 visits left, it is the therapists’ responsibility to contact the billing department at ILI to request more visits. If a therapist provides treatment past either the authorization period or authorized visits, ILI will not reimburse for their treatment time. It is very important to have accurate documentation.
Referral Procedures
I
LI has a “time line” policy as a guideline for scheduling new patients. Please use the following guideline for all referrals:
1). ILI calls or emails a therapist to check availability to take a new patient.
2). If the therapist agrees to take the new patient, ILI will mail the patient info, authorization form, no-show policy, etc. The therapist must attempt to contact the parent within 24 hours of receiving the patient information.
3). Each therapist must evaluate or initiate treatment for a new client within 7 days of accepting the referral (if applicable). If this is not possible, ILI must be informed in order to document any problems in the patient’s chart.
4). Contact your therapy coordinator if you wish to reassign, shift or remove a client from your caseload. You must give the coordinator 30-day advanced notice to find another therapist in order to maintain continuity of care.
Contact the therapy coordinator if you have any problems contacting the patient or if you need to reassign a client for any reason. This allows the therapy service coordinator sufficient time to locate a new therapist in order to maintain continuity of care.
Medical Consent Procedures
T
he medical consent form must be signed by a parent or guardian before an evaluation or treatment can be initiated. The medical consent form may or may not be included in the paperwork for a new client. If it is included, please obtain the parent or guardian's signature and return with your timesheet. The authorization form will reflect whether or not it is your responsibility to obtain medical consent from a client's family. If you have any questions, contact the therapy coordinator. Evaluations and/or treatment may not be initiated without a completed medical consent form
Authorization Process: Medicaid
M
edicaid is a federally funded program available for children birth to twenty-one years of age. Clients must qualify for Medicaid funding.
✓ Medicaid allows for a maximum of 60-minute treatment sessions, however standard treatment time is 30 minutes unless medical necessity is documented.
✓ The maximum allowable treatment time is 3.5 (14 units) hours per week for each discipline.
✓ One unit is a minimum of 15 minutes.
✓ If a child is also receiving therapy from a school that is billing Medicaid, the total therapy time must not exceed the maximum of 3.5 hours between the school and ILI combined.
The following procedures must be followed when working with a client who is funded by Medicaid:
Evaluations
1. COMPLETE THE EVALUATION, INCLUDING A REASON FOR MEDICAL NECESSITY FOR 60 MINUTE SESSIONS, IF APPLICABLE. REASON MUST BE MEDICAL AND NOT EDUCATIONAL.
2. Send your Evaluation to ILI with your timesheets. If an evaluation is completed several days before your timesheets are due, please mail ILI the evaluation and write the date mailed to ILI on your timesheet. This will speed up the authorization process.
3. If treatment authorization is pending for 2 weeks, call ILI (medical records dept.) to check authorization status.
4. A therapist can only bill one hour for an Evaluation. Complete a treatment note for the evaluation visit listing “Evaluation”. Have parent/caregiver sign verifying session.
Re-evaluations
1. THERAPISTS ARE RESPONSIBLE FOR KEEPING TRACK OF EVALUATION PERIODS AND COMPLETING RE-EVALUATIONS. IF YOU ARE UNSURE OF AN EVALUATION PERIOD, CALL ILI (MEDICAL RECORDS DEPT.). IF THE PATIENT IS UNDER THE AGE OF 21 YEARS OLD, EVALUATION PERIODS CANNOT EXCEED SIX MONTHS AND A RE-EVALUATION MUST BE COMPLETED. COMPLETE THE RE-EVALUATIONS 6 WEEKS PRIOR TO THE EXPIRATION DATE TO ALLOW TIME FOR THE DOCTOR TO SIGN AND SEND THE AUTHORIZATION BACK.
2. When documenting the next evaluation period on your Re-evaluation, make sure that the dates do not overlap with the current evaluation period. This will maximize the amount of time that the therapist has before the next evaluation is due. The evaluation period date IS NOT the date the re-eval is administered, rather it is the day after the current 6 month evaluation period expires.
3. Mail documentation to ILI
Authorization Process: Medicaid Waiver, Medicaid HMO’s, CMS, Private Insurance (PPO’s) *
Medicaid Waiver
M
edicaid Waiver guidelines apply to patients that are 21+ years old. The Evaluation must be mailed to the PCP and authorization must be obtained from the PCP and the Medicaid Waiver support coordinator.
❑ Only one Evaluation can be done per year with prior authorization.
❑ A Monthly Progress Summary must be completed and turned in to ILI by the 2nd of the following month of treatment.
❑ Daily Treatment Notes must also be completed after each visit and turned in with the timesheets bi-weekly.
❑ A two page Progress report is due 3 months prior to the expiration date.
❑ Evaluation periods are for 1 year.
❑ All Therapists treating Medicaid Waiver clients must attend a three hour training. Please familiarize yourself with the Medicaid Waiver information provided in a packet at orientation.
Medicaid HMO’s / Healthy Kids / Group Insurance / CMS
❑ THERAPY MUST HAVE PRIOR INSURANCE AUTHORIZATION.
❑ If the patient is changing to/from an HMO, call ILI to get authorization for continued therapy.
❑ Authorizations will vary according to the type of insurance. Check with ILI for details.
*The above insurances will always go in the “Other” column on your timesheets.
Early Steps
T
he Early Steps Program (also known as Part C) is available to children ages birth to three. Children have to qualify for this program based on developmental standards and expectations. Independent Living provides therapy services in the natural environment for this population. The Early steps program has undergone significant changes in the past few years including a name change and a model change. It has changed from a “medical model” to a “coaching model” or “primary service provider model”. Services are provided in the child’s natural environment and treatment goals and objectives are embedded into the family’s everyday routines. A few key points will be defined with regards to documentation and expectations for the Early Steps Program. For further clarification, please refer to the service delivery manual provided by the Early Steps Program at orientation.
The following terms will be defined for documentation purposes.
Eligibility Evaluation (EE)- an evaluation completed by a multidisciplinary team consisting of an Early Steps service coordinator, Early Interventionist, and Healing Arts Specialist (i.e. therapist). This is billed on the timesheet under column E. Therapists are reimbursed their regular rate per Eligibility Evaluation based on the amount of time up to 2 hours. Total the amount of time for EE’s and carry this number to the bottom right hand corner of the timesheet.
Indirect Consult (IC)- a consultation between team members for a Part C client. These are meetings conducted via telephone, or face to face and does not involve direct contact with the child. This is reimbursed at a rate of $18.00 per hour. This must be documented and authorized on the IFSP to be reimbursed. IC’s can also be requested for weekly phone calls to parents/caregivers when client is seen at daycare or when the parent is not present during the session. Consult forms must be completed and submitted with time sheets in order to be reimbursed for this time.
Direct Therapy Consult (DC)- a therapy session or co-treat session with another provider involving direct contact with the client. These visits are in addition to the visits authorized for each discipline on an IFSP. This must be built into the IFSP and authorized in order to bill for your time. Reimbursement is your regular rate of pay. A consult form must be completed and included with your timesheet for reimbursement.
Re-evaluations- cannot be conducted without prior authorization from the child’s Early Steps service coordinator. Please contact the ILI therapy coordinator when needing authorization for a re-evaluation. They will contact the appropriate service coordinator to obtain the necessary authorization. DO NOT initiate therapy or complete an evaluation based on information provided from an Early Steps service coordinator. We need the actual authorization IN WRITING on site before a therapist may initiate any service for an Early Steps client. The treating therapist will receive an authorization form from their ILI therapy coordinator once proper documentation has been received from Early Steps. A re-evaluation may not be necessary
Please review the Part C handout and manual provided at the orientation for new employees.
Timesheets
T
imesheets can either be dropped off at the office or sent by mail; faxes of timesheets and documentation are only accepted if Monday is a post office holiday. They must be legible and include location of session, supervisor’s name (if applicable). Timesheets are turned into ILI no later than every other Wednesday (see schedule) and must include a list of every client on your caseload regardless of whether treatment was provided during that time period. Timesheets that are turned in after Wednesday will not be processed until the next scheduled pay period. If a timesheet is more than one pay period past due according to the pay schedule, the employee will not receive reimbursement for the amount billed until ILI is reimbursed for all Early Steps, insurance or private pay clients. Failure to submit timesheets each pay period may result in probation and/or termination.
Timesheets must be turned in with: Part C travel logs (if applicable), all Daily Treatment Notes, Evaluations, Re-evaluations, Discharge Summaries, Early Steps Attendance Logs (if applicable) and Monthly Progress Reports.
Time Reports
A
ccurately recording time worked is the responsibility of every employee. Time worked is all of the time actually spent on the job performing assigned duties. Employees are required to accurately record the time they begin and end their work. It is the employee’s responsibility to sign his or her time record to certify the accuracy of all time recorded. If a question arises regarding hours worked, contact the Human Resources Department.
