Implementation Plan
Executive Order RP 33
Relating to Reforming the
Adult Protective Services Program
Health and Human Services Commission
July 12, 2004
Printable Adobe Acrobat (pdf) version
of this report
HHSC News Release
Table of Contents
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Under Executive Order RP 33, issued April 14, 2004, the Health and
Human Services Commission (HHSC) is directed to oversee the systemic
reform of the Adult Protective Services (APS) program of the Department
of Family and Protective Services (DFPS). The executive order was
motivated by reports that indicated serious fundamental and systemic
problems within the APS program.
HHSC began an intensive review of the APS program and issued a
preliminary report on May 19, 2004, that included findings from case
readings from the El Paso area. The report also included preliminary
findings on program performance, functional review, and policy
assessment of the APS program, including the Guardianship program. The
preliminary investigation confirmed deficiencies, identified key issues,
and listed performance outcome goals for each area. Immediate corrective
actions were identified and the oversight process was described.
Executive Order RP 33 requires HHSC to submit an implementation plan
that outlines the specific actions taken and to submit this report to
the Governor no later than 90 days from the issuance of the order. This
implementation plan will outline additional key deficiencies and
corrective actions to reform the APS program to meet the protective
needs to the elderly and adults with disabilities.
The APS program has been reviewed to:
- Ensure clearly defined outcomes at each step of the APS
involvement with clients (the APS process), including partnering with
community organizations to define and maintain ongoing services;
- Define management structure and support systems that are clearly
aligned with the outcomes defined for the APS process; and
- Identify the current problems that prevent APS staff from
achieving these outcomes.
Though APS investigates reported allegations in a variety of
settings, this report focuses primarily on non-facility based
investigations. Based on these parameters, a clear and definitive
implementation plan has been developed. The implementation plan consists
of actions that address issues identified for each key deficiency in the
APS process, the management structure, and support systems.
From information obtained through the work sessions and groups,
charts were developed that illustrate the APS process, desired outcomes,
deficiencies, and corrective actions. These charts are included in
Appendix A.
The implementation plan will require additional resources. HHSC is
working to identify the funding needs to implement this plan for
consideration by the Governor and legislative leaders. HHSC will ensure
strict accountability for funding provided to programs.
Since the release of the preliminary report, 13 workgroups have been
formed to examine all aspects of the APS program, identify deficiencies,
and recommend corrective actions. Three underlying themes emerged during
the workgroup process.
- The goals of APS are not well defined;
- There is not a clear delineation of the APS process steps; and
- There are few performance standards for the APS program.
This report describes corrective actions to be taken in each area of
the APS program. The general timeline for implementation is in three
phases.
First, policy must be developed, clarified, or revised to align with
the desired outcomes for the APS program. Of particular concern are the
policy issues related to the:
- Balance between self-determination and the agency's mandate for
the protection of individuals at risk of abuse, neglect, and
exploitation;
- Distinction between investigation and service delivery; and
- Responsibilities of the Guardianship program.
It is anticipated that these policy issues will be resolved by the
fall of 2004.
Second, procedures must be developed to ensure established policy is
effectively implemented. This will be accomplished by the following
methods:
- Performance standards must be defined and adopted;
- Organizational structure must be uniformly defined;
- Mobile technology to streamline procedures must be deployed;
- Current APS in-home investigations handbook must be modified;
- New and effective training curriculum and processes must be
implemented; and
- Community and judicial relationships reestablished and maintained.
These procedures will be fully developed by the spring of 2005.
Finally, the administrative structure and supporting technology must
be implemented to ensure that:
- Staffing positions are filled;
- APS technology is modified to align with established policies and
procedures; and
- Staff are retrained on new policies and procedures and APS support
technology.
The administrative structure and supporting technology will be fully
implemented by the summer of 2005.
HHSC is committed to implementing the corrective actions in this plan
as quickly as possible within the timeframes indicated. Three critical
areas are receiving the highest priority. One area is ensuring
sufficient staff in critical areas of the state. HHSC is working with
APS to identify needs and deploy necessary staff as quickly as possible.
Another critical area is the development and deployment of a new risk
assessment tool to replace the current capacity tool. Field-testing of
this tool should begin this fall. Lastly, HHSC is working closely with
state leaders to secure funding to expand the capacity of local
Guardianship programs.
A full accounting of progress will be provided in the final report
required by Executive Order RP 33 due November 1, 2004.
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Under the Governor's Executive Order RP 33, issued April 14, 2004,
the Health and Human Services Commission (HHSC) is directed to oversee
the systemic reform of the Adult Protective Services (APS) program of
the Department of Family and Protective Services (DFPS). DFPS is charged
with protecting children and adults who are elderly or have disabilities
living in their home. APS is responsible for investigating abuse,
neglect, and exploitation of adults who are elderly or have
disabilities. The executive order was motivated by reports that
indicated serious fundamental and systemic problems within the APS
program.
HHSC began an intensive review of the APS program and issued a
preliminary report on May 19, 2004, that included findings from case
readings from the El Paso area. The report also included preliminary
findings on program performance, functional review, and policy
assessment of the APS program, including the Guardianship program. The
preliminary investigation confirmed deficiencies, identified key issues,
and listed performance outcome goals for each area. Immediate corrective
actions were identified and the oversight process was described.
Executive Order RP 33 requires HHSC to submit an implementation plan
that outlines the specific actions taken and to submit this report to
the Governor no later than 90 days from the issuance of the order. This
implementation plan outlines additional key deficiencies and corrective
actions to reform the APS program to meet the protective needs of
elderly and disabled persons.
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The goal of the APS reform effort is to ensure the Texas Department
of Family and Protective Services meets its legislative mandate to
provide protective services to Texans with disabilities and the elderly
who are at risk of abuse, neglect, and exploitation. The goal is guided
by the principle that protective services represents only one aspect of
the full array of services that individuals with disabilities and the
elderly may need to ensure a high quality of life. An important
component of meeting the needs of the clients is to identify the best
resources, which may include services provided by local community
groups.
The APS program has been reviewed to:
- Ensure clearly defined outcomes at each step of the APS
involvement with clients (the APS process), including partnering with
community organizations to define and maintain ongoing services;
- Define management structure and support systems that are clearly
aligned with the outcomes defined for the APS process; and
- Identify the current problems that prevent APS staff from
achieving these outcomes.
Though APS investigates reported allegations in a variety of
settings, this report focuses primarily on non-facility based
investigations in accordance with the Governor's Executive Order.
Based on these parameters, a clear and definitive implementation plan
has been developed. The implementation plan consists of actions that
address issues identified for each key deficiency in the APS process,
the management structure, and support systems.
The implementation plan will require additional resources. HHSC is
working to identify the funding needs to implement this plan for
consideration by the state leadership. HHSC will ensure strict
accountability for funding provided to programs.
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Using the same case reading strategy employed in El Paso in
developing the preliminary findings, the Office of Inspector General (OIG)
case review team continued their investigation with case readings from
the Fort Worth area (Region 3). Their findings support the systemic
nature of the problems within the APS program.
- In El Paso it was found that the investigation did not fully
address all allegations of abuse, neglect, or exploitation in 35 percent
of the cases read. That figure was 57 percent in Forth Worth.
- In El Paso it was found that in 30 percent of the cases read the
actions (service plan) taken did not address all findings of abuse,
neglect, or exploitation. In Fort Worth the comparable statistic was 47
percent.
- In El Paso it was found that in 41 percent of the cases appropriate
action to prevent further abuse, neglect, or exploitation of the client
was not taken. Case readings in Fort Worth revealed this outcome in 53
percent of cases.
The OIG review also indicates that each area of the state will vary
in the quality of APS services. In El Paso, for example, community
relations were weak and non-supportive. Fort Worth, in contrast, has a
relatively strong community network to support APS efforts.
Overall, the Fort Worth case readings support the general finding of
the preliminary report that APS does not establish accountability for
positive outcomes.
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Since the release of the preliminary report, 13 workgroups have been
formed to examine all aspects of the APS program, identify deficiencies,
and recommend corrective actions. Three underlying themes emerged during
the workgroup process.
The goals of APS are not well defined. Ill-defined goals result in
various interpretations of the scope of APS activities and inconsistent
application of policies and procedures. Internally, staff in one region
may focus on determining capacity, while in other regions staff may
focus on providing non-protective service delivery to clients (i.e.,
services which do not relate directly to the reduction of risk).
Externally, this lack of clarity results in variations regarding how,
and when, APS interacts with local community organizations.
There is not a clear delineation of the APS process steps. While each
case referred to APS is different, the basic APS process should be the
same for every case. The handbook offers minimal guidance for key
decision points and even less for direction regarding the criteria and
decision processes. Without such specificity in the decision making
process, there is great variation in how decisions are reached and the
appropriateness of these decisions. Clear, well-reasoned, and uniform
decision-making criteria needs to be incorporated in each stage of the
APS process and outlined in the APS handbook and training curriculum.
There are few performance standards for the APS process. Appropriate
performance criteria for what constitutes a good investigation or a good
service delivery plan are lacking in the APS process. Current criteria
appear to be subjective; therefore, it is difficult to measure staff
performance. When management does have performance indicators, such as
number of days an investigation is open, there are no clear standards
for staff to follow. This lack of standards impairs the ability to
effectively manage time and resources, to ensure quality investigations,
and maintain accountability.
These three fundamental issues underlie virtually all deficiencies
identified with the APS program. It is critical that deficiencies are
remedied to ensure that the mission and goals of the program to protect
the elderly and adults with disabilities is accomplished.
