humane

INDICATOR A

The Agency ensures/supports the clients’ rights to a wholesome, clean, safe, pleasant, and dignifying treatment environment (i.e., a supportive, family-style or most natural, nonjudgmental atmosphere)? See Standard 206.

What does a 4 look like?

Agency is fully compliant with standard 206. Under this indicator, agencies should take advantage of all opportunities to make treatment environments more home-like, family-style and dignifying. Agencies often also make sure all systems and resources are more than adequately apportioned to maintenance of the treatment environment.

To earn a 4 for this indicator, treatment environments must be well-maintained, ensuring safety and cleanliness, with clear effort at making the treatment environment as home-like, pleasant and dignifying as possible.

While it is not required for an agency to establish an environment like a home, the more the environment replicates a home, the more likely the agency will score higher on this indicator. It is often the case that an agency will work to turn a traditional and sterile environment into one that is warm, engaging and reflective of the client’s individual preferences is more likely to be demonstrated. Even in institution-like settings, a humane environment can be established through the use of personalized pictures, art, and bedding, as examples.

EXAMPLES FROM REVIEWER REPORTS

“Clients are encouraged to personalize their living spaces, as well, which is especially remarkable given the contract limitations placed upon the agency. In fact, the agency goes to great lengths to adorn the homes in a way that suggests family living including creating a family-room environment that is relaxing and engaging.”

“The cottages we visited were clean and well maintained without any visible maintenance concerns. We observed the cleanliness of the youth bedrooms as well as noting that the youth’s needs for clothing, bedding, medications, and hygiene, etc. were all met in the cottages.”

“The environments themselves varied, but we were able to observe positive motivators in all environments and types of facilities as well as an emphasis on skills acquisition, rewards and consequences in the form of privileges that could be earned… There was a strong emphasis on diversity which was reflected in the decoration and artwork displayed in the homes. There were many creative treatment strategies employed by the treatment providers to address issues with youth including a tree built into the scenery in a room for the youth to hide under and feel safe when they needed time alone and chalk board paint for them to express their feelings when they were upset.

“While the buildings are hardwired institutionally, the staff works hard at personalizing the homes and making them the most family-friendly as possible. There remains work to go here but the direction is obvious as the staff work to move from cinderblock to warmly painted dry wall, etc.”

What does a 3 look like?

Agency is adequately compliant with standard 206. Under this indicator, it is not uncommon for agencies to overlook opportunities to make treatment environments more home-like, family-style and dignifying, or for systems and resources to be inadequately apportioned to maintenance of the treatment environment.

To earn a 3 for this indicator, an agency might have overlooked some opportunities to make the treatment environment more home-like and dignifying, or some instances of inadequate maintenance might be visible, but beyond certain instances, there is a clear commitment to providing wholesome, safe, clean and dignifying treatment environments. Examples of shortcomings are not common or widespread.

EXAMPLES FROM REVIEWER REPORTS

“In regards to a clean and safe environment, it was observed that in the culinary classroom cleaning chemicals were left out, pots and pans were placed on a dirty floor, and shelves were disorganized. Administration acknowledged that they are aware of the problem. A suggestion is to do random checks of the classroom to ensure that chemicals are locked up so that youth cannot access them and to give feedback on cleanliness as needed.”

“[Agency Name] has already begun an initiative to develop the new RTC on campus – the buildings in this setting will benefit from being modernized with a view to maintaining safety while improving the homeliness and family style. The review team supports this initiative to ensure the most dignifying environment for these youth. The home that uses the staffed model would also benefit from some thought on how to ensure that it has a more family style feel. This is hard in a staffed home model but some color, additional items in common areas, bedrooms and child appropriate décor will help to improve the family style feel of the house. This will be appreciated by staff and youth alike.”

