To All:

This may be one of those matters where one approach does not necessarily fit all situations.  Hattie Larlham has 1100 employees and provides services at locations ranging from a large ICF to ICF and waiver homes to day programs, etc.  At the large ICF, in addition to DSPs, we employ RNs, LPNs, respiratory therapists, social workers, etc. all subject to different rules and regulations and ethical guidelines

We needed to develop a policy that could be applied to all employees - and simple to monitor and enforce.  For example - although there may be no statutory or administrative code provisions that prohibits a DSP from accepting a gift from an individual served, Ohio Administrative Code Section 4761-10-01(H) strictly prohibits a respiratory therapist from accepting a gift.

We made the decision to prohibit all employees from accepting gifts from individuals served or their family members or guardians.  We did allow the exception for food subject to some guidelines - and only from a parent, guardian or family member.

Perhaps the policy does not need to be as restrictive at a smaller organization or one that does not have the licensed professionals on staff.  In those cases I think that gifts should still be limited by dollar amount or language such as "nominal value".

For whatever it is worth - here is the key language from our policy.

Steve

POLICY
Employees of Hattie Larlham shall not accept gifts, gratuities, gift cards, entertainment or any other special considerations from a person served, or parent, guardian or family member of a person served, or a company or agency doing business with or being considered to do business with Hattie Larlham or any affiliated organization.

Employees of Hattie Larlham are permitted to accept a gift of food from a parent, guardian or family member of a person served if the food is available for consumption by all employees at a particular location or unit or on a particular shift; provided that the cost of said food is reasonable, appropriate and not intended to influence the level of care or services provided.  Employees of Hattie Larlham are strictly prohibited, directly or indirectly from requesting or soliciting food from a parent, guardian or family member of a person served.  Under no circumstances shall an employee of Hattie Larlham accept a gift of food from a person served.

Stephen Colecchi
Chief Executive Officer
Hattie Larlham
330-840-6838 (O)
330-472-5572 (C)

-----Original Message-----
From: Than Johnson [mailto:TJohnson@CRSI-OH.com]
Sent: Tuesday, December 18, 2018 10:36 PM
To: Stephen Colecchi
Cc: Justin Blumhorst; OPRA General Listserve
Subject: Re: Misappropriation

Agree with Stephen statements. The gifts our DSPs and all of receive from individuals they support are the small acts of appreciation that feel like a million dollars.
Than

Than Johnson
Chief Executive Officer, CRSI
Office: 937-653-1307
Mobile: 937-776-5515 > On Dec 18, 2018, at 6:29 PM, Stephen Colecchi <Stephen.Colecchi@hattielarlham.org> wrote:
>
> We just reviewed and updated our policy a month or so ago.  Gifts to DSPs are prohibited.  Many of the ethical guidelines for some of the licensed professionals also prohibit gifts from being accepted.   If a family wants to provide a meal (for example pizza) - that is permitted - provided that all employees working at the specific location are included.  I can send the specific language tomorrow when I get to the office.
>
> Steve
>
> Stephen Colecchi
> Chief Executive Officer
> Hattie Larlham
> O:  330-840-6838
> C:  330-472-5572
> Stephen.Colecchi@hattielarlham.org
>
>
> Sent from my iPhone
>
>
>
>
>
>> On Dec 18, 2018, at 5:55 PM, Justin Blumhorst <justin.blumhorst@capabilitiesinc.biz> wrote:
>>
>> Hey Everyone!
>>
>> With it being the holiday season, people are giving gifts. What are your policies if people you serve give presents to DSP's? My understanding is that they cannot take the gifts... if anyone has anything wrote up or has any training on how to say no to these appropriately, I would appreciate it :)
>>
>> If anyone has any other thoughts on accepting the gifts, I would appreciate that too...
>>
>> JB
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