Protection & Advocacy, Inc.
Telephone:
Toll Free/TTY/TDD:
(800) 776-5746
www.pai-ca.org
VIA E-MAIL (brian.koepp@dss.ca.gov)
&
Brian Koepp, Chief
Quality Assurance Bureau
Adult Programs Branch
California Department of Social Services
|
RE: |
IHSS
Hourly Task Guidelines Workgroup |
Dear Mr. Koepp:
We are submitting this letter to provide you
with the comments that PAI has on the time for task guidelines task tools.
Under the definition of “bathing
(bath/shower),” we think you should add:
1. Getting
supplies and putting them away;
2. Undressing
and dressing;
3. Getting
to and from the bathroom (if this is not a part of the definition of
ambulation, which it currently is not, then it should be included here as it is
included under bowel and bladder care.);
4. Cleaning up the bathroom; and
5. Shampooing
hair (including drying and applying conditioner to hair).
Once again, we think that DSS should get
approval from Adult Protective Services before making the following statement
in the guidelines: “Note: Unless there is a safety issue, this does not
include the time a provider is standing by while a consumer bathes
himself/herself or waiting.” The reason
for this is that most accidents occur in the bathtub and somebody would need to
be around if somebody cannot get in and out of the bathtub by themselves since
they will not be able to help themselves or call for help if a problem
arises.
In addition, we think the following should be
added to “things to be considered for all” for “bathing (bath/shower):
1.
Does the consumer need supplies handed to him/her?
2.
Does the provider need to walk away and come back to
the bathroom?
3.
Does the consumer need prompting? And
4.
Does the layout of the bathroom result in increased or
decreased need for assistance? (The
layout could make harder or easier to get on and off the toilet.)
Under the definition of “bathing (routine bed
bath),” we think you should add:
1.
Cleaning up;
2.
Undressing and dressing; and
3.
Preparing the bed.
We think that you should amend the definition
of meal preparation (cooking) to read, “Preparation of healthy, nutritious and
balanced meals with fresh foods (if desired by the consumer) includes such
tasks as . . . .” We also think that
you should add the following:
1.
Hand washing;
2.
Putting containers in the trash;
3.
Putting dishes in the sink;
4.
Removing food from the refrigerator or pantry;
5.
Measuring;
6.
Looking at menus and recipes; and
7.
Preparing and packaging meals for later consumption (including
marking).
Under the definition of meal cleanup, we think
you should add:
1.
Cleaning food from the table, tray and floor;
2.
After each meal the wiping of the stove, counter, sink,
microwave, etc. (This is opposed to only cleaning these items twice a month
which is what the IHSS program allows under domestic services. Not cleaning counters, stove, sink, microwave
etc. after every meal is a health hazard to recipients.);
3.
Vacuuming, bed or sofa (if consumer must eat in bed or
on the sofa); and
4.
Cleaning food spilled on clothing, hair, face or hands.
In addition, we believe that the note under
“things to consider for all” under meal cleanup should be amended to read as
follows: “This does not include
the heavy cleaning of the
refrigerator, oven, or stove as these IHSS services are authorized under
domestic services.” Only “heavy
cleaning” is a service authorized under domestic services, not every day
cleaning. Domestic services are only
authorized twice a month. An oven or
stove usually needs to be cleaned after cooking a meal. Hours for this everyday cleaning should be
authorized.
Under the definition of Bowel and Bladder Care,
we think you should add:
1.
Wiping and cleaning of the recipient, including the use
of toilet paper and other cleaning material.
2.
Positioning of the recipient in bed for diaper changes,
and catheter care.
3.
Putting on/taking off disposable gloves.
In addition, we believe that the third bullet under “things to consider for all” should be amended to read: “Are there assistive devices (such as elevated toilet seats or Hoyer lifts) available or a bathroom layout which result in increased or decreased need for assistance?” The layout could make it harder or easier to get on and off the toilet.