“The other item that we discussed was that although there was adequate space in the group homes and day treatment facilities, there were may needed repairs and updates in the form of painting, cabinetry etc… One of the homes we visited had a cupboard hanging off its hinges and severely matted carpets. The furniture in the living room was damaged and scratched and there were holes in the couches… It was unclear as to how maintenance issues were taken care of and new items purchased for the home… It is more likely that the youth will learn to care for property, and family teachers and staff will be more concerned with teaching to these areas and maintaining their homes when they look nice. It also reassures consumers when their youth are being served in environments that are clean and well kept. If there is not formal process for maintaining the homes, you may want to look at a process of upgrading or replacing items on an annual budget if this isn’t already in place. It may be helpful to have consultants or maintenance supervisor walk through the homes monthly to report items that need attention, upgrades or feedback to providers as to the maintenance of the home.”

What does a 2 or 1 look like?

What does a 2 look like?

Agency is minimally compliant with standard 206, where deficits or shortcomings interfere with or prevent the agency from effectively meeting the purpose and function of the indicator—providing a clean, safe, dignifying treatment environment.

Under this indicator, it is not uncommon for agencies to overlook opportunities to make treatment environments more home-like, family-style and dignifying, or for systems and resources to be inadequately apportioned to maintenance of the treatment environment.

A score of 2 might reflect that safety or cleanliness in the treatment environment is compromised too often, or there are systemic issues with systems in place to maintain the treatment environment, and resources are not being adequately apportioned for maintenance.

What does a 1 look like?

Agency is not at all compliant with standard 206, where the agency neglects or fails to provide a clean, safe, or dignifying treatment environment. Failures are readily apparent and widespread, indicating an institutional neglect of client safety, etc. in the treatment environment.

NO RECENT EXAMPLES OF 2 OR 1 RATINGS

Providing a clean, safe and dignifying treatment environment is a key provision of any care-giving agency and the most visible indicator to external stakeholders of humane treatment.

Inadequate cleanliness, safety or dignity of the treatment environment likely indicates larger agency shortcomings such as an improper allocation of age**ncy resources from leadership

Standard Relevant to Indicator A

206 Members ensure the participant’s right to a wholesome, safe, clean, pleasant, and dignifying treatment environment. In this regard, they provide and do not restrict or make contingent regular and adequate sleep; rest; clean bedding; a comfortable bed; access to outdoors; physical exercise; light; warmth; ventilation; personal supplies; space for personal belongings and activities; physical safety; hygiene and sanitation (including access to daily shower or bath, regular laundry, hygienic materials, toilet use, and hot water); well-balanced, nutritional, and appealing diet; and, normal, accepted dress items.

INDICATOR B

The Agency does not tolerate in any way inhumane approaches to treatment (e.g., humiliating, shaming, or frightening clients, or using corporal or aversive stimulation or excessive or arbitrary restrictions with clients)? See Standards 219-222.

What does a 4 look like?

Agency is fully compliant with Standards 219-222. Under this indicator, it is not uncommon for agencies to struggle with reducing agency-wide use of physical restraints. To earn a 4 for this indicator, it must be demonstrated through complete documentation that physical restraints are rarely used and only under emergency conditions.

In addition, only reasonable and limited restrictions on activities are used, (e.g. no restrictions on client rights as further outlined in INDICATOR C) and only when more positive and less intrusive alternatives are exhausted. These restrictions are outlined specifically in informed consent. Consequences are natural and not humiliating, shaming, or frightening. Agency demonstrates absolute non-tolerance of inhumane approaches to treatment via policies, procedures and systems (e.g. clients are told and understand clear policies, procedures and systems to report inhumane treatment as are outlined in INDICATOR D).

Bottom line: clients must be treated with dignity and respect and this apparent and obvious in all ways.

EXAMPLES FROM REVIEWER REPORTS

“From the mission to implementation, it is clear at all levels that providing the best, most naturalized (i.e., least institutional) care possible is paramount.”

“The agency has clear policies, procedures and training that ensure inhumane treatment approaches are not tolerated, and the understanding of, and agreement with those policies and procedures is evident throughout the organization.”

