Roles of Child Care Health Consultants in New York
In 2004, New York State adopted new child day care regulations regarding the administration of medication in child care settings by lay providers who are not licensed health professionals. These new regulations created additional duties for a position called a Health Care Consultant.
As my colleagues at Child Care Resource and Referral CCR&R agencies across the state explored this new position and started to find answers to the question “What type of duties I would be expected to accomplish?” we found three main activities:
- Health Care Consultant approval of the health care plan
- Conducting a Health Care Plan Review that included a program site visit
- Training on medication administration and other health related topics
In New York State the qualifications and role of a Health Care Consultant (HCC) are defined by a variety of child day care regulations. Per child day care regulation the HCC must be a registered nurse, nurse practitioner, physician’s assistant, or physician licensed to practice in New York. Caring for Our Children (CFOC) recommends additional training for Child Care Health Consultants (CCHC) and also outlines a broader scope of practice. Our primary role as a Health Care Consultant (HCC) in New York is to approve the Health Care Plan (HCP) for child care programs that choose to administer medication.
Approve the Health Care Plan
Child care programs are only required to utilize the services of an HCC if they are planning to administer medication to children. An HCC is not required for a program that administers only over-the-counter (OTC) topical products and emergency medications that are limited to inhaled asthma medications, auto-injected epinephrine, and diphenhydramine in combination with the auto-injector.
If a program chooses to become authorized to administer medication, then the program must engage with a HCC whose role is to approve the HCP before it is submitted to the Office of Children and Family Services (OCFS) licensor or registrar.
The child day care regulations stipulate what needs to be addressed in the HCP and that it must be on a form “furnished by the Office” which is OCFS. The most current HCP form for each modality, be it Day Care Center, Family or Group Family, School Age Child Care, or Legally Exempt, can be found on the ‘Forms’ page of the OCFS website.
The Health Care Plan is a comprehensive form in Microsoft Word format that is available in English and Spanish. It contains specific sections for all programs to complete and sections that only need to be completed by programs that plan to become authorized to administer medication. The HCP poses questions to the program that are answered using check boxes and short answer fields.
To child care providers, I describe the HCP as a translation of the Health and Infection Control section of the child day care regulations into what will essentially serve as the child care program’s policies and procedures for many health related concerns. The HCP addresses infection control, exclusion criteria, children with special health care needs, medical emergency preparation including First Aid Kit storage location and contents, and of course medication related practices.
The HCP will need to specify how often the HCC will visit the program to conduct a Health Care Plan Review.
Health Care Plan Review or “Site Visit”
The child day care regulations specify that the HCC review of the HCP occur at least every two years, though many HCCs visit more frequently. Some child care programs are accredited and require more frequent visits such as National Association for the Education of Young Children NAEYC accreditation that requires quarterly program visits from the HCC.
Prior to program visits, the HCC might want to visit the OCFS Find Child Care page to see if there is any public information that might be helpful in preparing for the visit, such as past, or current health related violations.
During program visits, the HCC must conduct a “review of the health care policies and procedures and a review of documentation.” This is often referred to as a ‘Health Care Plan Review’ or a ‘Site Visit.’ The New York State Child Care Health Consultant Resources website has some sample checklists for use by HCCs when conducting program visits.
In order to review documentation at a program, the program will want to notify parents of the purpose of the visit, what the HCC will be looking at, and obtain parental consent. It will also be helpful if the HCC can provide parents with information about how s/he will maintain the confidentiality of any information contained in the program’s records.
Resource: Confidentiality for HCCs
The child day care regulations also stipulate that the program “demonstrate to the health care consultant how medications are administered in the program.” This demonstration is a useful tool to identify deficiencies in the medication administration procedure once child care providers are in their natural setting rather than the Medication Administration Training (MAT) competency setting.
The HCC also has a responsibility to revoke the HCP if they find that “the approved health care plan is not being reasonably followed by the program”, but what does ‘reasonably followed’ mean?
It can mean the sheer number of deficiencies identified, it can be that the staff are not following procedures outlined in the HCP, and it would certainly be a deficiency that puts a child at risk of imminent harm. In reality, it is a program’s failure to make efforts to follow the procedures outlined in the HCP.
If the HCC is in a position to revoke a child care program’s HCP, the HCC must immediately notify the person responsible for the program, who in turn must notify OCFS within 24 hours. The HCC is not obligated to notify OCFS by regulation, but notifying the licensor/registrar can minimize the time that a program is deficient following the HCP.
Training Early Care Providers:
As health professionals with experience in the field of child care, it is logical for HCCs to provide training in medication administration and other health related topics, to early care providers. In NY, there are specific qualifications and requirements to providing training that is accepted by OCFS as well as a complex system for accessing funds to make training affordable to child care providers.
Child care programs that choose to administer medication to children, which are not already staffed with health professionals, must have staff with the Medication Administration Training certification in addition to HCC approval of the HCP. Another course that many HCCs become trainers for is Health & Safety, which provides the basics for maintaining a healthy and safe environment in home based child care programs. SUNY Professional Development Program (PDP) through a contract with OCFS, develops both training curricula, trains, and monitors the trainers ensuring quality and consistency throughout the state. In addition, OCFS provides funds through a system of rebates to child care providers to offset the cost of both Health & Safety and MAT training.
Health & Safety and MAT trainers are categorized as Verified Specialty Trainers. They must maintain a specific status as a trainer for each of those courses in order to conduct valid trainings that are eligible for the training rebates. CPR and First Aid is another example of a curricula that HCCs can provide training in and receive state funds for once they have established their credentials as Verified Specialty Trainers. This funding comes through the Education Incentive Program (EIP) which is a state funded tuition assistance program for low income child care providers. EIP can only be used for courses taught by trainers who meet the qualifications of Verified Specialty Trainers or Content Specialist, and/or a credentialed Early Learning Trainer. (See Below or Download)
The licensure required to be an HCC also enables the Health Care Consultant to be a Content Specialist Trainer in health related topics. Recognition as a Content Specialist also enables the HCC to receive EIP funds for health related trainings. Sometimes the training objectives and outline need to be approved by the EIP program. This is done to ensure that New York State is using its funds to pay for high-quality training for child care providers.
There is a final category of early education trainers in NY that is the Early Learning Trainer Credential . This credential recognizes training professionals who possess the knowledge, skills, and attitudes to provide training to early care providers and programs. Credentialed trainers are assigned a level based on their education and experience. Few HCCs are credentialed trainers, but it does carry a higher EIP reimbursement rate than Content Specialist.
Health Care Consultants and Child Care Health Consultants provide essential services to child care programs and providers. Services such providing MAT and/or First Aid/CPR training to staff at a program and then subsequently approving the program’s HCP so that they can be approved to administer medication. The HCC will then conduct a site visit the program to Review the HCP and monitor the staff implementation and compliance with the practices set forth in the HCP. These health services, provided by health professionals with training and experience in child care health consultation lead to improved health practices in early education settings.