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To ensure an outcome driven process, HHSC convened a work session of
stakeholders to help define successful outcomes in the investigative
process. Stakeholders were invited from across the state, representing a
broad array of groups. The participants in attendance represented
various organizations dealing with issues on aging and disability,
including judicial, legal, aging and disability advocates, and
guardianship. Over 45 groups were contacted to send a representative to
the work session.
Work session participants began by defining positive outcomes for
individuals found to be at risk. These included such items as better
access to services, working utilities, and ability to manage medication.
Next, work session participants defined the critical elements of the
investigation process, including desirable outcomes and best practices.
Guiding Principles
A number of guiding principles emerged from the desirable outcomes
session and correspondence received by HHSC related to the APS reform
efforts. The guiding principles identified were:
- Do no harm
- Maintain client dignity
- Maintain client's civil rights
- Perform tasks from a person-centered philosophy
- Preserve balance of personal rights and self-determination with
mitigation of risk
- Maintain commitment to work with stakeholders
Mapping Outcomes to Process
A workgroup of business process engineers and policy specialists from
HHSC reviewed the APS handbooks, work session outcomes, interviewed APS
staff, and accompanied investigators on a number of investigations and
site visits to collect process information. From the data collected, the
APS process was mapped from start to finish. This map provides vital
information for a comprehensive assessment of the APS process to ensure
all aspects are analyzed during the development of corrective actions.
Identifying Deficiencies and Corrective Actions in the APS Program
Each workgroup researched the current APS process and compared it
with the desired outcomes. The workgroups identified deficiencies and
made recommendations for corrective actions.
While the majority of the deficiencies were connected to the various
APS stages, a few were not. Several of the issues identified were
overarching of the APS program or were tied to multiple steps in the APS
process, such as administrative, organization, or support. For example,
administrative organization of staff-the deployment of APS
professionals, management, and support staff-will depend in large part
on improvements in the APS process that clearly define the steps in
investigation and service delivery. Once those steps are defined, the
appropriate staff can be deployed to ensure successful outcomes.
From all the information obtained through the work sessions and
groups, charts were developed that illustrate the APS process, desired
outcomes, deficiencies, and corrective actions. These charts are shown
in Appendix A.
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This section describes the actions in the implementation plan
associated with each step in the APS process. The APS process includes
these steps:
- Intake
- Investigation
- Risk Assessment
- Service Delivery
- Guardianship
For each step, a narrative provides an overview of the issues
followed by a table that relates specific outcomes, issues, and actions.
Intake
Intake is a critical function for APS and plays several key roles.
First, it is how the public accesses and provides information to the APS
system. The intake process assures that all information necessary to
initiate a case is received. The amount and type of information obtained
are vital because they are used to classify, prioritize, and route cases
to the field. To be effective, APS must help ensure that the public
understands what constitutes abuse, neglect, and exploitation, and how
to report it.
The number of calls that statewide intake can process effectively has
been the subject of scrutiny in the recent past, in particular with
regard to hold time. The wait time for callers has been reduced through
the deployment of call center technology.
Each call is unique, and staff is trained to elicit information
relevant to each allegation. There may be efficiencies gained by
formally reviewing closed cases to determine whether certain information
turns out to be more relevant than others and what additional
information should be obtained to aid in investigations. The review
would also be informative in assessing whether the appropriate
notifications have gone to law enforcement, any special issues or
requirements are identified, and if cases are being appropriately
classified and prioritized.
While intake is responsible for routing cases, a routing protocol is
followed to ensure appropriate staff is deployed to initiate the APS
investigation. Issues concerning routing are covered in the
investigation section of this report.
Corrective actions for improving the intake process include
finalizing the roll-out of the public reporting website and reviewing
closed cases to identify the importance of key variables to further
enhance the intake, prioritizing, and routing of calls.
Investigation
The in-home investigation is the primary function of the APS
caseworker in handling cases of abuse, neglect, and exploitation of
elderly and disabled adults. Investigations must be conducted in a
thorough and efficient manner to identify all issues that need
corrective services. The purpose of investigations is to gain further
knowledge of a situation, determine the priority of actions to be taken,
and initiate any immediate intervention that may be required. Numerous
deficiencies have been noted in the investigative process.
First, there is a clear need to improve the process for assigning and
prioritizing cases to improve responses to reports and to minimize
administrative costs. APS can utilize information from past cases to
better estimate priorities and staffing needs for future cases. In
addition, a lack of adequate administrative personnel exists to handle
issues of routing, maintaining call lists, and appropriately assigning
cases. Supervisors are performing administrative tasks in addition to
their regular case management duties.
Second, reports of abuse, neglect, and exploitation have not been
fully or appropriately investigated and documented. The current
assessment tool focuses exclusively on capacity and does not identify
and document potential physical and psychological harm, medical issues,
environmental conditions, personal relationships, and the client's risk
to self or others. The current practice is to identify these areas of
need in the service delivery phase and not the investigative phase,
blurring the critical distinction between validating the allegation(s)
and assessing the potential for risk through investigation, and reducing
risk through service delivery. The client must agree to accept services
for this assessment to be completed. Creating a new assessment tool to
replace the current capacity tool is dealt with in a separate section of
this report. Currently, under-utilization of legal and judicial avenues
for gathering supporting evidence limits staff ability to assess risk.
Third, the investigative phase is specifically designed to support
subsequent actions, many of which may require legal decision-making.
Legal decisions require well-documented facts. There are clear
deficiencies in documentation and variation in staff understanding of
what documentation is required.
Finally, processes and standards for APS in-home investigations need
to be expanded and clarified. Caseworkers are faced with situations for
which no clear guidance is provided in the handbook. Without clear
guidelines, practices vary widely by region.
Corrective actions for improving the investigative process are to
review and enhance current guidelines on prioritization and appropriate
routing to trained caseworkers, delineate and separate the investigative
phase from the service delivery phase of the process, and more
effectively allocate administrative personnel to relieve supervisors and
allow them to focus on case management. Perhaps the most important
corrective action is the replacement of the current capacity questions
with a more comprehensive risk assessment tool and the retraining of
caseworkers to properly utilize that tool.
Risk Assessment Tool
The law simultaneously gives APS the mandate to provide for the
protection of individuals with disabilities and the elderly and provides
the client the option to refuse the investigation or any services. The
capacity assessment used by APS is a limited decision-making tool that
does not take into account the complexities in cases in which
appropriate balance must be found.
The current assessment tool focuses solely on mental and functional
capacity without regard to environmental issues or concerns. Caseworkers
must focus too narrowly on how the client answers the capacity questions
without consideration of factors that may indicate continued or further
exposure to risk. In many cases, caseworkers will skip the capacity
assessment if they determine that capacity is not an issue related to
the primary reported allegations, thus prematurely closing the
investigation.
APS must develop a comprehensive risk assessment tool to replace the
current capability questions. This tool should cover all areas of risk,
including an assessment of environmental, social, medical, mental
health, and financial conditions found. It should provide for ways to
assess risk in the absence of the client's cooperation and should ensure
that clear criteria for referrals are made when warranted. Most
importantly, this tool should reveal the client's capacities as they are
evidenced in various aspects of their life.
This comprehensive risk assessment tool should appropriately refer
clients to professionals for assessment of capacity, ensure that complex
cases have extended but rapid review, and direct the investigator to
initiate and appropriately document removal proceedings.
A particular deficiency was noted in the ability of APS staff to
detect financial exploitation. APS must work to develop explicit
guidelines for staff to follow to detect financial exploitation and
train staff accordingly. A multidisciplinary team should be formed to
help develop these guidelines and review the more complex and difficult
cases.
Corrective actions include implementation of a new assessment tool,
establishing clear rules for the acquisition of medical or mental health
determinations of capacity and internal quality assurance teams to
review cases of questionable risk and establish guidelines for scheduled
supervisor case reviews. HHSC considers the development of the risk
assessment tool a high priority and expects to pilot the tool in the
fall of 2004.
Service Delivery
The scope of APS is that it shall conduct investigations of abuse,
neglect, and exploitation and may provide protective services to
minimize further risk. APS caseworkers provide protective services to an
elderly or disabled person who has been determined by APS to be in a
state of abuse, neglect, or exploitation. These services may include
case management, arranging for psychiatric evaluations, home care, adult
day care, social services, health care, and other services. These
services differ from guardianship activities in that the client retains
legal control over his/her situation but is assisted in these efforts by
APS caseworkers.
A major issue is the lack of distinction between the investigative
stage and the service delivery stage. In life-threatening or emergency
situations service delivery must begin immediately and concurrently with
the investigative process. Although, in the majority of cases, the
primary allegations do not necessarily warrant immediate action, and
service delivery activity should not commence until the investigative
stage is complete. Since provision of services is a major factor of the
funding allocation, there appears to be an undue emphasis on service
delivery at the expense of a thorough investigation.
Another issue is the lack of clarity around what constitutes
protective services. Protective services are those services that remove
a client from risk of abuse, neglect, or exploitation. Protective
services are only one of an entire array of life-enhancing services
available to individuals with disabilities and the elderly. Without this
clarity, service plans may include services that more appropriately
belong to other public or private social service organizations, such as
the Area Agencies on Aging. APS' collaboration with local community
groups may not result in attaining appropriate resources, and service
delivery may extend far past the assurance of protection. Further, there
may be confusion about whether and what types of guardianship services
are needed. Also, as with the investigation process, there is a lack of
clear guidelines for service delivery resulting in plans differing for
similar risks and indefinite service delivery for multi-needs or
multi-handicapped individuals.