“Through document reviews and on-site observations it was extremely clear that inhumane approaches are unacceptable; the employees demonstrate intolerance to inhumane approaches to treatment consistently at all levels of the organization. In fact, all family teachers with whom we spoke stated repeatedly that treatment of the children in care in a supportive and caring way was a crucial element of practice.”

“Without exception, all of the clients met demonstrate they feel safe and comfortable with [Agency Name]’s staff and the direct care practitioners.” “Every Practitioner reported that they would prefer to never restrain children and support efforts to reduce restraints… Staff consistently reported that restraints are only used when youth are engaged in extreme behaviors that would cause harm to themselves or others.”

“In fact, in one of the homes we visited the RC jokingly said to a child that a child wouldn’t be able to recognize a good grade. While this was shared in humor, the PM gently stated (and wrote) that this could be interpreted poorly and result in humiliation to the child even though this was all communicated in humor. The sensitivity to the client, and the way the feedback was shared underlie the commitment to providing humane treatment to ALL at [Agency Name] (not just clients)!”

“Practitioners encourage clients to exercise freedom of choice and supportive disclosure in a warm and nurturing environment. For example, clients were encouraged to disclose they were bringing contraband into the home but they all did so of their own accord knowing that, while it was wrong, they were not afraid of the consequences. It is remarkable the effort and creativity that is put into providing such an environment for the clients in care.”

What does a 3 look like?

Agency is adequately compliant with Standards 219-222. Under this indicator, it is not uncommon for agencies to struggle with reducing agency-wide use of physical restraints. To earn a 3 for this indicator, the agency might use physical restraints more regularly than an agency earning a 4, but the agency must clearly demonstrate an organizational commitment to reducing the use of restraints through policies, procedures, systems, and programs (e.g. complete documentation and regular review of restraints, supplemental training to reduce restraints, etc.). Reviewers might offer formal supportive suggestions to aid the agency in reducing the use of restraints.

In addition, the organization must more or less meet the requirements of the four relevant standards, as outlined in the second paragraph of “What does a 4 look like?” though there might be a slightly larger degree of room for improvement. Agency must demonstrate non-tolerance to inhumane approaches to treatment via policies, procedures and systems.

Bottom line: clients must be treated with dignity and respect.

EXAMPLES FROM REVIEWER REPORTS

“In fact, it is through the staff and administration’s dedication to providing the most supportive and safe environment possible that they are have pursued a self control initiative with the goal of reducing restraints significantly. The administration’s interest in tracking and then identifying ways in which to reduce restraints demonstrates their recognition and intolerance to any suggestion of inhumane approaches or treatments.

“SUGGESTION: Continued support of reducing restraints and following the staff practices which help in this regard will add to the agency’s implementation of the Teaching-Family Model while continuing to support quality driven data measures.”

“While restrictive interventions regularly occur, [Agency Name] takes steps to ensure safety and dignity of both staff and students. Data pertaining to restrictive interventions is regularly collected and reviewed. Individualized plans are developed for any student that requires several restraints. Data clearly demonstrates that the individualized plans are effective.

“A restraint coordinator position was developed to lead formal debriefs after every restrictive intervention. Video footage is reviewed following each physical restraint. Staff identified in overuse of restraints receives mandated training aimed at decreasing physical interventions. Calm down and seclusion rooms are decorated with pictures to provide stimulation.”

What does a 2 or 1 look like?

NO RECENT EXAMPLES OF 2 OR 1 RATINGS

Adequate implementation of the Teaching-Family Model and its procedures and systems generally precludes inhumane approaches to treatment.

Often, inhumane approaches to treatment arise due to organizational culture—it becomes a learned pattern of staff or direct-care practitioners because nothing else seems to work. You might hear statements from staff defending inhumane treatment approaches like “It’s the only way they’ll understand.”

The Model truly works to improve client behavior—when it is adequately trained and practitioners are supported through the Model’s systems to fully grasp and be able to carry out its treatment procedures, direct care staff can experience a humane approach to treatment working in real time to solve problems they thought couldn’t be solved any other way (other than the way they’ve inhumanely solved it in the past).

