Agency Policies and Procedures

Policy:  

Employee Records are kept in the strictest confidence, and contain the information and documents on the individual employment relationship with Counseling Kids and Adults L.L.C.. This policy outlines the procedures for keeping and accessing Employee Files.  

Background : To ensure Employee Records are confidential, and are held and maintained in a manner that respects the privacy of employee information and meets the requirements of the Freedom of Information and Protection of Privacy Act (“FOIP”).  

Policy Objective: The employee manager, owner or Human resources director located at Counseling Kids and Adults L.L.C. will maintain an Employee File. These files are property of Counseling Kids and Adults L.L.C. and contain relevant information with respect to each employee.  

Purpose: The purpose of Employee Records is to maintain current employee data and information for business and employment related purposes, or where authorized or required by law.  

To ensure that access to employee information is adhered to, any requests related to the Employee File must be directed to Carla McKean. 

Scope: This policy applies to all current and former employees (as required by the applicable legislations).  

Definitions:  

“Employee File” is a collection of records and facts about the employee and related employment status changes. It also contains a record of events (i.e. including promotions, transfers, absenteeism, performance appraisals and letters of discipline). All records of events will not be disclosed to outside entities unless required by law. 

“Employee Record” refers to any form, report, original, microfilmed or electronic record, notes or documentation relating to or impacting the selection, status, salary, performance, benefits, disciplinary action, training, etc. of an employee, prospectively employed or separated person.  

“Human Resources” refers to any staff member, owner, administrator or contractor assigned the role of human resources and responsible for carrying out dues pertaining to employment. 

Guiding Principles:  

1. Internal Request to access Employee Files  
2. Access to Employee Files is restricted to authorized personnel where it is necessary for the performance of their duties, including but not limited to Human Resources, Payroll, Legal advisors, internal auditors, and the employee’s supervisor, the applicable Director, the applicable Vice-President and the President if one presides. 
3. All information placed in the Employee Files is confidential in nature and it will only be divulged to individuals who have been authorized to receive such information. The right of every staff member to privacy shall be recognized and protected and applicable to legislation set forth by state and federal governmental entities.  
4. Employee’s files may be viewed under the following conditions:  
5. Employee: Upon employee’s written request with at least 24 business hours advance notice. Employees are allowed access to their own Employee File under the guidance and supervision of responsible staff.  
6. Supervisor, Managing Member(s), Owner or Director or HR staff for the purpose of record keeping. For confidential use where it is necessary for the performance of their duties. 
7. No employee may alter or remove any document from his or her Employee File. 
8. Access to Employee Files for reasons other than those listed above must make written application with at least 24 hours notice to the Director, Human Resources or applicable staff. 
9. Employee Files must remain in the Human Resources Department.  
    

External Requests to Access/Share Employee Information  

1. Personal information will only be released in compliance with statutes.  
2. The Human Resources Department will verify employment as required by applicable legislation or with the employee’s consent (written or verbal) to release the information to any external party.  
3. Information/Records Retained  
4. To ensure accuracy in our records, any changes to an employee’s personal information (i.e. address, marital status) must be provided in writing to Human Resources in a timely fashion. Requests to amend or remove documents from an Employee File must also be made in writing to Human Resources.  
5. The following information and records will be placed in the employee file: 
6. Hiring documentation (i.e. recommendation form, resume);  
7. Leave approvals (notification and acceptance);  
8. Tenure documentation;  
9. Documentation related to performance evaluations;  
10. Faculty workload statements;  
11. Faculty Spring and Summer Activities;  
12. Benefits documentation;  
13. Personal information, including birth date, marital status, address, phone number, and emergency notification;  
14. Performance Evaluations; 
15. Written disciplinary action and related materials;  
16. Letters of resignation and documentation of termination;  
17. Pension information; and  
18. Other relevant information regarding the employee's employment with Counseling Kids and Adults L.L.C..  
19. The following documents will be reviewed on a regular basis and outdated material will be removed. This includes the following:  
20. Absence reports older than five years;  
21. Disciplinary action, subject to Collective Agreement requirements and Progressive Discipline Policy; and/or  
22. Other information as determined by the Director, Human Resources 
23. Retention of Employee Records  
24. Employee Records of former employees of Counseling Kids and Adults L.L.C. may be transferred to electronic storage for one year following the employee leaving. electronic records will be retained for a minimum of seven years. 

Exceptions to the Policy  

1. Exceptions to the guiding principles in this policy must be documented and formally approved by the Owner, or managing member.  
2. Policy exceptions must describe: 
3. the nature of the exception;  
4. a reasonable explanation for why the policy exception is required; 
5. any risks created by the policy exception; and 
6. evidence of approval by the owner or managing member.  

Inquiries: Inquiries regarding this policy can be directed to the staff responsible for carrying out Human Resources job duties.  

Amendments (Revision History): Amendments to this Policy will be published from time to time and circulated to the Counseling Kids and Adults staff, employees, contractors, providers, as it may pertain to the individual. 

Policy and Procedure: Background investigations within Counseling Kids and Adults LLC.

Policy:  It is the policy of Counseling Kids and Adults LLC to conduct background investigations on all employees, contractors, partners, and volunteers providing mental health services. Background investigations will be completed on all parties prior to providing services. If a party is found to have an adverse report in the background investigation process the conduct of that individual will be reported to the party within 3-5 business days and with adequate notice and an opportunity for a hearing. 

Procedure:

1. Prior to providing services providers will need to successfully pass a background check.
   1. The background check will consist of providing the following information
      1. Current name and all aliases
      2. Current address and prior address for the past 7 years.
      3. Academic accomplishments
      4. Professional license(s) held
      5. Employment history for the past 5 years.
      6. Proof of completion of Medicare Fraud, Waste and Abuse Training within 30 days upon hire or start date.
      7. Disqualification standards
         1. The same disqualification standards will be used as for foster care providers pursuant to MN Statute Section 245A.04 Subd. 3d.
         2. All individuals working in direct client care will be searched for in the excluded provider database monthly. If found to be excluded, the provider will be contacted and a review will take place as to whether this provider will continue care and a plan for return to work or leave.
   2. Clerical staff will obtain the aforementioned information and will be the responsibility of Carla McKean to review the information. It will be Carla McKean’s decision, based upon state statutes to determine if the applicant is qualified or disqualified for hire or contract. Carla McKean will advise by mail, within 5 working days, whether the applicant is qualified or disqualified. Carla McKean will use MN Statutes for  foster care providers under Minnesota Statutes, section 245A.04, subdivision 3d to determine disqualification.

2. If the provider is registered under a federal student loan forgiveness program additional actions will be taken to either report or query through NPDB National Practitioner Data Bank according to  45 CFR § 60.3.  Entities that participate in the NPDB are defined in the provisions of Title IV, Section 1921, Section 1128E. Under Title IV, Counseling Kids and Adults LLC is "A health care entity that provides health care services and follows a formal peer review process for the purpose of furthering quality health care". Counseling Kids and Adults LLC is required to query the NPDB to ensure there are no adverse reports for the provider. Counseling Kids and Adults LLC also reports to the NPDB to ensure NPDB has the most current information regarding adverse reports for providers.

1. The NPDB report and query may/will consist of providing certain information requested by NPDB. A query is done upon hire of work or contract and monthly thereafter.
   1. The same disqualification standards will be used for providers pursuant to 45 CFR § 60 . 
2. National Practitioner Data Bank and will be the responsibility of Carla McKean or a NPDB certifying official to review the information. It will be Carla McKean’s decision, based upon statutes to determine if the applicant is qualified or disqualified for work or contract. Carla McKean will advise by mail, within 5 working days, whether the applicant is qualified or disqualified. If a provider is found to have an adverse report in the background investigation process the conduct or offense will be reported to the provider with adequate notice and an opportunity for a hearing.
3. If there is an adverse report made against a provider by another provider, client, patient, volunteer, or employee there will be a report made to the National Practitioner Data Bank. If a provider is found to have an adverse report the conduct or offense will be reported to the provider with adequate notice and an opportunity for a hearing

Grievance Policy

Policy:

It is the policy of Counseling Kids and Adults  to ensure that people served by Counseling Kids and Adults have the right to respectful and responsive services.  We are committed to providing a simple complaint process for the people served and their authorized or legal representatives to bring grievances forward and have them resolved in a timely manner.

Procedures:

1. Service Initiation

A person receiving services will be notified of this policy, and provided a copy, within five working days of service initiation.

1. How to File a Grievance
2. The person receiving services or person’s authorized or legal representative:
   1. should talk to a provider, staff, or contractor that they feel comfortable with about their complaint or problem;
   2. clearly inform the provider, staff, or contractor that they are filing a formal grievance and not just an informal complaint or problem; and
   3. may request provider, staff, or contractor assistance in filing a grievance.
3. If the person or person’s authorized or legal representative does not believe that their grievance has been resolved they may bring the complaint to the highest level of authority in this program.

• That person is Carla McKean..
• They may be reached at PO Box 974, Lindstrom. MN 55045. Or by phone: 651-755-4276.

Response by Counseling Kids and Adults:

1. Upon request, provider, staff, or contractor will provide assistance with the complaint process to the service recipient and their authorized representative. This assistance will include:
   1. the name, address, and telephone number of outside agencies to assist the person; and
   2. responding to the complaint in such a manner that the service recipient or authorized representative’s concerns are resolved.
2. Counseling Kids and Adults will respond promptly to grievances that affect the health and safety of service recipients.
3. All other complaints will be responded to within 14 calendar days of the receipt of the complaint. 
4. All complaints will be resolved within 30 calendar days of the receipt. 
5. If the complaint is not resolved within 30 calendar days, provider, staff, or contractor will document the reason for the delay and a plan for resolution.
6. Once a complaint is received, the provider, staff, or contractor is required to complete a complaint review. The complaint review will include an evaluation of whether:
   1. related policy and procedures were followed;
   2. related policy and procedures were adequate;
   3. there is a need for additional provider, staff, or contractor training;
   4. the complaint is similar to past complaints with the persons, provider, staff, or contractor or services involved; and
   5. there is a need for corrective action by Counseling Kids and Adults to protect the health and safety of persons receiving services.
7. Based on this review, Counseling Kids and Adults must develop, document, and implement a corrective action plan designed to correct current lapses and prevent future lapses in performance by provider, staff, or contractor, if any.
8. The provider, staff, or contractor will provide a written summary of the complaint and a notice of the complaint resolution to the person that:
   1. identifies the nature of the complaint and the date it was received;
   2. includes the results of the complaint review; and
   3. identifies the complaint resolution, including any corrective action.

D.  The complaint summary and resolution notice must be maintained in the person’s record.

Emergency Treatment of Minors Policy

Policy: Emergency Treatment of Minors MN Statute 144.344 is our guide for making decisions relative to what does-and what does not qualify for consent by a minor.

Minnesota Statute

144.344 EMERGENCY TREATMENT.

Medical, dental, mental and other health services may be rendered to minors of any age without the consent of a parent or legal guardian when, in the professional's judgment, the risk to the minor's life or health is of such a nature that treatment should be given without delay and the requirement of consent would result in delay or denial of treatment 

 Maltreatment of Vulnerable Adults

Policy: Counseling Kids and Adults providers, staff, or contractors are mandated reporters, if becoming aware or suspecting that a vulnerable adult has been maltreated, you must report it immediately (within 24 hours).

Procedures:

Where to Report

You can report to the state-wide common entry point, the Minnesota Adult Abuse Reporting Center, at 844-880-1574. Or, you can report internally to Carla McKean, managing member. If the individual listed above is involved in the alleged or suspected maltreatment, you must report to the state of Minnesota as stated below..

Internal Report

When an internal report is received, Carla McKean, managing member is responsible for deciding if the report must be forwarded to the state-wide common entry point. If that person is involved in the suspected maltreatment, the report must be forwarded to the state-wide common entry point. The report must be forwarded within 24 hours. If you have reported internally, you will receive, within two working days, a written notice that tells you whether or not your report has been forwarded to the state-wide common entry point. The notice will be given to you in a manner that protects your identity. It will inform you that, if you are not satisfied with the facility’s decision on whether or not to report externally, you may still make the external report to the state-wide common entry point yourself. It will also inform you that you are protected against any retaliation if you decide to make a good faith report to the state-wide common entry point.