There appear to be issues surrounding the identification of client
resources. Clear standards do not exist for ensuring that staff have
identified client resources that need to be utilized prior to any
outside funding. This includes whether or not clients are currently
enrolled in state and federal programs.
Finally, there seems to be inadequate coordination and referral with
other state agencies that provide non-protective services. This is due,
in part, to unclear cooperative agreements between APS and other health
and human services agencies.
Corrective actions include evaluation of the need to separate
investigative staff from service delivery staff and identify those
workers as social services aides, decision criteria to determine when to
initiate guardianship proceedings, and improved inter-agency
cooperation.
Guardianship
Guardianship is pursued when a client is deemed to be at continued
risk of abuse, neglect, and/or exploitation, and the client has been
shown to lack capacity and a less-restrictive alternative is not
available. APS staff ensure the case record provides the information a
judge will need to make this determination, including the identification
of an appropriate guardian for consideration.
APS makes every effort to find an appropriate guardian. APS policy
requires staff to consider family members or other trusted individuals
for primary consideration. If such an individual cannot be identified,
APS considers attorneys, financial institutions, private professional
guardians, or Guardianship programs. If no other entity can be
identified, a referral is made to a contracted guardianship provider if
available in the area. The court may also identify an appropriate
guardian. APS provides case information and support to the proposed
guardian, the attorney, and the court as needed during the guardianship
proceedings.
If no other appropriate guardian can be found for the client, APS may
be directed by the court to take temporary guardianship while efforts
are made to continue to identify a guardian or, ultimately, take
guardianship responsibility for the client. Guardianship is determined
by a judge.
Since the 1995 repeal of a statute that designated APS as
"guardian of last resort" in Texas, there is presently no
"guardian of last resort" in Texas. There is, in some areas of
the state, a difference between APS guardianship policies and the
judges' interpretation of the law. This issue needs clarification and
may need legislative remedy.
Several issues are identified with the Guardianship program. First,
the problems identified with determining capacity contribute to the
Guardianship program being underutilized. The department's emphasis on
self-determination and deficiencies found in the capacity tool are
leaving some clients at continued risk to health and safety. These
clients cannot adequately protect themselves from risk and should more
appropriately be in a Guardianship program. Development of a risk
assessment tool in place of the current capacity tool and appropriate
training will help resolve this issue.
Second, there is a lack of contractors offering guardianship
services. In some areas the capacity of existing local Guardianship
programs is limited, while in other areas there are no local programs.
Additional funding provided to ensure guardianship services would help
build a more solid infrastructure of guardian support. HHSC will work
with state leadership to identify and provide seed money as quickly as
possible to help build capacity for local Guardianship programs across
the state.
The issue is further compounded due to the fact that some contractors
may lose money providing guardianship services. Guardianship programs
may collect money from estates for private-pay clients. Some programs
also have other funding sources such as Area Agencies on Aging, United
Way, county funds, and other sources that pay for services to their
wards. Programs contracting with DFPS cannot use money from the client's
estate. Guardianship programs are less motivated to accept private-pay
wards with relatively small estates. This inadvertently results in APS
retaining clients that are more resource intensive.
Third, the Guardianship program is located within APS, creating a
conflict of interest. Clients in the Guardianship program who are
reported at risk would be the subject of an investigation carried out by
the same program. HHSC will examine the appropriateness of moving the
Guardianship program in fiscal year 2005.
Finally, guardianship duties and responsibilities for incapacitated
adults are carried out by two health and human services agencies, DFPS
and HHSC. The DFPS guardianship-related statutes are contained in
Chapter 48 of the Human Resources Code, and the HHSC
guardianship-related duties are contained in Chapter 531 of the
Government Code. The HHSC Guardianship program administers the local
Guardianship program grants. HHSC also receives recommendations for
program improvement from the HHSC Guardianship Advisory Board.
Corrective actions include providing additional resources to build
the guardianship infrastructure at the local level, transferring the
Guardianship program, and strengthening the training of APS staff on the
appropriate use of guardianship. HHSC has placed a high priority on
strengthening the Guardianship program as quickly as possible.
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This section describes the actions in the implementation plan
associated with the organization and administration of the APS program,
including:
- Staffing
- Funding
- Performance Management
- Technology
- Mobile Technology
- Records Retention
- Training
For each area, a narrative provides an overview of the issues,
followed by a table that relates specific outcomes, issues, and actions.
Staffing
The effective and efficient deployment of staff is critical in
maximizing the limited resources available to the program. APS is not
deploying staff to best meet the needs of clients.
Of immediate concern is ensuring that staff are deployed to areas in
the state to alleviate chronic staff shortages that are having a
negative impact on clients. HHSC is working with APS to immediately
identify these areas and develop staffing remedies. HHSC considers this
a high priority and is acting quickly to implement this corrective
action.
The basic APS caseworker is, at the same time, service delivery
planner, service provider, community relations specialist, records
retention staff, and legal support rolled into one. Critical distinction
must be made between the roles of investigator and service delivery
staff. In prior times when there were fewer complexities associated with
investigation and service delivery, an individual may have been able to
do a competent job for both functions. Today, each function is so
specialized and complicated that each requires particular skills.
Financial exploitation and self-neglect require highly specialized
skills beyond what can be expected of all APS caseworkers. The array of
medical conditions present also requires specialized consultation and
efficient procedures for acquiring that consultation.
Additionally, supervisors must be able to provide guidance to workers
on those cases that are complex and present unique problems. This is a
key responsibility for supervisors that is not consistently applied in
the field.
More efficiency may be gained by separating the development of a
service plan from routine administrative tasks of arranging for and
delivering those services. In a similar manner, the community relations,
judicial relations, and other support functions are likely best provided
by designated staff rather than incorporated into a general APS
caseworker position.
Finally, the frustration of staff in having to do all these functions
may contribute to the high turnover rates in this program. It is
important that a realistic job preview for applicants shows how they can
succeed and thereby provide incentive to participate in this important
work.
Corrective actions to staffing include examining the need for
creating positions designed specifically to identify service needs of
clients and allow caseworkers and supervisors to focus their efforts of
conducting thorough investigations. These "social service
aides" will improve overall program efficiency and assist in
managing excessive caseloads. Additional corrective actions are to
redesign selection and training criteria to improve retention rates.
Funding
Funding for field operations in APS is based on the equity of service
statement (ESS), a model that attempts to equalize funding for services
across regions. Based on indicators of workload, the goal of ESS is to
provide each region an equitable distribution of available funds. The
cost of providing services is primarily a function of the number of
staff that can be afforded. The ESS formula, therefore, in effect
determines the number of staff for each region.
The APS ESS formula has four components: intake, investigation,
service delivery and guardianship. A workload study is performed to
identify the average time for each component. Then the number of intake,
investigation, service delivery and guardianship cases are computed for
each region. Finally, the number of staff hours for each component is
computed and totaled by region. The ratio of regional staff hours to the
total statewide hours is the percentage of funding allocated.
Weakness or flaws in the indicators upon which the ESS is based cause
distortions in the distribution of funding.
One weakness is the lack of definition of what constitutes a case.
The distinction between cases investigated and those in service delivery
is blurred by the lack of clarity in policy and, as a result, the lack
of clarity in IMPACT.
The level of effort involved in each phase of investigation and
service delivery cannot be determined at the regional level and is not
part of the work measurement study. Moreover, without some system of
profiling cases, it cannot be determined which cases are complex and
require more time and which are relatively simple and do not.
DFPS conducts work measurement studies to determine how much time is
spent on cases. Currently the work measurement study for APS focuses on
the statewide average of time to complete a case. Complex cases take
more time and there are indications that regions may differ such that
some regions have a higher rate of these cases than others. The use of a
statewide average in the formula for determining regional funding
allocations may be inappropriate if regions differ in their ratio of
complex cases.
Current average caseloads vary widely by region. This may be the
result of differing caseload demands between regions. The lack of
regional time information prevents informed decision making regarding
how similar caseload sizes should be. There is no way to determine if
the observed variation in caseloads is equitable or not.
The target population of APS services is relatively well defined, yet
demographic information is not used in the ESS to anticipate future
caseload trends.
Finally, the lack of clarity on what constitutes protective services
results in a misallocation of resources into non-protective services.
This lowers the funding available for protective services and shifts the
cost for non-protective services to DFPS.
Corrective actions are to redesign funding allocations to more
accurately consider regional geographic and demographic needs, analyze
current workloads after modifying the work measurement study (WMS), and
assess more appropriate resource allocations in terms of funding and
staff.
Performance Management
Many, if not most, of the problems identified in the APS reform
occurred due to a lack of established performance management tools and
processes. First, there are few, if any, performance standards. Staff do
not have clear, program-wide standards to guide them in handling
particular cases or to manage their caseload. The lack of available
policies and procedures in handling cases also contributes to this
problem. Staff do have performance standards associated with their
annual performance review, but the reviews are not always done in a
timely manner.
This lack of clear program-wide performance standards makes it
difficult to appropriately monitor and supervise staff. Performance
standards vary by supervisor, making it difficult to consistently
monitor program performance.
Second, and as a result of the first, the current management
reporting system is inadequate and underutilized. The absence of clearly
stated performance measures makes it difficult to identify problems and
tailor solutions to address issues in a timely manner. As a result,
problems arise in the form of high profile cases that are brought to the
attention of management from outside the agency. These types of cases
generate specific solutions that may not address the underlying problems
that created them. The ability to resolve these high profile cases does
not address the underlying fundamental problem.