In addition, accreditation through the Teaching-Family Association provides agencies with an outside point of view, impetus and resources to improve on areas where they might be inhumane—usually unintentionally. It is rare for Teaching-Family Association accredited agencies to receive a 2 in this indicator.

What does a 2 look like?

Agency is minimally compliant with standards 219-222, where deficits or shortcomings interfere with or prevent the agency from effectively meeting the purpose and function of the indicator—non-tolerance of inhumane approaches to treatment.

Under this indicator, it is not uncommon for agencies to struggle with reducing agency-wide use of physical restraints. A score of 2 might reflect an agency regularly using physical restraints without documenting or demonstrating any systemic attempt to reduce their use.

If physical restraints are not a problem, a score of 2 might reflect clients that are treated in an inhumane manner too often, without adequate systems in place or organizational commitment to reducing the prevalence of inhumane approaches to treatment.

Bottom line: agency demonstrates an organizational culture where clients are too often not treated with an appropriate level of dignity and respect.

What does a 1 look like?

Agency is not at all compliant with standards 219-222, where the agency neglects or fails to be non-tolerant of inhumane approaches to treatment.

Bottom line: agency demonstrates an organizational culture where clients are often not treated with dignity or respect.

Standards Relevant to Indicator B (219-222)

219 Members protect participants from physical or psychological discomfort, harm, or danger. Prohibitions include mental cruelty, emotional cruelty and intentional emotional stress (e. g., humiliating, shaming, frightening), hazardous procedures, and physically intrusive procedures (e.g., corporal punishment, chemotherapy).

220 Members do not employ corporal punishment or other aversive stimulation (whether tactile, auditory, gustatory, olfactory, or visual), but rather employ more humane ways of interacting and fostering goals of education, training, and socialization.

221 Members provide treatment that is the least restrictive necessary and avoid excessive, arbitrary, or otherwise undue restrictions on the activities of participants. Those reasonable and limited restrictions that are employed are described in the informed consent and are used when more positive and less intrusive alternatives are either exhausted or would be clearly ineffective, when the procedures would be in the best interest of the participant, and when the benefits clearly outweigh the harm. (Discussion: The issue of whether or not a treatment environment, such as a group home, represents the least restrictive alternative for a potential participant is an issue that needs to be discussed and weighed by a duly constituted admissions committee.)

222 Members avoid the use of physical restraint except under emergency conditions when there is a clear and imminent threat to the physical safety and well-being of the participant or others or when there is actual extensive property damage. Such restraint is the minimal (least restrictive) necessary, is used only during the acute episode, is not of a mechanical or chemical nature, and is not used for punishment or staff convenience. Any use of restraint will be documented in the participant’s file with specification of date, time, and nature of the inappropriate behavior, surrounding conditions, and length of the restraint episode.

INDICATOR C

The Agency meets all other client rights listed in Part Two of the Teaching-Family Association Standards of Ethical Conduct (e.g., rights to privacy, Standard 216; free exercise of religious, political, cultural, or other philosophical beliefs, Standard 217; medical treatment, Standard 212; communication with others, Standard 215; etc.)?

What does a 4 look like?

Agency is fully compliant with all standards related to client rights in part two of the Standards of Ethical Conduct. Under this indicator, it is not uncommon for agencies to struggle with communicating client rights to the clients and making sure that they understand. It is important that the agency work through any challenges to ensure the client fully comprehends the full scope of their rights.

To earn a 4 for this indicator, it must be demonstrated through documentation and on-site review (with interviews) that clients are not only afforded all rights outlined in the Standards but also are told and understand them such that they could employ them if needed. Often times this means being able to identify the individuals with whom the clients can communicate any issues and/or concerns.

Agency must demonstrate an organization-wide commitment to client rights that is communicated to and understood by all, from leadership to direct-care staff and their clients.

EXAMPLES FROM REVIEWER REPORTS

“Clients are afforded their right to free access of the telephone and mail, and enjoy sending mail with a picture and a note to family members, even if it’s a scribble.”

