There are many potential disruptive threats which can occur at any time and affect the normal business process. We have considered a wide range of potential threats and the results of our deliberations are included in this section. Each potential environmental disaster or emergency situation has been examined. The focus here is on the level of business disruption which could arise from each type of disaster.
Potential disasters and recovery methods have been assessed as follows:

Key business processes and the agreed backup strategy for each are listed below. The strategy chosen is for an offsite backup through the Vault Logics company. This strategy entails the maintenance of full daily backups of mission critical data and the backup site(s). Each campus has two domain controllers all running within the same active directory forest. This way even if both fail there is no data stored only on the servers that cannot be recovered from another.

Data & Backup Plan

PLAN DOCUMENTATION STORAGE

Hard copies of this plan will be stored in the data center/computer closet of all sites. Each member of the IS Department will be issues hard copy of this plan. The plan will be reviewed yearly with all IS staff during the month of June. A master protected copy will be stored on the Policies & Procedures website.

The principal objective of the disaster recovery program is to develop, test and document a well-structured and easily understood plan which will help the company recover as quickly and effectively as possible from an unforeseen disaster or emergency which interrupts information systems and business operations. Additional objectives include the following:

• The need to ensure that all employees fully understand their duties in implementing such a plan
• The need to ensure that operational policies are adhered to within all planned activities
• The need to ensure that proposed contingency arrangements are cost-effective
• The need to consider implications on other company sites
• Disaster recovery capabilities as applicable to key customers, vendors and others

STATEMENT OF INTENT

This document delineates our policies and procedures for technology disaster recovery, as well as our process-level plans for recovering critical technology platforms and the telecommunications infrastructure. This document summarizes our recommended procedures. In the event of an actual emergency situation, modifications to this document may be made to ensure physical safety of our people, our systems, and our data.

Our mission is to ensure information system uptime, data integrity and availability, and business continuity.

The time and date of the order for involuntary anti-psychotic medication administration must be documented on the doctor’s order sheet by the physician, or documented by a licensed nurse as a telephone order from the physician. The use of medication will be documented in the student’s case record with at least the following information:
a) A description of the precipitating incident or series of incidents, the alternative interventions attempted including all efforts to prevent the use of chemical restraint, and the reasons the medication was necessary.
b) The fact that involuntary medication was the least restrictive alternative and why.
c) The time and from whom the order for administration was obtained, and the names and titles of all other persons notified and/or involved in the decision.

On the day new orders are received, the nurse must enter a progress note in the student’s chart that explains the new order and the reasons for the change. When a verbal consent from a family guardian/agency guardian is received, it must be recorded on the consent form with a signature from two nurses and also in a progress note in the student’s chart.

a. Associated with Restraints and altercations
A body check of the student is to be conducted by the nurse within 24 hours or sooner if indicated, whenever any of the following conditions are met:
1. A physical intervention has been difficult, severe or such that injury may have occurred, regardless of the duration of the hold or restraint e.g., the student has struggled and the staff has had to apply some degree of force to maintain safety.
2. The student has been involved in a floor hold (i.e., prone, on the floor-not seated).
3. The restraint exceed 20 minutes
4. The student reports any pain or discomfort, or the student appears to be in pain or uncomfortable, regardless of whether or not he/she reports or confirms pain or discomfort.
5. After a physical altercation between students that meets any of the criteria outlined above (i.e., difficulty, severity or duration of physical altercation; report or appearance of injury, pain or discomfort).

If there is no nurse on duty at the time of the incident, the on call nurse will be consulted by telephone. If it is determined that the on call nurse need not come to the program to do a body check; the body check will be done as soon as possible at the beginning of the next nurse’s shift on campus.

b. Documenting Body Checks Associated With Multiple Restraints
It is sometimes necessary to restrain a student more than once and sometimes with little time in between restraints and before a body check can be conducted. In such cases the body check and finding (e.g. “minor injury”) will be documented only on the most recent or last Physical Intervention Report form for the series, even though there will be a PI form completed for each restraint (incident).
On the most recent or final PI form in a series, the nurse conducting the body check will include the following note: “Body check for multiple physical interventions”.
On all other PI forms in that same series, the nurse conducting the body check will include the following note: “See the most recent PI form” with both date and time of the final PI form noted.
Sequential PI forms should be clearly marked to show the sequence of events.

c. Prior to and on return from unsupervised leave of absence
A body check is also done prior to and upon returning from, an unsupervised home visit or an unsupervised off-campus visit. This is not a contraband check; it is a visual inspection looking for signs of illness or injury.

d. Student Refusal of Body Check
If a student refuses a body check, the supervisor is notified and the event is documented on the Incident Report form and in the case record Progress Notes. Additional attempts are made until the body check is completed.

