How to verify Prevention Plan Implementation

For any MUI (regardless of findings), Summit DD is required by Rule to verify the implementation of all prevention plans before the case can be closed with DODD. To do this, the assigned Investigative Agent (IA) to the MUI must obtain this proof from the providers involved in the prevention plan implementation. This verification requires indisputable evidence that the prevention plan information has been provided to relevant Direct Support Personnel (DSPs) and that the DSPs indicated understanding of how to implement the plan.

To accomplish this, most prevention plans will require the provider to conduct some level of training with their DSPs. Remember, if a prevention plan has new information that DSPs need to know to do their jobs, no matter how minor, the provider must be able to produce verification that this information was given to the DSPs.

Here are a few recommendations to successfully implement prevention plans. While there are several methods, these are the most common:

1. Formal in-person training: This is the preferred method for implementing any prevention plan, as it is more intensive and allows DSPs to ask questions. This also provides an opportunity to include third parties in the training, such as SLPs, nurses, Summit DD staff, etc. Note: This method should be the primary approach for any major changes to a person’s supports, such as adding restrictive measures, modified diets, major medical issues, etc.
2. Staff meetings: If your agency has regularly scheduled staff meetings, prevention plan information can be provided as an agenda item during that meeting. Note: Be sure this is documented in your meeting agenda and include all who attended.
3. Informal communication: Emails or text messages can be used to convey simple prevention plans. Ensure that proof of this communication is maintained for the record and includes the individual emails or cell phone numbers of any staff who were part of this communication. Please DO NOT communicate prevention plans over phone calls or in simple conversations that cannot be documented.
4. Read & signs: This is the least preferred method of prevention plan implementation. This method does not offer staff the opportunity to ask follow-up questions directly after receiving the information. Also, because there is no administrative oversight to ensure a DSP read the information prior to signing off, this can affect the safety of the person served. If using this method, be sure to follow-up with staff in-person to confirm they understand the information and answer any questions they may have.

No matter how you inform your staff of prevention plan information, proof is required through either verifiable sign-in sheets or other verifiable documentation clearly showing the following:

1. The full names of any staff that attended the training;
2. Individualized verification of a staff’s attendance and understanding of the materials such as the trainee’s signature, verifiable email, verifiable cell number, etc.;
3. The name/signature/individualized verifier of the trainer;
4. The date of the training;
5. And at least a summary of the training topic, if not the direct contents of the prevention plan provided.

For more information about prevention plan best practices, please see Tips for Creating a Collaborative Prevention Plan.