“Administrative, program, medical and Teaching-Family staff lay eyes on clients several times each week and are vigilant in their assessments of clients and potential safety or rights concerns.”

“Clients indicated they were aware of their rights and could access a copy by asking staff for a copy if they couldn’t find their own copy. Signs were posted in facilities to indicate this as well. Training appears to be very humane and indicate orientation of policies and procedures that ensure staff understand the client’s rights and freedom to access religious, political, cultural, or other beliefs as indicated in TFA Standards of Ethical Conduct.”

“All staff, including volunteers, are trained on client and youth rights in order to help promote dignified treatment of those supported.”

“Everyone is clearly well versed in managing client rights, issues of concern and allegations. In fact, the attitude is to over report and share information so as to be sure that the clients’ needs are met most appropriately, safely and swiftly. The open door policy among the agency leadership supports the communication of all issues of concern enabling anyone to manage those issues accordingly.”

What does a 3 look like?

Agency is adequately compliant with all standards related to client rights in part two of the Standards of Ethical Conduct. Under this indicator, it is not uncommon for agencies to struggle with communicating client rights to the clients and making sure that they understand. There may not be a regular system or process in place to measure whether a client fully understands their rights, however.

To earn a 3 for this indicator, the agency might demonstrate a commitment to all client rights but fail to adequately or completely communicate those rights to clients and/or staff so that they understand. Agency must demonstrate an organization-wide commitment to protecting client rights.

EXAMPLES FROM REVIEWER REPORTS

“Each child receives [an Agency] Handbook which specifically explains the children’s rights as well as other information related to their stay in [Agency Name]. With several children questioned, however, they were unclear on what latitude was possible in these areas.

“It is suggested that further reinforcement be provided to the family teaching professionals so that they can reiterate the rights to their children in care – not only is this humane, but it can be used as a teaching moment and it can provide an opportunity to help build skills (e.g., self determination) for the children in care.”

“There were some times; however, the children were unclear regarding what their rights consisted of relative to treatment. While staff clearly understood process and procedures, this was not always clearly communicated to clients in care. This could be because staff did not always recognize the importance or rationales for clients to embrace these rights with ease. Through clear client recognition of their rights especially with regards to Practitioner treatment and Agency support, the staff will be much better protected from risk and exposure since they are supporting client understanding and recognition which includes the importance of substantiation and what that entails.”

What does a 2 or 1 look like?

NO RECENT EXAMPLES OF 2 OR 1 RATINGS

Organizational commitment to the Standards of Ethical Conduct of the Teaching-Family Association is a key component of Teaching-Family Model implementation. Most agencies can easily demonstrate through documentation and on-site review that the organization is fully committed to protecting client rights at all levels.

It is extremely rare for a Teaching-Family Association accredited or developing agency to receive a 2 or 1 in this indicator, which would indicate that either an organization was not adequately affording and protecting client rights or completely neglecting certain rights they should be affording and protecting.

Incomplete knowledge of client rights can easily be rectified—take a look at one of our members’ client rights handbooks, or discuss the Standards with a member—but an inadequate organizational commitment to protecting client rights at all levels speaks to larger, more fundamental shortcomings.

What does a 2 look like?

Agency is minimally compliant with all standards related to client rights, where deficits or shortcomings interfere with affording, protecting and communicating all client rights throughout the organization.

Under this indicator, it is not uncommon for agencies to struggle with communicating client rights to the clients and making sure that they understand. To earn a 2 for this indicator, however, an organization’s shortcomings extend beyond inadequate client understanding of their own rights.

A score of 2 might reflect incomplete knowledge of clients’ rights afforded by the Standards of Ethical Conduct or inadequate communication and training throughout the organization specifically related to clients rights. Too often, essential rights are not being afforded to clients by the agency.

What does a 1 look like?

Agency is not at all compliant with all standards related to client rights, where the agency neglects or fails to afford, protect or communicate client rights throughout the organization.

