Frequently Asked Questions

Home and Community Based Waiver (HCBS) providers as well as Managed Care Organizations (MCOs) requested that DIDD and TennCare together with stakeholders review the current critical incident management systems for the 1915 (c), Employment and Community First Choices Program and the CHOICES Programs taking the best each system had to offer and aligning them into one unified system across all waiver programs. The main motivation for this request was to alleviate the administrative burden to providers of having to work within three different systems all with their own unique reporting and investigative requirements. The critical event management group and specialized sub-groups consisting of members of DIDD, TennCare, the MCOs and providers met over a two-year period to design the one aligned system.

The main benefit of a single system is to alleviate the administrative burden of agencies having to operate in different systems with different requirements for event reporting and investigations. A single system with one set of reporting requirements encompassing what is reportable, to what entity to report and one Reportable Event form across all systems will help to ensure that consistency and enhance the ability to track and trend events across the state to help prevent future events from occurring.

All HCBS Waiver programs will be required to use the Reportable Event Management System this includes all 1915(c) waiver programs, The Employment and Community Choices program, The CHOICES program, the Katie Beckett Waiver program and both public and private Intermediate Care Facilities for Persons with Intellectual Disabilities (ICF/IID).

Information on REM on the new aligned system can be found here on this site.

Also, any questions that providers or stakeholders may have regarding the new system can be emailed to the REM dedicated mailbox at DIDD.REMHelp@tn.gov

The REM system is required for all providers who participate in 1915(c) waiver programs, The Employment and Community Choices program, The CHOICES program, the Katie Beckett Waiver program and both public and private Intermediate Care Facilities for Persons with Intellectual Disabilities (ICF/IID).

Reporting will follow the Operational Protocol reporting requirements:

• For Tier 1 – verbal notification to the Abuse Hotline within 4 hours, APS/CPS/Law Enforcement as warranted, and submit the written REF by the next business day.
• For Tier 2 and Additional Reportable Events and/or Interventions, -submit the written REF submitted the next business day to both DIDD and MCO

The role of the MCO Care Coordinator and Support Coordinator will be similar to the current CHOICES Critical Incident and ECF CHOICES Reportable Event Processes.

• Participate in Reportable Event Management training (internal per MCO) for a working understanding of the Operational Protocol and Definitions
• Participate in Reportable Event Form Training (to be located on DIDD REM site)
• Understanding of the Provider Investigator role, Provider Reportable Event Review Team, and Due Process
• Contact Abuse Hotline and/or complete and submit Reportable Event Form as needed per reporting  requirements to DIDD and/or MCO per protocol
• Work with DIDD and Provider Investigators on required documentation, ie. PCSP, BSP
• Provide support for person-supported as needed related to the Reportable Event according to their job description and MCO policies/procedures
• One change of note – All investigations, Tier 1 and Tier 2 will be conducted by DIDD or Provider Investigator.  

MCOs aren’t currently required to have a Certified Provider Investigator, however we have identified those associates who will participate in either the pilot or final  PI training as we want to fully understand the process we’re asking of our providers. We do have assigned Reportable Event Managers who will have an active part with the review, tracking, trending, correspondence, and training of this process.

In ECF, providers have been completing investigations for Tier 2 events since ECF began. We’ve viewed this process as a way for providers the have the autonomy to effectively/appropriately  identify and address areas of remediation to ensure quality supports are provided for those supported. Tier 2 Reportable events require a Certified Provider Investigator to complete the investigation aside from the few previously noted exceptions DIDD will investigate in place of the provider. This process will continue with the alignment in all programs to for Tier 2 events.

Each Provider Executive Staff will determine who will fulfill the responsibilities of the Event management Coordinator and the Provider Investigator.  This can be the same person but is not an expectation. 

The role and responsibility of the Event management Coordinator and the Provider Investigator is included in the Reportable Event management protocol in the Resources Section of this webpage.  Additionally, the Event Management Coordinators will have a specialized training in Relias.   The Provider Investigator’s responsibilities will be detailed in the Provider Investigator training through the QuILTSS Institute. 

Yes. There will be a new Reportable Event Form for the aligned system.

The REF was released approximately 2 weeks before the Go live Alignment Date. Communication was released to let everyone know that it is available. After its initial release, the current REF  available at all times by clicking here. 