Internal Review

When the facility has reason to know that an internal or external report of alleged or suspected

maltreatment has been made, the facility must complete an internal review within 30 calendar days and take corrective action, if necessary, to protect the health and safety of vulnerable adults. The internal review must include an evaluation of whether:

1. related policies and procedures were followed;
2. the policies and procedures were adequate;
3. there is a need for additional provider, staff, or contractor training;
4. the reported event is similar to past events with the vulnerable adults or the services involved; and
5. there is a need for corrective action by Counseling Kids and Adults to protect the health and safety of vulnerable adults.

Documentation of the Internal Review

Counseling Kids and Adults must document completion of the internal review and make internal reviews accessible to the commissioner immediately upon the commissioner's request.

Corrective Action Plan
Based on the results of the internal review, Counseling Kids and Adults must develop, document, and implement a corrective action plan designed to correct current lapses and prevent future lapses in performance by individuals or agency, if any.

THIS REPORTING POLICY MUST BE POSTED IN A PROMINENT LOCATION, AND BE

MADE AVAILABLE UPON REQUEST.

 Policy 

It is the policy of Counseling Kids and Adults to promote the rights of persons served and to protect their health and safety during the emergency use of manual restraints.

“Emergency use of manual restraint” means using a manual restraint when a person poses an imminent risk of physical harm to self or others and it is the least restrictive intervention that would achieve safety. Property damage, verbal aggression, or a person’s refusal to receive or participate in treatment or programming on their own, do not constitute an emergency.

Procedures

1. Positive support strategies and techniques required
   1. The following positive support strategies and techniques must be used to attempt to de-escalate a person’s behavior before it poses an imminent risk of physical harm to self or others:

• Shift the focus  by verbally redirect the person to a desired alternative activity;
• Model desired behavior;
• Reinforce appropriate behavior
• Offer choices, including activities that are relaxing and enjoyable to the person;
• Use positive verbal guidance and feedback;
• Actively listen to a person and validate their feelings;
• Create a calm environment by reducing sound, lights, and other factors that may agitate a person;
• Speak calmly with reassuring words, consider volume, tone, and non-verbal communication;
• Simplify a task or routine or discontinue until the person is calm and agrees to participate; or
• Respect the person’s need for physical space and/or privacy.
  1. Counseling Kids and Adults will develop a positive support transition plan on the forms and in manner prescribed by the Commissioner and within the required timelines for each person served when required in order to:
  2. eliminate the use of prohibited procedures as identified in section III of this policy;
  3. avoid the emergency use of manual restraint as identified in section I of this policy;
  4. prevent the person from physically harming self or others; or
  5. phase out any existing plans for the emergency or programmatic use of restrictive interventions prohibited.

Permitted actions and procedures

Use of the following instructional techniques and intervention procedures used on an intermittent or continuous basis are permitted by Counseling Kids and Adults. When used on a continuous basis, it must be addressed in a person’s coordinated service and support plan addendum.

1. Physical contact or instructional techniques must be use the least restrictive alternative possible to meet the needs of the person and may be used to:
   1. calm or comfort a person by holding that persons with no resistance from that person;
   2. protect a person known to be at risk of injury due to frequent falls as a result of a medical condition;
   3. facilitate the person’s completion of a task or response when the person does not resist or the person’s resistance is minimal in intensity and duration; or
   4.  block or redirect a person’s limbs or body without holding the person or limiting the person’s movement to interrupt the person’s behavior that may result in injury to self or others, with less than 60 seconds of physical contact by staff; or
   5. to redirect a person’s behavior when the behavior does not pose a serious threat to the person or others and the behavior is effectively redirected with less than 60 seconds of physical contact by staff.
2. Restraint may be used as an intervention procedure to:
   1. allow a licensed health care professional to safely conduct a medical examination or to provide medical treatment ordered by a licensed health care professional to a person necessary to promote healing or recovery from an acute, meaning short-term, medical condition; or
   2. assist in the safe evacuation or redirection of a person in the event of an emergency and the person is at imminent risk of harm.

Any use of manual restraint as allowed in this paragraph [Section B] must comply with the restrictions identified in [Section A].

C.    Use of adaptive aids or equipment, orthotic devices, or other medical equipment ordered by a licensed health professional to treat a diagnosed medical condition do not in and of themselves constitute the use of mechanical restraint.

Prohibited Procedures

Use of the following procedures is prohibited by Counseling Kids and Adults:

1. chemical restraint;
2. mechanical restraint;
3. manual restraint;
4. time out;
5. seclusion; or
6. any aversive or deprivation procedure.

Manual Restraints Not Allowed in Emergencies

1. Counseling Kids and Adults does not allow the emergency use of manual restraint. The following alternative measures must be used by staff to achieve safety when a person’s conduct poses an imminent risk of physical harm to self or others and less restrictive strategies have not achieved safety:

• Continue to utilize the positive support strategies;
• Ask the person and/or others if they would like to move to another area where they may feel safer or calmer;
• Remove objects from the person’s immediate environment that they may use to harm self or others
• Call 911 for law enforcement assistance if the alternative measures listed above are ineffective in order to achieve safety for the person and/or others. While waiting for law enforcement to arrive providers, contractors or staff will continue to offer the alternative measures listed above if doing so does not pose a risk of harm to the person and/or others.

1. Reporting Emergency Use of Manual Restraint

      As stated in section V, Counseling Kids and Adults does not allow the emergency use of manual restraint. Any person who believes or knows that a manual restraint was implemented during an emergency basis they must immediately report the incident to the person listed below.

The program has identified the following person or position responsible for reporting the emergency use of manual restrain according to the standards in section 245D.061 and part 9544.0110, when determined necessary.

Carla McKean, Managing Member

Policy reviewed and authorized by: Carla McKean, Managing Member

Emergency Report and Internal Review
 

Date of emergency: __________________  Time of emergency:     ______    □ am / □ pm

Location of emergency:                                              

"Emergency" means any event that affects the ordinary daily operation of the program including, but not limited to, fires, severe weather, natural disasters, power failures, or other events that threaten the immediate health and safety of a person receiving services and that require calling 911, emergency evacuation, moving to an emergency shelter, or temporary closure or relocation of the program to another facility or service site for more than 24 hours.

This report must be completed within 24 hours of the emergency or within 24 hours of when the program became aware of the emergency.  

This form is completed when an Event AND a Response are checked below.

I.    Emergency Type (check all that apply):

Event:
⬜     Fire
⬜    Severe weather
⬜    Natural disaster
⬜    Power failure
⬜    Other event that threatened the immediate health and safety of a person

Response:
⬜     Calling 911
⬜    Emergency evacuation
⬜    Moving to an emergency shelter
⬜    Temporary closure or relocation of the program for more than 24 hours

II.    Description of emergency:

NOTE:  People receiving services do not need to be identified who were affected by or involved in the emergency.  If the emergency resulted in an incident to a person, then an Incident Report and Internal Review form must be completed for that person.  

III.    Description of response to the emergency:  

       □  Applicable coordinated service and support plan addendum(s) were implemented for person(s) involved.

□  Applicable program policies and procedures were implemented as written.

Person(s) who responded to the emergency:                                  

Name and signature of reporting staff                         Date

IV.    Internal Review 

1.    Was the emergency similar to past events with the persons or the services involved?  

⬜ Yes    ⬜ No    If yes, identify the patterns, if any.  

2.    Based on the internal review, is there a need for corrective action by the program to protect the health and safety of the persons receiving services and to reduce future occurrences? 

⬜ Yes    ⬜ No          If yes, identify the corrective action plan designed to correct current lapses and prevent future lapses in performance by providers, contractors or staff. This will be the responsibility of Carla McKean within 5 business days from the time of the incident.
 

Name of staff completing internal review: ______________________

Signature of staff completing internal review: ______________________________Date:______________

 Policy:

Upon awareness of changes to Counseling Kids and Adults L.L.C. structure, ownership, facility data, location information, licenses/certificates, address, or contact information, it will be the responsibility of managing member, Carla McKean, to complete and remit the MHDHS form DHS-3535A-ENG.

 It will be the responsibility of Carla McKean, to at least annually and preferably, 2 times per year, review our current liability insurance coverage and take necessary changes as determined reasonable. Currently, we have the following liability limits 1m/3m and have both General and Professional liability insurance through CPH Insurance. It will be required of all providers to maintain at least he aforementioned liability coverage.

 Policy:

The scope of a provider’s practice, relative to the supervision of Outpatient Mental Health services, will involve the documented time a clinical supervisor and supervisee spend together to discuss the supervisee's work, to review individual recipient cases, and for the supervisee's professional development. It includes the documented oversight and supervision responsibility for planning, implementation and evaluation of services for a recipient's mental health treatment.

Procedures:

Clinical supervision must be based on each supervisee's written supervision plan and must:

1. Promote professional knowledge, skills and values development
2. Model ethical standards of practice
3. Promote cultural competency by:
   1. Developing the supervisee's knowledge of cultural norms of behavior for individual recipients and generally for the recipients served by the supervisee regarding the recipient's cultural influences, age, class, gender, sexual orientation, literacy and mental or physical disability.
   2. Addressing how the supervisor's and supervisee's own cultures and privileges affect service delivery.
   3. Developing the supervisee's ability to assess their own cultural competence and to identify when consultation or referral of the recipient to another provider is needed
   4. Emphasizing the supervisee's commitment to maintaining cultural competence as an ongoing process
4. Recognize that the recipient's family has knowledge about the recipient and will continue to play a role in the recipient's life and encourage participation among the recipient, recipient's family and providers as treatment is planned and implemented.
5. Monitor, evaluate and document the supervisee's performance of assessment, treatment planning and service delivery

Clinical supervision must be conducted by a qualified supervisor using individual or group (or both) supervision. Individual or group face-to-face supervision may be conducted via electronic communications that utilize interactive telecommunications equipment that includes at a minimum audio and video equipment for two-way, real-time, interactive communication between the supervisor and supervisee, and meet the equipment and connection standards of telemedicine.

1. Individual supervision means one or more designated clinical supervisors and one supervisee.
2. Group supervision means one clinical supervisor and two to six supervisees in face-to-face supervision.

Clinical supervision must be recorded in the supervisee's supervision record. The documentation must include:

1. Date and duration of supervision
2. Identification of supervision type as individual or group supervision
3. Name of the clinical supervisor
4. Subsequent actions that the supervisee must take
5. Date and signature of the clinical supervisor

Clinical supervision pertinent to recipient treatment changes must be recorded by a case notation in the recipient record after supervision occurs.

A clinical supervisor must:

1. Be a licensed mental health professional
2. Hold a license without restrictions that has been in good standing for at least one year while having performed at least 1,000 hours of clinical practice
3. Be approved, certified or in some other manner recognized as a qualified clinical supervisor by the person's professional licensing board, when this is a board requirement
4. Be competent as demonstrated by experience and graduate-level training in the area of practice and the activities being supervised
5. Not be the supervisee's blood or legal relative or cohabitant, or someone who has acted as the supervisee's therapist within the past two years
6. Have experience and skills that are informed by advanced training, years of experience and mastery of a range of competencies that demonstrate the following:
   1. Capacity to provide services that incorporate best practice
   2. Ability to recognize and evaluate competencies in supervisees
   3. Ability to review assessments and treatment plans for accuracy and appropriateness
   4. Ability to give clear direction to mental health staff related to alternative strategies when a recipient is struggling with moving towards recovery
   5. Ability to coach, teach and practice skills with supervisees
7. Accept full professional liability for a supervisee's direction of a recipient's mental health services
8. Instruct a supervisee in the supervisee's work, and oversee the quality and outcome of the supervisee's work with recipients
9. Review, approve and sign the diagnostic assessment, individual treatment plans and treatment plan reviews of recipients treated by a supervisee
10. Review and approve the progress notes of recipients treated by the supervisee according to the supervisee's supervision plan
11. Apply evidence-based practices and research-informed models to treat recipients
12. Be employed by or under contract with the same agency as the supervisee
13. Develop a clinical supervision plan for each supervisee
14. Ensure that each supervisee receives the guidance and support needed to provide treatment services in areas where the supervisee practices
15. Establish an evaluation process that identifies the performance and competence of each supervisee and document clinical supervision of each supervisee and securely maintain the documentation record.