Under the exceptions for the category of
Feeding, we think the third bullet should be amended to read as follows: “Consumer prefers
to eat foods that he/she can manage without assistance.” Obviously, if a person does not currently
have assistance, he/she would have no choice but to eat foods they can manage
without assistance. Thus, social workers
should not be prompted or encouraged to reduce a consumer’s hours for feeding merely
because a consumer usually eats foods
that he/she can manage without assistance.
Also, we recommend that the following exceptions
be added:
1.
Consumer must eat in bed; and
2.
Food must be placed into the consumer’s mouth a special
way because the consumer has difficulty swallow or other reasons.
Under the definition of Menstrual Care, we
think you should add:
1.
Putting on/taking off disposable plastic gloves;
2.
Assisting the recipient to and from the bed or toilet;
3.
Washing hands;
4.
Use of and disposal of barrier pads;
5.
Managing clothing;
6.
Wiping and cleaning of the recipient, including the use
of toilet paper and other cleaning material;
7.
Positioning of the recipient in bed/toilet for sanitary
napkin change; and
8.
Wiping off blood from toilet seat.
Under the definition of repositioning, we think
you should add:
1.
Any repositioning required for the completion of any
task if not included in the task definition (for example, dressing does not
include any time for positioning of a recipient necessary to assist a recipient
with dressing).
Under the definition of Care and Assistance
with Prosthesis, which includes self-administration of medication, we think you
should add:
1.
Putting pills or liquid in consumer’s mouth. (This is not
considered “dispensing.”)
2.
Crushing and/or cutting tablets.
Under “things to consider for all” under Care
and Assistance with Prosthesis, we think you should add the following: “Does the consumer needs tablets crushed or
otherwise needs special preparation to distribute medications (e.g., cutting
tablets).”
Under the definition of Dressing, we think you
should add:
1.
Applying deodorant (if not included in Grooming);
2.
Putting on/taking off accessories (such as a watch or
eyeglasses); and
3.
Positioning of the recipient to allow clothes to be put
on comfortably.
Under “things to be considered for all” for
Dressing, we think you should add: How
much does the consumer have over his extremities.” Another exception for dressing should be:
“The consumer needs to wear a suit or dress regularly (e.g., for religious
services or an internship).
Under the definition of Ambulation, we think
you should add:
1.
Moving a wheelchair away from recipient.
2.
Plugging wheelchair battery into charger.
Also, under the exceptions for Ambulation, we
think you should add:
1.
Consumer lives in a spacious three-bedroom house.
2.
Consumer cannot push or otherwise propel his/her
wheelchair.
Under the definition of Moving In and Out of
Bed, we think you should add:
1.
Bringing a wheelchair to recipient.
2.
Moving a wheelchair away from recipient (if not covered
under Ambulation).
3.
Plugging wheelchair battery into charger (if not
covered under Ambulation).
Under “things to be considered for all” under
Moving In and Out of Bed, we think you should add: “How much the consumer
weighs”. In addition, we think another
exception should be: “The individual is
large and/or has very weak bones and must be transferred very slowly and
carefully, more than an average person with a disability.
As you can see, we have added tasks in most of
the task category because we feel this is necessary because, without every task
a consumer needs in a definition of a category, social workers will not grant
hours for them. Even though the
Department of Social Services (DSS) may envision that social workers would take
the definitions as mere examples of tasks in the categories, the reality is the
social workers will read it as excluding all tasks that are not in the
definitions partly because the definitions, as they are currently written, are
a detailed list rather than a general description of the task category. If, on the other hand, the task categories
had a general description of the category, it would not be necessary to spell
out each and every task covered within that category. However, since these definitions of
categories are very specific as it is, we feel it is necessary to spell out
every task that is in each category.
If you have any questions, please feel free to
contact me.
|
|
Sincerely, Fred Nisen |
|
|
Crystal Padilla |