Tier 1 Reportable Events: are the more egregious allegations. This includes alleged wrongful conduct by a service provider that resulted in harm to the person supported and required medical treatment or intervention (intervention definition as outlined in the REM definitions), all sexual abuse allegations, exploitation exceeding $1,000, and unexpected or unexplained deaths,

Tier 2 Reportable Events: are less egregious allegations. This includes alleged wrongful conduct by a service provider that did not result in harm to the person or a minor injury to the person supported, the person is not at continued risk of harm, exploitation valued at $250 to $1,000, or exploitation of the person. Tier 2 allegations are those events that do not require medical treatment or intervention other than that of a lay person.

For detailed list of Reportable Events and examples please see the REM Protocol. 

DIDD will conduct Tier 2 investigations for exempt providers. Providers who are exempt are persons supported that are the employers through self -direction or consumer direction and do not utilize a provider agency to provide services or Fiscal Employment Agent (FEA) and ancillary providers such as Home Improvement/Home Modification contractors, Pharmacy, Pest Control,

Behavioral Service, Nutritionist, Physical Therapist, Assistive Technology Providers or single person employers. Please review the REM Protocol for additional information on the process for Provider Request for Exception to Investigate and Parameters for determining when a provider is not permitted to conduct provider investigations.

All providers, excluding those providers listed above as being exempt, must have a Provider Investigator who has either completed the competency based QuILTSS Institute Provider Investigator Training or has achieved certification through the current LRA (Labor Relations Associates) training. Providers will be expected to interview both the alleged victim and the alleged staff, collect documentary or physical evidence, list the evidence they collected in a report form and draw a conclusion based on their evidence. The report and supporting evidence will be sent to DIDD Investigations Specialist.

The Provider Investigator may conduct visual virtual interviews with the persons supported and the alleged staff. However, the witness must be afforded an in-person interview, if requested. Visual virtual interviews must permit the witness the privacy necessary for being interviewed, must include visual monitoring for the witness and investigator, and conducted via a secure platform, (example: Microsoft teams). The Provider Investigator should ensure that the alleged staff is not on duty at the time of the interview with the person supported as this could compromise the interview and comfort level of the person supported being interviewed.

A standard investigation template has been created and is available on the DIDD REM Webpage at this link.

The Initial Notifications will continue to be sent to the Provider involved in the allegation and the Support Coordinator/Case Manager Provider for Tier 1 and Tier 2 investigations. 

The Investigative Summaries are still a part of the Tier 1 investigations and the Tier 2 investigations assigned to a DIDD Investigator and will be sent to the Support Coordinator/Case Manager Provider. However, Investigative Summaries will not be a part of the Tier 2 investigations assigned to Provider Investigators.

The provider will complete the Action Plan for all substantiated Class 1 and Class 2 investigations. The Action Plan shall address each Informational Findings and late reporting discovered as a means of provider self-improvement.

Upon acceptance of the final investigative report, the provider will have an additional ten (10) days to complete the Action Plan, which will be tracked by the date in which the Final Investigative Report was closed. The provider will continue to discuss the outcome of the investigation with the person(s) supported and invite the person’s legal representative and/or primary contact, if any, to participate in this discussion.

The Action Plan shall include the following information:

• The procedures that have been implemented to mitigate future risks to the person, including steps to prevent similar occurrences in the future;
• Verification that the substantiated perpetrator(s) was notified of the outcome of the investigation;
• A statement of what, if any, disciplinary action, training, reassignment, or any other remediation occurred as a result of the findings of the investigation;
• A response to any informational findings contained in the investigation report.

The DIDD Regional Event Management Coordinator (EMC) and respective MCO(s) will review the Action Plan, which shall include any concerns or issues identified. DIDD Regional EMC will include the respective MCO when asking for any additional information within 10 calendar days if the Action Plan submitted does not sufficiently address the identified concerns. The provider has ten (10) calendar days to provide the additional information. The DIDD Regional EMC or designee has forty-five (45) calendar days from the date of closure (release of the Final Investigative Report) to provide a Closure Letter.

If allegations were not substantiated, an Action Plan is not required. For both substantiated and unsubstantiated investigations, providers must ensure that informational findings are acted upon in a timely manner. DIDD or the MCO can request follow-up action to unsubstantiated Informational Findings, to include Late Reporting.

The provider is not restricted to regional boundaries. For example, a provider investigator in the Middle region may also investigate Tier 2 events in East and West.