Clinical Supervisors who supervise clinical trainees must complete the Qualified Mental Health Professional Clinical Supervision Assurance Statement form (DHS-6330) (PDF) in order for clinical trainee’s time spent conducting diagnostic assessments, psychotherapy or explanation of findings to be billed.

The supervision plan must be developed by the supervisor and the supervisee. The plan must be reviewed and updated at least annually. For new staff, the plan must be completed and implemented within 30 days of the new staff person's employment. The supervision plan must include:

1. The name and qualifications of the supervisee and the name of the agency in which the supervisee is being supervised
2. The name, licensure and qualifications of the supervisor
3. The number of hours of individual and group supervision to be completed by the supervisee including whether supervision will be in person or by some other method approved by the commissioner
4. The policy and method that the supervisee must use to contact the clinical supervisor during service provision to a supervisee
5. Procedures that the supervisee must use to respond to recipient emergencies
6. Authorized scope of practices, including:
   1. Description of the supervisee's service responsibilities
   2. Description of recipient population
   3. Treatment methods and modalities

 Policy:

It is the responsibility of Counseling Kids and Adults L.L.C. and providers completing diagnostic assessments, consent forms treatment plans, progress/psychotherapy notes, crisis plans, and discharge summaries for assuring the accuracy and completeness of the aforementioned documentation. Additionally, when using an outside assessment it is the responsibility of Counseling Kids and Adults L.L.C. and the provider to identify acute and chronic clinical disorders, co-occurring medical conditions and sources of psychological and environmental problems, including baselines and a functional assessment. When the requirements of an outside diagnostic assessment do not meet Counseling Kids and Adults, 3rd party payers or MN DHS requirements, it is up to the provider and Counseling Kids and Adults L.L.C. to provide missing components of the DA, such as baseline measures are not provided in an outside DA, or when baseline measures cannot be attained in a one session an updated or extended DA may be required.

The treatment plan will drive psychotherapy to address the client's underlying mental health disorder and must be documented as part of the client's ongoing treatment. When the psychotherapy has been identified in the treatment plan, it will be our policy to either deliver or arrange for, medically necessary psychotherapy. One exception is if a client, child's parent or caregiver chooses not to receive psychotherapy. When that is the case, Counseling Kids and Adults and the provider will make sure that is noted in the client's file. 

All providers, employees, and staff will receive SimplePractice training prior to providing services. They will also receive ongoing training and support to facilitate successful use of the application to ensure excellent quality of care and documentation.

Procedures:

Standard diagnostic assessment must include a face-to-face interview with the client and contain a written evaluation of a client by a mental health professional or practitioner working under clinical supervision as a clinical trainee according to part 9505.0371, subpart 5, item C. The standard diagnostic assessment must be done within the cultural context of the client and must include relevant information about:

1. the client's current life situation, including the client's:
2. Age; current living situation, including household membership and housing status; basic needs status including economic status; education level and employment status; significant personal relationships, including the client's evaluation of relationship quality; strengths and resources, including the extent and quality of social networks; belief systems; contextual nonpersonal factors contributing to the client's presenting concerns; general physical health and relationship to client's culture; and current medications; the reason for the assessment, including the client's: perceptions of the client's condition; description of symptoms, including reason for referral; history of mental health treatment, including review of the client's records; important developmental incidents; maltreatment, trauma, or abuse issues; history of alcohol and drug usage and treatment; health history and family health history, including physical, chemical, and mental health history; and cultural influences and their impact on the client; the client's mental status examination; the assessment of client's needs based on the client's baseline measurements, symptoms, behavior, skills, abilities, resources, vulnerabilities, and safety needs; the screenings used to determine the client's substance use, abuse, or dependency and other standardized screening instruments determined by the commissioner; assessment methods and use of standardized assessment tools by the provider as determined and periodically updated by the commissioner; the client's clinical summary, recommendations, and prioritization of needed mental health, ancillary or other services, client and family participation in assessment and service preferences, and referrals to services required by statute or rule; and the client data that is adequate to support the findings on all axes of the current edition of the Diagnostic and Statistical Manual of Mental Disorders, published by the American Psychiatric Association; and any differential diagnosis.
3. Include current diagnoses including any differential diagnosis, in accordance with all criteria for a complete diagnosis and diagnostic profile as specified in the current edition of the Diagnostic and Statistical Manual of the American Psychiatric Association, or, for children under five years old, as specified in the current edition of the Diagnostic Classification of Mental Health Disorders of Infancy and Early Childhood
4. Document treatment as medically necessary to address an identified disability or functional impairment, and the recipient’s needs and goals.
5. Be used in the development of the recipient’s ITP goals and objectives.
6. Be completed annually until child is 18 years old or updated annually for recipients 18 through 20 years old, unless a recipient’s mental health condition has changed markedly since the most recent diagnostic assessment.
7. Diagnostic assessment used to establish eligibility for  services must be done by a mental health professional or clinical trainee within 365 days before services begin.

Extended diagnostic assessment must include a face-to-face interview with the client and contain a written evaluation of a client by a mental health professional or practitioner working under clinical supervision as a clinical trainee according to part 9505.0371, subpart 5, item C. The face-to-face interview is conducted over three or more assessment appointments because the client's complex needs necessitate significant additional assessment time. Complex needs are those caused by acuity of psychotic disorder; cognitive or neurocognitive impairment; need to consider past diagnoses and determine their current applicability; co-occurring substance abuse use disorder; or disruptive or changing environments, communication barriers, or cultural considerations as documented in the assessment.

1. For child clients, the appointments may be conducted outside the diagnostician's office for face-to-face consultation and information gathering with family members, doctors, caregivers, teachers, and other providers, with or without the child present, and may involve directly observing the child in various settings that the child frequents such as home, school, or care settings.
2. To complete the diagnostic assessment with adult clients, the appointments may be conducted outside of the diagnostician's office for face-to-face assessment with the adult client. The appointment may involve directly observing the adult client in various settings that the adult frequents, such as home, school, job, service settings, or community settings. The appointments may include face-to-face meetings with the adult client and the client's family members, doctors, caregivers, teachers, social support network members, recovery support resource representatives, and other providers for consultation and information gathering for the diagnostic assessment.
3. The components of an extended diagnostic assessment include the following relevant information:
   1. for children under age 5:
      1. utilization of the DC:0-3R diagnostic system for young children;
      2. Early Childhood Service Intensity Instrument (ESCII). 
      3. an early childhood mental status exam that assesses the client's developmental, social, and emotional functioning and style both within the family and with the examiner and includes:
         1. physical appearance including dysmorphic features;
         2. reaction to new setting and people and adaptation during evaluation;
         3. self-regulation, including sensory regulation, unusual behaviors, activity level, attention span, and frustration tolerance;
         4. physical aspects, including motor function, muscle tone, coordination, tics, abnormal movements, and seizure activity;
         5. vocalization and speech production, including expressive and receptive language;
         6. thought, including fears, nightmares, dissociative states, and hallucinations;
         7. affect and mood, including modes of expression, range, responsiveness, duration, and intensity;
         8. play, including structure, content, symbolic functioning, and modulation of aggression;
         9. cognitive functioning; and relatedness to parents, other caregivers, and examiner; and
      4. other assessment tools as determined and periodically revised by the commissioner;

                       2. Children over age 6, but under age 18, must include all of the above, but rather a Child and Adolescent Service Intensity Instrument (CASII) instead of a ESCII. Additionally, the DSM5 shall be used for children over age 6.

Procedures:

Individual treatment plan (ITP) is a written plan that documents the treatment strategy, the schedule for accomplishing the goals and objectives, and the responsible party for each treatment component. A treatment plan review (ITP review) is a review of progress and changes that have occurred during the 90 days since the initial ITP or previous ITP review was implemented. An ITP must be completed before mental health service delivery begins. An ITP review must be completed within 90 days after the ITP is implemented.

An ITP for any service is based on a standard or extended diagnostic assessment. It documents the plan of care and guides treatment interventions. Development of the ITP includes involvement of the client, the client’s parents or guardian who must consent to the mental health services for the client, caregivers or others that the family determines should be included in ITP development and review. ITP development includes arrangement of treatment and support activities consistent with the client’s cultural and linguistic needs.

The ITP focuses on the client's treatment needs, the family’s vision and desires for recovery in accordance with their personal and cultural values, family-driven and child-focused priority treatment goals and objectives, and the interventions that will help meet those goals and objectives. The plan must be written in a way that facilitates a clear understanding of the services being offered, that describes how the services will address client and family concerns, and that establishes goals and objectives that can be objectively measured for treatment outcomes. The client and/or family must participate in developing the ITP to ensure the treatment is relevant to their priorities and incorporates their strengths and values.

The following components must be on the individual treatment plan:

1. Specific treatment needs identified in the diagnostic assessment to be addressed
2. Measurable treatment goals and objectives, including baselines and expected changes from baselines
3. Strategies for meeting the goals and objectives
4. Specific staff responsible for implementing and monitoring each goal and objective
5. Type, frequency and duration of the services that will be provided under the ITP, including need for provider travel or add-ons such as interactive complexity. If psychotherapy is not going to be provided in the next 90 days, the plan should explain why.
6. Cultural considerations and how they will impact the service plan and service delivery
7. Client and family participation, including time spent with the family to develop the ITP and the documentation of any family concerns related to ITP implementation
8. Signatures of the client and/or other adult authorized by law to provide consent for treatment
9. Signatures must be dated

Policy:

Counseling Kids and Adults L.L.C. is committed to ongoing agency evaluation and improvement. Counseling Kids and Adult’s Managing Member, Carla McKean, is responsible for the evaluation of the agency and staff, employees, and contractors.

Quality Management Evaluation and Program Improvement Plan

Counseling Kids and Adults L.L.C. is committed to ongoing agency evaluation and improvement.  Counseling Kids and Adult’s Managing Member, Carla McKean, is responsible for the evaluation of the following information in order to develop, document, and implement the agency’s ongoing service improvement. Carla McKean is responsible for the following:

1. Maintaining a current understanding of the licensing requirements sufficient to ensure compliance throughout Counseling Kids and Adults L.L.C..
2. Ensuring implementation of any corrective action identified during the review of incident and emergency reports.
3. Ensuring that an internal review of incident reports of alleged or suspected maltreatment has been conducted.
4. Assessing the results of the Satisfaction Evaluations that are completed by the person, the person’s legal representative, if any, and case manager.  Counseling Kids and Adults L.L.C.’s schedule for conducting satisfaction evaluations is annual, or at the termination of services.

6.    Ensuring provider competency requirements are met according to the provider's professional license requirements.

7.    Ensuring that corrective action was taken when ordered by the Department of Human Services.

Procedures:

1. Each year in December, or when a client discharges from services, a Client Satisfaction survey will be sent to the client and reviewed by Carla McKean.

Policy:

Counseling Kids and Adults L.L.C. is committed to providing clients and the community with excellent mental health services. Counseling Kids and Adults L.L.C. utilizes evidence-based practices (EBP) to improve the quality of services to the clients and community we serve. The Minnesota Department of Human Services has published fact sheets that will be used at Counseling Kids and Adults L.L.C. by providers to inform services. 