Standards Relevant to Indicator C (211-217)

211 Members represent the participant’s best interests and advocate for them in situations involving decision-making processes that directly effect the participant, the removal of the participant from the program, and/or, the temporary exercise of control over the participant by another agency. In such situations, members monitor the procedures, attempt to ensure that the participant and parent or guardian is informed of guaranteed rights (including, where appropriate, right to counsel and/or an advocate), attempt to encourage the least restrictive alternative course of action, and attempt to secure for the participant and his or her representative the opportunity to be fully heard.

212 Members seek for their participants any necessary medical or dental treatment and take steps to ensure that such treatment is immediate and of high quality (Discussion: When a reasonable question arises as to whether or not a given behavior or condition is a result of a physical problem, members should obtain certification from a physician before extended attempts to treat the problem as non-physical.)

213 Members provide reasonable and regular opportunities for participants to engage in the following activities and ensure that such opportunities are free from restraint, interference, coercion, discrimination, reprisal, or undue influence: 1) participation in decisions that affect disciplinary processes, daily life patterns, and participant’s lives, including decisions concerning regulations and policies; 2) explanations of their own actions; 3) expressions of dissatisfaction and grievances; and, 4) recommendations for changes.

214 Members seek to provide a supportive setting in which participants can learn to accept responsibility for their own actions and, where appropriate, those of other participants. This includes the opportunity for participants to participate (under conditions in which they have volunteered, are specifically trained and adequately and closely supervised, have demonstrated humane judgement, and in which their judgements and actions are subject to careful ongoing review and approval) in the determination of fair, reasonable, and justified consequences for fellow participants; the reporting of serious rule violations of other participants, and, the supervision of routine activities of other participants.

215 Members ensure that participants have reasonable, regular opportunities for communication with others (e.g., parents, same and opposite sex peers, counsel, public officials, and agency personnel) through visits, telephone, mail, and other means of contact. Furthermore, members ensure that participants have reasonable and regular opportunities for access to mass communication and information (e.g, radio, television, and reading material). (Discussion: For example, members cannot fail to deliver mail or phone calls, nor can they make all television viewing contingent upon behavior. Here, reasonable access to television news and educational programs should be routinely available.)

216 . While members are aware of the need to provide adequate supervision, they respect participants’ right to privacy and do not, without due cause, seek access to personal information concerning participants or conduct searches of their person, belongings, or room. Members do not read participants’ mail and do not, without informed consent, permit public display of the participants’ pictures or names either in association with the program or in any manner with some likelihood of adverse effects.

217 Members protect the participants’ right to the free exercise of religious, political, cultural or other philosophical beliefs, including attendance at services, and do not impose religious or political attitudes or prayers. (Discussion: If specific religious behaviors are required by the board or funding support of a program, such a situation needs to be clearly specified in the informed consent.)

INDICATOR D

The Agency has clear policies, procedures, and systems to address alleged or substantiated abuse/neglect, restrictive interventions, and unethical actions by service providers/practitioners, and staff is trained and has an understanding of client rights and procedures regarding unethical practices, including abuse and neglect?

What does a 4 look like?

Agency is fully compliant with the indicator. This indicator is closely related to indicator C, as it requires an agency to provide adequate training systems so that infringement on client rights can be reported by staff or clients, and requires agency staff to be adequately informed of all client rights.

Under this indicator, it is not uncommon for agencies to struggle with communicating policies and procedures surrounding reporting unethical procedures to clients adequately so that they understand and can use them to report abuse if necessary, or for training of client rights to be inadequately documented or integrated into training.

To earn a 4 for this indicator, it must be demonstrated through documentation and on-site review (with interviews) that staff fully understand all client rights and both clients and staff understand and can use procedures to report abuse or rights infringements within the agency. Clients can often identify the hierarchy for reporting concerns and/or issues in addition to identifying the individual at the agency responsible for client right reporting.