Yes, all agencies must update their policies and procedures to align with the new REM system prior to the implementation date.

The REM Group comprised of DIDD, TennCare, and the Managed Care Organizations are pleased to announce a new training platform for Provider Investigators. We have contracted with Labor Relations Alternatives (LRA) to be the official training partner for both Provider and State Investigators. LRA is a national leader in providing training and consultation in the development of incident management systems and conducting investigations for human service agencies and oversight entities. LRA has developed a virtual training platform that will allow for their nationally recognized in-person training to be done in an online forum. The three-day training will be taught by LRA certified DIDD Investigators and will come at no cost to providers. On the fourth day, Provider and State Investigators will be required to take the LRA online exam and a subsequent REM Tier 2 Training (formerly the DIDD One-Day Training), which will also be virtual. After successfully passing the LRA exam and completion of the REM Tier 2 Training, the Provider Investigator will have successfully completed the certification process.

Beginning in January, 2023 we will resume taking registration requests for the LRA training, utilizing the same process as the previous QuiLTSS Institute training. This link will take the provider to the registration page. DIDD will monitor the registrations and ensure all required backgrounds checks have been completed.If you were previously certified through QuiLTSS Institute or have submitted your LRA certification by the deadline previously announced during the initial rollout of the QuiLTSS Institute training, you will not need to attend the LRA training to become a Certified Provider Investigator. Please send any questions you might have to DD.PITraining@tn.gov.    

Registration can be completed at Provider Investigator Registration Form - Formstack

Prior to approval, DIDD will conduct background checks to ensure the applicant is in good standing. The following background checks will be conducted:

State Abuse Registry: https://apps.health.tn.gov/abuseRegistry/default.aspx

Sate Sexual Offender Registries: https://sor.tbi.tn.gov/SOMainpg.aspx

National Sexual Offender Registries: https://www.nsopw.gov

State Felony Offender (FOIL): https://foil.app.tn.gov/foil/

Services Office of Inspector General's List of Excluded Individuals/Entities (OIG/LEIE): https://exclusions.oig.hhs.gov

Systems for Award Management (SAM), https://www.sam.gov/SAM

Substantiated Investigations Records Inquiry (SIRI)

Anyone that the provider chooses may be the Provider Investigator if the background checks have no findings. It is anticipated that the PI will serve in more than one role within a provider and not be solely assigned to conduct Tier 2 Investigations.

There is no cost to the provider. 

LRA Training sessions began on 1/9/23. You can register at Provider Investigator Registration Form - Formstack.   You will receive a confirmation email from DIDD after your registration form has been processed

Yes, the intent of the One Aligned system was to meet the needs for all programs within the intellectual and developmental disabilities community.

The Provider Investigator training is one time. Should there be revisions based on CMS, IOG, TCA, TennCare or other regulatory body, DIDD will provide this training or in-service as needed and in a format necessary to complete the training effective, timely , and at the least expense. While there is no anticipated annual in-service, it is not unreasonable to believe that additional training or instructions would be needed at a future date.

Providers such as Independent Support Coordinators, Behavioral Services, Nutrition, Physical Therapy, Home Improvement or Modification type providers that are engaging with person supported but not the primary provider will be excluded. Investigations related to witnesses or alleged staff are involving multiple providers. Also, Self-Determination and Fiscal Employment Agents waivers are excluded as the person supported is the employer and alleged victim.

Neither State nor Private ICF/IIDs are Exempt or excluded, they are required to have a Provider investigator. State and Private ICF/IID providers are required to complete the investigations within 5 business days due to federal requirements instated by the Center for Medicaid Services. All other providers will have 25 calendar days to complete an investigation.

In developing the Alignment with Providers, MCOs, TennCare; we recognized that there are several providers that have nominal reportable events that warrant a Tier 2 Investigation. For that reason, it was agreed upon that provider could have a Business Associate Agreement and utilize a provider Investigator from another provider agency. In doing so, this would be an option for addressing cost.

