vulnerable individuals residing in these facilities. Eliminating the department’s
opportunities to quickly intervene and/or investigate an incident or elopement
increases risks unnecessarily to residents and can be interpreted as a convenience and
in the interest of AFC staff and the department. Additionally, it does nothing to protect
individuals who do not have an authorized representative or if the incident or
elopement occurs outside of normal business hours when their representative or
responsible agency can reasonably be reached. Further, while the proposed language
in R 400.1416a(4) references what the department can do during a renewal inspection,
DRM believes this follow-up may occur too long after the event occurred which may
make interventions and remedies moot.
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R 400.1416a(1) Incident notification, incident records. Add (f) Medication errors.
ADULT FOSTER CARE CONGREGATE HOMES
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R 400.2404(3). Keep language requiring reporting to the department when a serious
accident requiring medical attention occurs. This allows for timely review and follow-up
by the department. Eliminating the department’s opportunities to quickly intervene
and/or investigate an accident increases risks unnecessarily to residents and can be
interpreted as a convenience and in the interest of AFC staff and the department.
Removing this layer of reporting weakens protections for residents and eliminates the
department’s oversight responsibility for reasons that do not support vulnerable
individuals residing in congregate settings.
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•
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DRM appreciates the new language proposed in the definition of “elopement” (R
400.2404a (1)(b)) as it supports HCBS Rules and doesn’t presume all individuals who live
in a congregate setting require constant supervision or that they need permission to
leave their home.
R 400.2404a (1)(c) Incident. Modify the proposed definition to include medication
errors (…elopes or medication errors) in addition to what is already proposed. This
would be consistent with the definition of incident used in MCL 333.20106 as it applies
to licensed homes for the aged.
R 400.2404a (2) Incident notification, incident records. Add (f) Medication errors.
ADULT FOSTER CARE SMALL GROUP HOMES
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DRM appreciates the new language proposed in the definition of “elopement” (R
400.14102 (1)(k)) as it supports HCBS Rules and doesn’t presume all individuals who live
in an AFC require constant supervision or that they need permission to leave their
home.
•
R 400.14102 (1)(o) Incident. Modify the proposed definition to include medication
errors (…elopes or medication errors) in addition to what is already proposed. This