"Real" Money for Training in the ICF/IID Program

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If you are in Texas, if you go through annual surveys, and if you have individuals living in the ICF training on money management skills (you better have) then you may have faced the "Fake Money" issue.  There are several ICF programs in Texas that have received deficient practice for failing to use "Real" money in their training programs.  Often these programs note several reasons for not using real money such as "The clients will take it," "The staff will take it," or "Real money simply disappears."  By most people's standards, those are all good reasons to make fake money.  The fact is a small purchase of "Fake" money can cover bills and coins ranging from pennies up to hundred dollar bills for training.  If they are lost, torn up, or even thrown away there is usually plenty more in the set to be used (see picture above).  The argument sounds solid until the surveyor walks through the door.

If you have gone through a survey and had "Fake" money, then there is a good chance that it was an area of concern at the least, and possibly written into deficient practice at the most.  Several sets of deficient practice I have seen have listed it as an example under Active Treatment or the famous "W159" or as some call it "The QIDP Tag".  There has always been the possibility of filing an Informal Dispute Resolution (IDR) in Texas over the issue, but the fact is the example of the "Fake" money is usually worked into a tag with several other issues.  In the end you might get the example removed, but in most cases you would still have the tag to contend with for your plan of correction (POC).

After a home recently received the "Fake" money as an example under a tag, I decided to read the specific tag that was written.  This, as warned above, was a situation where several examples were listed to support the tag and planning an IDR simply was not as feasible as correcting the tag.  ONce you start looking at the Federal Standards, you can find the word "Money" mentioned 19 times.  Since "Fake" and "Real" "money" was the issue, there was no reason to search anything else.  Out of the 19 times money is mentioned, the tie to training only falls under tag W126.

W126 deals with encouraging and allowing the individuals (clients) to manage their financial affairs and for the facility to teach them how to manage their money if they do not know how to do it.  It is not until you read into the guidelines that you find the mention of money brought up.  Remember, these guidelines are the guide for surveyors to use when they are in the facility.  In the third full paragraph we find the following statement:

"Money management includes a broad spectrum of programs with varying levels of participation by the client ranging from the use of choice in money expenditures, to an understanding of the concept of money, and ultimately to actual money handling and budgeting. The IDT must not conclude that a money management program is inappropriate based solely upon the level of intellectual or physical disability of the client."

The first thing the reader will notice is that money management "includes a broad spectrum of programs and varying levels of participation".  This statement supports the IDTeam's efforts for some people to manage checkbooks, others to take care of banking needs, and still others to study the meaning and use of something as small as a penny.  In other words, through assessments the IDTeam has to determine at what level and what training the individual needs for money management.   The next interesting thing to note is that the guide states "...ultimately to actual money handling".  This statement would seem to support a facilities use of "Fake" money and even the use of pictures, or references of some kind to something other than actual money.  So, with this in mind, how can the facility use fake money in a world where the surveyors seem to insist on "Real" money for training only?

You basically have two choices.  You could simply use real money and avoid all confrontation.  That would be the simple method.  The second method you could use is documentation.  Documentation would need to be very strong for your case.  For example, what are the reasons you can not use "Real" money?  Maybe it's a case where the person you are training eats the money, throws it away, tears it up during training, etc.  Is there a plan to work toward "Real" money eventually?  You would clearly need to demonstrate the pattern.  For example, a person might use "Fake" money because he tears it up, but part of his training is to not tear the money up.  So, at some point, "Real" money could be used - remember the guidelines state your goal is "ultimately to actual money handling."

There are multiple ways that an IDT could address the issue and justify the use of "Fake" money for training.  However, the bottom line is that you must have solid documentation, justification, and a goal in place to work toward the eventual use of "Real" money.  If you put these in place, it is doubtful that most surveyors would write an example of "Fake" money into deficient practice- and while doubtful that they would write the "Fake" money into deficient practice, it is almost a certainty that they would not write it under W126.   Remember, the surveyor writes the 2567 in such a way that it can stand alone as evidence.  This is done to protect the survey process, the individual's we serve, and to ensure that should the 2567 be called into question through an IDR or another avenue of review, it can stand as evidence alone of the deficient practice.

One final thought before you go out and buy up ton's of "Fake" money to use.  Do your documentation as discussed above, and consider contacting your program manager for the region you operate in (if in Texas).  Talk with the Program Manager about your reason for wanting to use "Fake" money.  If you do that, then odds are the Program Manager will talk with surveyors before they come to your facility.  You may be able to avoid having "Fake" money as an example in the 2567, and you will not have to waste time and resources with an IDR for what will likely be an example in a tag only.

Reference:
State Operations Manual. Washington: U.S. Dept. of Health, Education, and Welfare, Social Security Administration, 2015. CMS. CMS, 14 Aug. 2015. Web. 2 Apr. 2016. W126 page 48-49