Only persons employed by a contracted provider may conduct Tier 2 investigations. Once you have identified the provider with whom you wish to contract the use of their certified Provider Investigator, this will require the same process as any other Business Associate Agreement (BAA). The agreement must address Health Information Portability and Accountability Act (HIPAA) and Title 33. All BAAs shall be submitted to DIDD.REMHelp@tn.gov. The BAA must include the identified Provider Investigator(s) selected. Presently, there is not a list of staff that are eligible to be Provider Investigators. We are still receiving information and supporting documentation from Providers for staff that have completed the Labor Relations Alternative course. Once a provider has been identified as eligible to conduct Tier 2 investigations and has a certified Provider Investigator, the Provider will be posted on the DIDD REM website. This list will be updated regularly as to a Provider’s status. At this time, no Providers have been identified as this is the initial phase of the Provider Investigator roll out.

I know previously with Critical Incidents reporting, we just completed the form and sent it in to the Critical Incident team. We conducted our investigation and then submitted the follow up report to the CI team.

Yes, you will need to have Certified Provider Investigator trained to conduct these investigations in the future as part of the Alignment process or have a business associate agreement with another provider who has a Certified Provider Investigator to conduct these investigation for your agency.

Event Management Alignment for Executive and Management Staff is 1.5-3 hours.  Event Management for Direct Care Professionals is 1.5 hours

There are 2 trainings in Relias at this time:

Event Management Alignment for Executive and Management Staff: This training is for Executive and Management staff responsible for oversight of the Reportable Event Management system.  For most agencies this will include the Executive Director and Event Management Coordinator.  The training is in the DIDD Relias platform for all service providers including Employment Community First Choices program, The Choices Program, 1915c Waiver programs, The Katie Beckett Waiver, and Intermediate Care Facilities Intermediate Care Facilities for Individuals with Intellectual Disabilities providers (ICF).  This training is a review of the Reportable Event Management protocol and details the responsibilities and role of the executive staff and Reportable Event Coordinator for every Waiver or ICF provider.

Yes. This training covers all MCOs, DIDD, and ICF/IID requirements for the Reportable Event Management System.

Yes, if you are responsible for the Executive Director, Management Oversight, Event Management Coordinator, or responsible for completing Reportable Event Forms.  There is a Reportable Event Form Training Spreadsheet for Relias Enrollment form on the webpage.  This form should be submitted to DIDD.REMHelp@tn.gov

This is information is available here.

No, they will be able to view the Event Management for Direct Care Professionals video at tn.gov/didd/rem once available. 

Additionally, there will be Train the Trainer course for those providers that cannot utilize the Relias system for Reportable Event Form Training.  This training has not been developed yet.  

This is a one-time training.  However, the user will be able to return to Relias to review the material as needed.  This is an important feature for those smaller providers or providers that have few reportable events as there may be substantial time between reporting events.    

There is no cost to the provider to utilize the DIDD Relias training system.  

DIDD has requested the identities for 2 staff, preferably the Executive Director or designee and Event Management Coordinator or previously known as the Incident Management Coordinator.   The identified parties will be the providers points of contact for Reportable Event Management.  This information will also be utilized to provide access to a statewide data management system once created.  At this time, DIDD does not have a management system that providers can enter Reportable Event Forms directly into and real time.  The Department is actively pursuing the development of a system, but at this time no details are available to share.  

REFs or data entry into a data system will not be expected until a “go live” date has been set and a data system is in place and training completed. 

Training on the Reportable Event Form and what is required to be reported will be held in Relias.

In this specific situation, if a person supported went to the Urgent Care, it would be reportable as a Reportable Medical Event, as well as a Reportable Intervention. Part of the definition of a Reportable Medical Event shall mean an event that occurs during the delivery of services or discovered during the delivery of services, outside of a diagnosed chronic condition, which requires assessment and treatment in an emergency room or urgent care facility.

If the PCP refers the person supported to Urgent Care, in lieu of an emergency room, then the event should be treated the same as if it were an ER visit, meaning we would consider it non-reportable if situation was for assessment instead of treatment, or if it was routine care that the PCP could not provide.  For example, reinserting a catheter, peg tube displacement, reinsert a colostomy bag etc. that could have been done at the PCPs office as routine care.  ER/Urgent Care would be synonymous based on the manner they are used.

In this specific situation, if a person supported went to the Urgent Care, it would be reportable as a Reportable Medical Event, as well as a Reportable Intervention. Part of the definition of a Reportable Medical Event shall mean an event that occurs during the delivery of services or discovered during the delivery of services, outside of a diagnosed chronic condition, which requires assessment and treatment in an emergency room or urgent care facility.

New hires will need to complete the REM training within the first 30 days of employment or before working alone with a person supported.