Development of performance standards tied to clear policies and
procedures is just one of the corrective actions required for the APS
program. Consistent with H.B. 2292 and the vision for health and human
service delivery, APS must develop and implement a quality assurance
program to identify current issues, anticipate potential problems, and
design corrective action plans to correct those problems immediately.
Technology (IMPACT)
The technology supporting the APS program is the Information
Management Protecting Adults and Children in Texas (IMPACT) system.
IMPACT is a case tracking and reporting system that also supports the
Child Protective Services and Child Care Licensing programs at DFPS.
Three problem areas were identified during evaluation of the system.
The first issue occurs in developing caseload reports. Standard
caseload reports are currently generated from summary tables. These
tables are built using rules for classifying and sorting service
delivery data. On the other hand, when service delivery data is accessed
directly, rather than through the summary tables, conflicting reports
are generated.
This issue seems to be based on rules for coding and summarizing data
that lack clarity regarding specific decision-making points in the
intake, investigative, and service delivery phases of the APS process.
An information systems audit is planned to assess the scope of this
problem.
The second issue relates to compliance with records retention policy.
Records retention policy is tied to the date a case is closed. Records
are being kept longer than necessary due to a lack of clarity in
policies and procedures for closing cases. Additionally, a lack of staff
resources has resulted in a backlog of case records that need to be
merged or purged. This corrective action will require extra staff effort
and resources to implement. Once the retention policy has been
clarified, IMPACT will be modified.
APS supervisors should more fully utilize existing IMPACT data
warehouse reports and ad-hoc reports that provide detailed information
on caseloads at regional, unit, and worker level for quality assurance
and performance management. Existing reports should include drill-down
capability to more readily identify outlying cases to create the
development of key performance indicator (KPI) reports that record the
performance of workers.
Finally, it was reported that IMPACT was "dropping" cases
that had been entered into the system. Further research indicated the
identified cases had not actually been entered into the system, due in
large part, to staff error in the data entry process. The Department of
Family and Protective Services identified the staff error and
implemented an adjustment to the system to disallow inappropriate data
entry. HHSC found no evidence to support that IMPACT has dropped cases.
Corrective actions include performing an information systems audit
regarding the rules for coding and summarizing data, modifying IMPACT
according to new records retention policies and procedures, and
retraining staff in advanced uses of IMPACT.
Mobile Technology
Technology is critical in the overall operation of the APS program.
When used to its full potential, it can provide staff with efficient and
effective tools to carry out their jobs. It can also provide supervisors
and management with the tools necessary to create and implement revised
performance standards and quality assurance measures.
A complete and through review of all current technology being used by
APS was conducted. Technology was identified that can be more
consistently and efficiently employed, such as the use of digital
cameras by caseworkers. Computer based training is not fully utilized
but could be to provide information and training to staff in the field.
The lack of real time access to policies and key APS tools and forms
was also identified as an issue. The delay of inputting case notes into
IMPACT results in misreporting and loss of data. Mobile technology will
address this issue.
APS should deploy wireless technologies and handheld devices with
electronic reporting capabilities to caseworkers. A case wizard
prototype that integrates policies, procedures and application tasks to
guide a user should be developed. For example, wizards for the
step-by-step performance of critical tasks, such as Chapter 48 removals
and risk assessments, would expedite reporting and improve caseworker
efficiency. Supporting evidence should also be scanned into the case
file. These improvements will require an increase in storage
capabilities of field office computer systems.
In all, the deployment of wireless technologies, tablet PCs, and
digital recording media would greatly enhance the documentation,
efficiency, and thoroughness of investigations. The availability of
these devices would also facilitate the implementation of telemedicine
consultations should this pilot prove successful. With such
technologies, upgrades to IMPACT and increased training would be
necessary.
Records Retention
Records retention is a vital support component of the investigative
and service delivery phases of the APS process. Proper records retention
provides justification and substantiates the decisions made through the
duration of the case. It is critical to the success of a case if
referred to the courts.
Several areas of concern have been identified within the APS records
retention processes that need corrective actions. One area of concern is
that records retention practices are not consistent with or supportive
of the investigative and/or judicial processes.
APS case files are not retained in accordance with state approved
policies, and the DFPS records management program has no standard
electronic tracking system for monitoring records management activities
and agency compliance. According to the records retention policies, DFPS
is behind schedule on destruction of case files, creating a legal
liability for the agency. At the current destruction rate, DFPS will not
be in compliance with records retention policy for several years.
Agency policies regarding merging of case files within IMPACT are
unclear and inconsistently applied throughout the state. If the case is
not merged correctly, the information may appear to be lost due to the
difficulty of maneuvering through multiple electronic cases. Quality
assurance measures are not in place to ensure that retention policies
are consistently applied throughout the state.
Training regarding records retention is not regularly provided to APS
staff. Understaffing in the field also creates a problem with performing
records management activities.
Corrective actions include developing a uniform case file merging
policy, implementing a system of organized automated records (SOAR), and
purging the backlog of electronic files.
Training
Training provides the tools for APS staff to efficiently carry out
the investigative mandates of APS. It is critical to every aspect of
program operations.
APS training is deficient. One reason for this is the lack of
specific policies and procedures in investigation, service delivery, and
community and judicial relations. Changes in policies and procedures
will improve training dramatically. A complete overhaul of the APS
curriculum will then be necessary.
Current training practices do not ensure all staff have the skills
necessary to perform their jobs. The training is too brief for the
amount of material that must be mastered by the new worker. Pre- and
post-tests are not used to evaluate staff learning. There is no
requirement for annual training for caseworkers. A certification process
is available but voluntary for staff. Although this practice has been
discontinued, new APS caseworkers were allowed to investigate cases
without formal training.
A number of areas in training must be improved. Better training on
building and maintaining community relations is needed, as well as
training on the law enforcement and judicial aspects of investigations
and casework.
APS must provide specialized training in complex areas, such as
financial exploitation, mental health, and self-neglect. Basic training
should include significant coverage of these topics, including criteria
for when to consult with subject matter experts.
Supervisor training should focus more in-depth on decision-making
regarding complex cases to ensure supervisors are able to provide
appropriate guidance to staff.
Finally, training needs to be more readily available to staff. This
includes access to the standard training curriculum via computer-based
training and to ongoing refresher training.
Corrective actions include a complete revision of the basic service
delivery curricula, developing performance standards for learning, and
developing computer-based training for easy access by field staff.
<<back to top>>
To ensure community involvement and establish best practices in
building and maintaining relationships with community partners, HHSC
convened a work session of stakeholders. Stakeholders were invited from
across the state representing a broad array of groups. The participants
in attendance represented various organizations dealing with issues on
aging and disability, including judicial, legal, aging, and disability
advocates and guardianship. Over 100 groups were contacted to send a
representative to the work session.
Work session participants began by defining positive community
relationships that would assist APS in meeting its goals. These included
such items as better access to services, improving communication, and
steps to successfully building relationships in each region.
This section describes the actions in the implementation plan
associated with the collaborations needed to ensure the success of the
APS program.
- Community Relations
- Judicial Relations
For each area, a narrative provides an overview of the issues
followed by a table that relates specific outcomes, issues, and actions.
Community Relations
Community relationship building is a significant part of the APS
program. A collaborative working relationship with local community
groups ensures that client needs identified in APS investigations can be
effectively met.
APS should play a critical role in developing and maintaining local
community networks. There is a large variation in the quality of such
networks across the state. Staff should receive clear direction from
management about the essential components necessary to support community
networks. Staff should also be provided the tools, in the form of a
handbook, to be successful in their efforts. Additionally, the APS basic
training should include a section on building and maintaining strong
community relations.
APS should strategically and consistently develop and maintain
community resources to ensure services are available for clients. Local
community resource books should be created and maintained. APS staff
should be dedicated to ensure they are current.
Community networks should be the vehicles for a coordinated,
comprehensive public awareness campaign. Community partners can help
effectively translate the message in terms of their respective community
cultures.
The engagement of volunteer coordinators varies significantly across
the state. Volunteer services are an important piece of the APS service
model, and dedicated staff should be deployed to ensure effective
volunteer programs in all areas of the state.
APS needs to develop better communication and cooperation with other
state health and human services agencies. In many areas APS is unable to
successfully engage other health and human services agencies and
programs, such as mental health and family services, in appropriate
interventions. APS should engage other state health and human services
agencies in collaborative working relationships to meet the needs of
Texans.
APS can benefit from working collaboratively with community groups
that currently provide health and human services. A number of successful
partnership programs have identified best practices and APS could profit
by engaging with them to provide services to clients of APS. In
particular, the faith-based community has several well-regarded service
delivery programs, most notably with Child Protective Services, from
which APS may benefit.
Corrective actions include formalizing the process for building and
maintaining community relations, engaging other state and local entities
in collaborative service delivery, and developing local resource lists.
Judicial Relations
Judicial relations are important to the successful operation of the
APS program. Deficiencies in current policies and procedures have
resulted in a reduction of the number of referrals to probate courts,
leaving APS clients at risk. These deficiencies reflect the need to
develop policies, procedures, and training that will provide staff with
the guidance and direction needed to effectively work with local
judicial systems.
The varied quality of APS investigations, case documentation, and
understaffing has impaired the relationships with local prosecutors and
judges not only in El Paso, but also in other areas of the state. APS
must act decisively to reestablish these relationships. Supervisors must
engage the judicial community to build an effective working relationship
based on mutual trust.
In building this trust, APS must ensure caseworkers are trained in
the legal avenues available to protect clients, including emergency
removals and guardianship. APS must also ensure caseworkers are trained
in the appropriate documentation requirements to support legal action.