Procedures:

1. All providers at Counseling Kids and Adults will use the MN DHS fact sheets, DSM 0-5 manual for children ages 0-5, DSM5,  to inform diagnosis, assessment, treatment planning, and care coordination.
2. Current evidence based practices used by Counseling Kids and Adults providers include, but are not limited to: psychoeducation, exposure, cognitive behavior therapy, family therapy, family systems therapy, motivational interviewing, relaxation, communication skills, problem solving skills, family engagement, relapse prevention/maintenance, TFCBT, goal setting, multi-systemic therapy, and Parenting with Love and Logic®

Policy:

In an effort to be in compliance with Minnesota Statute 256B.0943, we as a company. will rigorously adhere to the following. It is incumbent upon all contractors, staff, and employees of Counseling Kids and Adults L.L.C. to be familiar with resources within the communities we serve, It is imperative that each of us network within our respective "sphere of influences" with local resources in our local service area (s). Keep in mind, as we continue to journey toward being culturally competent, to include diversity within our networking sources. This will assist us with providing a culturally competent service package, with maximum benefit to our client(s).

Procedures:

1. It will be the responsibility of our mental health professional to draft all diagnostic assessments. Nonetheless, it does not negate our responsibility for providing services in an appropriate, culturally sensitive manner. Additionally, it will be the responsibility of the mental health professional assigned to the case to, on a monthly basis or more if necessary, keep the appropriate outside parties informed of all our services/outcomes provided, Remember, all necessary signed releases must be in place before any information of any kind is exchanged with anyone or any organization.
2. Furthermore, to avoid duplication of services for our clients, providers have the option to attend, if requested,
   appropriate quarterly meetings with respective case managers, If there is not a case manager assigned to the case, it will be the mental health professional's responsibility to contact necessary agencies/personnel involved in the case. Often times this could include school, other mental health personnel, child welfare, correctional officials, etc. Again, it wiII be necessary to comply with appropriate statutes addressing the release of information. This procedure will enhance our ability to provide culturally competent services, avoid duplication of services, and maximize benefit for our client(s).
3. Upon the initial phone call the client or caregiver will be asked by the phone representative, to inquire as to whether the individual receiving services has been working with or will plan to work with any external providers such as case managers, therapists, primary care physicians, psychiatrists, school workers, law enforcement, guardian ad litem, child protection workers, or probation officers.
4. Additionally, at the intake session the client and/or caregiver will be asked to complete the “Client Intake Questionnaire” which has the following questions pertaining to external communications. If there are outside providers identified, the client will be asked if he/she is interested in our agency communicating with the outside provider to coordinate care. If the client agrees to include this outside provider, the client will be required to sign a release of information prior to attempting contact with outside providers.
   1. Is there an open child protection case?
   2. Previous counseling
   3. Previous psychiatric service received
   4. Hospital admissions for psychiatric problems
   5. Is your child currently working with any other mental health providers?
   6. Does your child currently have a Primary Care Physician?
   7. Does your child currently have a Dental Provider?
   8. Does your child receive assistance with communication barriers, child care or public assistance?
   9. Support System: List persons of importance in your child’s life:
   10. School child currently attends:..Teacher:..School Counselor:
   11. What is the school doing to address your child specific needs?
       1. Special Ed, IEP, Honors Classes, School Counselor, Gifted/talented
   12. History of chemical dependency treatment?

Policy: Counseling Kids and Adults staff will treat services providers and receivers in a culturally competent manner. If the services provider is unsure of the best way to work with a culturally diverse services provider or client - this service provider must reach out to other resources within and outside the agency to ensure the client is served in a culturally competent manner.

Procedures:

1. Staff, contractors, service providers will be required to obtain education regarding cultural competency.
   1. Interventions need to be based not on the client’s cultural group but, rather upon the nature of the individual client whose individuality is partly a manifestation of his or her culture.
2. The organization will implement a step-by-step process to determine the needs of the population likely to be served by Counseling Kids and Adults L.L.C.
   1. STEP ONE: COMMUNITY NEEDS ASSESSMENT.
      1. Analyze the demographic characteristics of the service population and how a specific group’s service needs differ from the mainstream.
   2. STEP TWO: ORGANIZATIONAL AND PROVIDER CAPABILITY ASSESSMENT.
      1. Assess your organization’s ability to provide culturally appropriate services and access for diverse populations.
   3. STEP THREE: CULTURAL COMPETENCE PLAN.
      1. Compare the community needs assessment to the organization’s capability assessment, then develop a plan to address the organization’s deficiencies.
3. The organization hires culturally skilled and knowledgeable people. When it lacks professionals competent in the culture or language of a client in the waiting room, it consults with—or refers to—someone who possess those skills.
   1. The practical standard is that extraordinary effort is directed toward any cultural group likely to receive inadequate services because of differences in understanding of health, mental health, illness, and disability or differences in family customs, social patterns, child-rearing practices, and religious values.
   2. Focus simultaneously on strengthening existing personnel and recruiting diverse personnel:
   3. Recruit new diverse providers.
   4. Contract with culturally-specific providers for assessment, services, and cultural consultations and establish referral arrangements with out-of area providers.
   5. Use culturally-informed consultants, interpreters, and cultural brokers to confer with a professional who is not skilled in or knowledgeable about a client’s culture.
   6. Teach clients how to be more responsible for their own health; child development education for parents of newborns.
4. When conducting eligibility or intake activities, ensure that:
   1. communication is designed primarily to establish rapport with the client and, secondarily, to gather administrative information;
   2. Oral and written communication is understandable to clients and parents with limited English proficiency and cognitive disabilities and understandable to clients who have low levels of literacy, are non-verbal, unable to understand directions, or unable to make informed choices.
   3. Intake or enrollment forms indicate the client’s preferred language and need for an interpreter.
   4. Client is contacted by phone, mail, or other means, in the appropriate language, to inform the client how to obtain services.
   5. Counseling Kids and Adults arranges for language or hearing interpreters for scheduled appointments.
5. Conflict Resolution.
   1. Anticipate the inevitable cross-cultural differences that arise between clients and the organization and among members of a multicultural staff. Ensure that the organization’s conflict and grievance resolution processes are able to identify and resolve.
   2. Cross-cultural complaints related to services and appeals;
      1. Cultural conflicts between a client and the organization; and
      2. intra-organizational conflicts.
6. Quality Management. The organization’s overall quality management activities are linked to needs identified in the cultural competence plan.
   1. Use periodic organizational self-assessments to measure progress toward cultural competence.
   2. Integrate cultural competence measures into internal audits, performance improvement programs, client satisfaction assessments, and outcomes-based evaluations.
   3. Identify both the organization’s strengths and weaknesses.
7. Data and Management Information Systems (MIS).
   1. Enhance data collection and management information systems in order to better identify the specific needs of the diverse populations served, evaluate service outcomes of diverse clients, and track the organization’s progress toward delivering more appropriate services.
      1. Collect individual-client data on race/ethnicity, preferred language and limited English proficiency, nation of origin, and literacy in any language.
      2. African American / Black American (Descendants of those people who were enslaved)      African Immigrants      American Indian / Indigenous Communities        Asian/Pacific Islanders      Hispanic/Latinx      LGBTQIA      Limited English Proficiency      People with Disabilities      Veterans 
      3. Collect and evaluate client outcomes data by cultural and linguistic group.
         1. Analyze aggregate data as necessary to determine how the service needs of one group may be different from needs of another.
         2. Client protections are crucial to minimize potential discriminatory use of data.
            1. inform clients about the purposes for collecting data;
            2. provide written policy statements and verbal assurances that data will not be used for purposes of discrimination;
            3. allow clients to self-identify race and ethnicity and to select more than one category; but no client may be denied services for refusal to provide race, ethnicity, or nation-of-origin information.
8. Enhance cross cultural and culturally-specific services to serve diverse clients well.
   1. tailor customary services to be effective with diverse populations:
   2. client records indicate the need for a cultural broker, a bilingual provider, or an interpreter.
   3. discharge and transition planning is negotiated with the client, family, and other persons requested by the client in a communication style congruent with the client’s values in order to ensure effective services with follow-up providers.
9. Client needs determination. Determining what is normal within the client’s culture is fundamental to accurate needs assessment.
   1. Assessments and diagnoses are performed or supervised by professionals who are clinically competent and who have demonstrated competence in determining the needs of culturally diverse clients.
   2. Assessment instruments are validated and normed for use with the client’s cultural group and assessment practices are culturally appropriate.
      1. Evaluators understand the norms, biases, limitations, and appropriate uses of each assessment or diagnostic instrument.
   3. Providers administering the assessment need to understand how the bicultural encounter may distort the results. Both the professional evaluator and the client or client family may alter their typical behavior.
10. Service Planning. Service and case planning is performed or directly supervised by individuals skilled in, and knowledgeable about, the client’s culture.
    1. When service planners are not so qualified, they confer with a culturally-informed consultant.
    2. Counseling Kids and Adults L.L.C. and its service providers develop sufficient knowledge of client’s cultures to enable the use of cultural strengths to assist in the intervention.
    3. The planning process incorporates culturally-defined factors including, but not limited to:
       1. cultural attitudes toward health, mental health, family roles and success;
       2. English proficiency and preferred language;
       3. literacy;
       4. religious and spiritual needs;
       5. level of acculturation;
       6. use of alternative healers and therapies;
       7. interdependence among family members;
       8. nutritional practices;
       9. cultural differences among groups;
       10. socioeconomic stressors relevant to the client’s condition; and
       11. use of natural support systems and community organizations.
11. Service Coordination / Case Management. Organizations maximize the opportunity for client and family-directed decision-making in the delivery of services and supports. Clients and families can help to identify culture-related needs.
    1. Counseling Kids and Adults L.L.C. will adjust caseloads to allow for the extra time required for clients with limited English proficiency and for those who need family or supporters to be present;
    2. hire, credential, and evaluate service coordinators and case managers based, in part, on their demonstration of cultural and linguistic competence.
    3. help case managers learn to use the client’s own informal support network.
12. Self-Help. Counseling Kids and Adults L.L.C. encourages culturally-specific family and client self-help groups. Self-help groups are directed by the group and function as part of the continuum of service. 
13. Practice standards for health and mental health.
    1. Providers tailor general clinical practice so it will be more effective with diverse clients.
    2. Clinical practice is expanded to:
       1. provide culturally-specific interventions or treatment modalities that are common to particular cultural or linguistic populations and
       2. include practitioners who are characteristically found within a particular cultural or linguistic population or whose practices have their roots within particular cultural or linguistic traditions.
14. Inform staff of the multilingual phone lines for staff and client support
    1. Arabic (800) 358-0377 Hmong  (888) 486-8377 Khmer (Cambodian) (888) 468-3787 Lao (888) 487-8251 Oromo (888) 234-3798 Russian (888) 562-5877 Serbo-Croatian (Bosnian) (888) 234-3785 Somali (888) 547-8829 Spanish (888) 428-3438 Vietnamese (888) 554-8759
       

Policy:

Families that receive services from Counseling Kids and Adults L.L.C. will receive a client satisfaction survey that will help the agency evaluate the effectiveness and efficiency of services. The feedback provided on the client satisfaction survey will be used to develop, implement and evaluate current and future policies and procedures within the agency Counseling Kids and Adults L.L.C.

Procedures:

1. Each client will be provided with information on how to register for the client portal within the electronic medical record utilized by Counseling Kids and Adults L.L.C, Procentive.
2. The client will be encouraged to register for the client portal within the first week of services.
3. Within the client portal the client will be sent a client survey to complete either in the comfort of their own home or over the phone with staff of Counseling Kids and Adults L.L.C.
4. The client survey may be sent to clients after the first 90 days of services or every 6 months thereafter.
5. The information collected on the survey will help inform Counseling Kids and Adults L.L.C. on necessary policy changes, implementation, and development.
   

 Counseling Kids and Adults L.L.C. recognizes the right of each person receiving services to confidentiality and data privacy.  This policy provides general guidelines and principles for safeguarding service recipient rights to data privacy  and access to their records.