Times written on time sheets should be as follows: 15 minutes = .25
30 minutes = .50
45 minutes = .75
60 minutes = 1.0
Pay Periods
T
he employee’s pay is calculated bi-weekly. The following options are available for employee paycheck / pay stub distribution:
1. Direct Deposit. This option will automatically deposit an employee’s payroll check into the bank account they designate and generate a pay stub for their records. All pay stubs will be mailed to the employee’s home address.
2. Receipt of a Paycheck. This option will generate an actual payroll check which will be mailed to the employee’s home address.
If a holiday falls on a Thursday, Friday, or Monday, paychecks and direct deposits will be delayed by one day.
Travel Logs & Part C Travel Logs
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ravel Logs are turned in with your timesheets for therapists who are reimbursed for travel when approved by a supervisor and/or when Part C has authorized travel.
Part C Travel Reimbursement Guidelines:
Part C travel reimbursement is a maximum of 60 minutes for Hillsborough County Only. See the “Sample Travel Log” in the orientation notebook for details. A separate log needs filled out for each client. Part C travel logs are separate from the general travel logs. Travel reimbursement rates are based on current reimbursement rates set by Early Steps, then adjusted to risk share. Please contact the billing department for current rates.
General Travel Reimbursement Logs:
Therapists are reimbursed for mileage in special situations only. Please record the mileage and client name from one client to the next on the log. Do not include from home to the first client or from last client home unless otherwise approved. Transfer total miles to the front bottom corner of timesheet and turn in every two weeks with paperwork.
Evaluations / Re-evaluations
E
valuations and Re-evaluations must be typed or neatly written in black ink on ILI’s evaluation forms and must include the following:
✓ Evaluation period dates that are the same calendar date (that do not overlap)
✓ Name of patient.
✓ Name of evaluating therapist.
✓ Date of Evaluation or Re-evaluation: Date you are performing assessment.
✓ Medical & Therapy history (include this on both evaluations and re-evaluations).
✓ Prematurity is measured in weeks, not months. Normal gestation is 40 weeks, if parent says baby was born 6 weeks early, record as 34 weeks gestation. Corrected adjusted age versus chronological age should be documented and considered up to 2 years of age.
✓ Diagnosis (not just doctor’s diagnosis, but the therapist’s clinical diagnosis following an evaluation).
✓ Objective data.
✓ Severity Rating (see below for chart)
✓ Equipment needs.
✓ Methods of caregiver training.
✓ Assessment- implement and document the use of standardized testing (if applicable). Must reference reason for not using standardized test. Must include age equivalence for developmental skills. Contact human resources at ext. 235 for materials.
✓ Plan of care.
✓ Previous time-related measurable long and short term goals/ objectives (re-eval only).
✓ Time-related measurable long and short term goals/ objectives.
✓ Frequency, duration and estimated length of treatment sessions**
✓ Document the frequency/duration recommended versus the amount authorized for.
✓ Professional signature, credentials and date (including year).
✓ Approved abbreviations (see approved abbreviation list)
It is the responsibility of the evaluating therapist to determine the frequency of treatment for each patient. This will often require additional phone calls and conversations explaining the plan of care and recommendations to both physicians and caregivers. If functional goals are not being met over a period of time, then treatment frequencies need to be adjusted accordingly. Please keep this in mind when completing evaluations & re-evaluations.
** When a therapist recommends treatment for more than 30-minute sessions, medical necessity must be documented (see Evaluation Recommendations). If a therapist cannot incorporate all of the visits recommended for a client into their schedule, the other visits can either be shared with another therapist or put on a waiting list to be picked up by another therapist. Please contact your therapy coordinator if you cannot incorporate all of the recommended visits into your schedule.
Severity Rating Chart based on Standard Scores (please use as a baseline and/or guideline):
90-85= Mild
84-80= Mild-Moderate
79-75= Moderate
74-70= Moderate-Severe
69-65= Severe
64-60= Severe-Profound
59-< = Profound
Please keep in mind that professional/clinical judgment may differ from the above scale. If that is the case, document the reasoning for assigning a different severity rating with supporting documentation or notes reported on evaluation/re-evaluation.
Daily Treatment Notes
I
n order to ensure that we have proper documentation and procedures are followed properly, we require that you complete the daily treatment notes in the following way. Daily treatment notes may be in SOAP or narrative format. (All areas of the treatment note must be addressed)
1. Fill out the patient's name and date of birth.
2. Circle where the treatment session took place.
3. Progress Achieved section: This section should include qualifiers such as; min assist, 3/5 trials, 75% accuracy and so forth. There should be an adequate amount of detail and qualifiers so that treatment can be duplicated if another therapist were to begin treating the client.
4. Change In Status section: Document any global changes that you or a caregiver have observed in the patient. This is not necessarily specific to the treatment session, but a generalized direction that you are seeing in the patient's status. If there is a regression, document this and report any reason for the decline, i.e. recent hospitalization.
5. Circle: Continue Plan of Care (POC), Discharge or On Hold Due To. If the client is placed on hold, write in the reason and write “On hold” or “Discharge” on your timesheet with the reason.
6. Fill in date, time in/out and have the parent/guardian sign at the conclusion of the session after the treatment time has been filled in. If the child was seen in a school or daycare, write "see attendance log" in the signature space. Do not ask a teacher to sign for you.
7. Please write legibly in black ink and include your credentials behind your signature. Remember, protect yourself with documentation.
Attendance Logs (Hillsborough County only)
A
ttendance logs must be filled out for every child ages birth to three in Hillsborough County. Use a separate log for each child. The parent/ guardian must sign each entry for each visitation. The daily treatment notes do not need to be signed if attendance logs are being used. Send attendance logs in with your timesheets and treatment notes.
Discharge Planning & Discharge Summaries
Discharge planning is an important part of therapy. We want each child to meet specific, functional goals as quickly as possible. Discharge from therapy will occur when:
✓ The client has met established goals.
✓ The client is no longer making progress in therapy.
✓ The client has a medical or behavioral problem, which interferes with therapy.
✓ The client is unable to attend at least 80% of scheduled therapy sessions.
✓ The client has three no-shows, has cancelled or arrives late in the clinic for scheduled appointments (missing over half of therapy session) more than two times in one month.
✓ The client’s family withdraws them from therapy.
✓ The parent/guardian does not participate during at least 50% of the treatment sessions, does not follow through with home program and/or does not communicate with therapists regarding their child’s progress if not present during the therapy sessions.
✓ The physician asks that the client be discharged.
✓ The therapist(s) feel that the treatment site is unsafe in any way and arrangements to move the treatment site to a different/safe location is not possible.
Discharge summaries must be completed within 7 days of being discharged. Discharge summaries must include progress toward goals and must be submitted with timesheets.
*A note about discharges: Please do not discharge a client if you are recommending a re-evaluation in 6 months or a year to check for carryover of skills. A discharge is not necessary for children who are going on hold or are being terminated from a therapist’s caseload where another therapist is picking up the client.
Wheelchairs & Wheelchair Clinic: Evaluation, Assessment and Modification
T
here are a few pediatric, custom wheelchair vendors in the area. Parents & caregivers have the right to use any vendor they choose. However, ILI therapists have worked mainly with Custom Mobility. They can be reached at: 1-800-622-5151.
We currently offer wheelchair clinic at ILI monthly, in conjunction with Custom Mobility.
• PT’s are reimbursed 1 hour of time for wheelchair evaluations under Medicaid guidelines.
• There is a FL Medicaid form that must be completed by the evaluating PT and wheelchair vendor. Be sure to put “wheelchair eval” on your time sheet for billing purposes.
• A letter of medical necessity may be requested in addition to this form; however, that is included in the 1-hour time reimbursed for the evaluation.
• The PT is also reimbursed 1 hour for a “wheelchair fitting” once they receive the new chair. Be sure to indicate, “wheelchair fitting” on your time sheet.
• Wheelchair modifications to patient’s current wheelchair will require a letter of medical necessity that is not reimbursed in addition to their PT treatment visits.
Authorization For Therapy Services (AFTS) Form
T
his form is used for requesting a change in treatment frequency and/ or duration. The therapy coordinator may fill out this form to get the correct authorization from the client’s physician. If a therapist would like to request an increase in frequency or duration, contact your therapy coordinator and fill out the form. You will be contacted when the billing department has received the authorization.
Chapter
3
Supply, Expense and Benefit Guidelines
PRN/Salary
Non-Reimbursable Expenses
Reimbursable Expenses
Continuing Education Requirements
Referral Bonuses
Medical and Dental Healthcare Plans
COBRA
401 K
Other available benefits
Family Medical Leave Act (FMLA)
Workers’ Compensation
Change in status guidelines
Contract
Probationary Period/ Annual Reviews
Reimbursable Expenses
Testing Materials
Benefits
Referral Bonuses
The following guidelines apply to those therapists and office staff who are employees only.
Non-Reimbursable Expenses
C
ellular phones, pagers, tolls, phone calls and faxes are not reimbursable expenses. Copies of documentation for the therapist’s personal records are not reimbursable. Copies of blank paperwork are also not reimbursable. All ILI forms are available for no charge through the office.