Incident Reports and Physical Intervention Reports must be completed and submitted to a supervisor as soon as possible but not later than the end of the shift in which the incident takes place. The report must then be processed according to the procedures at each campus.

Documenting Physical Interventions

1. Physical Intervention Reports
Every physical intervention with a student, including holds and restraints, requires a Physical Intervention Report form to be completed by the staff member who initiated the restraint.

Documentation for the continuous monitoring of a restraint and the 15 minute assessments of a restraint will also be made in the appropriate section on the Physical Intervention Form, not in the chart progress notes. If the restraint is continued for more than 2 hours, an additional PI form must be attached for documentation of the 15 minute assessments.

Physical Intervention Reports are reviewed daily by clinicians, nursing and administrative staff

2. Progress Notes
The supervisor on duty, or the LP who ordered the restraint, if he/she is on site, must write a progress note in the student’s case record that fully describes the incident, the reasons why a less intrusive measure was not justified or was ineffective, the process of reassessment and an explanation of how the child’s rights were maintained. The progress note will also concisely describe the final progression at the end of the restraint, time the restraint ended, student behavior and the processing of the restraint with the student, the student’s return to program or to a Time Out.

3. Written Approval of Verbal LP Orders for Restraint
within 72 Hours
If an LP orders a restraint, or the continuation of a restraint, by telephone, and the supervisor on duty writes the progress note, the LP who ordered the restraint will sign and date the progress note, with his/her title, in the margin beside the note, within 72 hours of the time he/she gave the order to restrain/continue the restraint.

In these instances, as long as the LP agrees that the supervisor’s progress note is accurate, it is not necessary for the LP to write an additional note. He/she will simply sign and date the supervisor’s note in the margin beside the note.

In the event that the LP does not believe the supervisor’s note to he accurate, he/she will discuss the differences with the supervisor and a program administrator. If any corrections are necessary, they will be explained in a progress note, and a final, accurate note will be made. The Physical Intervention report will also he checked for accuracy and corrections made and initialed as necessary.

The safety, continuity of care and coordination of interdisciplinary treatment for any Hillcrest student depend in part on the accurate and timely documentation of services provided to, and significant events in the student’s life. Effective case documentation also serves to support the student’s treatment plan and effective clinical decision-making, and it constitutes part of the legal record for that student.
Hillcrest utilizes many different forms of case documentation including the Progress Note, an important record written by staff who directly provide care and services to the student. All progress notes at HEC are in electronic form and are accessible through a secure privileging system assigned to clinical and administrative staff. Electronic progress notes are backed up and stored off site on a daily basis. They are periodically archived to DVD media on a yearly basis. Progress notes for, at least, the previous 24 months are always available in the online system.
It is commonly considered to be “best practice” for Progress Notes that, to the extent possible:
• They reflect the chronology or order of service and care events as they happen, and,
• They are written as soon as possible after the service or event, because the closer the documentation is recorded to the actual event, the more accurate and reliable the documentation tends to be.
It is Hillcrest’s policy that, whenever possible, the Progress Note will be entered into the student record on the day or the day following the provision of the service or the occurrence of the event. If circumstances prevent the entry by the end of the day following the provision of the service or the occurrence of the event, the entry is made as soon as possible after that day, and is classified as a late entry.
The following format and protocol are used when making a late entry.
• The current date and time are written in the left hand column.
• The entry begins: “Late entry for (date the service or event occurred)”, followed by the identification of the service or event. For example, “Late entry for 1/24/049. Weekly Individual Therapy x 45 minutes.”

Progress Notes – Time of Day In Progress Notes
Traditionally at Hillcrest we have required that the time of day at which a Progress Note is being written be included under the date of the PN in the left hand margin. However, in addition to sometimes causing confusion (i.e., is it the time the note is written or the time the service was provided?), we have determined that only HEC policy requires this inclusion of the time in the Progress Notes of all disciplines. It is apparently not required by any regulatory agency or accreditation body, and it is not commonly considered standard practice among behavioral health care providers.

Therefore, after consultation with other managers, we have determined that from this point forward, with the exception of Nursing PNs, it will not be necessary to enter the time of day under the date on a PN. Nurses will continue to note the time of day.