Health, Safety, Welfare, Reporting and Follow-up of Incidents

Incidents regarding member health, safety and welfare are defined by Illinois state law. They involve actions that may risk the health, safety and well-being of vulnerable adults by causing harm or creating a serious risk of harm to a person by their caregiver or other trusted person, whether or not harm is intentional.

Incidents

Incidents regarding member health, safety and welfare are defined by Illinois state law. They involve actions that may risk the health, safety, and well-being of vulnerable adults by causing harm or creating a serious risk of harm to a person by their caregiver or other trusted person, whether or not harm is intentional.

Types of Incidents include:

  • Physical abuse – the willful infliction of physical pain or injury, or the willful deprivation of services necessary to the physical safety of an individual
  • Emotional abuse – an act that inflicts emotional harm, invokes fear or shame or otherwise negatively impacts the mental health or safety of an individual
  • Neglect – the failure of an agency, facility, employee, or caregiver to provide important services needed to maintain the physical and or mental health of a vulnerable adult
  • Financial abuse – the misuse or taking of the vulnerable adult’s property or resource using undue influence, breach of a fiduciary relationship, deception, harassment, criminal coercion, theft, or other unlawful or improper means

 

 

Incident Reporting Requirements

Incidents involving member abuse, neglect and financial exploitation must be reported to the appropriate authorities, as required by state law.

How to Report an Incident

Incidents related to CountyCare members can be reported to CountyCare by phone, fax, or email. You should use this form.

You may also report Incidents to the right state agency, as follows:

  • For members 18-59 with a disability or 60 and older living in the community: Illinois Department on Aging-Adult Protective Services Hotline Telephone Number: 866-800-1409 (voice)TTY: 888-206-1327
  • For members under the age of 18 years old: Illinois Department of Children & Family Services (DCFS) Hotline Telephone Number: 800-252-2873 (voice)TTY: 800-358-5117. For non-DCFS membership.
  • For members in Nursing Facilities: Department of Public Health Nursing Home Complaint Hotline Telephone Number: 800-252-4343
  • For members 18-59 receiving mental health or Developmental Disability services in DHS operated, licensed, certified or funded programs: Illinois Department of Human Services Office of the Inspector General Telephone Number: 800-368-1463 (voice and TTY)
  • For members in Supportive Living Facilities: Department of Healthcare and Family Services SLF Complaint Hotline Telephone Number: 800-226-0768

If you or a family member witness, told of, or suspect an incident of abuse, neglect, financial abuse or any other event that may place the member at risk or the member services at risk it is important to report the allegation immediately.  Below are a few examples:

Physical abuse signs to look for:

  • Punching, hitting, beating
  • Slapping, smacking
  • Pushing, shoving, shaking
  • Pinching, cutting, slicing
  • Improperly physically restraining

Sexual abuse signs to look for:

  • Rape
  • Date rape
  • Attempted rape
  • Inappropriate touching
  • Sexual assault or battery
  • Coerced nudity
  • Sexually explicit content

Emotional abuse signs to look for:

  • Name calling
  • Yelling, bullying
  • Ridicule, insults
  • Threats
  • Coercion, manipulation

Neglect signs to look for:

  • Injury that has not been cared for properly
  • Dehydration or malnutrition without illness-related cause
  • Poor coloration, sunken eyes or cheeks
  • Soiled clothing or bed
  • Lack of necessities such as food, water, or utilities Same clothing all of the time
  • Fleas, lice on individual
  • Unkempt, dirty
  • Hair matted, tangled or uncombed

Financial abuse signs to look for:

  • Accessing another individual’s funds without consent
  • Changing ownership of assets
  • Forged signature for financial transactions
  • Changing legal documents, such as wills
  • Using someone else’s money for personal reasons

 

Program Integrity (Fraud, Waste, Abuse, Mismanagement and Misconduct)

CountyCare takes the detection, investigation, and prosecution of fraud, waste, abuse, mismanagement and misconduct very seriously. CountyCare’s Program Integrity efforts operate under policies, procedures and guidelines to ensure compliance with all Illinois and federal laws and regulations.