C
opies of most forms are also available on the website at . Upon visiting the website for the first time, you must request a login from the home page. An email will be sent to you confirming your ability to access the website. Please contact human resources if you do not gain access within 48 hours of your request. Copies are also available in the office. Contact either the receptionist or human resources if you need any copies sent to you.
Reimbursable Expenses
All reimbursable expenses must be recorded on an expense reimbursement form and submitted with timesheet for supervisor’s approval (with the exception of postage).
Postage
P
ostage is reimbursed to a therapist when mailing payroll documentation or returning testing materials to ILI. Regular 1st class mail rates are reimbursed. The postage expense must be written on the time sheet. Any postage reimbursement over $1.00 must include the receipt attached to the timesheet.
Treatment Supplies
T
herapists can be reimbursed an allotted amount as agreed upon for supplies used during therapy, such as toys, balls, mats, exercise equipment, etc each year from his/her date of hire. These supplies will be reimbursed when written on the expense form, submitted for supervisor’s approval and a receipt is attached after successful completion of their 90 day probationary period. If the therapist does not maintain employment with ILI for one year within the reimbursement period, then a prorated amount will be deducted from his/her last paycheck.
Testing Supplies
T
esting supplies may be checked out for the therapist’s use for a period of two weeks. Protocols will be provided as needed for employees only. Contract therapists must provide their own protocol. Postage will be reimbursed for any testing supplies returned by mail to ILI. Testing materials must be returned prior to termination of employment, otherwise the total cost of the testing materials will be deducted from the last paycheck.
Continuing Education
T
he purpose of this policy is to assist employees in obtaining continuing education units or training pertaining to the pediatric population. It is also meant to increase their knowledge regarding evaluation and treatment techniques and to maintain professional licensure. Reimbursement rates will be based on ILI’s CEU/Supply allotment tier combined with your average hours at time of request and will be based on the prior 4 pay period average. Reimbursement must be recorded on an expense form and submitted for supervisor’s approval.
A. An employee must be employed with Independent Living when the course is completed in order to qualify for reimbursement. Each therapist is eligible for reimbursement after successful completion of their 90 day probationary period.
B. Therapists who attend a CEU course must provide a copy of their certificate of completion and a receipt of payment with their request for reimbursement. They also may be asked to present the course information during a scheduled in-service meeting for other Independent Living employees.
C. If the therapist does not maintain employment with ILI for one year within the reimbursement period, then a prorated amount will be deducted from his/her last paycheck.
Referral Bonuses
New Therapist Referral
R
eferral bonuses may also be given to a therapist employed by Independent Living- Pediatrics for referring therapists. The therapists may be given a bonus of up to $100.00 per therapist referred to ILI. The bonus will be paid after the referred therapist completes their first 6 months of employment and has billed a minimum of 100 hours. Referral bonuses must be requested within the therapist’s first 30 days of employment, recorded on the expense form and submitted for supervisor approval.
Bonuses will not be given if the following criteria apply:
A. Another therapist has previously referred the therapist to ILI
B. The therapist was previously employed with ILI
C. The therapist was paid or compensated to recruit therapists through marketing, conventions or conferences.
Medical and Dental Healthcare Plans
F
ull-time employees are eligible to participate the 1st day of the month following 90 days of full-time employment within the same three month period. Therapists are considered full-time when working 25 or more hours per week. A minimum of 25 treatment hours per week must be maintained to receive health benefits through ILI. Average number of treatment hours will be checked quarterly. If average hours fall below 25 hours per week over a three month period, the therapist will be placed on COBRA and will be responsible for paying the total premium through payroll deduction for the following quarter. If the required hours increase back to 25 per week, ILI will resume the agreed amount of premium.
Both you and Independent Living Inc. share the cost of these benefits. Your contributions will be automatically deducted each payroll period. Deductions begin one month prior to the start date of the insurance policy. These benefits are described in greater detail in the appropriate enrollment materials.
Consolidated Omnibus Budget Reconciliation Act (COBRA)
I
n accordance with the Consolidated Omnibus Reconciliation Act of 1986, as amended (“COBRA”), regular full time employees have the opportunity for continuation of health coverage under the group plans. A regular, full time employee and any covered dependent(s) may elect continuation of health coverage. If the medical insurance of any covered employee or covered dependent(s) ends, the employee or covered dependent(s) may elect to continue such insurance. Insurance must end due to a qualifying event, which is described as follows:
A. Voluntary or involuntary termination (other than for gross misconduct) or the reduction of hours of your employment.
B. Employee’s death.
C. Employee’s divorce or legal separation.
D. Employee or covered dependent’s child ceasing to be an eligible dependent.
E. Employee becoming entitled to Medicare benefits.
If any of the above mentioned events occur, please notify human resources immediately. If you do not receive notice of your right to benefits under COBRA, contact the Director of Human Resources.
Employee Savings Plan– 401(k)
I
ndependent Living, Inc. has established a 401(k) Plan to help employees supplement their retirement income. The Plan is a retirement plan whereby the Company contributes twenty-five cents on the dollar for up to 6% of the employee’s salary. The employee may contribute up to 15% of their salary to their 401(k) Plan.
With automatic payroll deductions, contributions go directly from the employee’s paycheck to the deferred compensation account before the government considers it taxable. Interest or earnings on contributions also accumulate on a tax-deferred basis. Employees will not pay taxes on the money contributed or the interest income until the employee begins withdrawing funds, generally at retirement.
All regular full time employees of Independent Living, Inc. who meet the criteria listed below are eligible to enroll in the Independent Living, Inc. 401(k) Plan. Eligibility criteria are as follows:
A. Employee must meet federal minimum age requirements.
B. Employee must be employed by ILI for a minimum of one year.
C. Employee must work a minimum of 1,000 hours within any one-year
period.
Other Available Benefits
I
ndependent Living also offers life insurance, short and long-term disability insurance and health savings accounts (HSA). Joining a plan can occur at any time throughout the year, however, the premium deductions can be pretax dollars only if joining during the open enrollment period. If you join any other time of the year, the premiums are not pretax, but can be changed over when the open enrollment period begins. Please contact the benefits administrator for more information.
Family and Medical Leave Act – FMLA
Eligibility for Leave
UNDER FEDERAL LAW, ELIGIBLE EMPLOYEES ARE ENTITLED TO TAKE UP TO TWELVE (12) WEEKS UNPAID LEAVE PER CALENDAR YEAR:
A. For the birth of a child and to care for a newborn child;
B. For placement with the employee of a child for adoption or foster care;
C. To care for the employee’s child, spouse or parent with a serious health condition;
D. Because of a serious health condition that makes the employee unable to perform the junctions of his or her job.
An employee is eligible for Family and Medical Leave if the employee has been working for Independent Living for at least twelve (12) months before the leave request and the employee has worked at least 1,250 hours during the twelve (12) months immediately preceding the commencement of leave.
A “serious health condition” entitling an employee to FMLA leave is an illness, injury, impairment or physical or mental condition that involves:
A. Inpatient care (an overnight stay) in a hospital, hospice or residential medical care facility, and any period of incapacity or any subsequent treatment in connection with such inpatient care;
B. Any period of incapacity (inability to work, attend school or perform regular daily activities due to the serious health condition) of more than three (3) consecutive calendar days that also involves continuing treatment by (or under the supervision of) a health care provider;
C. Any period of incapacity due to pregnancy or for prenatal care;
D. Any period of incapacity or treatment for such incapacity due to a chronic, serious health condition involving continuing treatment by or under the supervision of a health care provider;
E. A period of incapacity which is permanent or long-term due to a condition for which treatment may not be effective that involves the continuing supervision of a health care provider; or
F. Any period of absence to receive multiple treatment by a health care provider either for restorative surgery after an accident or other injury, or for a condition that would likely result in a period of incapacity of more that three (3) consecutive calendar days in the absence of medical intervention or treatment, such as cancer, severe arthritis, or kidney disease.
Unless complications develop or inpatient hospital care is required, the common cold, flu, earaches, upset stomach, minor ulcers, headaches other than migraines, routine dental or orthodontia problems, periodontal disease and cosmetic treatments are not serious health conditions.
Upon completion of such leave, the employee will be allowed to return to the same positions or an equivalent position with no loss of pay, benefits or other employment status.
Notice and Certification
IF LEAVE IS FORESEEABLE BECAUSE OF THE EXPECTED BIRTH OR PLACEMENT OF A CHILD OR PLANNED MEDICAL TREATMENT, THE EMPLOYEE MUST GIVE THIRTY (30) DAYS ADVANCE NOTICE TO THE COMPANY. WHEN THE NEED FOR LEAVE IS NOT FORESEEABLE, THE EMPLOYEE SHOULD GIVE NOTICE TO THE COMPANY OF THE NEED FOR FMLA LEAVE AS SOON AS POSSIBLE. IT IS EXPECTED THAT AN EMPLOYEE SHOULD GIVE NOTICE TO THE COMPANY WITHIN NO MORE THAN ONE OR TWO WORKING DAYS OF LEARNING OF THE NEED FOR LEAVE. IN CASE OF AN EMERGENCY, THE EMPLOYEE OR A FAMILY MEMBER SHOULD NOTIFY THE APPROPRIATE MANAGER OR SUPERVISOR AS SOON AS POSSIBLE TO ALLOW THE COMPANY TO MAKE ANY NECESSARY ARRANGEMENTS OR ADJUSTMENTS.
