A. THE NEW YORK CITY DEPARTMENT OF SOCIAL SERVICES (“DSS”) AND THE DEPARTMENT OF HOMELESS SERVICES (“DHS”) CATEGORIZE INCIDENTS CONCERNING THE AGENCY’S SHO INTO THREE PRIORITY LEVELS IN ITS DHS INCIDENT REPORTING PROCEDURE FOR DHS FUNDED PROGRAMS
1/6/22 (ATTACHED
I.
Black Veterans for Social Justice, Inc.
Incident Reporting Policy – Issued: January 15, 2025
I. PURPOSE
a. Black Veterans for Social Justice, Inc. (“BVSJ” or the “Agency”) recognizes that the sensitive nature of its operations may result in various incidents that require reporting to government agencies.
b. This Incident Reporting Policy (the “Policy”) is intended to ensure incidents are properly and promptly reported to promote safety and in a manner compliant with relevant regulations.
II. SCOPE
a. This Policy shall apply to all incidents that may occur in any of the Agency’s operations and programs.
III. GENERAL INTERNAL OPERATIONS REPORTING
a. For purposes of this Policy, any occurrence occurring in the Agency’s general operations that is caused by either human action or natural phenomena, that requires action to prevent or minimize injury, loss of life, or damage, loss of, or other risks to property, information, and/or natural resources, shall be considered an incident.
b. All incidents should immediately be reported to the:
i. Hotline,
ii. Chief Executive Officer,
iii. Chief Compliance Officer, or to
iv. Human Resources.
IV. SHELTER OPERATIONS DIVISION INCIDENT REPORTING
a. Incidents occurring in the Agency’s Shelter/Hotel Operations (“SHO”) division shall be governed by §§V – VII of this Policy.
V. DEFINITIONS
a. The New York City Department of Social Services (“DSS”) and the Department of Homeless Services (“DHS”) categorize incidents concerning the Agency’s SHO into three Priority Levels in its DHS Incident Reporting Procedure for DHS Funded Programs Policy, dated 1/6/22 (attached “DHS Incident Reporting Procedure”):
i. Priority 1 (“P1”) Incidents;
1. Priority 1 Incidents are referred to as “Serious Incidents.” Serious Incidents are those that “have a significant impact upon the safety and well-being of clients and/or staff,” and must be promptly reported to DHS’s Serious Incident Unit (“SIU”)
ii. Priority 2 (“P2”) Incidents;
1. Priority 2 Incidents “do not significantly impact the safety and well-being of clients or staff,” per New York State Office of Temporary & Disability Assistance (“OTDA”) guidelines, but must be recorded in the DHS Client Assistance Rehousing
Black Veterans for Social Justice, Inc.
Incident Reporting Policy – Issued: January 15, 2025
Enterprise System (“CARES”) promptly, so DHS’s SIU can address the incident in a timely manner.
iii. Priority 3 (“P3”) Incidents;
1. Priority 3 Incidents are “quality of life” occurrences which require recording in CARES and review for possible corrective action.
VI. P1 INTERNAL AND EXTERNAL SHO INCIDENT REPORTING PROCEDURE
a. Internal P1 Incident Reporting Procedure:
i. If a Priority 1 event occurs at a BVSJ SHO site and/or is reported to DHS, the following internal protocol must be followed internally:
1. All relevant documentary evidence including but not limited to video footage, photos, and witness statements must be gathered as soon as possible and preserved.
2. The P1 incident must be immediately and accurately reported to the site’s Program Director.
a. Failure of a Program Director’s subordinate staff to accurately report an Incident to the site’s Program Director as soon as possible shall be grounds for disciplinary action against subordinate staff member(s) up to and including termination.
b. Immediately after a staff member submits a P1 Incident Report, the DHS Incident Report must be sent in an Email from that same staff member to the:
i. Chief Executive Officer,
ii. Chief Compliance Officer,
iii. Senior Internal Security Director
iv. Senior Director of Shelter Hotel Operations,
v. Regional Program Director who supervises the respective shelter site, and
vi. Program Director, if the Program Director is not the staff member who submitted the P1 Incident Report.
3. If the shelter site’s Program Director is not present on-site during the P1 incident, the highest-ranking staff member on site must call the Program Director informing them of the incident.
a. If the Program Director is unable to be contacted by phone, the highest-ranking staff member on site must send the Program Director a text message or email informing them of the Incident immediately.
b. If a Program Director reasonably believes that either:
i. the Priority 1 Incident was inaccurately reported to them, or
Black Veterans for Social Justice, Inc.