Procedures

1. Private Data
   1. Private data includes all information on persons that has been gathered by providers or from other sources for purposes as contained in an individual data file, including their presence and status in services.
   2. Data is private if it is about individuals and is classified as private by state or federal law. Only the following persons are permitted access to private data with a consent to release information is signed by legally responsible parties:
      1. The individual who is the subject of the data or a legal representative.
      2. Anyone to whom the individual gives signed consent to view the data.
      3. Employees of the welfare system whose work assignments reasonably require access to the data.  This includes staff persons in this program.
      4. Anyone the law says can view the data.
      5. Data collected within the welfare system about individuals are considered welfare data. Welfare data is private data on individuals; including medical and/or health data. Agencies in the welfare system include, but are not limited to: Department of Human Services; local social services agencies, including a person’s case manager; county welfare agencies; human services boards; the Office of Ombudsman for Mental Health and Developmental Disabilities; and persons and entities under contract with any of the above agencies; this includes this program and other licensed caregivers jointly providing services to the same person.
      6. Once informed consent has been obtained from the person or the legal representative there is no prohibition against sharing welfare data with other persons or entities within the welfare system for the purposes of planning, developing, coordinating and implementing needed services
      7. Data created prior to the death of a person retains the same legal classification (public, private, confidential) after the person’s death that it had before the death.
2. Providing Notice
   1. At the time of service initiation, the person and his/her legal representative, if any, will be notified of this program's data privacy policy.  Staff will document that this information was provided to the individual and/or their legal representative in the individual record.
3.  Obtaining Informed Consent or Authorization for Release of Information
   1. At the time informed consent is being obtained staff must tell the person or the legal representative individual the following:
      1. why the data is being collected;
      2. how the agency intends to use the information;
      3. whether the individual may refuse or is legally required to furnish the information;
      4. what known consequences may result from either providing or refusing to disclose the information; and with whom the collecting agency is authorized by law to share the data. What the individual can do if they believe the information is incorrect or incomplete;
      5. how the individual can see and get copies of the data collected about them; and any other rights that the individual may have regarding the specific type of information collected.
   2. A proper informed consent or authorization for release of information form must include these factors (unless otherwise prescribed by the HIPAA Standards of Privacy of Individually Identifiable Health Information 45 C.F.R. section 164):
      1. be written in plain language;
      2. be dated;
      3. designate the particular agencies or person(s) who will get the information;
      4. specify the information which will be released;
      5. indicate the specific agencies or person who will release the information;
      6. specify the purposes for which the information will be used immediately and in the future;
      7. contain a reasonable expiration date of no more than one year; and
      8. specify the consequences for the person by signing the consent form, including: "Consequences: I know that state and federal privacy laws protect my records. I know:
         1. Why I am being asked to release this information.
         2. I do not have to consent to the release of this information.  But not doing so may affect this program's ability to provide needed services to me.
         3. If I do not consent, the information will not be released unless the law otherwise allows it.
         4. I may stop this consent with a written notice at any time, but this written notice will not affect information this program has already released.
         5. The person(s) or agency(ies) who get my information may be able to pass it on to others.
         6. If my information is passed on to others by this program, it may no longer be protected by this authorization.
         7. This consent will end one year from the date I sign it, unless the law allows for a longer period."
      9. Maintain all informed consent documents in the consumer's individual record.
4. Access to Private Data
   1. This policy applies to all staff, volunteers, and persons or agencies under contract with this program (paid or unpaid).
   2. Contracted persons, staff, providers do not automatically have access to private data about the persons served by Counseling Kids and Adults or about other providers, staff, or contractors.  Providers, staff, or contractors must have a specific work function need for the information. Private data about persons are available only to those providers, staff, or contractors whose work assignments reasonably require access to the data; or who are authorized by law to have access to the data.
   3. Any written or verbal exchanges about a person's private information by providers, staff, or contractors other staff or any other persons will be done in such a way as to preserve confidentiality, protect data privacy, and respect the dignity of the person whose private data is being shared.
   4. As a general rule, doubts about the correctness of sharing information should be referred to the supervisor or managing member Carla McKean.
5. Individual access to private data.
   1. Individuals or their legal representatives have a right to access and review the individual record.
      1. Providers, staff, or contractors will be present during the review and will make an entry in the person's progress notes as to the person who accessed the record, date and time of review, and list any copies made from the record.
      2. An individual may challenge the accuracy or completeness of information contained in the record.  Providers, staff, or contractors will refer the individual to the grievance policy for lodging a complaint.
      3. Individuals may request copies of pages in their record.
      4. No individual, legal representative, providers, staff, or contractors, or anyone else may permanently remove or destroy any portion of the person’s record.
6.  Requesting Information from Other Licensed Caregivers or Primary Health Care Providers.
   1. Complete the release of information authorization form.  Carefully list all the consults, reports or assessments needed, giving specific dates whenever possible.  Also, identify the purpose for the request.
   2. Clearly identify the recipient of information.   Attention: (name of person to receive the information), and the name and address of the program.
   3. Assure informed consent to share the requested private data with the person or entity has been obtained from the person or the legal representative.
   4. Keep the document in the person’s record.
      

Regarding: Confidentiality, releases of information, presentations, 7 year destruction of client files, taped sessions, computer security, informed consent, Consideration of dual/multiple relationships, exploitive relationships, informed consent-our responsibilities; clients served by others, termination and referrals, client's rights, counselor responsibilities and integrity, competence, record keeping-fee arrangements and bartering, commitment to students, supervisees and employee relationships, commitment to the profession, teaching, research and publications, commitment to the public, public statements, advertising, resolving of ethical problems, and ethical decision making.

CODE OF ETHICS POLICY

Counseling Kids and Adults  LLC will conduct its business honestly and ethically wherever we provide services. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company's best interest. Counseling Kids and Adults  LLC will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

This code is a document intended as a guide to assist our members/affiliates to: regardless of what professional licensing board they mayor may not belong, make sound ethical decisions, to define ethical behaviors and best practices for our organization, to support the mission and values of Counseling Kids and Adults  LLC, to educate members, students and the public at large regarding ethical standards, to increase the knowledge of all members, contractors and affiliates of our organization, to make better ethical decisions.

A. Provider-Client Relationship

1. Primary Responsibility Counseling Kids and Adults  LLC  values objectivity and integrity in our commitment to understanding human behavior, and we maintain the highest standards in providing mental health counseling services. The primary responsibility of our organization is to respect client dignity and promote client welfare. Mental health professionals, Clinical Trainees, Mental Health Practitioners,  are clear with clients about the their respective provision of service(s). In a professional disclosure statement, they provide information about their respective expectations and responsibilities to the client. Each member explains their professional orientation and values regarding their provision of services, emergency procedures, supervision (as applicable) and business practices. Information is also provided regarding client rights and contact information.

2. Confidentiality

Each member of Counseling Kids and Adults  LLC  has a primary obligation to safeguard information about individuals obtained in the course of practice, teaching, or research. Personal information is communicated to others only with the person's written consent, or in those circumstances, as dictated by state laws. Disclosure of information, is restricted to what is necessary, relevant and verifiable.

a)Confidentiality is a right granted to all clients of mental health counseling services. From the onset of the counseling relationship, mental health professionals inform clients of these rights including legal limitations and exceptions.

b )The information in client records belongs to the client and shall not be shared without permission granted through a formal release of information. In the event that a client requests that information in his or her record be shared, mental health professionals educate clients to the implications of sharing the materials.

c)The release of information without consent of the client may only take place under the most extreme circumstances: the protection of life (suicidality or homicidality), child abuse, and/ or abuse of incompetent persons and elder abuse. Above all, mental health professionals are required to comply with state and federal statutes concerning mandated reporting.

d)Case reports presented in classes, professional meetings, supervision sessions or publications shall be disguised so that no identification is possible. Permission (written) must be obtained from clients prior to disclosing their identity.

e)Counseling reports and records are maintained under conditions of security, and provisions are made for their destruction after seven (7) years post termination or as specified by state regulations. Mental health professionals ensure that all persons in their employ, and volunteers, supervisees and interns, maintain confidentiality of client information.

f)Sessions with clients may be taped or otherwise recorded only with written permission of the client or guardian. Even with a guardians' written consent, mental health professionals should not record a session against the expressed wishes of a client. Such tapes shall be destroyed after seven (7) years post termination or as specified by state regulations.

The primary client owns the rights to confidentiality; however, in the case where primary clients are minors or are adults who have been legally determined to be incompetent, parents and guardians have legal access to client information. Where appropriate, a parent(s) or guardian(s) may be included in the provision of  Services. When using a computer to store confidential information, Counseling Kids and Adults L.L.C. staff will take measures to control access to such information. After seven (7) years post termination or as specified by state regulations, the information should be deleted from the system.

Counseling Kids and Adults providers, staff, contractors will always take necessary precautions to ensure client confidentiality of information transmitted electronically through the use of a computer, e-mail, fax, telephone, voice mail, answering machines, or any other electronic means. Counseling Kids and Adults L.L.C. will protect the confidentiality of deceased clients in accordance with legal requirements and agency or organizational policy.  Counseling Kids and Adults L.L.C. staff may disclose information to third-party payers only after clients have authorized such disclosure. (Informed Consent Form).

3. Dual/multiple Relationships

All members/contractors/staff/providers with Counseling Kids and Adults LLC are aware of their influential position with respect to their clients and avoid exploiting the trust and fostering dependency of the client. Counseling Kids and Adults staff will make every effort to avoid dual/multiple relationships with clients that could impair professional judgment or increase the risk of harm. Examples of such relationships may include, but are not limited to: familial, social, financial, business, or close personal relationships with the clients.

When deciding whether to enter a dual/multiple relationship with a client, former client

or close relationship to the client, Counseling Kids and Adults L.L.C. staff will seek consultation with our Managing Member and adhere to a credible decision-making process prior to entering this relationship. When a dual/multiple relationship cannot be avoided, Counseling Kids and Adults staff will take appropriate professional precautions such as informed consent, consultation, supervision and documentation to ensure that judgment is not impaired and no exploitation has occurred. Counseling Kids and Adults LLC does not accept as clients, individuals with whom they are involved in an administrative, supervisory or other relationship of an evaluative nature.

4 . Exploitive Relationships

All Counseling Kids and Adults L.L.C.  providers, staff, contractors will be educated and become aware of the intimacy and responsibilities inherent in their respective role of providing mental health services to clients, children and their families. At all times, they will maintain respect for the client and avoid actions that seek to meet their personal needs at the expense of the client. Regardless of title or professional status, all staff/providers/contractors/affiliates are strictly prohibited from romantic or sexual relationships with our clients. Furthermore, Counseling Kids and Adults L.L.C. staff/providers/contractors/affiliates will not provide any type of service with whom they had a previous romantic or sexual relationship. All Counseling Kids and Adults L.L.C. staff/providers/contractors/affiliates  will be educated and made aware of their own values, attitudes, beliefs and behaviors, as well as how these apply in a society with clients from diverse ethnic, social, cultural, religious, and economic backgrounds. In particular, will know how their own backgrounds and diversity might have an impact on their delivery of services to their respective clients.

5. Informed Consent

Clients have the right to know and understand what is expected, how the information

divulged will be used, and the freedom to choose whether, and with whom, they will enter into

a counseling relationship. Counseling Kids and Adults L.L.C. will provide information that allows clients to make an informed choice when selecting a provider. Such information includes but is not limited to: counselor credentials, issues of confidentiality, the use of tests and inventories, diagnosis, reports, billing, and therapeutic process. Informed Consent includes the mental health counselor's professional disclosure statement and client bill of rights. Informed consent is ongoing and needs to be reassessed throughout the entire professional relationship.

6. Clients Served by Others

When clients choose to change professionals or services from another organization(s) but have not terminated services with the former professional or organization, it is important to encourage the individual to first deal with that termination prior to entering into a new therapeutic relationship. When clients work with multiple providers, Counseling Kids and Adults L.L.C. staff will be purposeful to secure permission to work collaboratively with the other professionals/organizations involved.

5. Termination and Referral

Counseling Kids and Adults L.L.C. staff/providers/contractors/affiliates do not abandon or neglect providing services to their clients. Assistance is given in making appropriate arrangements for the continuation of treatment, when necessary, during interruptions such as vacation/sicknesses and upon following termination of services.

Counseling Kids and Adults L.L.C. staff/providers/contractors/affiliates will terminate a counseling relationship when it is reasonably clear that the client is no longer benefiting, when services are no longer required, when counseling services no longer serves the needs and/or interests of the client, or when agency or institution limits do not allow provision of further various services.