If the employee cannot return to work on the expiration date of the leave, he or she should request an extension of leave, in writing, and supply a doctor’s statement supporting the need for the extended leave. If an employee is not back at work on the day the leave of absence expires, the employee is considered to have abandoned his or her job and to have voluntarily quit, unless he or she has previously submitted a written request with certification for approval. If the extension is denied, the employee will have one day after notification to return to work.
An employee may also be entitled to leave under the relevant state statutes.
Workers’ Compensation
E
mployees injured on the job may not be responsible for medical bills that result from injury. Additionally, employees may be eligible for lost wages under state workers’ compensation law. Injured employees must complete an incident report within 24 hours of the incident and inform both the supervisor and the Human Resources Department. Failure to report such incidents may result in denial of the claim.
Employees may be eligible for FMLA, ADA, Military and Worker’s Compensation leaves. All leaves run in conjunction with FMLA.
Contact your Supervisor or Human Resources within 24 hours if you incur an injury on the job.
Change in Job Status
I
f a therapist changes from part-time to full-time status, they become eligible for benefits after billing at least an average of 25 hours per week over a ninety day period. When a therapist reduces the average amount of hours billed, they no longer qualify for full-time benefits and are subject to the reimbursement rates for CEU/supply allotments relative to the average number of hours billed per week.
The following guidelines pertain to those therapists who are Contract only
Reimbursable Expenses
Contract therapists are not eligible for reimbursable expenses such as CEU’s, postage, treatment supplies, copies, or any other expense such as Medicaid application fee, fingerprinting fee, or reimbursement for orientation.
Testing Materials
Tests will not be mailed for contract therapists to borrow and they must provide their own protocol. Postage will not be reimbursed to return the items. All other procedures regarding checkout and return of testing materials apply.
Benefits
Contract therapists are not eligible for benefits such as health, dental, 401K, FMLA, life insurance or supplemental insurance.
Chapter
4
School-Based Therapy
School-Based Therapy
Medicaid Policy Regarding School-Based Therapy
Policies and Procedures for School-Based Therapists
Mission
Purpose
School Assignments
Code of Conduct
Job Expectations
Important Contacts
Attendance Logs
Attendance Procedures
Expense Reimbursement/ Mileage Reimbursement
Hours
Other
H
School-Based Therapy
illsborough, Pasco and Pinellas County schools will not allow ILI therapists to see children in their school for OT, PT or Speech Therapy.
Therapists hired to provide services to children in the school system
must follow school district procedures in addition to the policies and procedures listed below.
Policies and Procedures for School-based Therapists
Mission
To provide quality school- based therapy to the local school district.
Purpose
Independent Living, Inc. has been contracted by various school districts to provide therapists when they are unable to fill all available positions with their own therapists.
School Assignments
School assignments occur when the district school board determines their need. Assignments can change if the school district deems necessary. While you are providing services within a school site, that school will continue to advertise that position in order to directly hire a therapist. You will be contacted immediately if that position will be filled and you will need to be transferred to a different site. We are hoping to provide at least two to three weeks notice of any possible changes. ILI will attempt to place you at a requested site but the school district representative will have the final decision on all placements. Please notify us if you have concerns or questions regarding your school assignment.
Code of Conduct
The school system is our customer and we, as ILI employees, should conduct ourselves in a professional manner at all times. Not only do we value you as an employee, we also value our reputation in the community. Please refer to the school district code of conduct and abide by your school procedures and guidelines.
Job Expectations
School-based therapists are expected to provide therapeutic services to the school age population in a timely and appropriate manner. Services should be educationally relevant while following the school districts eligibility criteria. Therapists are required to follow district policies and procedures and complete all necessary documents, as determined by the school system. We ask that you work congruently with other professionals to ensure the best delivery model for students. A Speech/Language manual from the district school system will be provided at orientation/training days. If asked by school based personnel to perform other duties (i.e. bus duty, lunch duty, etc.) this must receive prior approval by the district ESE representative.
You are also required to attend trainings and meetings as determined by ILI and the school system.
Important Contacts
If you have any concerns or questions, please contact:
Hope Lewis, Lead Speech-Language Pathologist, hlewis@, 813-468-8255
Carrie Guise, Director of Speech-Language Pathology, cguise@ , 813-963-6923 ext. 228
Attendance Logs
You are required to complete an attendance log documenting your dates and times. Your attendance logs will need to be verified and signed by the designated administrator at your school site. These signature logs need to be submitted every two weeks per the enclosed payroll schedule. This form is very important. We are required to submit them to the school- district for payment in a timely manner. Please refer to the appropriate payroll schedule provided in this book.
Attendance Procedures
You are required to be in attendance at your school site as long as school is in session. You will also be expected to be at your sites when it is a teacher planning day. This time can be utilized to complete any necessary paperwork such as IEP’s and Progress Reports and attend any scheduled staffing meetings. If you are unable to work due to illness or any other reason, you are required to notify your school site and contact either Hope Lewis at hlewis@ OR Carrie Guise at cguise@ AND Sheri Rodriguez at srodriguez@.
If you are a part- time employee at a school site, please contact the school ESE Specialist and administration to determine your work schedule to ensure proper coverage of staffing meetings, etc.
Please document on your timesheet your absences.
Expense Reimbursement/Mileage Reimbursement
If requesting reimbursement based on your supply allotment, please use the enclosed expense reimbursement form.
If requesting mileage reimbursement based on your contract, please use the enclosed mileage log. Mileage is reimbursed if asked to drive between sites or any other pre-approved activities.
Hours
Expected hours might vary between therapists and school sites. Please refer to your school administrator’s specific expectations. We are contracted to be at a school no more than eight hours per day. There maybe times where additional time might be needed for difficult staffings or IEP meetings. These do not need prior approval unless it happens frequently. Please contact the District SLP assigned to supervise the contract therapists.
Other
If you provide home-based services in addition to your school position, you will need to follow the home-based protocol for paperwork, etc.
Chapter
5
Office Staff Guidelines
Full-Time/Part-Time Employment
Work Hours
Paid Holidays
Sick Policy
Paid Time Off (PTO)
Payroll
Annual Reviews
Dress Code
Office Equipment/Supplies Use
Email Policy
Customer Service
Forms & Letters
FULL TIME / PART TIME EMPLOYMENT
1. Full time employment is a 40-hour workweek. Employees that are hired full time and do not work a 40 hour week are not be eligible for benefits and/or any type of paid time off. Disciplinary action may be taken if the employee is not meeting their full time status including termination.
WORK HOURS
1. The standard work hours are 8 hour workdays with a set schedule between 8:00 a.m. to 5:00 p.m., unless otherwise determined by a supervisor, Monday through Friday with a 30 minute lunch break. Every employee is required to take a lunch break and may not use their lunch break to make up lost hours due to tardiness or absences. The company does not pay for lunch breaks.
2. Employees who will be arriving to work late must directly inform their immediate supervisor. Excessive tardiness may also result in disciplinary action including probation and termination.
3. Hourly employees may not work more than 40 hours per week unless requested by the supervisor. Unauthorized overtime will be subject to disciplinary action.
PAID HOLIDAYS
1. Full time employees are given the following eight paid holidays per calendar year: New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Thanksgiving Friday, Christmas Day and an additional “Floating Holiday”. Eight hours will be added to the employees PTO bank during the first pay period of the year. New employees will be given this floating holiday if hired in January or February; if hired during other months, the floating holiday will not take effect until the following year.
2. “Floating Holidays” must be chosen in advance and approved by the
Supervisor.
3. If a part-time employee’s benefits package includes holiday time, the agreed upon hours will be lumped in with PTO time and the employee would request to be paid using PTO for holiday pay.
SICK POLICY
When an employee is sick and not coming into work, the employee must contact their immediate supervisor as soon as possible.
1. Full time employees are given 5 accrued paid sick days (40 hours) per calendar year which is included with their paid time off.
PAID TIME OFF (PTO)
1. Full time employees start accruing earned paid time off on their start date however, cannot be used until their 90-day probationary period is successfully completed. Accrued PTO hours are separate from paid holiday time. Full time employees must work a total of 40 hours per week to accrue their PTO. PTO can only be used for sick days, vacation days, and/or pre-approved time off. PTO cannot be used to compensate for being tardy or leaving early without pre-approval by a supervisor.
