GSSSI Did Not Always Properly Develop, Execute, and Reassess Service Plans to Address Elderly Persons’ Needs

Lack of developing and reviewing service plans means GSSSI might not be providing the right type or amount of services to seniors in need

Overview

In our review of 60 investigations of substantiated allegations performed by GSSSI during the audit period, we identified issues with the way GSSSI developed, executed, and reassessed service plans for abused elderly persons. These issues included the following:

• One (2%) of the 49 applicable¹⁴ case records lacked documentation that the service plan was developed in consultation with the elder.
• Two (3.6%) of the 56 applicable¹⁵ case records lacked evidence of the Protective Services Unit supervisor’s involvement in the development of the service plan. In addition, in 2 (3.6%) of 56 case records, the service plan was not developed within five business days after the investigation ended.
• Twenty-two (59.5%) of the 37 applicable¹⁶ case records lacked evidence that the service plan was reassessed during the first month of services.
• Eight (32%) of the 25 applicable¹⁷ case records lacked evidence that the service plan was reassessed every three months after the first month of services.
• Thirteen (36.1%) of the 36 applicable¹⁸ case records lacked evidence that the Protective Services Unit caseworker performed a home visit or in-person interview with the elderly person once per month while the service plan was in effect.
• Seven (21.2%) of the 33 applicable¹⁹ case records lacked evidence that the Protective Services Unit caseworker maintained contact with the elderly person in a manner that was consistent with his/her service needs and service plan.

Without properly developing, executing, and reassessing service plans, GSSSI may not provide the correct type and amount of services needed by elderly persons to prevent, eliminate, or remedy the effects of abuse.

Authoritative Guidance

According to 651 CMR 5.13,²⁰

The Service Plan shall:

(1)  be developed in consultation with the Elder and/or reflect the Elder’s needs and wishes as much as possible . . .

(2)  be developed in consultation with the Protective Services Supervisor;

(3)  be developed within five business days following the completion of the Investigation; and

(4)  be reassessed at least once during the first month of service. After the initial month, each Eligible Elder’s need for services shall be reassessed at least every three months thereafter until such service(s) are no longer required.

Additionally, 651 CMR 5.18(1)(a)²¹ states,

Throughout the provision of Protective Services Casework, the Protective Services Caseworker shall . . .

5.   Maintain contact with the Elder consistent with the service needs and service plan of the Elder and at a minimum of one home visit or in-person interview per month.

Reasons for Noncompliance

GSSSI had not established monitoring controls to ensure that it properly developed, executed, and reassessed service plans. Additionally, GSSSI stated that turnover of Protective Services Unit personnel during fiscal year 2017, and increased caseloads due to changes in the intake and screening process in June 2017, led to delays in service plan reassessments.

Recommendation

GSSSI should establish monitoring controls to ensure that service plans are properly developed, executed, and reassessed, even in the event of increased caseloads and employee turnover.

Auditee’s Response

Since April 2018, GSSSI’s service plans contain home visit documentation regarding the elder’s input. Service plan reassessments are included in the quality assurance monitoring tool utilized by the PS Operations Coordinator. Any issue will be reported to the PSPD and the respective PSS. The PSPD will include assessing whether or not the PSSs are approving the Service plan within 5 days as part of her quality assurance monitoring tool.

Auditor’s Reply

Based on its response, GSSSI is taking measures to address our concerns in this area.

14.    The requirement did not apply to the other 11 case records for various reasons, including the elderly person declining Protective Services involvement, GSSSI being unable to contact the person, and the person passing away.

15.    The requirement did not apply to the other four case records because no service plan was created in those cases.

16.    The requirement did not apply to the other 23 case records for various reasons, including services not lasting long enough to be reassessed, no service plan being developed, the elderly person refusing further services, and GSSSI being unable to contact the person.

17.    The requirement did not apply to the other 35 case records for various reasons, including services not lasting long enough to be reassessed, no service plan being developed, the elderly person refusing further services, and GSSSI being unable to contact the person.

18.    The requirement did not apply to the other 24 case records for various reasons, including services not lasting long enough to require a visit, no service plan being developed, and GSSSI being unable to contact the person.

19.    The requirement did not apply to the other 27 case records for various reasons, including the elderly person lacking decisional capacity and GSSSI being unable to establish contact with him/her.

20.    The wording is substantively the same for both versions of the regulation that were in effect during our audit period.

21.    The wording is substantively the same for both versions of the regulation that were in effect during our audit period.

Date published:	September 4, 2019