Guardianship should be used more effectively as a tool for ensuring
client safety. Referrals should be made in a timely manner consistent
with court requirements. Reform efforts related to guardianship are
described in a previous section of this report.
Corrective actions include plans to mitigate strained relations with
the judiciary, establishing uniform guidelines for relating with local
law enforcement and the judicial system, and uniform criteria for
emergency removals.
<<back to top>>
The general timeline for implementation is in three phases.
First, policy must be developed, clarified, or altered to align with
the desired outcomes for the APS program. Of particular concern are the
policy issues related to the:
- Balance between self-determination and the agency's mandate for
the protection of individuals at risk of abuse, neglect, and
exploitation;
- Distinction between investigation and service delivery;
- Boundaries of protective services and non-protective services; and
- Responsibilities of the Guardianship program.
It is anticipated that these policy issues will be resolved by the
fall of 2004.
Second, procedures must be developed to ensure established policy is
effectively carried out. This will be accomplished by the following
methods:
- Performance standards must be defined and adopted;
- Organizational structure must be uniformly defined;
- Mobile technology to streamline procedures must be defined;
- Current APS in-home investigations handbook must be modified;
- New and effective training curriculum and processes must be
implemented; and
- Community and judicial relationships reestablished and maintained.
These procedures will be fully developed by the spring of 2005.
Finally, the administrative structure and supporting technology must
be implemented until:
- Staffing positions are filled;
- IMPACT is modified to align with established policies and procedures;
and
- Staff are retrained on new policies and procedures and IMPACT.
The administrative structure and supporting technology will be fully
implemented by the summer of 2005.
Priority Corrective Actions
HHSC is committed to implementing the corrective actions in this plan
as quickly as possible within the timeframes indicated. Three critical
areas are receiving the highest priority. One area is ensuring
sufficient staff in critical areas of the state. HHSC is working with
APS to identify needs and deploy necessary staff as quickly as possible.
Another critical area is the development and deployment of a new risk
assessment tool to replace the current capacity tool. Field-testing of
this tool should begin this fall. Lastly, HHSC will work closely with
state leaders to secure funding to expand the capacity of local
Guardianship programs.
A full accounting of progress will be provided in the final report
required by Executive Order RP 33 due November 1, 2004.
<<back to top>>
APS Intake
|
Desired Outcomes |
Issues Identified |
Corrective Actions
|
Public is aware of APS program and services |
Public is not aware of
what constitutes abuse/neglect/exploitation
Information and referral
functions do not understand criteria for reporting abuse, neglect, and
exploitation |
Work with local community groups to ensure public is
informed regarding abuse/neglect/exploitation of adults with
disabilities and the elderly
Work with HHS information and referral
functions to ensure appropriate referrals to statewide intake |
Public has multiple points of access |
Web-based application
available to professionals and only to hot line callers that have been
on hold for 3 minutes |
Allow wider access to web-based referrals from
public
|
Obtain information to ensure case appropriately prioritized |
No
formal review to determine if cases have been appropriately prioritized
Information received by staff from statewide intake may be
inaccurate or insufficient
Priority levels assigned by statewide
intake (SWI) may at times be inaccurate |
Conduct a review of
prioritization criteria and ensure APS staff provide input
Implement a
process for periodically reviewing cases to determine if improvements in
information collection and prioritization can be made at the point of
intake
Examine professional literature to identify information that is
likely to indicate abuse, neglect, and exploitation and modify intake
interview process as necessary
|
Intake specialist screens for any special issues/requirements |
No
formal review to determine quality of intake screening protocol |
Implement a process for periodically reviewing cases to determine if
improvements in information collection and prioritization can be made at
the point of intake
|
APS Investigations |
Case appropriately routed |
Cases routed to inexperienced or
untrained staff
Cases not geographically assigned within counties to
build and maintain community relations, and minimize travel
Lack of
administrative staff to handle routing to appropriate investigator
Supervisors performing routing administrative tasks in addition to case
management duties
|
Develop a case profile system to differentiate
cases on the basis of complexity
Review professional literature for
information to help develop case profile system
Clarify training and
readiness level of new caseworkers in relation to assignment of cases
Redesign case routing system
Determine staffing levels to provide
sufficient administrative support to handle routing issues and
assignment logs and better enable case managers to supervise casework
|
Appropriate priority will be assigned to the case |
Priority
assigned by statewide intake can be changed by investigator· Improve
process for assuring quality of changed case priorities |
Develop
guidelines for investigators to use in reassessing priority levels·
Align priority levels with criminal standards of abuse and
exploitation· Clarify exceptions to face-to-face initiation of
investigations
Ensure face-to-face exception policy is reviewed by
judicial and legal experts
Formalize priority change review by
supervisor
|
Clear guidelines for law enforcement referrals |
Investigators must
rely on professional judgment in making law enforcement referrals
Possible illegal activity not reported to law enforcement until
validated
Cases of abuse not being referred for prosecution
|
Work
with law enforcement agencies to develop clear guidelines for referrals
|
Risk is thoroughly assessed |
Lack of appropriate assessment tool |
Develop and implement a risk assessment tool
|
Relevant information already with APS is brought to bear on
allegation(s) |
Current search and merge policy and IMPACT processes do
not assure all known information is uncovered |
Review and revise
search and merge policy to maximize information
Modify IMPACT
accordingly
|
Subject matter experts are readily available to help assess risk |
Delays in getting expert review of evidence may keep clients at risk |
Establish local support networks for quick response
Evaluate use of
telemedicine technology
Develop APS staff with specialized skills for
complex areas such as financial exploitation and self neglect
|
Allegations fully investigated |
Allegations not fully addressed
Cases closed prematurely· Inadequate follow up for individuals refusing
services
Did not obtain sufficient evidence to reach a
conclusion
Insufficient collateral documentation
Underutilization of court orders
to allow investigations
|
Create a decision tree for in home case
disposition and tracking, and clarify APS in-home handbook accordingly
Review guidelines for collateral interviews
Reexamine policy on
criminal history checks on collaterals
Clarify conditions for seeking
court orders for investigations
|
Assessment of risk is balanced appropriately with right of
self-determination |
Clients refusing investigations remain at risk·
Staff not consistently assessing risk with collaterals on refusal by
client |
Create a multidisciplinary team to review investigative
decision tree for appropriate balance and to ensure all efforts at
assessing risk are exhausted
Where client is unable or unwilling to
participate in the investigation, notify law enforcement, judiciary, and
other community groups as appropriate
|
Immediate risks are mitigated promptly |
Not all allegations are evaluated
Clients refusing investigations are still at risk
|
Better
utilize court orders to allow investigations
|
Case decisions made appropriately |
Service delivery provided
without substantial evidential support
Appropriate action not taken
to address initial allegation and prevent further abuse, neglect, or
exploitation
|
Clear decision making criteria established and revise
handbook accordingly
Improve criteria for independent verification of
evidence
|
Thoroughly document findings to support actions taken |
Lack of
documentation may negatively impact future actions
Subsequent
decisions may not address actual problems
Supervisors unable to
determine if appropriate action was taken
Subsequent legal
alternatives jeopardized
When and how to use digital technology to
document conditions is not clear to staff
|
Review documentation
policies and procedures for clarity
Retrain staff on documentation issues
Implement employee performance measures to improve quality assurance
Work with judicial representatives to establish
documentation standards that support legal decisions
Review policy and
training on digital technology
|
Cases appropriately moved from investigation to service delivery or
guardianship when needed |
Employee handbook not clear on how decisions
are made with regard to case determination
Client does not always
receive appropriate services
Appropriate legal action may not be taken
|
Revise handbook accordingly
Work with judicial representatives to
establish case closure standards that support legal decisions
|
Clear performance standards for the investigative process established
|
Expectance of employee performance vary by region and/or
supervisor
|
Define and implement clear investigative performance standards
relating to both quality and time
|
Case completion is based on documented compliance with established
criteria
|
Compliance with documentation is inadequate· Inconsistently
addressing all reported allegations of abuse, neglect, or exploitation·
Inconsistent independent verification of facts
|
Establish standards
for determining the investigation component of the case is complete
Ensure the investigative process is separated from the service delivery
plan
|
APS Risk Assessment |
Consistent use of a comprehensive risk assessment survey |
Current
capacity tool focuses solely on mental and functional capacity without
regard for environmental issues or concerns
Caseworkers tended to
focus too narrowly on capacity questions as opposed to assessing risk of
client
Inadequate follow-through of assessment in cases of client
refusal
All avenues of collateral assessment were not fully explored
prior to determination of investigation
Underutilization of current
APS assessment tools |
Develop and implement risk assessment tool to
assess environmental, social, financial, physical, and mental health
issues
Ensure tool is reviewed broadly by subject matter experts·
Eliminate questions of capacity and replace with assessment of risk
Train field staff on thorough assessment of risk to include evaluation
of environment, social, financial, physical, and mental health
Develop
decision criteria for assessing risk of a non-compliant client
Align
documentation of areas of concern with service plan development
Revise
handbook and IMPACT
Take steps to ensure survey is reliable and valid
|
Appropriately refer to professionals for assessment of capacity · |
All avenues of collateral assessment were not fully explored prior to
determination of investigation
Inconsistent use of professional
evaluations to assess capacity |
Revise employee handbook to clearly
define rules for acquisition of medical or mental health determinations
of capacity
Ensure professional assessments are obtained when
conditions exceed limits of APS training
|
Complex cases have extended but rapid review |
Lack of clear
guidelines on inclusion of supervisor on cases of questionable capacity
No formal, uniform process for evaluating complex cases |
Develop case profile system based on complexity
Establish formal
quality review process for caseworkers and supervisors when assessing
high risk conditions
Develop internal regional case management quality