EXAMPLES FROM REVIEWER REPORTS

“The agency’s policies, procedures and systems are clear regarding client rights and addressing substantiated abuse/neglect, restrictive interventions and unethical actions. Children interviewed remembered receiving a client rights handbook, and in [one home] one youth pointed to the consultant’s office when asked who he can talk to if he has any problems with how things are going. He stated, ‘We can go talk to Dave.'”

“The agency’s client grievance and staff practice interview policies, procedures and systems are very clear regarding addressing alleged or substantiated abuse/neglect, restrictive interventions and unethical actions. Most children interviewed indicated if they didn’t like something or felt threatened they would approach a family teacher and or consultant to express their dislikes or fears.”

“Staff practices we largely consistent across homes, youth have access to ‘outpatient rights and responsibilities’ and ‘grievance boxes’ across the settings visited. The organization also has a rights officer who will respond to urgent concerns.”

What does a 3 look like?

Agency is adequately compliant with the indicator. This indicator is closely related to indicator C, as it requires an agency to provide adequate training systems so that infringement on client rights can be reported by staff or clients, and requires agency staff to be adequately informed of all client rights.

Under this indicator, it is not uncommon for agencies to struggle with communicating policies and procedures surrounding reporting unethical procedures to clients adequately so that they understand and can use them to report abuse if necessary, or for training of client rights to be inadequately documented or integrated into training.

To earn a 3 under this indicator, an agency might have adequate policies and procedures in place but fail to adequately or completely communicate those procedures to clients so that they understand, or rather, training of client rights might not be adequately documented or demonstrated through staff interviews.

Bottom line: there must be adequate assurances and safeguards in place to protect clients from practices that may be unethical or suspect in any way.

EXAMPLES FROM REVIEWER REPORTS

“The Teaching-Parents seem to have a good knowledge of client rights and adhere the direction given in the policy and procedure manual. One suggestion would be to document that this is reviewed in the pre-service workshop with all new staff… The evaluations of direct care staff contain staff practices questions that address areas of abuse in a pro-active way. This question is asked at the time of all in-home evaluations. A suggestion would be to ask this question even more often especially when there is turnover with direct care staff.”

“While the agency has very clear policies and procedures to address any alleged incident or any practice that is not obviously one that is strength-based and supportive, not all staff have an equally clear understanding of these policies and procedures. SUGGESTION: It may be worthwhile to reinforce the agency’s requirements and directives in these safety matters through a regular reminder/update quarterly in one of the many treatment, team or leadership meetings to ensure that practitioners are all clear on the process. This is especially important for alternates and those positions where turnover may be higher (and more recognized and accepted).”

What does a 2 or 1 look like?

NO RECENT EXAMPLES OF 2 OR 1 RATINGS

Organizational commitment to the Standards of Ethical Conduct of the Teaching-Family Association is a key component of Teaching-Family Model implementation. Most agencies can easily demonstrate through documentation and on-site review that appropriate reporting policies and procedures are in place and that clients and staff are at least adequately aware of them.

It is very rare for a Teaching-Family Association accredited or developing agency to receive a 2 or 1 in this indicator, which would indicate that an organization’s training with regards to client rights or the organization’s policies and procedures for clients and staff to reporting abuse, neglect, or rights infringements were vague and inadequate or non-existent.

What does a 2 look like?

Agency is minimally compliant with the indicator, where deficits or shortcomings interfere with training client rights to staff or providing clear policies and procedures for the reporting of abuse, neglect or rights infringements.

Under this indicator, it is not uncommon for agencies to struggle with communicating policies and procedures surrounding reporting unethical procedures to clients adequately so that they understand and can use them to report abuse if necessary, or for training of client rights to be inadequately documented or integrated into training.

A score of 2, however, reflects deeper shortcomings where the policies and procedures themselves might exist but are inadequate, or both staff and clients are largely unaware of them, and staff training in client rights is inadequate.

Bottom line: a crucial organizational safeguard for client safety and rights is inadequate.

What does a 1 look like?

Agency is not at all compliant with the indicator. Policies and procedures for reporting abuse, neglect or rights infringements might not exist, or training and communication is so inadequate that they might as well not exist.