2. Employees will be eligible for the following paid time off:
Years of Employment Accrued Vacation per Year
Up to 1 year 5 days
1-2 years 10 days
2-3 years 11 days
3-4 years 12 days
Each successive year earns an additional day per year until a maximum of 3 weeks has been accrued. (Employees, who already have more than that will be grandfathered in, however will not be able to accrue more than they have currently.)
3. Management must approve vacations. Vacation time will be limited to one week off during the holidays to allow a rotation of vacations during the holiday season and the first of the year.
4. A maximum of 40 hours of unused PTO may be paid to the employee upon termination of employment if the employee provides ILI with 14 days notice of termination. Unused vacation time will not be paid if employee is terminated by ILI or if the employee terminates their employment without at least 14 days notice.
PAYROLL
Employees are paid bi-weekly. All employees are required to submit a time report to the Payroll Department by 4:00 p.m. the Wednesday immediately following the end of each pay period.
Accurately recording time worked is the responsibility of every employee. Time worked is all of the time actually spent on the job performing assigned duties. Employees are required to accurately record the time they begin and end their work, as well as the beginning and ending time of each meal or break period. It is the employee’s responsibility to sign his or her time record to certify the accuracy of all time recorded. The supervisor will review and then sign the time record before submitting for payroll processing.
No employee is permitted to work “off the clock” under any circumstances unless requested by their supervisor. If a question arises regarding hours worked, contact the Human Resources Department.
ANNUAL REVIEWS
This policy applies to employees in full-time and part-time positions; exempt and non-exempt, except independent contractors and temporary positions, to maintain a program of internally and externally equitable salaries.
Independent Living strives to pay competitive salaries and wages. Reviews for compensation adjustments are conducted annually. Regular full-time and part-time employees may be eligible for a merit increase based upon completion of a satisfactory performance appraisal at the end of the pay period month in which their merit anniversary falls. Employee Self-Assessment form and other documentation needs to be completed and sent back to Independent Living Inc. before an increase can be given.
Annual reviews will be completed upon the employee’s original anniversary date. However, if the employee is promoted at any time during the year, a review will be completed at that time and annually from the promotion date, not the original start date. If the employee changes positions within the year with no pay increase, then the annual review date will not change.
DRESS CODE/PERSONAL APPEARANCE & DEMEANOR
This policy is to establish guidelines for appropriate dress and appearance during normal business hours at Independent Living, Inc. Employees may dress more casual of Fridays, if desired.
ILI places great emphasis on the importance of personal cleanliness and professional appearance. Personal hygiene and clothing should be appropriate for a medical office environment.
Examples of inappropriate dress includes:
1. Blue jeans that are ripped frayed or that show undergarments when sitting or performing regular job functions.
2. T-shirts of any kind.
3. Overalls, sweatshirts/pants, jogging suits.
4. Any clothing that reveals bare backs, midriffs or shoulders.
5. Athletic shoes (other than Friday unless medically necessary) or flip-flops.
All employees are expected to conduct themselves at all times in a professional manner which will bring credit to themselves as well as the public’s confidence in the company. All employees are also expected to promote cohesiveness, a positive attitude and a team environment.
OFFICE EQUIPMENT / SUPPLIES USE:
Office equipment and supplies include, but are not limited to, telephones, Internet service, computers, copiers, fax machines, postage meters and office supplies. Equipment and supplies are to be used for Company use only without prior authorization from your supervisor.
Employees shall not use Company telephones for personal local and/or long distance calls unless authorized by your supervisor. Both incoming and outgoing personal calls on company phones or personal cellular phones should be kept as brief as possible or made during your lunch break. No personal long distance calls should be made regardless of the amount without advance approval from the employee’s supervisor. All personal long distance calls will be charged to the employee.
Computer settings may not be changed. Computer software, including screen savers, games and sounds, may not be added or downloaded. Computers and computer equipment may not be moved without approval from the IT department.
Failure to adhere to the above policies may lead to disciplinary action up to and including termination.
EMAIL POLICY
1.0 Purpose
To prevent tarnishing the public image of Independent Living, Inc. When email goes out from Independent Living, the general public will tend to view that message as an official policy statement from the company.
2.0 Scope
This policy covers appropriate use of any email sent from an Independent Living email address and applies to all employees, vendors, and agents operating on behalf of the company
3.0 Policy
3.1 Prohibited Use.
The Independent Living email system shall not to be used for the creation or distribution of any disruptive or offensive messages, including offensive comments about race, gender, hair color, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any ILI employee should report the matter to their supervisor immediately.
3.2 Personal Use.
Sending chain letters or joke emails from an ILI email account is prohibited. Virus or other malware warnings and mass mailings from ILI shall be pre-approved by the company. These restrictions also apply to the forwarding of mail received by an Independent Living employee.
3.3 Monitoring
Independent Living employees shall have no expectation of privacy in anything they store, send or receive on the company’s email system. Independent Living may monitor messages without prior notice. Independent Living is not obliged to monitor email messages.
4.0 Enforcement
Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.
5.0 Definitions
Term Definition
Email The electronic transmission of information through a mail protocol such as SMTP or IMAP. Typical email clients include Eudora and Microsoft Outlook.
Forwarded email Email resent from an internal network to an outside point.
Chain email or letter Email sent to successive people. Typically the body of the note has direction to send out multiple copies of the note and promises good luck or money if the direction is followed.
Sensitive information Information is considered sensitive if it can be damaging to Independent Living Inc. or its customers' reputation or market standing.
Virus warning. Email containing warnings about virus or malware. The overwhelming majority of these emails turn out to be a hoax and contain bogus information usually intent only on frightening or misleading users.
Unauthorized Disclosure The intentional or unintentional revealing of restricted information to people, both inside and outside Independent Living Inc., who do not have a need to know that information.
CUSTOMER SERVICE:
Efficient telephone service is vital to Independent Living, Inc. operations. Employees must adhere to the following guidelines:
A. Answer all calls promptly and courteously.
B. Always identify yourself when answering the phone.
C. All office employees are expected to answer incoming phone calls on the
main phone line as needed.
D. All voice mail messages received by ILI employees must be responded to within the same day.
FORMS & LETTERS
All letters or memos that are written with the intent of mailing, email or faxing to more than one person (bulk) must be pre-approved by administrative staff.
This includes all new or revised memos / letters being sent to parents, agencies, therapists, etc.
Forms and any other documents in the computer system may not be changed unless requested by the supervisor.
Chapter
6
Administrative & Program Management Policies
HIPPA Compliance Standards
Records Management
Medication Administration
Workplace Grievance
Non-Discriminatory Employment Policy
Anti-Harassment Policy
Fair Labor Standards Act-FLSA
Confidentiality Statement
Infection Control & Universal Precautions
Professional Office/ Clinic Cleaning
Linens
Pest Control
Administrative Management
Governing Body
Program Evaluation
Personnel Policies
Progressive Disciplinary Action Procedures
Employment Termination Procedures
Reporting Incidents
Emergency Management and Disaster Preparedness Plan
HIPAA Compliance Standards
Confidential Conversations
CONVERSATIONS REGARDING A PATIENT’S NAME OR PERSONAL INFORMATION MAY ONLY TAKE PLACE IN AREAS THAT CANNOT BE OVERHEARD BY OTHER PATIENTS OR NON-STAFF INDIVIDUALS. STAFF MAY NOT LEAVE DETAILED MESSAGES ON AN ANSWERING MACHINE REGARDING A PATIENT.
Medical Records
ALL MEDICAL RECORDS ARE KEPT IN A SECURE, LOCKED LOCATION. ALL EMPLOYEES AND NON-EMPLOYEES WHO HAVE ACCESS TO THE MEDICAL RECORDS AREAS MUST SIGN A CONFIDENTIALITY AGREEMENT.
Medical records must be scanned into a computer database so that they cannot be altered. In the event of an emergency, these records will be backed up daily to a tape and also backed up to an offsite location.
Computers
NON-EMPLOYEE INDIVIDUALS CANNOT GAIN ACCESS TO OUR COMPUTERS OR FAX MACHINES. ALL EMPLOYEES MUST HAVE A CONFIDENTIAL USER NAME AND PASSWORD TO GAIN ACCESS TO COMPUTER DATA. THE PASSWORDS MUST CHANGE ON A REGULAR BASIS, AND PASSWORDS OF TERMINATED EMPLOYEES GET DELETED IMMEDIATELY.
All portable equipment, such as laptops, calendars and “personal assistants” that contain patient information must be kept secure in an appropriate fashion.
The IT department will keep a complete listing of the computer systems, including all software.
information Transfers
OUR FAX COVER LETTERS AND EMAILS MUST HAVE A CONFIDENTIALITY DISCLAIMER. ONLY APPROPRIATE INFORMATION IS TRANSFERRED AND IT MUST BE TRANSFERRED TO THE PROPER INDIVIDUALS. EMPLOYEES TRANSFERRING INFORMATION MUST OBTAIN WRITTEN AUTHORIZATION FROM THE PATIENT OR GUARDIAN.