assurance team to review cases of questionable risk
Establish
guidelines for scheduled supervisor case reviews for quality assurance
|
Initiation of Chapter 48 (removal) action when necessary |
Standards
on when to initiate Chapter 48 are unclear |
Work with judicial
community to develop clear guidelines on documenting areas of concern to
substantiate case for initiation of Chapter 48 proceedings
|
APS Service Delivery |
Commencement of service delivery stage is clearly defined |
Lack of
distinction between investigative stage and service delivery stage
Two
cases can be open on a single client and staffed by different APS field
employees at the same time
Service delivery is initiated before
completion of investigation
Inappropriate initiation of services |
Sharpen definition of APS functions
Realign IMPACT to allow for
proper flow from investigative stage to service delivery stage
Clarify
case assignment protocol
Clarify service delivery parameters for each
stage
|
Client resources identified and used appropriately |
No performance
standards for ensuring staff have identified client resources |
Develop
performance standards for identifying client resources
|
Service plans address client needs |
Service plan tool (outcome
matrix) does not allow for sufficient detail
Insufficient caseworker
knowledge of available resources, local services, and entitlement
programs
No criteria for evaluating service plans
Lack of
appropriate referrals to Guardianship program
Service delivery driven
by funding concerns
Service plan documentation inadequate
Service
plan limited by staff expertise |
Redesign outcome matrix· Develop and
maintain resource and service database
Implement performance standards
and quality assurance guidelines to enhance employee performance
Improve guidelines for referring cases to Guardianship program· Augment
training with regard to service delivery
Revise funding formulary to
take away inappropriate incentives
Develop standards for service plan
documentation
|
Staff have access to information on shared cases |
Client's
enrollment in current state and federal programs may not be known |
Improve access to information from other service program databases
|
Service plan addresses protective services with clearly defined goals
and timetable |
Variation in service plans due to lack of definition of
protective services
Indefinite service delivery for multi-needs
clients
Service delivery for clients extends past stabilization to
meet ongoing non-protective needs |
Develop criteria for what
constitutes protective services
Ensure coordination with other
providers for needed post-stabilization services
APS service delivery
disposition rules developed and employee handbook updated accordingly
Develop uniform criteria for service delivery and follow-up timelines
|
Service delivery plans minimize possibility for future referrals to
APS |
Repeat cases indicate service plan inadequacies |
Create a
multidisciplinary team to review repeat cases and develop strategies in
service plan development to reduce chance of recidivism
|
Staff decisions are appropriately documented |
Clients remain at
risk |
Review documentation policies and procedures for clarity
Retrain staff on documentation
Develop and implement a quality
assurance process to ensure compliance with documentation
|
Staff decisions are appropriately reviewed |
Clients remain at risk |
Develop and implement a quality assurance process for reviewing staff decisions
Use long-term follow-up strategy in collaboration with
community groups to reevaluate criteria for successful interventions
|
Service delivery cases staffed by appropriate subject matter experts |
Lack of multi-disciplinary team review
Inappropriate utilization
of APS caseworkers for development of service plans for
post-institutionalized clients
Scope of APS unclear in servicing of
clients with chronic needs |
Case profiles identify complex cases that
need staffing by multi-disciplinary group
Establish intra-agency
protocol for managing multi-needs clients
Include judicial review as appropriate
Explore the need for formal community review panels
|
Cases appropriately referred to judicial system |
Lack of clarity in
guidelines for judicial referrals
Staff do not always know when to
refer to judicial system
Strained judicial/APS relationships in some
areas of the state |
Provide criteria for case referral to judicial
system
Retrain staff on procedures for cases requiring judicial
involvement
Work to improve community relations with judiciary
|
Appropriate contact with referral agency regarding service plans |
Inadequate coordination and referral with other state agencies that
provide supportive services
No clear interaction between APS and other
health and human services agency staff |
Use health and human services
agencies' Center for Program Coordination to ensure seamless service
delivery system
|
Community resources utilized for long-term, non-protective services |
APS continues to provide services past protective phase |
Build and
maintain local support networks to ensure clients receive ongoing
services as needed
|
There are clear criteria for service delivery phase closure |
Service delivery continues past protective service stage |
Create a
decision tree for ending service delivery
Ensure appropriate
documentation for closing case· Clarify APS handbook
|
APS Guardianship |
Seamless coordination of guardianship services throughout the HHS
system |
No problem substantiated |
Bridge gaps to facilitate
appropriate guardianship services
Increase the accountability and
monitoring of guardianship service provision efforts
Evaluate whether
APS Guardianship program should be mandated to serve as guardian for
children aging out of the Child Protective Services program
|
Guardianship efforts are enhanced through a network of community and
stakeholder organizations and contracted entities |
Lack of
coordination within HHS agencies and local community organizations
regarding guardianship services |
Establish a collaborative network of
HHS agencies and local community organizations and contractors
Consider state agency regulatory authority over local Guardianship
programs
Support development of more local Guardianship programs
|
Investigators make proper referrals to guardianship |
Lack of
appropriate referrals to Guardianship program |
Improve guidelines for
referring cases to Guardianship program
|
Improved policies regarding decisions to refer cases to the judicial
system |
APS policy of contesting the assignment of the guardian of
last resort has resulted in judges being critical of APS
APS places
great emphasis on self-determination, which has resulted in fewer
Chapter 48 emergency removal petitions and/or guardianship court
referrals |
Review statute regarding the role of guardian of last
resort to ensure proper policies are in place to carry out this function
Review whether APS Guardianship program should be designated as
"guardian of last resort"
Evaluate policies to ensure that
APS takes appropriate actions to prevent abuse, neglect, or exploitation
of the elderly and disabled adults
|
Potential conflicts of interest are identified and resolved |
APS
serves as the guardian and as the protective agency. APS investigators
could be called upon to investigate allegations of abuse, neglect, or
exploitation filed against the APS-appointed guardian |
Develop an
organizational structure that will provide adequate separation of duties
to clearly delineate the role of guardian from protection
|
Regional case review teams review guardianship cases |
Insufficient
case monitoring/case management |
Form case management teams that
support the provision of guardianship services by Guardianship program
staff
|
APS Staffing |
Staff skill sets match job functions |
Skill sets for investigations
and service delivery functions are different in scope and level
Both
investigations and service delivery functions are combined in single job
position
Dual focus weakens effectiveness of each
function
Unclear
differentiation of functions contributes to lack of clarity on
definition and requirements of each |
Clearly define investigative
function and service delivery function
Identify appropriate skill sets
for each function
Consider separate case technician function to
administer routine services according to service plan
Realign
staffing structure as appropriate
Revise handbook
Compare on a
regular basis defined skill sets with those evidenced by successful
performers of the position
|
Staff hired into APS have appropriate qualifications |
Job
descriptions do not adequately identify the required knowledge, skills,
and abilities
Current job requirements may not effectively achieve
program goals and objectives
Hiring practices are inconsistently
applied across regions
Potential staff have unrealistic expectations
about job duties
Staff promoted to supervisors do not always have the
advanced skill sets necessary |
Develop job descriptions based on
redesigned staffing structure with appropriate classification
Identify
appropriate knowledge, skills, and abilities required for each position
Conduct a job analysis to identify key educational
requirements and personal skills and qualities needed for each position
Design a survey based on program requirements to identify
available degree plans that will effectively support program execution
Ensure hiring process includes demonstration of appropriate skills by
applicants
Develop and implement standardized interview procedures
statewide
Develop and implement job preview process for interested
applicants
Develop and implement a recruitment program
Consider
using eligibility staff to serve as case technicians/human services
aides
Ensure supervisor job description is defined by advanced skill
sets
|
Field staff have manageable caseloads |
Average caseload varies
widely across state
No distinction between relatively simple and
complex cases and the amount of effort required to resolve each
Investigators are engaged in service delivery activities that can be
performed by case technicians
Large portion of investigator's time
spent managing non-protective services |
Develop case profile using
complexity as a component
Ensure equitable caseload distribution based
on case profile
Minimize service delivery in investigative phase
Clarify non-protective from other services and work with local resources
to collaborate delivery
Consider case technicians to administer
routine services according to service plan
|
Staff are available with specialized skill sets |
Complex cases,
such as financial exploitation and self neglect, require specialized
knowledge
Staff involved with clients are also engaged in general
support activities for the program |
Consider utility of specialization
and staff accordingly in the following areas
Nursing
Financial Exploitation
Community Relations· Mental Health
Self-Neglect
|
Staff deployed to meet caseload demands |
Caseloads vary widely by region
Roles and responsibilities for staff support functions vary by
region
Specialists are not always available |
Examine alternative
staffing models for effective deployment of APS staff
Standardize
management structure of field operations
Develop recommendations for
APS organizational structure
|
Turnover rates are minimal |
Employee turnovers cause disruptions in
investigative and service delivery phases
Turnover rates vary widely
by region |
Develop and implement a retention program
Ensure
supervisor training addresses employee retention
|
APS Funding |
Workload expectations are accurate |
Workload measurements are not
assessed by region
Average units of time from the work measurement
study (WMS) do not accurately report time spent on individual casework |
Perform analysis of workload time requirements for use in the funding
formulary
|
Data on case activity is accurate and reliable |
Service delivery
information in IMPACT may be counted different ways
Service delivery
in the investigation phase creates confusion about whether case is open
for investigation or service delivery
APS field staff may record any
interaction with client as service delivery
Number of cases is not
reliable because of duplication and pre-mature case closures |
Develop
a standard for what constitutes delivery of services to client
Differentiate more clearly investigative and service delivery phases·
Modify IMPACT accordingly
|