CountyCare’s Program Integrity efforts include performing front and back end audits to ensure provider compliance with billing regulations.

A Special Investigation Unit (SIU) performs routine internal monitoring and back end auditing of program integrity compliance risks and investigations of any issues identified. CountyCare promptly responds to compliance issues detected, including the correction of issues through education and the implementation of corrective action plans in compliance with program integrity-related requirements. In some cases, this may result in taking the appropriate actions against those who, individually or as a practice, commit fraud, waste, abuse, mismanagement or misconduct , including but not limited to:

  • Remedial education and/or training to attempt to eliminate the egregious action
  • Increasingly stringent utilization review process
  • Recoupment of previously paid monies from a provider/practice
  • Termination of provider agreement or other contractual arrangements
  • Civil and/or criminal prosecution
  • Any other remedies available to rectify the issue identified

The CountyCare SIU may also conduct prepayment reviews of provider claims as a result of suspected fraud, waste, abuse, mismanagement or misconduct, which may require the provider to submit additional records or documentation.

Some of the most common fraud, waste, abuse, mismanagement or misconduct  issues identified are:

  • Unbundling of codes
  • Up-coding
  • Add-on codes without primary CPT
  • Diagnosis and/or procedure code not consistent with the member’s age/gender
  • Use of exclusion codes
  • Excessive use of units
  • Misuse of benefits
  • Claims for services not rendered
  • Claims for services not covered

If you suspect or witness a provider inappropriately billing for Medicaid services or a member receiving inappropriate services, please call our anonymous and confidential hotline at 844-509-4669.

For more information on CountyCare’s Program Integrity process and efforts, please see the Provider Manual.

For more information on the False Claims Act and other federal and state laws including administrative, civil and criminal remedies for false claims and statements, and whistleblower protections with respect to the role of such laws in preventing and detecting fraud, waste, abuse, mismanagement, and misconduct in federal health care programs, please see the Cook County Health FWA Policy.

CountyCare expects that its providers will cooperate with all appropriate federal and state agencies in the detection and prevention of fraud, waste, abuse mismanagement and misconduct, as well as all investigations or prosecution by any duly authorized agency.

Provider Complaints, Disputes, Member Grievances, and Member Appeals

CountyCare has established a system to allow members and providers to bring their concerns to our attention. See below for additional information on provider complaints, member grievances and member appeals.

CountyCare has established a provider complaint system that allows a provider to dispute the policies, procedures, or any aspect of the administrative function. We take all complaints very seriously, and all provider complaints will be thoroughly investigated. CountyCare has designated a Provider Complaints Coordinator (PCC) to process these provider complaints. The PCC will provide written notice of resolution to the provider within thirty days from the decision date.

Provider Complaints may be submitted in writing to:

CountyCare Health Plan
P.O. Box 21153
Eagan, MN 55121

Or you can call Provider Services at 312-864-8200 / 855-444-1661 (toll-free) / 711 (TTD/TTY).

HCBS or LTSS Waiver Providers –
Communication with Care Coordination

Communication and collaboration between HCBS Waiver Providers and Care Coordination is essential to ensuring the health, safety, and welfare of CountyCare’s HCBS members.

Please utilize the HCBS Member Communication Form to communicate member needs, changes, and issues to ensure they are addressed timely, including:

  • Start Date of Services
  • When services need to be placed on hold, with the date and reason
  • When services are resumed
  • Changes in Member’s Living Situation (provide new address/phone if applicable)
  • Changes in Member’s Condition and/or Circumstances
  • Member’s Refusal or Non-Cooperation with Services

The HCBS Member Communication Form should be sent to countycarewaivers@cookcountyhhs.org.

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