Monday, January 26, 2015

Confidentiality: Pitfalls and Best Practices

Confidentiality is of paramount concern when dealing with Resident information. In the daily hustle and bustle of the office, it's easy to overlook some of the risks that present themselves. We must, however, always make an effort to keep confidentiality in mind.

What is considered to be confidential?  
Confidential information includes dates of birth, social security numbers, bank account information, medical providers, pharmacy contacts (and in some cases, the names of medications), and other personal information. There are federal and state laws which require careful handling of this information.

Physical Safeguards:
Whenever you leave the office, ensure that the office door is closed and locked. When you leave for the day, ensure that all resident files and other confidential information is secured in a locked cabinet, and the office doors are closed and locked. Compartmentalize information. Resident financial information should not be kept in the same file cabinet with maintenance records needed by the Superintendent. Ensure that file cabinets are accessible only to those people who need that information. Secure the keys so that unauthorized persons do not have access.

Other Safeguards:
Under no circumstances should one Resident's personal information be discussed with another Resident. This includes information about Residents who are in a health care facility. Do not share information about a Resident without their express written permission. Do not post information on a common board that indicates that a Resident may be away from the facility.  If you are asked to share information by a Resident or their designee, use care when deciding what to share and what not to.

Always ensure that you have proper authorization before sharing information about a Resident with another person. This includes Resident Service Coordinators, Police and other EMS personnel, healthcare providers, and others - including, sometimes, the Resident's family members.

Remember that sharing financial information with the RSC requires the Resident's authorization. You are NOT permitted to share EIV information with anyone other than the Resident. If you provide the Resident with a copy of their EIV print-out, mark it "copy," and document in the tenant file that you have provided a copy to the Resident.

What if There's a Breach?
Report any breach of confidentiality to your Regional Manager immediately so that he/she may begin to work with you to address it.

Wednesday, January 14, 2015

Reasonable Accommodation Pitfalls and Best Practices

Few aspects of property management generate more angst, irritation, agitation, and worry than Reasonable Accommodations / Modifications. In order to help in starting the New Year off right, I thought I'd take some time to touch on some of the important elements of this challenging aspect of our job:

1. ALL REASONABLE ACCOMMODATIONS are to come to me - including the ones
    you believe are "obvious and known." I will work with you to assess what needs to be
    verified and what doesn't.  This is in order to keep our approach consistent.

2. I cannot make a determination of whether we can approve without all the needed
    information. This means that if a doctor / verifier does not fill out form completely,
    I am going to send it back to you in order to clarify. In order to avoid delays,
    follow up with the verifier to ensure the form is completed before you send it to me.

3. A verifier need not be a physician.  They need only be qualified to make the
    determination.  If you are unsure as to whether someone can serve as a verifier,
    please check with me.

4. A doctor's note is acceptable ONLY if it verifies that the resident a) qualifies as
    disabled and b) needs what they're asking for. "Mary tells me she needs..." 
    "...would benefit  from..." or "Please consider..." is likely to be insufficient.
    If you receive a letter like this, it's a good idea to have the resident sign a
    verification form so that we can easily get more info if needed. Send the letter to me,
    and if we need more info, I'll let you know.

5. "It's too expensive" is not necessarily a reason to refuse. HUD / USDA may have
     a very different definition of that than you do. If you believe a request constitutes a
    burden, let me know and I'll talk with you to see what we deem reasonable.

6. Let me know any pertinent facts when you email me. For instance:

    Resident makes a request for carpeting to be removed and replaced with tile due to 
    allergies and chemical sensitivity. She insists that only ceramic tile will suffice. 
    Her physician confirms the need for replacement of the carpeting; but does not 
    mention anything about the tile. The Administrator is aware that apartment is not 
    compliant with housekeeping standards, and there is lots of dust, etc. in the
    apartment. The Resident also has a cat. 

    When you email me the forms, you should include some information for me, such as:

    Pam, Attached is a RA request for Mrs. Smith. Her request only mentions removing 
    carpeting but she has said that she needs ceramic tile. Apartment failed last 
    housekeeping inspection due to a large amount of dust. This resident also has a cat. 
    Could you please call me to discuss? 

    If you believe the information is best discussed with me on the phone, you can simply
    write something like this:

    Pam, Attached is a RA request for Mrs. Smith. I would like to provide 
    some additional information before you make your determination. Could you 
    please give me a call?

7. RSCs can verify the existence of a disability and the need for an accommodation in
    most cases.  There are some cases where they have been instructed not to verify.
    That determination is made by Lee. If you disagree with your RSC's conclusion,
    let me know so that Lee and I can help reconcile the information and help determine
    the best course of information.

8. When working with disabled residents to accommodate their needs, we should always
    be looking for how we can be helpful, not how we can avoid making changes. That
    being said, we are looking to do what is REASONABLE, and what is NEEDED,
    not necessarily what meets the resident's personal preference. We can say no, but
    we can only do so under specific guidelines. Always speak with your RM or me if
    you are unsure of anything.

9. Be aware that a casual comment can be construed as a request. The resident need
    not say "I am disabled," or "I need a reasonable accommodation" or put their
    request in writing when they bring it to your attention. It is up to you to be alert for
    any indication that a resident has asked for an accommodation.
 
    Examples of "requests" that may be harder to discern are:

    "The knobs on this stove are so hard to turn! With my arthritis I can hardly 
    work them." 

    "Whew, I had to park really far away today - I can hardly breathe, and I had 
    to stop three times on the way to the entrance!" 

    When you hear a comment like this, it's appropriate to take the resident aside and
    advise that if they believe that they need a change to something because of a medical
    or disability-related need, we have a process that allows that to be done. You can
    assist them with filling out the request, or advise them that you will have the RSC
    follow up with them to see how we may be able to help.

Reasonable Accommodations are not always easy to navigate through.  If you have any
questions, or need assistance, please feel free to ask!