Funding formulary represents accurate and reliable service delivery
information |
Service delivery inappropriately driven by funding
concerns |
Revise funding formulary to take away inappropriate
incentives
|
Differences in workload based on case complexity are factored into
formulary funding |
Complex cases require more effort, use more
resources, and take more time· It is unknown whether regions differ in
the incidence of complex cases |
Develop case profiles based on
complexity of case
Determine regional differences
Factor case
profile into funding formulary if appropriate
|
Funding is allocated with regard for demographic and socio-economic
factors |
Funding allocation does not consider changing populations of
interest |
Modify the current funding allocation to incorporate
relevant demographic and socio-economic factors
|
Regional differences are considered in the funding allocation |
Funding allocation does not consider regional differences |
Ensure
regional differences in case profiles are factored into the funding
formulary
|
Demographic and socioeconomic levels are monitored at the regional
level |
IMPACT does not currently allow for tracking of socioeconomic
factors |
Modify IMPACT to record socioeconomic information reported at
the regional level
|
Funding is allocated equitably |
Funding allocation formula does not
provide a clear equitable standard for service delivery
Inadequate
documentation exists to support the current funding allocation process |
Revise the funding allocation formula to match scope of APS policy
Review and thoroughly document the funding formulary
process
Revise
fiscal year 2005 formulary to include available work measurement study
and demographic information as appropriate
|
APS Performance Management |
Well defined staff performance standards are provided |
There are
few, if any, formal performance standards for APS functions
Staff
performance expectations, and their clarity, vary by supervisor
Lack
of standards diminishes accountability |
For each APS function, develop
relevant performance standards
Ensure performance standards are
clearly defined in the handbook
|
Staff performance is appropriately monitored |
There are no formal
guidelines, criteria, or process for monitoring staff performance on a
day-to-day basis
Staff are not receiving feedback on performance
Staff are not being held accountable for deficiencies |
Develop
procedures for monitoring staff performance
Train supervisors and
staff on procedures
|
Program performance is continually tracked |
The current management
reporting system is inadequate
Supervisors and leadership focus on
high-profile cases and not on fixing underlying causes |
Develop an
effective management reporting system
Secure and implement data
management tools that provide daily reports of program and staff
performance
|
A quality assurance process ensures continuing improvements |
Identification of problem areas usually comes from high-profile cases
which may not focus on root causes
Case review approach currently
utilized does not address programmatic issues and concerns
Supervisors
and leadership unaware of major problems in program |
Develop a
comprehensive quality assurance process that reviews all aspects of the
APS program systematically and periodically
Initiative improvements as
warranted by review
Consider requiring DFPS Internal Audit to include
a review of the Quality Assurance program in its yearly audit plan until
the time at which the risk relative to the program is reduced
|
APS Technology (IMPACT) |
IMPACT supports intake |
Changes in policies and procedures, as a
result of reform efforts, may require changes to IMPACT |
Modify IMPACT
according to approved changes in policies and procedures
|
IMPACT supports investigative stage |
Changes in policies and
procedures as a result of reform efforts may require changes to IMPACT |
Modify IMPACT according to approved changes in policies and
procedures
|
IMPACT supports service delivery stage |
Changes in policies and
procedures as a result of reform efforts may require changes to IMPACT |
Modify IMPACT according to approved changes in policies and
procedures
|
IMPACT is consistent with records retention policy |
Changes in
policies and procedures as a result of reform efforts may require
changes to IMPACT |
Modify IMPACT according to approved changes in
policies and procedures
|
IMPACT supports reporting needs |
Differences in data reports from
IMPACT indicate potential deviations from policies and procedures
Changes in policies and procedures as a result of reform efforts may
require changes to IMPACT |
Conduct an information systems audit on IMPACT
Modify IMPACT according to approved changes in policies and
procedures
|
APS Mobile Technology |
Field-based access to electronic technology to minimize travel and
reduce time lag on documentation |
Lack of real time access to
policies, key APS tools and forms
Delay of input of case notes into
IMPACT results in delays in reporting and loss of data. |
Deploy
wireless technologies and handheld devices to field staff with
electronic reporting capability
APS handbook deployed with mobile
technology
|
Field staff utilize computer based decision-making tools |
Technology has not been fully utilized to document the investigative
process |
Develop decision making "wizards" to guide staff
decision making in the field
Upgrade IMPACT to support field-based
technologies
|
Digital camera technology is deployed to support case findings |
Insufficient photographic evidence of conditions
No capability for
merging paper and photographic evidence into case file
Digital
photographic evidence cannot be stored in IMPACT |
Supporting evidence
is scanned into case file
Increase storage capabilities of field
office computer systems
Redesign IMPACT to allow for importation of
electronic photographs
|
Medical experts are consulted in real time as needed |
Telemedicine
intervention techniques have not been utilized |
Investigate the
potential of telemedicine
|
APS Records Retention |
Timely compliance with records retention statutes |
Lack of rules in
Title 40 TAC that address records retention· DFPS is behind on
destruction of case files and not in compliance with records retention
policy
Paper case files are not consistently purged in compliance
with agency retention policies
DFPS Records Management program does
not have a standard electronic tracking system to monitor records
management
Understaffed offices creates a problem for timely
compliance with records management policies |
Implement system of
organized automated records (SOAR) in APS
Develop consistent case
file merging policy
Remove backlog of electronic files needing purging
to comply with records retention policy
Review and align DFPS records
retention policies and procedures with state and federal laws regarding
records retention and destruction
Reassess human resource allocations
to ensure compliance with records retention policies
|
Proper utilization of paper and electronic documentation for records
access and case review |
Inconsistent records management training
provided to APS staff
Merging policy is unclear and not followed
consistently throughout agency |
Develop and implement regularly
scheduled training on records management
Modify IMPACT to support
search and merge policies
|
Stakeholders have appropriate access to case records |
Current
practices are inconsistent with and not supportive of the investigative
or judicial processes |
Provide training to APS staff regarding HIPAA
standards and statutes on sharing of personal medical information
Improve relationships with medical/mental health professionals and
associations regarding HIPAA cooperative agreements
|
APS Training |
Staff are well trained |
New staff are investigating cases without
formal classroom training
Current training curriculum is inadequate
Tests for staff who attend training are not used by training staff to
address employee deficiencies
There are no annual training requirements
Certification process is optional and not time
limited
Opportunities for specialized training are
limited
IMPACT training
inadequate |
Strengthen training requirements for new field staff
Develop specific outcome measures for staff training that ensure staff
have appropriate skills
Require completion of formal classroom
training before staff can independently investigate or do casework
Use
pre- and post-tests to document learning and enhance accountability
Employ an additional post-test after skills have been applied on the
job
Develop and implement a standardized continuing education
program
Consider merging certification process and annual training
process
Identify and make available specialized training as
appropriate
Improve IMPACT training
|
Training is high quality |
Training time is insufficient for needed
training
Curriculum varies in quality
Basic curriculum is weak in
some areas of specialized training
On-the-job training (OJT) is not
well defined and clearly linked to formal training
Advanced training
in specialized areas is weak and inconsistently utilized |
Review and
improve APS training curriculum
Ensure training curriculum is aligned
with desirable outcomes as defined in policy
Ensure that draft
curriculum is reviewed by subject matter experts
Define and formalize
an OJT program that is linked to formal training
Have training
curriculum reviewed yearly by multidisciplinary review team
|
New investigators receive training quickly |
Human resources is not
notifying and coordinating with the training department regarding new
employee hires
Caseworkers receive basic skills development (BSD)
training at varying times after being hired
Caseworkers are not
provided adequate training prior to being assigned cases
Need for a
training program that includes classroom instruction and experiential
exposure
Lack of sufficient awareness on more graphic aspects of APS
investigations |
Establish a referral link between human resources and
the training department to identify and coordinate timing of training
for new employees
Create a mandatory schedule of basic skills
development training
Define clear guidelines for assignment of cases
ensure staff with appropriate skills are assigned
Include time and
experienced staff availability for on-the-job training and mentoring for
new workers
Ensure staff understand and can manage the broad array of
cases assigned
|
Caseworkers well trained on timely and accurate documentation |
Inconsistent quality in documenting cases |
Ensure staff have
appropriate documentation skills
|
Experienced workers receive ongoing advanced training |
Need to
differentiate training between new workers and experienced workers |
Develop basic training protocols and a different set of advanced
training protocols to focus on more specialized issues
|
Training is essential to career advancement |
Lack of expectations
for continuing education or advanced training |
Tie training and
certification expectations to career ladder
|
Training is readily available to all field staff |
Training not
readily available or consistently scheduled for all field staff |
Develop web-based, video, and teleconference training modules to allow
for flexibility and greater access
Develop refresher training to meet
immediate needs of reformation
|
Caseworkers maintain community relations and support networks |
Training does not fully address the need to build community relations |
Include module on building community relations in the basic service
training
|
Supervisors have adequate training and skill sets |
Supervisors are
not receiving necessary training in judgment and decision-making
relative to complex cases
Supervisors need more training in evaluating
case documentation for completion |
Develop training more specific to
supervisor role of evaluation staff judgments and reviewing case for
completion
Train supervisors to review quality and quantity of staff
work
|
Performance measures are tied to appropriate case management |
Supervisors are deficient in use of IMPACT to track performance measures |
Create supervisor training on advanced uses of IMPACT for research
|
Caseworkers are consistently trained |
Levels of competency vary by
caseworker and within regional areas |
Develop training modules to
address specialized topics of abuse, self-neglect, and exploitation
Review of basic documentation
Provide refresher training to all
current field staff