Counseling Kids and Adults L.L.C. may terminate a professional relationship/therapeutic relationship, when clients do not pay fees charged or when insurance denies treatment. In such cases, appropriate referrals are offered to the clients.

When Counseling Kids and Adults L.L.C. refers clients to other professionals, open and collaborative communication is important to ensure an appropriate transition. If clients are in danger, such as domestic violence or suicidality, Counseling Kids and Adults L.L.C. staff will take steps to secure a safety plan, refer to appropriate resources, and if necessary contact appropriate support.

7. Clients' Rights

In the delivery of all services by Counseling Kids and Adults L.L.C., all clients have the right to be treated with dignity, consideration and respect at all times. Clients have the right:

1. to expect quality service provided by concerned, trained, professional and competent staff,
2. to expect complete confidentiality within the limits of the law, and to be informed about the legal exceptions to confidentiality; and to expect that no information will be released without the client's knowledge and written consent,
3. to a clear working contract in which business items, such as time of sessions, payment plans/fees, absences, access, emergency procedures, third-party reimbursement procedures, and termination and referral procedures,
4. to know purposes, goals, techniques, rules limitations, and all other pertinent information that may affect the ongoing mental health counseling/skills work relationship, to appropriate information regarding our staff's and education, skills, license and practice limitations and to request and receive referrals to other clinicians when appropriate,
5. to receive full, knowledgeable, and responsible participation in the ongoing treatment plan to the maximum extent feasible,
6. to obtain information about their case record and to have this information explained, clearly and directly, to request information and/or consultation regarding the conduct and progress of their therapy,
7. to refuse any recommended services and to be advised of the consequences of this action,
8. to a safe environment for counseling free of emotional, physical, or sexual abuse,
9. to a client's grievance procedure, including requests for consultation and/or mediation; and to file a complaint with the supervisor (where relevant), and/or the appropriate credentialing body,
10. to a clearly defined ending process, and
11. to discontinue therapy at any time.

8. Counselor Responsibility and Integrity

The maintenance of high standards of professional competence is a responsibility shared by

all mental health professionals/practitioners/supervisors etc. in the best interests of the client, the public, and the profession.

All Counseling Kids and Adults L.L.C. staff/providers/contractors/affiliates will:

1. recognize the boundaries of their particular competencies and the limitations of their expertise,
2. provide only those services and use only those techniques for which they are qualified by education, techniques or experience. 
3. maintain knowledge of relevant scientific and professional information related to the services rendered, and recognize the need for on-going education.
4. represent accurately their competence, education, training, and experience including licenses and certifications.
5. perform their duties, as teaching professionals, based on careful preparation in order that their instruction is accurate, up-to-date and educational.
6. recognize the importance of continuing education and remain open to new skills approaches and procedures documented by peer-reviewed scientific and professional literature.
7. recognize the important need to be competent in regard to cultural diversity and are sensitive to the diversity of varying populations as well as to changes in cultural expectations and values over time.
8. recognize that their effectiveness is dependent on their own mental and physical health. Should their involvement in any activity, or any mental, emotional, or physical health problem, compromise sound professional judgment and competency, they seek capable professional assistance to determine whether to limit, suspend, or terminate services to their clients.
9. have a responsibility to maintain high standards of professional conduct at all times.
10. take appropriate steps to rectify ethical issues with colleagues by using procedures developed by employers and/or state licensure boards.
11. maintain awareness of the intimacy of their relationship, maintain a healthy respect for the integrity of the client, and avoid engaging in activities that seek to meet their personal needs at the expense of the client.
12. will actively attempt to understand the diverse cultural backgrounds of the clients with whom they work. This includes learning how each staff/providers/contractors/affiliates own cultural, ethical, racial, religious, financial,  immigration status etc. identity impacts his or her own values and beliefs about their delivery of service(s).
13. are responsible for continuing education and remaining abreast of current trends and changes in their respective field(s) including the professional literature on best practices.
14. develop a plan for termination of practice, death or incapacitation by assigning a colleague or records custodian to handle transfer of clients and files.
15. 
    

9. Competence

Mental health professionals employ only those diagnostic tools and assessment instruments they are trained to use by education, or supervised training and clinical experience. Mental health professionals/Clinical Trainees seek appropriate workshops, supervision and training to familiarize themselves with assessment techniques and the use of specific assessment instruments. Mental health supervisors ensure that their supervisees have adequate training in interpretation before allowing them to evaluate tests independently.

10. Record-Keeping, Fee Arrangements, and Bartering

• Record keeping

Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates will create and maintain accurate and adequate clinical and financial records. Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates creates, maintain, store, transfer, and dispose of client records in ways that protect confidentiality and are in accordance with applicable regulations or laws. Counseling Kids and Adults L.L.C. establishes a plan for the transfer, storage, and disposal of client records in the event of withdrawal from practice or death of the counselor that maintains confidentiality and protects the welfare of the client.

• Fee Arrangements, Bartering, and Gifts

Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates is cognizant of cultural norms in relation to fee arrangements, bartering, and gifts. Staff, providers, contractors, affiliates clearly explain to clients, early in the counseling relationship, all financial arrangements related to counseling.

In establishing professional fees, Counseling Kids and Adults L.L.C. takes into consideration the financial situation of clients and locality. If the usual fees create undue hardship for the client, the counselor may adjust fees or assist the client to locate comparable affordable services.

Generally, Counseling Kids and Adults L.L.C. and staff, providers, contractors, affiliates will refrain from accepting goods or services from clients in return for counseling services because such arrangements may create the potential for conflicts, exploitation and distortion of the professional relationship. Nonetheless, if the aforementioned warrants a different approach it will be brought to Counseling Kids and Adults L.L.C. for final consideration. Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates contributes to society by providing pro bono services.

When accepting gifts, Counseling Kids and Adults L.L.C. will take into consideration the therapeutic relationship, motivation of giving, the staff's motivation for receiving or declining, cultural norms, and the value of the gift.

11. Commitment to Students, Supervisees and Employee Relationships

Counseling Kids and Adults L.L.C. has an ethical concern for the integrity and welfare of supervisees, students, and employees. These relationships typically include an evaluative component and therefore need to be maintained on a professional and confidential basis. Counseling Kids and Adults L.L.C. recognizes the influential position they have with regard to both current and former supervisees, students and employees and avoid exploiting their trust and dependency. Counseling Kids and Adults L.L.C. staff does not engage in ongoing counseling relationships with current supervisees, students and employees. All forms of sexual behavior with supervisees, students and employees are unethical. Counseling Kids and Adults L.L.C. staff does not engage in any form of harassment of supervisees, students, employees or colleagues. Counseling Kids and Adults L.L.C. supervisors advise their supervisees, students and employees against holding themselves out to be competent to engage in professional services beyond their training, experience, or credentials.

With supervisees, students and employees, Counseling Kids and Adults L.L.C. staff makes every effort to avoid dual/multiple relationships that could bias their judgment or increase the risk of personal or financial exploitation. When a dual/multiple relationship cannot be avoided, Counseling Kids and Adults L.L.C. will take appropriate professional precautions to make sure that detrimental effects are minimized. Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates will not disclose supervisee confidences regarding client information except:

1) To prevent clear and imminent danger to a person or persons.

2) As mandated by law,

(a) as in mandated child or senior abuse reporting or

(b) where the counselor is a defendant in a civil, criminal or disciplinary action.

(c) or where there is a waiver of confidentiality obtained in writing prior to such

a release of information.

Students and supervisees have the same ethical obligations to clients as those required of other Counseling Kids and Adults L.L.C. staff, providers, contractors, affiliates. The primary obligation of Counseling Kids and Adults L.L.C. supervisors is to monitor services provided by supervisees to ensure client welfare. Supervisors are expected to monitor clinical performance of supervisees; including but not limited to regular meetings, review of case notes and records, direct observation of supervisee's clinical work via audio/video records, or live supervision. Counseling Kids and Adults L.L.C. professional supervisees will have a Supervision Plan in place before providing supervision.

12. Commitment to the Profession

Counseling Kids and Adults L.L.C. promotes the goals, values, and knowledge of the profession. We engage in activities that maintain and increase the respect, integrity, and knowledge base of the counseling profession and human welfare. Such activities include but are not limited to teaching, research, serving on professional boards and membership in professional associations.

Teaching

As teaching professionals, mental health professionals perform their duties based on careful preparation in order that their instruction is accurate, current, and educational.

Research and Publications

Mental health professionals, as researchers, conduct investigations and publish findings with respect for dignity and welfare of the participants and integrity of the profession.

1. The ethical researcher seeks advice from other professionals if any plan of research suggests a deviation from any ethical principle of research with human subjects. Such deviation protects the dignity and welfare of the client and places on the researcher a special burden to act in the subject's interest.
2. The ethical researcher is open and honest in the relationship with research participants.
3. The ethical researcher protects participants from physical and mental discomfort, harm, and danger. If the risks of such consequences exist, the investigator is required to inform participants of that fact, secure consent before proceeding, and take all possible measures to minimize the distress.
4. The ethical researcher instructs research participants that they are free to withdraw from participation at any time.
5. The ethical researcher understands that information obtained about research participants during the course of an investigation is confidential. When the possibility exists that others may obtain access to such information, participants are made aware of the possibility and the plan for protecting confidentiality and for storage and disposal of research records.
6. The ethical researcher gives sponsoring agencies, host institutions, and publication channels the same respect and opportunity for informed consent that they accord to individual research participants.
7. The ethical researcher is aware of his or her obligation to future research and ensures that host institutions are given feedback information and proper acknowledgement.

 13. Commitment to the Public

Counseling Kids and Adults L.L.C. recognizes they have a moral, legal, and ethical responsibility to the community and to the general public.Counseling Kids and Adults L.L.C. is aware of the prevailing community and cultural values, and the impact of professional standards on the community.

• Public Statements

Counseling Kids and Adults L.L.C. may be expected or required to make public statements providing counseling information, or services that are being offered or professional opinions, or supply information about the availability of counseling products and other mental health services. In making such statements, mental health counselors accurately present their education, professional qualifications, licenses and credentials, expertise, affiliations, and functions, as well as those of the institutions or organizations with which the statements may be associated. Public statements serve the purpose of providing information to aid the public in making informed judgments and choices. All public statements will be consistent with this Code of Ethics.

• Advertising

Counseling Kids and Adults L.L.C. will advertise in the following manner: highest counseling-related degree, type and level of certification or license, and type and/or description of services or other relevant information concerning areas of clinical competence. These statements will not be false, inaccurate, misleading, or out of context.

14. Resolution of Ethical Problems

At times, because of the nature of Counseling Kids and Adults L.L.C. clinical practice, ethical dilemmas may arise. When the aforementioned ethical dilemmas occur, not warranting immediate/emergency attention, supervision is always paramount. Counseling Kids and Adults L.L.C. LLC and it's members will utilize the following simple approach to ethical decision making.

Ethical Decision Making Model at a Glance

1. Notify Counseling Kids and Adults L.L.C., our Mental Health Professional
2. Identify the problem.
3. Apply the Code of Ethics (if a professional) use your respective licensing boards Code of Ethics
4. Determine the nature and dimensions of the dilemma.
5. Generate potential courses of action.
6. Consider the potential consequences of all options, choose a course of action.
7. Evaluate the selected course of action.

There is rarely one right answer to a complex ethical dilemma. However, Counseling Kids and Adults L.L.C. will follow the aforementioned systematic model for resolving ethical dilemmas. Counseling Kids and Adults L.L.C. staff, providers, contractors, member, affiliates must maintain personal and professional honesty coupled with the best interests of the client. Counseling Kids and Adults L.L.C.,  in choosing the "selected course of action", will only use commonly recognized procedures for ethical decision-making. Additionally, our managing member may, but not be limited to : consulting with other colleagues, consulting with respective state/national licensing board(s), consulting with varying Ethics Committees (mental health), reviewing germane Rules, Mn /statutes, Federal Laws, or perhaps reporting Counseling Kids and Adults L.L.C. staff, providers, contractors, member, affiliates  to their respective licensing board etc.