Incident Reporting Policy – Issued: January 15, 2025
ii. the Priority 1 Incident was inaccurately reported to DHS,
1. then the Program Director must raise that concern to the Chief Compliance Officer, who will initiate an independent investigation pursuant to the Agency Investigative Policy and Procedure Manual.
b. External P1 Incident Reporting Procedure:
i. If a Priority 1 event occurs at a BVSJ SHO site and/or is reported to DHS, the following internal protocol must be followed externally: 1
1. A SHO staff member who witnessed the event must notify the SIU by telephone within 1 hour of becoming aware of the incident. 2
a. The caller must provide the following information:
i. Caller’s name, title, and call-back number;
ii. Facility code;
iii. Facility name and address;
iv. Building name and address, if different from facility’s;
v. Description of the incident using factual information and noting the source of all information;
vi. Date and time of the incident;
vii. When facility staff was notified;
viii. All participants involved (staff, clients, etc.);
ix. Where the incident occurred;
x. Any injuries suffered; and
xi. Whether or not there was an arrest/hospitalization.
2. The Shelter Program Director, their designee, or the SHO Staff member who initially reported the incident must call SIU with any updates where available while the case is still open.
3. After contacting SIU, as per above, the Shelter Program Director or their designee will ensure facility staff creates an Incident Report in CARES within 4 hours of the staff becoming aware of the incident. 3
1 BVSJ SHO Staff must always closely comply with the DHS Incident Reporting Procedure.
2 SIU is available 24 hours a day and 7 days a week @ (212) 361-5700.
3 The Incident Report in CARES must not include less information than staff provided to SIU. All pertaining information contained in attachments must be included in the incident description or resolution; attachments are not visible to OTDA. All incident questions must be answered. If a question does not apply – the answer must be “no.”
Black Veterans for Social Justice, Inc.
Incident Reporting Policy – Issued: January 15, 2025
a. If an incident occurs during overnight hours, on a weekend, or on a holiday, the Incident Report must be entered in CARES by 12:00 noon on the next calendar day.
b. The Incident Report in CARES must include the following:
i. Incident date and time;
ii. Incident type and category;
iii. Facility name, building, and specific location in the facility where the incident occurred;
iv. All incident participants including clients and staff.
1. (Rather than typing participant information into CARES, link participants’ names to the report, which connects to the CARES client homepages and client history and include in the incident description. This will ensure all the information is added in their DHS client record.);
v. A complete description of the incident (who, what, where, when), which must include:
1. Factual narrative in sequence noting the source of all information;
2. Date and time of incident;
3. Date and time the facility was notified, if different from date and time the incident occurred;
4. All participants involved (clients, staff, etc.);
5. Emergency responders (name and badge numbers);
6. Resolution/update (e.g., whether the missing child was located, elevator repaired, or the expected date of repairs, etc.).
4. The Shelter Program Director or their designee must review and within 24 hours of the incident, submit the Incident Report in CARES which goes to SIU. 4
4 DHS Procedure requires that Incident Reports must be reviewed by “either the Shelter Director/on-site designee” within 24 hours of the incident and before the Incident Report is submitted in CARES. Generally, a BVSJ Program Director should always review the Incident Report for purposes of this Policy before it is submitted in CARES. However, if a Program Director is unable to do so within the 24-hour timeframe, they may designate the nexthighest ranking Director or supervisor in the chain of command to conduct this review before submission. When possible, the Program Director should make this designation in advance of a planned absence.
Black Veterans for Social Justice, Inc.
Incident Reporting Policy – Issued: January 15, 2025
5. The Incident Report may be returned for updates and the Program Director, or their designee must review and submit requested information immediately.
VII. P2 & P3 INTERNAL AND EXTERNAL INCIDENT REPORTING PROCEDURE
a. Internal P2 and P3 Incident Reporting Procedure:
i. Priority 2 and Priority 3 events may be relatively common and do not require internal escalation beyond the respective BVSJ Shelter site’s leadership.
b. External P2 and P3 Incident Reporting Procedure:
i. If a Priority 2 or Priority 3 incident occurs at BVSJ SHO site, a BVSJ staff member on site at the time of the incident must complete an Incident Report in CARES;
1. reviewed by either the Program Director or their designee, and 2. submit the report through CARES within 72 hours of the incident.
a. Please note that DHS may send this Report to SIU.
ii. If the Priority 2 or 3 incident occurs during the weekend or on a holiday, an Incident Report in CARES must be submitted by the close of the next business day in compliance with DHS Procedure.
iii. The Incident Report may be returned for updates and the Program Director, or their designee must review and submit requested information immediately.