|
Caseworkers are sufficiently trained in financial exploitation and
self-neglect |
Identified lack of training on issues of financial
exploitation and self neglect of clients |
Work with the Attorney
General's Office and other subject matter experts to develop more
focused and specific training on financial exploitation, with attention
on developing a pattern of exploitation
Consider creating staff
specialists in financial exploitation and self-neglect
Expand
financial exploitation training in basic skills development
Improve
training on self-neglect
|
Caseworkers are trained on mental health commitment |
APS provides
ongoing assistance to clients who may need mental health commitment |
Improve training curriculum related to mental health commitment· Ensure
mental health experts review training module
|
Caseworkers are prepared for judicial proceedings |
Insufficient
understanding of judicial involvement for Chapter 48 actions |
Coordinate with judicial experts on the creation of a training module
for Chapter 48 proceedings
|
Clear and thorough training standards exist |
Employee handbook
insufficient on training requirements |
Update employee handbook to
reflect new training schedules, modules, and records management
|
APS Community Relations |
APS strategically and consistently develops and maintains community
support |
Community support efforts vary across
regions
Lack of
engagement with community limits common understanding of community
standards and expectations |
Engage community collaboration efforts
Develop and implement a community relations model for building and
maintaining support networks to provide ongoing needed services to
clients
Develop and implement a Guide to Community Resources
Development (handbook)
Evaluate the APS-sponsored annual conference in
supporting these efforts and make appropriate adjustments
Ensure
continuing interaction with community groups with periodic meetings
Work with local groups to develop collaborative follow-up strategies for
clients as appropriate
|
Local community support networks are established and thriving |
Varying levels of community involvement and activities across the state
Job roles and responsibilities for this function are not
defined
A common understanding of community standards and expectations
does not exist
Community groups change over time |
Develop and
implement a quality, comprehensive public awareness campaign
Establish
a clear community relations function and ensure appropriate staffing
Recruit subject matter experts to volunteer for consultation on an
as-needed basis
Develop and implement a strong community relations
module in the basic skills development training program
Develop and
maintain community resource books
Dedicate staff to keep resource
community list up to date
|
There is a strong volunteer program |
Engagement of volunteer
coordinators varies across the state |
Ensure dedicated staff assigned
to work with communities to strengthen volunteer programs
|
Ongoing and productive resource development in the community |
Community resource development efforts vary by region |
Evaluate the
feasibility of a mandated APS community partners program similar to CPS
partners
Engage with faith-based and other non-profit organizations to
deliver needed services
|
Good communications among health and human services agencies
regarding APS program operations and requirements |
Inability to
successfully engage other health and human services agencies for
appropriate interventions |
Establish policies and/or standard
operating procedures to facilitate APS in effectively performing its
duties
Work to ensure full HHS participation in local community
support network
|
APS Judicial Relations |
APS has positive working relationships with local law enforcement |
Protocols vary by locality |
Assess current relationships and develop
plans to mitigate areas of stress
Dedicate staff to build and maintain
local relations
Establish uniform guidelines and procedures for
relating with local law enforcement
|
APS has positive working relationships with local courts |
Protocols
vary by locality
Emergency removals underutilized |
Assess current
relationships and develop plans to mitigate areas of stress
Dedicate
staff to build and maintain local relations
Establish uniform
guidelines and procedures for relating with local courts
Work with
courts to establish uniform criteria for emergency removals
|
APS has positive working relationship with local code enforcement
officials |
Protocols vary by locality |
Work with local code enforcement
officials to develop criteria for referrals
|
APS casework supports legal actions |
Field staff untrained on legal
issues
Varying levels of quality of documentation found
Legal
training provided by courts and law enforcement not utilized |
Retrain
staff on case documentation· Establish a quality control process for
case documentation
Train staff on local legal and judicial reporting
requirements
|
Guardianship cases are referred timely and appropriately |
Cases not
appropriately assessed for guardianship
Confusion over criteria for
initiation of guardianship services |
Reexamine guardianship policies
and procedures
Retrain staff on guardianship policies and procedures
Work with courts and Guardianship program to ensure smooth transition to
guardianship
|
<<back to top>>
Adult Protective Services (APS): The program under the purview of
DFPS which is mandated to protect older adults and persons with
disabilities from abuse, neglect, and exploitation by investigating and
providing or arranging for services as necessary to alleviate or prevent
further maltreatment.
Basic Skills Development (BSD): The term used by the DFPS
Professional Development Division (PDD) that describes classroom
training provided to employees.
Case Documentation: The information collected by APS investigative
staff or caseworker staff that is included in the case record. This
information lists client contacts, collateral contacts, perpetrator
contacts, and other information obtained during the course of an
investigation or in providing services to clients.
Caseworker: The APS staff that provides direct delivery or contracted
services to clients after an investigation has been completed.
Certification Process: A voluntary process designed to recognize
professional development beyond the basic job skills required for DFPS
specialists and supervisors.
Community Involvement: A process that ensures effective and
deliberative methods of participation in local communities with the
purpose of providing information on the APS program and being visible in
the community as a partner in addressing needs of the community.
Community Organization: The process of organizing activities with
various groups or organizations within a community for a specific
purpose of meeting the needs of elderly or disabled clients served by
APS.
Community Resources: Services or items provided by groups or
organizations within a community that meet the immediate or long-term
needs of a client.
Comprehensive Risk Assessment Tool: The process by which a caseworker
or investigator completes a thorough analysis of the environment,
financial circumstances, physical and medical condition, social
interaction and support, and the mental and problem-solving abilities of
the individual to assess risk factors associated with the client
remaining in the home.
Community Relations: The effort to establish two-way communication
with the public to create understanding of APS programs and related
actions and to ensure public participation into decision-making
processes related to the delivery of services in the community.
Corrective Action: The administrative remedy imposed on an agency or
section of an agency that defines the scope of change that must occur.
Department of Family and Protective Services (DFPS): The APS and CPS
oversight agency that is mandated to protect the unprotected children,
elderly, and people with disabilities from abuse, neglect, and
exploitation.
Emergency Removals: A process through which the court may authorize
that an elderly or disabled person be moved to safer surroundings based
on an assessment that the person suffers from abuse, neglect, or
exploitation that presents a threat to life or physical safety and lacks
the mental or physical ability to consent to services.
Environment Issues: Refers to client's current living situations
including an assessment of working utilities, health hazards, adequate
food in the home, appropriate seasonal dress, and other factors
associated with the client remaining in a suitable living situation.
Equity of Service Statement (ESS): This is an allocation formula tool
that is used by DFPS to allocate funds for the APS program.
Forcible Entry: The process through which law enforcement is
contacted to gain entrance into a home for the purpose of gaining access
to the individual to conduct the investigation.
Guardianship: The power and duty of taking care of another person and
managing the property and rights of another person who, because of age,
understanding or self-control, is considered incapable of administering
his or her own affairs.
Health and Human Services Commission (HHSC): The oversight agency
responsibilities for designated health and human services agencies,
which includes DFPS, and administers certain health and human services
programs including the Texas Medicaid Program, Children's Health
Insurance Program (CHIP), and Medicaid waste, fraud, and abuse
investigations.
Information Management Protecting Adults and Children in Texas
(IMPACT):
IMPACT is a case tracking and reporting system that is used by APS staff
to document case activities. It also supports the Child Protective
Services and Child Care Licensing programs at DFPS.
Intake Specialist: APS staff responsible for obtaining information on
potential abuse, neglect, or exploitation referrals.
Intake: The process of obtaining information from a complainant on
the possible abuse, neglect, or exploitation of an elderly or disabled
individual.
Investigative Stage: Part of the APS process in which the
investigator initiates contact with the client, collateral contacts and
contacts with the alleged perpetrator to determine if there is abuse,
neglect, or exploitation of the elderly or disabled individual.
Investigator: The APS staff designated to conduct the investigation
regarding allegations of abuse, neglect, or exploitation.
Multi-Disciplinary Team (MDT): A group of subject matter experts who
work together in a coordinated and collaborative manner to review and
suggest corrected actions to address areas of concerns. Members of the
MDT are comprised of agency staff, stakeholders, and/or private
practitioners who have an interest in the way services are provided to
clients.
Performance Management: The systematic process of monitoring the
results of activities; collecting and analyzing performance information
to track progress toward planning results; using performance information
to inform program decision-making and resource allocation; and
communicating results achieved, or not attained.
Performance Standard: An established level of achievement, quality of
performance, or degree of proficiency.
Refresher Training: Training provided to APS staff to update them on
changes that are made to existing policies and procedures.
Service Delivery: The process of providing direct or contracted
services to clients to address client's immediate or long-term needs.
Service Delivery Plan: The types of services that will be provided to
the client and documented in the IMPACT system.
Service Delivery Stage: The part of the investigation that begins
when the investigator has determined that abuse, neglect, or
exploitation exists and services need to be provided to the client.
Skill Sets: The abilities needed by an individual in performing the
duties of an Adult Protective Services caseworker or supervisor.
Subcommittee: A subgroup of the APS Reform Team that was established
by HHSC to review and identify issues in specific areas of the APS
program.
Volunteer Programs: Groups established using volunteers to provide
services to individuals. Meals on Wheels is an example of a program that
utilizes volunteers to deliver meals.
Workgroup: A subgroup of the APS Task Force established to work on a
specific issue.
<<back
to release>>
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