Policy

It is the policy of Counseling Kids and Adults L.L.C. to ensure our procedures for service termination promote continuity of care and service coordination for persons receiving services. 

Procedures

A.    Counseling Kids and adults L.L.C. providers must permit each person to remain in the program and must not terminate services unless:

   1.    The termination is necessary for the person's welfare and the person's needs cannot be met in the facility;
  2.    The safety of the person or others in the program is endangered and positive support strategies were attempted and have not achieved and effectively maintained safety for the person or others;
  3.    The health of the person or others in the program would otherwise be endangered;
  4.    The Counseling Kids and adults L.L.C. providers have not been paid for services;
  5.    The Counseling Kids and adults L.L.C. providers ceases to operate; or 
  6.    The person has been terminated by the lead agency from waiver eligibility.

B.    Prior to giving notice of service termination Counseling Kids and adults L.L.C. providers must document the actions taken to minimize or eliminate the need for termination.

  1.    Action taken by the license holder must include, at a minimum:
     a.    Consultation with the client and/or family to identify and resolve issues leading to the issuance of the notice. The request for intervention services will not be made for service termination notices issued because Counseling Kids and adults L.L.C. providers have not been paid for services.

   2.    If, based on the best interests of the person, the circumstances at the time of the notice were such that Counseling Kids and adults L.L.C. providers are unable to consult with the client or client's family, Counseling Kids and adults L.L.C. providers must document the specific circumstances and the reason for being unable to do so.

C.    The notice of service termination must meet the following requirements:

   1.    Counseling Kids and adults L.L.C. providers must notify the person or the person’s legal representative and the case manager in writing of the intended service termination.  

 All incidents must be reported within 24 hours of the incident or within 24 hours of when the program became aware of the incident.  A separate form must be completed for each person – do not use identifying information, such as names or initials, if the incident involved another person receiving services.

Date of incident:      Time of incident:     □ am / □ pm

Location of incident:   

Person name:   

Agency Name:  Counseling Kids and Adults L.L.C.

1. Incident Type (check all that apply):

⬜ Death or serious Injury (Must also be reported using the forms from the Office of Ombudsman for Mental Health and Developmental Disabilities)

⬜ Any medical emergency, unexpected serious illness, or significant unexpected change in an illness or medical condition that requires services to call 911, physical treatment, or hospitalization

• Any mental health crisis that requires the program to call 911 or a mental health crisis intervention team.
• Any data privacy violations.
• An act or situation involving a person that requires services to call 911, law enforcement, or the fire department
• Unauthorized or unexplained absence
• Conduct by a person against another person that: is so severe, pervasive, or objectively offensive that it substantially interferes with a person’s opportunities to participate in or receive service or support; places the person in actual and reasonable fear of harm; places the person in actual and reasonable fear of damage to property of the person; or substantially disrupts the orderly operation of the services and agency.
• Any sexual activity between persons that involves force or coercion
• Any emergency use of manual restraint (Also refer to Emergency Use of Manual Restraint Policy)
• A report of alleged or suspected child or vulnerable adult maltreatment (Also refer to Maltreatment of Minors or Vulnerable Adults Reporting Policy)

1. Description of incident: 
2. Description of staff, provider, contractor, member or affiliate response to the incident:

• Applicable coordinated service and support plan addendum(s) were implemented for the person(s) involved.
• Applicable policies and procedures were implemented as written.

Staff, provider, member, affiliate, contractor person(s) who responded to the incident:   

Name of reporting Staff, provider, member, affiliate, contractor: ____________________________      

Signature of reporting Staff, provider, member, affiliate, contractor: ______________________________ Date :___________________

1. Persons Notified (within 24 hours of the incident)

Case manager:   Name                          Date                            Time

Legal representative or:    Name                          Date                            Time

designated emergency contact           

Other:   Name                          Date                            Time

Other:   Name                          Date                            Time

Ombudsman**:    Name                          Date                            Time                                                                           

DHS Licensing**:                                Name                          Date                            Time                                                                                                               

or OHFC for ICF/DD                           Name                          Date                            Time

** Notified of death and serious injuries only

1. Internal Review of Incident

Items A to C are required for serious injuries, including deaths, emergency use of manual restraint, and alleged or suspected maltreatment. Items D and E are required for ALL incidents.

1. Were the related policies and procedures followed?        ⬜ Yes ⬜ No⬜            

If no, explain. 

1. Were the policies and procedures adequate?      ⬜ Yes ⬜ No⬜            

If no, explain

1. Is there a need for additional training?         ⬜ Yes ⬜ No⬜            

If yes, what training is needed, when will it be provided, and who will attend? 

1. Is the incident similar to past events with the persons or the services involved?  ⬜ Yes ⬜ No

If yes, identify the incident patterns. 

1. Is there a need for corrective action by the agency to protect the health and safety of the persons receiving services and to reduce future occurrences?          ⬜ Yes ⬜ No 

If yes, identify the corrective action plan designed to correct current lapses and prevent future lapses in performance by Staff, provider, member, affiliate, contractor. (Include applicable implementation dates, Staff, provider, member, affiliate, contractor assigned to take the corrective action, and attach relevant documentation.) 

For emergency use of manual restraint only:  Is there a need to revise the person’s service and support strategies?          ⬜ Yes ⬜ No

Name of Staff, provider, member, affiliate, contractor completing internal review: ____________________________

Signature of Staff, provider, member, affiliate, contractor completing internal review: ____________________________Date: _______________

Policy:

Client outcomes guide our agency and providers as to current effectiveness in treatment and future goals for quality improvement. Minimally, every 90 days, it will be the managing member, Carla McKean’s, responsibility to ensure review of all treatment plans, progress notes and psychotherapy notes. In reviewing these documents we will also be looking for outcomes respective to the clients we serve. In an effort to track and follow functionality gains and losses of our clients efficiently, we will use the following instruments and procedures:

Procedures:

1. PHQ9, WHODAS, GAD7 CASII, ESCII, Vanderbilt, EMDR Assessments, or SDQ may be completed at intake and every 6 months thereafter. These documents will be completed by the client or caregiver via the kiosk feature in SimplePractice.
2. Outcomes will be monitored and patterns will be evident of changes in scores, length of services, frequency of services, and client satisfaction surveys.
3. Counseling Kids and Adults will use the information calculated on the spreadsheet to identify trends, strengths and weaknesses.
4. The results of the outcomes will be used to inform changes, updates, and additions to policies and procedures.
5. The results of the outcomes will be used to inform changes, updates, and additions to our cultural competency policies, procedures, and improvement plan.
6. The results of the outcomes will be used to inform changes, updates, and additions to the quality assurance process and quality improvement plan for future needs.
7. At least annually, the outcomes will be reviewed, changes will be made to improvement plans and policies and all staff, employees and contractors will be notified of the outcomes and the plan for change.
8. All staff, employees, and contractors will be allowed the opportunity to provide input and feedback to help inform possible changes to the agencies policies, procedures, and improvement plans.

Incident Report and Internal Review

All incidents must be reported within 24 hours of the incident or within 24 hours of when the program became aware of the incident.  A separate form must be completed for each person – do not use identifying information, such as names or initials, if the incident involved another person receiving services.

Date of incident:      Time of incident:     □ am / □ pm

Location of incident:   

Person name:   

Program Name:  Counseling Kids and Adults L.L.C.             License Number:                   

1. Incident Type (check all that apply):

⬜ Death or serious Injury (Must also be reported using the forms from the Office of Ombudsman for Mental Health and Developmental Disabilities)

⬜ Any medical emergency, unexpected serious illness, or significant unexpected change in an illness or medical condition that requires the program to call 911, physical treatment, or hospitalization

• Any mental health crisis that requires the program to call 911 or a mental health crisis intervention team.
• Any data privacy violations.
• An act or situation involving a person that requires the program to call 911, law enforcement, or the fire department
• Unauthorized or unexplained absence from a program
• Conduct by a person against another person that: is so severe, pervasive, or objectively offensive that it substantially interferes with a person’s opportunities to participate in or receive service or support; places the person in actual and reasonable fear of harm; places the person in actual and reasonable fear of damage to property of the person; or substantially disrupts the orderly operation of the program
• Any sexual activity between persons that involves force or coercion
• Any emergency use of manual restraint (Also refer to Emergency Use of Manual Restraint Policy)

Policy: We believe that all people should have access to care, therefore, whenever possible, we offer telehealth as an office location. For the purpose of practicing healthcare in the delivery, diagnosis, consultation, treatment, transfer of data, and education we use interactive audio, video, or data communications. 

Procedures:

1. Billing: 
   1. Billing for services must be in compliance with State and federal laws as well as in accordance with any third party payer’s requirements. These laws and requirements vary by state. 
2. Confidentiality/Privacy: 
   1. Transmitting Protected Health Information (PHI) including, but not limited to, patient records, diagnostic results, and videotapes must be secure on both the transmitting and receiving ends. We use the hipaa compliant video platform through Simple practice, our EHR.
3. Patient Consents: 
   1. Patient Consents are required documentation prior to the encounter. The provider requesting the telemedicine services at the originating site must advise the patient about the proposed use of telemedicine, any potential risks, consequences, and benefits and obtain the patient’s or the patient’s legal representative’s consent. 
4. 2.4 Medical Record Documentation: 
   1. Providers must document all telemedicine services, provide that documentation to the originating site when applicable, and maintain a copy in the facility’s medical record. The physical location of the patient as well as the physical location of the provider must be documented as well as everyone involved in the clinical encounter, including those who may be off camera. Additional documentation needs are dictated by the service or procedure performed. 
5. Providers: 
   1. Providers must be licensed in the state where the patient is (originating site) and credentialed at the originating site if it is another health care facility. Prior to the delivery of health care via telemedicine, the provider who is primarily responsible for the care of the patient and for indicating the patient's primary diagnosis and/or his/her designee will inform each patient that: 
      1. He/she has the right to withhold/withdraw consent to telemedicine at any time, without affecting his/her right to present/future care/treatment or the loss/withdrawal of any treatment benefits to which he/she or his/her legal representative would otherwise be entitled 
      2. The patient legal representative must sign a written statement, prior to the delivery of health care via telemedicine, indicating that he/she understands the information provided and that this information has been discussed with him/her by the provider and/or his/her designee 
      3. He/she is entitled to be given a description of the potential risks, consequences, and benefits of telemedicine 
      4. All existing confidentiality protections apply 
      5. All existing laws regarding patient access to medical/clinical information and copies of such information, apply
      6. Dissemination of any patient identifiable images/information from telemedicine interactions with researchers or other entities will not occur without his/her consent. 
6. Legal: 
   1. The patient legal representative must sign a written statement, prior to the delivery of health care via telemedicine, indicating that he/she understands the information provided and that this information has been discussed with him/her by the provider and/or his/her designee. 
7. III. Definitions: 
   1. Protected Health Information (PHI): Patient identifiable information contained in any medical record, report, test result, summary, video or communication. 
8. Telemedicine: 
   1. The practice of healthcare delivery, diagnosis, consultation, treatment, transfer of data, and education using interactive audio, video, or data communications. http://www.americantelemed.org/about/telehealth-faqs- 
   2. Interactive: Is an audio, video, or data communication involving real time (synchronous) or near real time (asynchronous) two-way transfer of medical data and information. 
   3. Neither a telephone conversation nor an electronic mail message between a healthcare provider constitutes “telemedicine”

 Crisis/Emergency Services is: The method(s) used to offer immediate, short-term help to individuals who experience an event that produces emotional, mental, physical, and behavioral distress or problems. In some instances, a crisis may constitute an imminent threat or danger to self, to others, or grave disability. At Counseling Kids and Adults, we take our client's safety seriously and we offer business and after hours crisis mental health support. 

A mental health emergency is a life threatening situation in which an individual is imminently threatening harm to self or others, severely disoriented or out of touch with reality, has a severe inability to function, or is otherwise distraught and out of control.