Verisign, Inc. or a similar third party must secure electronic transfer of information and a current copy of the security certificate must be kept on file.
Confidentiality Statements
ALL EMPLOYEES MUST SIGN PATIENT CONFIDENTIALITY STATEMENTS. THESE STATEMENTS ARE ALWAYS DISPLAYED IN A PROMINENT PLACE IN THE OFFICE.
Unauthorized Personnel
UNAUTHORIZED PERSONNEL MUST NEVER HAVE ACCESS TO CONFIDENTIAL INFORMATION. THIS INCLUDES ALL STAFF AND OTHER INDIVIDUALS WHO MAY HAVE, AT ONE TIME, BEEN AUTHORIZED TO HAVE SUCH ACCESS. WHEN AN EMPLOYEE IS TERMINATED, THEY MUST RETURN ALL KEYS AND OTHER ITEMS THAT ALLOW ACCESS TO INFORMATION.
Personnel Training
ALL PERSONNEL MUST RECEIVE TRAINING ABOUT OUR PRIVACY AND SECURITY POLICIES AND RECORDS MUST BE KEPT OF THE TRAINING. THE POLICIES MUST DETAIL WHICH PERSONNEL HAVE ACCESS TO DIFFERENT KINDS OF CONFIDENTIAL INFORMATION IN DIFFERENT CIRCUMSTANCES, PERSONNEL CLEARANCE PROCEDURES, AND PROCEDURES TO BE FOLLOWED WHEN A MEMBER OF THE OFFICE STAFF IS TERMINATED, AND PROCEDURES FOR IDENTIFYING AND CORRECTING POTENTIAL PROBLEMS. ALL TRAINING REQUIREMENTS MUST BE INCLUDED IN THE HUMAN RESOURCES POLICY MANUAL.
Disaster Plan
IN THE EVENT OF A DISASTER, A DAILY BACKUP OF COMPUTER FILES WILL BE STORED AT A BACKUP LOCATION. ALL MEDICAL RECORDS THAT ARE ON PAPER ONLY WILL BE SCANNED INTO THE COMPUTER SYSTEM AND ALSO KEPT AT AN OFFSITE LOCATION.
Records Management
Master files with all patient files are kept in an enclosed/locked room. Access is carefully monitored by our receptionist and/or her substitute.
Medical information, when on employee desks, is turned over and/or secured in desk files to keep patient information confidential. Therapists in the field are expected to keep files contained in a enclosed box.
All information provided by phone or fax is handled with the utmost care to ensure that the person receiving information for purpose of treating or patient well being is appropriate to receive such information.
All employees both present and past have signed HIPAA directive to ensure patient confidentiality and compliance.
All patient information no longer needed is deposited into a locked shredding container to be systematically retrieved and disposed of by a properly licensed and dependable shredding company.
Computer information and exchange is guarded for the purpose of patient confidentiality. Passwords are changed every forty-five days and access is carefully controlled.
A Patient/Parent/Caregiver release is in each patient’s file including a HIPAA statement and patient rights.
Medication Administration
I
ndependent Living, Inc. is not a Home Health Agency. Our therapists are NOT to administer, educate, nor become involved with patient medication requirements. Any requests for assistance in this area will be referred to the parent or caregiver responsible for the client’s care.
Workplace Grievance
WHAT IS A GRIEVANCE?
A
grievance is a dispute or a problem about any act, behavior, omission, situation or decision, which a person thinks is unfair and unjust, and is work related. Some examples would include: discrimination; harassment; EEO (equal employment opportunity) issues; or other issues to do with the workplace environment, performance reviews, safety issues, promotion opportunities, leave applications, etc.
It is Independent Living Inc.’s policy to maintain a harmonious working environment, which affords equality of opportunity. ILI recognizes the right of individuals to express their concern about work related issues and has an official avenue to resolve employees’ genuine grievances and complaints in a fair and timely manner.
In the first instance, all efforts will be made to resolve the complaint directly between the parties in a low-key manner and at the lowest levels of the organization.
However, if a formal complaint is lodged, grievance handling will be guided by the following principles.
Complete confidentiality
O
nly the people that are involved making or investigating a complaint will have knowledge of an allegation against someone. Every party involved in the investigation must maintain confidentiality about the matter and not disclose any details or discuss the matter with any person other than the staff member conducting the investigation.
Impartiality
T
he investigation will treat both parties equally with both being given an opportunity to provide explanation and detail without any assumptions being made until full details are available. Management will take all necessary steps to ensure no victimization occurs against anyone who makes a complaint.
timeliness
A
ll allegations or complaints will be dealt with as quickly as possible. The aim is to resolve all allegations within two weeks from when complaint is lodged with the staff member who will investigate. Within 48 hours, the complainant will be informed of how action is to be taken.
Fairness
E
very allegation will be taken seriously and people involved will be treated fairly. All individuals concerned will have access to support and representation during the course of the procedures should they choose this.
WHAT ARE THE LIKELY OUTCOMES?
I
f an allegation has been investigated and proven substantiated, outcomes of the grievance process and resolution of the issue could include: a written apology; counseling; an official warning; disciplinary action, dismissal, etc. The aim of the resolution should be to explain any misunderstanding, make people aware of the inappropriate nature of their behavior and to prevent the behavior from occurring again. Action recommended should be practical and positive. If the complaint is proven not to have occurred and it is in fact a frivolous or reckless complaint similar outcomes may be pursued.
WHAT SHOULD YOU DO IF YOU HAVE A GRIEVANCE OR A DISPUTE IN THE WORKPLACE?
1) AS A FIRST OPTION, YOU SHOULD TRY TO SORT OUT ANY DISPUTE DIRECTLY WITH THE PERSON(S) INVOLVED. SOMETIMES PEOPLE DO NOT REALIZE THEY HAVE HURT OR AFFECTED OTHERS WITH THEIR ACTIONS OR WORDS. IF YOU CAN, YOU SHOULD TELL THE PERSON THAT THEIR BEHAVIOR IS UNACCEPTABLE OR HURTFUL OR OFFENSIVE AND GIVE THEM THE OPPORTUNITY TO APOLOGIZE AND CHANGE THEIR BEHAVIOR. IN CASE THIS SITUATION IN NOT RESOLVED BY THIS TYPE OF APPROACH, YOU SHOULD ALSO NOTE THE DETAILS OF THE OCCASION ON WHICH YOU SPOKE TO THEM.
2) If the person(s) takes no notice of your approach and you feel that the issue is unresolved, contact an ILI Administrator. Explain the problem to this person and indicate how formal a procedure you wish them to undertake. Sometimes you may just want them to have a low-key discussion with the person, establish that the allegation is genuine and ask them to stop the behavior on your behalf.
3) There may be circumstances where you wish to complain about your Team Leader, Manager, Director or another senior staff member, or you do not feel comfortable discussing the matter with these people. You can choose to report the complaint to someone else. You should never be reticent to speak about the situation. Remember that your complaint will be treated confidentially, privately, impartially, seriously and quickly and there will be no victimization afterwards.
Non-Discriminatory Employment Policy
I
t is the policy of ILI to afford equal rights to all qualified personnel without regard to race, color, religion, sex, national origin, age, disability, veteran status, family status or any other unlawful selection criteria in recruiting, hiring, training, promoting, and all other terms and conditions of employment.
Each employee is encouraged to bring to the attention of his or her supervisor or manager or the Director of Human Resources any employment decision he or she feels in conflict with the letter and spirit of this policy. Individual managers and supervisors are responsible for ensuring that their decisions are in compliance with this policy and will be held accountable for the prompt execution of necessary preventative or corrective actions.
Anti-Harassment Policy
I
LI is committed to the principal that all employees have the right to work in an environment free from all forms of discrimination and conduct that can be reasonably considered harassing, coercive, or disrupted. It is the firm policy of ILI to prohibit harassment of any employee by another employee, or a supervisor on the basis of race, color, religion, sex, age, national origin, veteran status, marital status, mental or physical disability, or any other status or condition protected by applicable state or federal law. The purpose of this policy is to assure that, in the workplace, no employee is subject to harassment on the basis of the foregoing personal characteristics.
Harassment, sexual or otherwise, may include but is not limited to derogatory remarks, drawings or pictures, unwelcome “jokes”, teasing, unwelcome, deliberative, or repeated explicit verbal or physical conduct which embarrasses, humiliates or otherwise adversely affects the recipient or the recipient’s co-workers.
Sexual harassment is defined as unwelcome advances, requests for favors, and other verbal or physical conduct of a sexual nature. Sexual harassment occurs when:
1. submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment;
2. submission to or rejection of such conduct by an individual is used as a basis for employment decisions affecting such individual; or
3. such conduct has the purpose of effect or unreasonable interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.
ILI believes that harassment of an employee by another employee, patient, or vendor is a form of misconduct that undermines the integrity of the employment relationship. Such behavior will not be tolerated. Violations of this policy will not be permitted and will result in disciplinary action up to, and including, termination.
