1. Fiscal Accountability

Wisdom Care LLC is committed to strong fiscal accountability and ethical management of resources. At this time, a detailed business plan will be attached to this manual once completed. As a new business, financial operations are managed with oversight from an external accountant, who also participates on the advisory board (when formed) to ensure transparent financial practices.

Accounting and Audit Plans

All accounting and financial reporting will be handled by a qualified, independent accountant, who is responsible for maintaining accurate records and preparing any required reports for regulatory agencies or funding sources.

While Wisdom Care LLC is not currently subject to a formal independent audit, the organization intends to adopt annual independent reviews as the agency grows and as required by law or contractual obligations.

Rate Setting

Service rates for Residential Based Supported Community Living (RBSCL), Supported Community Living (SCL under ID Waiver), and Agency Consumer-Directed Attendant Care (CDAC) are set by the State of Iowa and the Managed Care Organizations (MCOs), including Iowa Total Care, Amerigroup Iowa, and Molina of Iowa.

  • Wisdom Care LLC accepts the approved, published rates determined by these payors for all covered services.
  • No rates are set independently by Wisdom Care LLC; adjustments or billing changes are implemented only upon official notification from the State of Iowa or an MCO.
  • Clients and families are informed of the current rates applicable to their services, and all billing practices are transparent and compliant with Medicaid/MCO requirements.

Maintenance of Records

All fiscal, clinical, and personnel records are maintained in compliance with the Iowa Administrative Code, Medicaid, and applicable federal regulations.

Financial Records

All financial documents, including invoices, payment records, payroll, bank statements, receipts, and contracts, are retained for a minimum of seven (7) years, or longer as required by law or contract.

Clinical Records

Service and clinical records for each member are maintained in a secure, confidential manner for at least five (5) years after service termination. Records include service plans, progress notes, incident reports, and correspondence.

Personnel Records

Employment applications, background checks, training logs, and performance evaluations are kept for at least seven (7) years after separation.

Record Storage

All physical records are stored in locked file cabinets or secure office locations with limited access. Electronic records are protected with secure passwords, encryption, and regular data backups.

Record Destruction

At the end of the required retention period, all records are destroyed by secure shredding or, for electronic data, permanent deletion using approved methods. A log of destroyed records is maintained.

Confidentiality

Access to records is restricted to authorized personnel only. Sharing of information occurs only with proper consent or as required by law.

2. Admission & Discharge Policy

Ensure all admissions and discharges are handled professionally, ethically, and in accordance with state/federal law.

Policy

  • Individuals are admitted based on eligibility, referral, and needs assessment.
  • Discharge may occur voluntarily, by mutual agreement, due to health/safety concerns, or by determination of ineligibility.

Procedures

  1. All referrals are reviewed by the Program Manager.
  2. Intake includes assessment of individual needs, preferences, and eligibility criteria.
  3. Written documentation provided to the member/guardian regarding services, rights, responsibilities, and the complaint process.
  4. Discharge is planned with the member, family, and case manager to ensure transition of care.
  5. All admission/discharge decisions are documented in the member’s file.

3. Member Rights & Responsibilities

Wisdom Care LLC is committed to protecting the legal and human rights of all members. Members and their guardians are informed of their rights and responsibilities at admission and annually thereafter.

Member Rights

  • Dignity, respect, and privacy
  • Choice of services and participation in planning
  • Freedom from abuse, neglect, and exploitation
  • Confidentiality of personal information
  • Access to records and information
  • Right to file grievances or complaints without fear of retaliation
  • Right to refuse services or specific interventions

Member Responsibilities

  • Provide accurate information during assessment and care planning
  • Notify staff of changes in health, contact info, or service needs
  • Participate actively in service planning and implementation
  • Treat staff and others with respect

Procedures

  1. All staff are trained to uphold and promote member rights.
  2. Written rights and responsibilities are provided to each member and explained upon admission.

4. Abuse, Neglect, and Incident Reporting

To ensure prompt, thorough reporting and response to suspected abuse, neglect, exploitation, or critical incidents.

Policy

  • All staff, contractors, and volunteers are mandatory reporters under Iowa law.
  • All incidents of suspected abuse or neglect are reported immediately to the Iowa Department of Human Services (DHS) and, as appropriate, law enforcement.
  • Critical and major incidents are documented and reviewed for trends and quality improvement.

Procedures

  1. Staff receive training on identifying, reporting, and documenting abuse/neglect within 30 days of hire, and at least every three years.
  2. Reports of suspected abuse/neglect are made verbally to DHS within 24 hours, followed by written documentation using state forms.
  3. Major incidents (e.g., injury requiring medical attention, death, missing persons, medication error, law enforcement involvement) are reported per state guidelines and internal protocols.
  4. All incident reports are reviewed by the Program Manager and Advisory Board for follow-up, remediation, and quality monitoring.
  5. Members are protected from retaliation for reporting.

5. Confidentiality & Privacy/HIPAA

To safeguard all personal and health information in accordance with state and federal law (including HIPAA).

Policy

  • All member information is confidential and is only disclosed to authorized persons with consent or as required by law.
  • All records are kept secure, with access limited to authorized personnel.

Procedures

  1. Members/guardians sign a Release of Information form at intake, annually, and as needed.
  2. Paper records are stored in locked files; electronic records are password protected.
  3. Staff are trained in confidentiality policies and must sign confidentiality agreements at hire and annually.
  4. Breach of confidentiality is grounds for corrective action, up to and including termination.
  5. In case of a breach, appropriate notifications and corrective actions are taken per HIPAA and state requirements.