Examples of a Mental Health Emergency include:

• Acting on a suicide threat
• Homicidal or threatening behavior
• Self-injury needing immediate medical attention
• Severely impaired by drugs or alcohol
• Highly erratic or unusual behavior that indicates very unpredictable behavior and/or an inability to care for themselves.

Suggestions for What to Do in Case of a Mental Health Emergency
Call 9-1-1, and then contact the Counseling Kids and Adults On-Call Crisis Therapist.

A mental health crisis is a non-life threatening situation in which an individual is exhibiting extreme emotional disturbance or behavioral distress, considering harm to self or others, disoriented or out of touch with reality, has a compromised ability to function, or is otherwise agitated and unable to be calmed.

Examples of a Mental Health Crisis include:

• Talking about suicide threats
• Talking about threatening behavior
• Self-injury, but not needing immediate medical attention
• Alcohol or substance abuse
• Highly erratic or unusual behavior
• Eating disorders
• Not taking their prescribed psychiatric medications
• Emotionally distraught, very depressed, angry or anxious

Suggestions for What to Do in Case of a Mental Health Crisis (note: we are not a emergency room or 24 hour care facility. We do not offer immediate walk in help.)

1. Call 651-755-4276 and state that you have a person in crisis. You will be transferred to the therapist that is assigned to the client or a clinical supervisor.
2. If possible, remain with the person or on the phone until help arrives.
3. All new clients will be provided with the the information on how to reach a therapist both during and after business hours if they have a mental health crisis.

After Hours and Weekends

1. Intake Representative will forward 651-755-4276 to the clinical supervisor during business hours and the intake line will be forwarded to the on-call therapist cell phone after hours.

Special Circumstances

If the person in Mental Health Emergency or Crisis is calling by telephone:

1. Attempt to get the person’s name, phone and location.
2. Keep the person on the phone, while you get a the on-call therapist's attention/911 and depending on the level of urgency, contact appropriate assistance.

POLICY: To make available discount services to those in need.

PURPOSE: This program is designed to provide free or discounted care to those who have no means, or limited means, to pay for their medical services (Uninsured or Underinsured). In addition to quality healthcare, patients are entitled to financial counseling by someone who can understand and offer possible solutions for those who cannot pay in full. The Patient Account Representative’s role is that of patient advocate, that is, one who works with the patient and/or guarantor to find reasonable payment alternatives. COUNSELING KIDS AND ADULTS LLC will offer a Sliding Fee Discount Program to all who are unable to pay for their services. COUNSELING KIDS AND ADULTS LLC will base program eligibility on a person’s ability to pay and will not discriminate on the basis of an individual’s race, color, sex, national origin, disability, religion, age, sexual orientation, or gender identity. The Federal Poverty Guidelines are used in creating and annually updating the sliding fee schedule (SFS) to determine eligibility.

PROCEDURE: The following guidelines are to be followed in providing the Sliding Fee Discount Program.

1. Notification: COUNSELING KIDS AND ADULTS LLC will notify patients of the Sliding Fee Discount Program by: • Payment Policy Brochure will be available to all uninsured patients at the time of service. • Notification of the Sliding Fee Discount Program will be offered to each patient upon admission. • Sliding Fee Discount Program application will be included with collection notices sent out by COUNSELING KIDS AND ADULTS LLC. • An explanation of our Sliding Fee Discount Program and our application form are available on COUNSELING KIDS AND ADULTS LLC'S website client portal. • COUNSELING KIDS AND ADULTS LLC places notification of Sliding Fee Discount Program in the clinic waiting area.

2. All patients seeking healthcare services at COUNSELING KIDS AND ADULTS LLC  are assured that they will be served regardless of ability to pay. No one is refused service because of lack of financial means to pay. 

3. Request for discount: Requests for discounted services may be made by patients, family members, social services staff or others who are aware of existing financial hardship. The Sliding Fee Discount Program will only be made available for clinic visits. Information and forms can be obtained from the business office via the client portal.

4. Administration: The Sliding Fee Discount Program procedure will be administered through the Business Office Manager or his/her designee. Information about the Sliding Fee Discount Program policy and procedure will be provided and assistance offered for completion of the application. Dignity and confidentiality will be respected for all who seek and/or are provided healthcare services.

5. Alternative payment sources: All alternative payment resources must be exhausted, including all third-party payment from insurance(s), federal and state programs.

6. Completion of Application: The patient/responsible party must complete the Sliding Fee Discount Program application in its entirety. By signing the Sliding Fee Discount Program application, persons authorize COUNSELING KIDS AND ADULTS LLC access in confirming income as disclosed on the application form. Providing false information on a Sliding Fee Discount Program application will result in all Sliding Fee Discount Program discounts being revoked and the full balance of the account(s) restored and payable immediately. If an application is unable to be processed due to the need for additional information, the applicant has two weeks from the date of notification to supply the necessary information without having the date on their application adjusted. If a patient does not provide the requested information within the two-week time period, his/her application will be re-dated to the date on which s/he supplies the requested information. Any accounts turned over for collection as a result of the patient’s delay in providing information will not be considered for the Sliding Fee Discount Program.

7. Eligibility: Discounts will be based on income and family size only. COUNSELING KIDS AND ADULTS LLC uses the Census Bureau definitions of each. a. Family is defined as: a group of two people or more (one of whom is the householder) related by birth, marriage, or adoption and residing together; all such people (including related subfamily members) are considered as members of one family. b. Income includes: earnings, unemployment compensation, workers' compensation, Social Security, Supplemental Security Income, public assistance, veterans' payments, survivor benefits, pension or retirement income, interest, dividends, rents, royalties, income from estates, trusts, educational assistance, alimony, child support, assistance from outside the household, and other miscellaneous sources. Noncash benefits (such as food stamps and housing subsidies) do not count.

8. Income verification: Applicants must provide one of the following: prior year W2, two most recent pay stubs, letter from employer, or Form 4506-T (if W-2 not filed). Self-employed individuals will be required to submit detail of the most recent three months of income and expenses for the business. Adequate information must be made available to determine eligibility for the program. Self- declaration of Income may only be used in special circumstances. Specific examples include participants who are homeless. Patients who are unable to provide written verification must provide a signed statement of income, and why (s)he is unable to provide independent verification. This statement will be presented to COUNSELING KIDS AND ADULTS LLC'S CEO or his/her designee for review and final determination as to the sliding fee percentage. Self-declared patients will be responsible for 100% of their charges until management determines the appropriate category.

9. Discounts: Those with incomes at or below 100% of poverty will receive a full 100% discount. Those with incomes above 100% of poverty, but at or below 200% of poverty, will be charged according to the attached sliding fee schedule. The sliding fee schedule will be updated during the first quarter of every calendar year with the latest Federal Poverty Guidelines.

10. Nominal Fee: Patients receiving a full discount will be assessed a $20 nominal charge per visit. However, patients will not be denied services due to an inability to pay. The nominal fee is not a threshold for receiving care and thus, is not a minimum fee or co-payment.

11. Waiving of Charges: In certain situations, patients may not be able to pay the nominal or discount fee. Waiving of charges may only be used in special circumstances and must be approved by COUNSELING KIDS AND ADULTS LLC'S CEO, CFO, or their designee. Any waiving of charges should be documented in the patient’s file along with an explanation (e.g., ability to pay, good will, health promotion event).

12. Applicant notification: The Sliding Fee Discount Program determination will be provided to the applicant(s) in writing, and will include the percentage of Sliding Fee Discount Program write off, or, if applicable, the reason for denial. If the application is approved for less than a 100% discount or denied, the patient and/or responsible party must immediately establish payment arrangements with COUNSELING KIDS AND ADULTS LLC Sliding Fee Discount Program applications cover outstanding patient balances for six months prior to application date and any balances incurred within 12 months after the approved date, unless their financial situation changes significantly. The applicant has the option to reapply after the 12 months have expired or anytime there has been a significant change in family income. When the applicant reapplies, the look back period will be the lesser of six months or the expiration of their last Sliding Fee Discount Program application.

13. Refusal to Pay: If a patient verbally expresses an unwillingness to pay or vacates the premises without paying for services, the patient will be contacted in writing regarding their payment obligations. If the patient is not on the sliding fee schedule, a copy of the sliding fee discount program application will be sent with the notice. If the patient does not make effort to pay or fails to respond within 60 days, this constitutes refusal to pay. At this point in time, COUNSELING KIDS AND ADULTS LLC  can explore options not limited, but including offering the patient a payment plan, waiving of charges, or referring the patient to collections.

14. Record keeping: Information related to Sliding Fee Discount Program decisions will be maintained and preserved in a centralized confidential file located in the Business Office Manager’s Office, in an effort to preserve the dignity of those receiving free or discounted care. a. Applicants that have been approved for the Sliding Fee Discount Program will be logged in a password protected document on COUNSELING KIDS AND ADULTS LLC shared directory, noting names of applicants, dates of coverage and percentage of coverage. b. The Business Office Manager will maintain an additional monthly log identifying Sliding Fee Discount Program recipients and dollar amounts. Denials will also be logged.

15. Policy and procedure review: Annually, the amount of Sliding Fee Discount Program provided will be reviewed by the CEO/Managing Member/Owner and/or Comptroller. The SFS will be updated based on the current Federal Poverty Guidelines. Pertinent information comparing amount budgeted and actual community care provided shall serve as a guideline for future planning. This will also serve as a discussion base for reviewing possible changes in our policy and procedures and for examining institutional practices which may serve as barriers preventing eligible patients from having access to our community care provisions.

16. Budget: During the annual budget process, an estimated amount of Sliding Fee Discount Program service will be placed into the budget as a deduction from revenue. Board approval for Sliding Fee Discount Program will be sought as an integral part of the annual budget.

Policy: Counseling Kids and Adults LLC takes client care seriously and we (providers, contractors, employees and volunteers) believe that patients are best served if they have access to comprehensive care, therefore support/facilitate coordination of care including but not limited to: physical health, mental health, addiction recovery, holistic services, educational, dental care, access to financial support/medical assistance, necessary language translation, transportation and housing resources, and community support/self-help.

Procedure:

1. Upon initial contact with Counseling Kids and Adults LLC the patient is screened and we determine if we have the services to meet the needs of the patient. Upon initial contact with Counseling Kids and Adults LLC via phone or electronic request for services each patient is asked a series of questions to determine if they are in crisis (ie. self-harm, suicide/homicide, addiction, eating disorder, non-formal mental status). If we determine they are in crisis, our intake coordinator involves a mental health/addiction therapist to aid patient with accessing appropriate crisis services prior to accessing care at our agency. The assigned therapist follows up with the referred agency to ensure the patient is able to attend services and continues coordination of care to ensure patient has seamless transition to initiate services with Counseling Kids and Adults LLC. 
   
2. Prior to the initial contact with the therapist the intake coordinator requests the patient complete an intake questionnaire (bio-psychosocial) to determine if they need alternative ancillary, inpatient or specialty care in addition to or prior to accessing our services.
3. We (providers, contractors, employees and volunteers) complete a thorough diagnostic bio-psychosocial intake assessment and review all pertinent records to determine if they need ancillary, inpatient or specialty care.
4. We (providers, contractors, employees and volunteers) educate the client on the resources and services that they may need and allow them to make a decisions if these resources and services are going to be a part of their care.
5. As a result of the intake assessment we create a treatment and care plan and if we (providers, contractors, employees and volunteers) determine they need access to care, our procedure is to request a release of information signed by the patient or responsible party for such services.
6. We (providers, contractors, employees and volunteers) then contact these services for the patient or work with the patient to aid them in making the contact if they desire to do their own advocating.
7. We (providers, contractors, employees and volunteers) do regular follow ups during client's active treatment with our agency with ancillary, inpatient or specialty care to ensure that our patients get the best care coordination and that we can better serve them in our role as a mental health and addiction provider.
8. We (providers, contractors, employees and volunteers), upon discharge or treatment termination if the client approves, we communicate discharge and treatment aftercare recommendations with ancillary, inpatient or specialty care professionals.