An employee who feels that he or she is a victim of such harassment is required to report it immediately to his or her supervisor, department head and/or a representative of the Human Resources Department. All complaints will be promptly and thoroughly investigated and disciplinary action will be taken where appropriate. Under no circumstances should any employee allow improper conduct to go unreported.
It is the responsibility of all managers to consult with the Director of Human Resources against acts of harassment by Company personnel or others. An employee should report any such harassment to his/her supervisor or to the Director of Human Resources.
Independent Living prohibits and will not tolerate any coercion, intimidation, retaliation, interference or discrimination against an employee for reporting harassment, for filing a complaint of harassment or for assisting in any investigation of a harassment claim.
Fair Labor Standards Act – FLSA
T
he FLSA requires employers to keep records with regard to all employees covered by the statute’s minimum wage and overtime provisions. Employees are responsible for making sure their time records are accurate
Confidentiality Statement
I
t is the obligation and policy of Independent Living Inc. to maintain the confidentiality of all patient information, including, without limitation, medical records information, and to protect each patient’s right to privacy. Copies of patient medical records/information shall not be revealed to anyone without the proper written and signed authorization from the party involved, the party’s guardian, the party’s legal representative, or as otherwise allowed or required by law.
Employees with Independent Living Inc. are never to discuss or disclose any patient information to any unauthorized person.
In addition, employees may not at any time, either during or subsequent to employment, disclose or use any information, knowledge or data received or developed during the employee’s period of employment with the Company, which is considered proprietary by Independent Living Inc. or which related to the trade secrets of Independent Living Inc. Such information, knowledge or data may consist of the following, without limitation: processes, know-how, designs, accounts, financial data, pricing or salary data, marketing data, business plans and strategies, negotiations, contracts, customer or vendor lists, inventions or discoveries.
The procedure is as follows:
A. All employees are required to sign a “Confidentiality Statement for Employees” and/or a “Non-Solicitation” contract
B. Violations of any portion of these policies will result in immediate disciplinary action up to and including termination.
Infection Control
Hand-Washing
H
and-washing is the single most important method to prevent transmission of infectious agents. Hands should be washed before and after each contact with patients, body fluids, and contaminated or soiled materials; between dirty and clean procedures on the same patient, after removing gloves; before and after performing invasive procedures; after using the rest room; and whenever hands are visibly soiled. Liquid soap in pump dispensers are used; the dispenser should be disposable or should be rinsed and washed before refilling to avoid contamination. Antibacterial soaps are not necessary for routine use. Use of sinks is preferred to waterless hand cleansers, especially if the hands are soiled. Paper towels are preferred for hand drying and always should be available and reached easily by the health care professional. Hand lotions should be available in pump-type containers that are replaced or cleaned at regular intervals. Hand lotions should not be petroleum-based as this may cause deterioration of latex material and thus reduce the effectiveness of gloves.
The method of hand-washing depends on the task to be performed. Routine hand-washing should be done by thoroughly covering the hands with soap and vigorously rubbing the hands under running water for at least 10 seconds.
Education
A
ll employees at the time of orientation should receive and review information regarding infection control policies and procedures. Furthermore, regularly scheduled educational sessions for all staff are important to ensure that the level of hand-washing and infection control awareness remain high. All staff members should be aware of and motivated to follow these policies.
Universal Precautions
S
tandard precautions should be used in the care of every child because it cannot be determined which child harbors an infectious agent. Gloves should be available for use by all health care professionals. Gloves should be worn when contact with blood, body fluids, secretions, excretions, and items contaminated with these fluids are reasonably anticipated. Gloves do not need to be worn for routine therapy or routine child care, such as wiping a nose. When gloves are used, hands should be washed after they are removed because contamination can occur during removal or from a break in the glove. Masks, face shields, and protective eyewear should be worn if splashing of body fluids is anticipated. When soiling of clothes with blood, body fluids, secretions, or excretions is highly likely, gowns can be worn. Any saturated bloody material must be disposed by a waste disposal company. Call---Waste Management 1-800-255-7172.
Skin surfaces that are contaminated with blood or other body fluids should be washed immediately and thoroughly. Environmental surfaces should be cleaned with a detergent, and then treated with freshly prepared bleach solution (diluted 1:64; 1/4 cup of bleach to 1 gallon of water, bleach contact time must be at least 30 seconds), with gloves worn during cleaning. OSHA mandates immunization with hepatitis B vaccine for all persons whose job might involve exposure to blood or blood-containing body fluids.
Waiting Areas
W
aiting rooms and reception areas offer the opportunity for child-to-child interaction, and, unfortunately, child-to-child transmission of infectious agents. Waiting rooms can be compared with childcare settings, where contamination of the environment and transmission of infectious agents occur at an increased rate compared with the home setting. Efforts should be made to limit transmission of infectious agents by avoidance of crowding, shortening waiting times, and minimizing the sharing of toys. Infected children who are symptomatic should have their appointment rescheduled for another day. Sick adults should be discouraged from spending time in waiting areas. Ideally, immunocompromised children should not wait in the general waiting area and services should be provided in their home.
Toys in the office and used in the clinic are to be either disposable or washable and of appropriate sizes and shapes to avoid choking or other injuries. Toys are cleaned between uses to avoid transfer of infectious agents. Toys contaminated with body fluids will be removed until cleaned and disinfected with soap, water and/or safe disinfectant.
Floors in the waiting area and office are vacuumed or mopped daily. After spills involving blood or body fluids contaminated with blood, linoleum or tile floors should be first cleaned with detergent, then disinfected promptly using a freshly prepared bleach solution (1/4 cup of bleach in 1 gallon of water, bleach contact time at least 30 seconds). To clean soiled carpets, using gloves, first blot up as much of the spill as possible with paper towels and put the soiled paper towels in a plastic lined, leak-proof container. Then scrub the carpet with germicidal rug shampoo and a brush. Soak the brush used for scrubbing in a disinfectant solution and rinse the brush. Let the carpet dry, and then vacuum it.
Professional Office / Clinic Cleaning
A
cleaning agency is used daily and is responsible for cleaning and disinfecting the outpatient clinic, the waiting room, administrative offices, and bathrooms. Surfaces should be cleaned with a low-level disinfectant. Phenolics, iodophors, and quaternary ammonium compounds are appropriate for use in daily cleaning and disinfection of surfaces. This service is managed by Luz Taborda at (813) 569-4763.
Linens
Linens will be cleaned after each use. A laundry service is used for pick up, cleaning and delivery of cleaned linens.
Pest Control
A licensed, professional pest control service is used on a monthly basis. This service is managed by the Citrus Park Professional Builders, Inc. (727) 967-7172. 334 E. Lake Rd. Palm Harbor, FL 34685
Infection Control Committee
Director of Physical Therapy, Occupational Therapy, Speech Pathology, & Clinical Coordinator
Meetings: Annually
Administrative Management
Subject: Overall Administrative Management Policy
Purpose: To ensure that ILI can effectively carry out its program mission by providing efficient and effective overall Administrative Management.
This policy statement provides the broad framework of goals, strategies, and principles which will guide Administrative Management in ILI. Administrative Management includes the areas of:
| Personnel Management | Emergency Management |
| Patient Care Policies | Records Management |
| Infection Control Policies | Program Evaluation |
| | |
Authority: See each appropriate directive.
Contact: Stephanie Harris
1. Administrative Management Policies. It is the policy of ILI to provide effective and efficient overall Administrative Management by ensuring that:
A. Within the constraints set by law and appropriate regulatory requirements, ILI will seek to reduce costs, promote efficiency, and improve services.
B. In the interests of efficiency, Administrative Management procedures common to all ILI offices will be uniform.
C. All Administrative Management directives require the minimum constraints necessary to provide implementation of the policies of ILI.
D. All Administrative Management procedures will be designed to allow responsible managers an appropriate degree of discretion and judgment in accomplishing their duties.
Governing Body
I
ndependent Living Inc. (ILI) is an outpatient rehabilitation facility. It is a corporation with one officer, Stephanie Harris. Stephanie Harris is the President of the corporation and is also the appointed “governing body”. The governing body assumes full legal responsibility for the conduct of Independent Living Inc. and is responsible for establishing policies and procedures. The governing body oversees and provides strategic direction for ILI.
The governing body has appointed a full-time “administrator” of the organization, The administrator is responsible for:
-implementing the written policies and procedures related to internal operations.
-hiring, training and managing professional medical and office personnel.
The administrator and governing body is responsible for assisting and guiding the “Management Team”. The members of the Management Team are as below. The Management Team assist with the administration and review of policies, procedures, quality and utilization management on a quarterly basis and as needed for decision making. The Management Team serves as the mechanism for disseminating information and communication related to the overall business process of ILI to all of the employees.
Program Evaluation
Implementation and monitoring/designation by Management Team will monitor the following for compliance and standards:
Therapist-ongoing monitoring:
1. Professional License-renewals.
2. Continuing Education Unit Updates/Credits.
3. Medicaid screening, if applicable.
4. 90-day and annual reviews by supervisors.