6. Personnel Policies (Hiring, Screening, Training)

All personnel must meet the qualifications for their position, undergo screening and background checks, and complete required orientation and ongoing training.

Procedures

  1. All staff positions have written job descriptions outlining qualifications, duties, and reporting lines.
  2. Pre-employment checks include criminal background, child and dependent adult abuse registries, and OIG exclusion checks.
  3. Orientation is completed before beginning unsupervised work; it includes mission, values, safety, abuse reporting, rights, and confidentiality.
  4. Annual performance evaluations are documented and maintained in personnel files.
  5. Personnel records include application, background check results, training logs, evaluations, and any incident/disciplinary action records.

7. Staff Training & Development

Staff must complete required training before providing direct services and maintain ongoing competency in all required areas.

Required Initial and Ongoing Training

  • Philosophy of HCBS, member rights, dignity, and person-centered planning
  • Abuse and incident reporting (mandatory reporter)
  • Confidentiality and HIPAA
  • Medication policy and safe administration (if applicable)
  • Service documentation
  • Emergency and safety procedures
  • Individual member support needs (prior to assignment, as updated)
  • Restrictive interventions/behavioral supports (if applicable)
  • Specific waiver/service-related training (e.g., BI modules, if applicable)
  • Annual refreshers as required by law and best practices

Documentation – Training logs are kept for all staff – Staff are not assigned unsupervised duties until all required training is complete

8. Service Coordination & Documentation

Wisdom Care LLC ensures that all services are coordinated effectively with case managers, family, and other providers and that service documentation is accurate and timely.

Procedures

  1. Each member has an individualized support/service plan developed in collaboration with the interdisciplinary team (IDT), reviewed annually or as needs change.
  2. All service activities and contacts are documented according to state rules and best practices.
  3. Documentation is reviewed regularly for quality and compliance.

9. Medication Management

If applicable, staff responsible for medication must be trained and follow all policies regarding safe administration, storage, documentation, and error reporting.

Procedures

  1. Medication administration is performed only by qualified, trained staff.
  2. Medications are stored securely according to regulatory requirements.
  3. Errors are reported immediately, documented, and reviewed for quality improvement.
  4. Members and/or their guardians are informed of medication procedures and may self-administer if capable.

10. Quality Improvement (QI) Plan

To ensure continuous improvement in service quality, outcomes, and member/stakeholder satisfaction.

Policy A written QI plan is maintained and updated annually, reviewed by leadership, and addresses:

  • Member and stakeholder experiences
  • Service documentation and compliance
  • Personnel training and evaluations
  • Appeals, grievances, and incidents
  • Outcomes for rights and dignity
  • Medication management (if applicable)

Procedures

  • Regular collection and review of data (e.g., surveys, incident reports, audits)
  • Trend analysis to identify areas for improvement
  • Remediation plans developed with action steps, timelines, and follow-up
  • Summary of QI activities documented and shared with leadership/board

11. Restrictive Interventions/Behavioral Supports

Restrictive interventions (restraint, seclusion, rights restrictions) are only used if allowed by law, included in a written plan developed by the IDT, and with appropriate documentation, review, and oversight.

Procedures

  1. All restrictions must be documented in the member’s service plan and reviewed at least quarterly.
  2. Use of restraints as punishment or convenience is strictly prohibited.
  3. Training provided to all staff on positive behavioral supports and least-restrictive alternatives.

12. Appeals, Complaints, & Grievances

All members, families, or guardians may file complaints or grievances regarding services. No retaliation will occur for filing a grievance.

Procedures

  1. Grievance forms are available, and the process is explained at intake and annually.
  2. Complaints may be made verbally or in writing to any staff or to the Program Manager.
  3. All grievances are documented and investigated within a set timeframe (e.g., 7 days).
  4. Resolutions and outcomes are shared with the complainant, and records are maintained.

13. Emergency, Safety, & Risk Management

Emergency preparedness, safety, and risk management plans are in place for all locations and staff.

Procedures

  1. Written emergency procedures (fire, natural disaster, severe weather, medical emergency, missing person, pandemic/infectious disease, etc.) are provided to all staff.
  2. Regular safety drills and review of emergency procedures.
  3. Incident/injury reports are documented, reviewed, and used for risk management and prevention.

14. Record Retention & Destruction

Purpose:

To ensure that all business, client, and personnel records are maintained and destroyed in compliance with federal and state laws, including Medicaid, IRS, and Iowa Administrative Code requirements.

Policy:

Wisdom Care LLC maintains fiscal, clinical, and personnel records according to the following retention periods, or longer if required by law, contract, or pending investigation:

Financial/Accounting Records:

All financial records (including invoices, payments, payroll, bank statements, receipts, contracts, and accounting reports) are retained for a minimum of seven (7) years.

Clinical/Service Records:

All service and clinical records for each member (including service plans, progress notes, assessments, incident reports, and correspondence) are retained for a minimum of five (5) years after termination of services, or longer if required by law or specific program requirements.

Personnel Records:

All employment records (applications, background checks, training logs, evaluations, and disciplinary actions) are retained for a minimum of seven (7) years after separation from employment.

Procedures:

  1. All physical records are kept in secure, locked storage with access limited to authorized personnel.
  2. Electronic records are protected with strong passwords, encryption, and regular secure backups.
  3. At the end of the required retention period, records are destroyed in a secure manner: paper records are shredded, and electronic files are permanently deleted using industry-approved methods.
  4. A log is maintained of all records destroyed, including type, date, and authorization. – If records are subject to litigation, audit, or investigation, retention periods are extended as required.
  5. Confidentiality is maintained at all times before, during, and after destruction.