Developing a Personal Caregiver Handbook that spells out expectations and accountabilities of both the resident hiring the caregiver as well as the caregiver is one of the best defenses to issues of liability that may arise. But where do you start in building out the Handbook? Here are some key considerations as well as areas that should be covered in the Handbook:
Prior to Developing Handbook
Because the CCC’s relationship with its residents is governed by each resident’s agreement and any move-in documents that accompanied that agreement, it is important first to review those documents to determine if there are any barriers to implementation. Because each resident contract might be different, this process might require review of all versions in effect for any current residents.
Assuming the resident contracts do not require any additional steps before rolling out such a program, the CCC can move to the drafting of the Personal Caregiver Handbook.
What Should Be Included in the Handbook?
As indicated above, the Handbook should establish clear expectations and accountabilities for both residents and their caregivers. For these reasons, the CCC should consider inclusion of the following in the Handbook and as part of the overall program:
- Tear sheet in the Handbook for Resident Acknowledgment and Indemnification.
- Tear sheet in the Handbook for Caregiver Acknowledgment and Indemnification.
- Credentialing process for reviewing/approving all caregiver’s allowed on the CCC’s property, at a minimum requiring background checks for anyone accessing the CCC.
- Create a Caregiver Application and obtain information necessary to evaluate for approval. The application is NOT an application for employment with the CCC, but it should solicit information concerning education, professional licenses/certifications, employment history and professional/personal references. If the caregiver is through an agency, the agency may assist in completing this information, but the caregiver must authorize the background check.
- Include in the application a caregiver consent to permit a background check to be performed.
- Facilitate background checks by offering a third-party service provider to perform the checks and bill the CCC, with resident agreeing to reimburse the expense of the background check.
- Maintain an administrative file on each personal caregiver admitted to the CCC that includes the items in the checklist at the end of this article.
- Required notification from residents whenever engaging or terminating a caregiver.
- Required notification from caregiver of any significant change in resident health status/condition.
- Defined limitations for permitting a caregiver to remain overnight in a resident’s CCC home.
- Safety and security procedures.
- Sign-in/sign-out procedures.
- For gated CCCs, consider issuance of an approved ID to each caregiver.
- Consider prohibiting personal visitors of the caregiver in the community.
- CCC’s policies on:
- Infection control
- Disposal of sharps/bio-hazardous waste
- Fire safety/disaster preparedness
- Rules of conduct for personal caregivers, including:
- Smoking, drug and alcohol use, weapons, etc.
- Personal caregiver pets in the community.
- Use of cell phones, cameras and other electronic devices
- Dress code
- Financial matters (i.e., with respect to residents)
- Use of common areas including dining rooms and waiting areas
- Orientation information, including important contact information
Implementation/Roll-Out of the Personal Caregiver Handbook
Resident communication is critical when making any changes anticipated to affect residents- and this is certainly an area where residents will be impacted. Consider engaging a resident council early on in the process to discuss the importance of developing the Handbook and to obtain feedback. The CCC should expect its communications to take several months, so it will need to plan accordingly. Equally important will be explaining to residents who already have caregivers how the CCC will help transition those caregivers into compliance with the Handbook’s accountabilities and expectations.
Residents with established caregiver relationships likely will want to maintain those despite any additional requirements. Effective communication, transparency and education of existing residents on the importance of various new requirements will be critical to assuring compliance and providing for the safety and security of your residents moving forward.
Post-Implementation of the Personal Caregiver Handbook
Once the Handbook is published, the CCC should provide a copy to all existing residents and any new residents when they move in as to their obligations with respect to employing a caregiver and the various compliance requirements.
As alluded to above, most residents will want to maintain relationships with their existing caregivers. The CCC initially may face some resistance and non-compliance. Monitoring and reinforcement of the accountabilities and expectations are essential to assure effective implementation of the new Handbook and mitigation of the risks. Implementation of the Handbook without enforcement may lead to increased risk in the event the CCC is aware of non-compliance but does not take steps to correct the non-compliance and that non-compliance results in harm to one or more residents.
The CCC must have a process and a plan to assure all personal caregivers already providing care to residents are “enrolled in” and comply with the Handbook requirements. The CCC should expect resistance and non-compliance and be prepared to manage that.