5. Comments/criticisms from patients, parents, caregivers.
Documentation and delivery of services-ongoing monitoring
1. Correctness, consistency of therapy, chart and appropriate placement of records.
2. Authorizations for services/physician’s signatures, insurance payers.
3. Initial Evaluations/re-evaluations.
4. Soaps and reports-clarity and appropriateness-consumer-representatives signoff.
5. Comments /criticisms from patients, parents, caregivers
6. Consent for treatment manifest.
Equipment Assessment-quarterly
1. Management team will assess equipment for safety each quarter or as specified by manufacturer standards.
Billing accuracy/documentation-random audits, ongoing
1. Therapy files must support billing.
2. Appropriate CPT/ICD codes utilized.
3. Correctness of primary payer, government last resort.
Management Team
Stephanie Harris, OTR/L (President / Governing Body).
Administrative Director.
Director of Speech Language Pathology.
Director of Occupational Therapy.
Director of Physical Therapy.
In the temporary absence of the clinical coordinator/administrator, the director of speech language pathology, physical and/or occupational therapy will act as the administrator and assume the responsibilities and roles of the administrator.
Governing Body meetings are scheduled and held monthly to review policies, procedures and program evaluation. Documentation of meeting minutes are kept on site.
Personnel Policies
A
ll personnel must attend an orientation, which will encompass all policies, procedures and expectations of the employee. The orientation must be completed before the employee begins working for ILI. The employee must display full understanding and agree to comply with all policies and procedures set forth by Independent Living Inc. All policies and procedures are documented in the “Independent Living Inc. Policy Manual”. The manual is revised and given to every employee on an annual basis.
All professional personnel must keep their state licensure current and provide ILI with a copy of the current license. A copy of the license is kept in the personnel file. If the employee does not submit current licensure to ILI they are immediately given an “inactive” status and prohibited from providing any type of service through Independent Living Inc.
All employees have a personnel file that is kept at Independent Living Inc. The personnel file must include the following:
-Resume
-Reference Checks
-Personal data (DOB, SSN, Address, Emergency Contact)
-Tax related documents
-Copy of professional license
-Background Screening and Fingerprint Screening results
-Medicaid Provider Number (if applicable)
-National Provider Identification Number
-Certificates of Continuing Education Units.
-Annual Reviews (competed by employee and supervisor)
-Letter of resignation upon resigning from Independent Living, Inc. for any reason or no reason.
Progressive Disciplinary Action Procedures
I
LI strives to maintain a fair and lawful disciplinary system. The following disciplinary system will be implemented for either misconduct or poor performance. Forms of misconduct include but are not limited to: violating work rules, sexual harassment, intoxication, sleeping, smoking, conducting personal business on the job, violent behavior, discrimination, substance abuse, safety violations, insubordination, and/or unacceptable conduct. Poor performance includes but is not limited to: not meeting expectations, negative attitude, missing deadlines, tardiness and/or absenteeism.
The steps of our progressive disciplinary action include:
1. Verbal Warning
2. Written Warning
3. Final Warning
4. Termination
If an employee is accused of any form of misconduct, an investigation into the allegation(s) will be conducted by the employee’s supervisor and the human resource department prior to the final determination of outcome. If the outcome of the investigation warrants immediate termination, termination procedures below will be followed.
Employment Termination Procedures
I
t is required upon termination of employment with ILI that the employee submits a letter of resignation with their original signature for the personnel file. All ILI materials must be returned before the employee can receive their final paycheck. This includes all paperwork, testing materials including unused protocols or files, badge, keys, etc. The employee must participate in an exit interview with the HR department. If employee owes ILI reimbursement for CEU’s, supplies or bonuses previously paid out, the therapist must pay back any monies owed in full before last paycheck, otherwise, the therapist authorizes ILI to withhold any monies due to ILI from last paycheck. If, for any reason, the last paycheck will not cover total debt, the balance of monies owed is due within 10 days after last day of employment; otherwise ILI will send the debt to collections.
Reporting Incidents
Objective- to provide maximum information and minimum delay with the child’s welfare being of paramount importance.
1. Non-critical incidents which do not compromise the child’s health, safety or welfare require written notification to parent or caregiver, ES Coordinator or Director, ILI Director.
2. Critical Incidents which do compromise the child’s health, safety or welfare require immediate referral to emergency services or abuse hotline, written notification and within one hour or as soon as possible to parent/caregiver, ES Lead Service Coordinator/Director and ILI Director.
Situations include but are not limited to:
a). life threatening illness
b.) abuse or neglect
c.) injury which results in a medical condition requiring immediate attention
d.) use of infection control/universal precautions are not apparent when highly communicable disease has been identified and which places the child at risk.
Contact Information
1. Emergency Contact Number 911
2. Abuse Hotline 800-96Abuse/800-962-2873
3. Aleisha Linck, ILI Clinical Coordinator 813-963-6923 ext. 226
4. Carrie Guise, Director of Speech Pathology 813-963-6923 ext. 228
5. Chantel Heitler, Director of Physical Therapy 813-963-6923 ext. 236
6. Cindy Cooley, Director of Occupational Therapy 813-963-6923 ext. 223
Emergency Management and Disaster Preparedness Plan
Independent Living, Inc. (ILI) has developed an emergency management and disaster preparedness plan that was created by the governing body of ILI with the assistance of the Hillsborough County Fire Marshall. It is reviewed and updated annually by the governing body. This emergency plan is distributed to and reviewed with all employees on an annual basis and provided to new employees upon orientation. The emergency plan is designed to train our employees how to react in emergency situations.
Fire/Explosion
In the event of a fire or explosion, employees are trained to assist patients and customers to the emergency exits as quickly as possible. ILI’s premises are approximately 4000 square feet and have four emergency exits. The emergency exits are marked with lit “exit” signs. A map of the building with marked evacuation routes and emergency exits is reviewed with the employees and is posted in the building. Employees are instructed to use the closest emergency exit.
Fire extinguishers are in clear view and located: 1) In the kitchen, hanging on a wall; 2) In the clinic/employee office, hanging on the wall.
All employees have been instructed on how to use the fire extinguisher and have been instructed to use the fire extinguisher if the fire appears to be containable and the employee is not in danger by trying to extinguish the fire. If possible, the employees should make an effort to contain the fire by closing the door to the room where the fire is located. This should only be done if it will not jeopardize the safety of the employee.
The fire department will be notified immediately by calling 911.
Medical records and pertinent documentation is stored on a HIPAA compliant encrypted computer system and backed up daily. The backup is kept offsite in case of a fire or emergency.
Hurricanes/Natural Disasters
In the event that a hurricane is endangering the facility, ILI will take necessary precautions to secure the building and its contents. We will close the facility and cancel patient appointments. Employees will not be allowed to stay in the facility.
Patient records and other pertinent documents will be backed up via computer storage and kept at an offsite location.
In the event of natural or man-made disasters/emergencies the following procedures and practices have been implemented toward patient safety and preservation/access of medical records:
1-Quarterly training and drills are conducted to insure appropriate and effective emergency/disaster occurrences:
All staff both present and future is apprised of the locations of alarms and safety and fire equipment (see map for location).
All staff both present and future is made aware of exit routes and handicap accommodations toward immediate evacuation from both clinic and administrative sections (see map for location).
All staff both present and future are made aware of the need to access emergency personnel by calling 911 with immediate dispatch.
All staff, both professional and office who are present, will aid with emergency procedures but the following staff will have specific responsibilities:
a) Designated Lead Worker (Therapist)-Will notify/sound alarm to initiate emergency activity, insure all workers listed beneath are in place and assist with patient dispatch (see separate list of employee assignments).
b) Emergency Lead Worker (Therapist)-Will assist with patient dispatch.
c) Emergency Assist (Therapist)- Will assist with patient dispatch.
d) Emergency Assist (Office)-Will contact 911 –will retrieve medical records.
e) Emergency Assist (Office)-Will disengage and use safety equipment as needed.
f) Emergency Assist (Office)- Substitute or addition as needed.
g) Receptionist will keep schedule book of all names of employees, patients and their regular schedules. In the event of an emergency evacuation she will make every attempt to account for scheduled employees and patients. Final accounting of their safety will take well outside the ILI building and away from harm.
h) First responders, or those people certified in First Aid and CPR are listed as follows: Lee Ann Nystrom, Cindy Cooley, Carrie Guise, Chantel Heitler, Anna Stephens, Patricia Falcon, Laura Lydic.
i) Physically closest physician: Steven Schweinshaupt M.D.
6502 Gunn Highway Tampa, FL 33625
(813) 969-2399 family-
j) Any fatality on the premises must be reported to:
OSHA: 1-800-321-OSHA
2. Patient Records:
a) Kept in protected and enclosed space.
b) Scanned for computer access and back-up procedure in place.
3. Periodic inspections by the fire department to insure compliance.
4. Periodic journal and computer review to secure new information regarding emergencies.
Revised 1-12-2010
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