Twogether Consulting has added some new services to include:

DEVELOPMENT OF INFECTION CONTROL POLICIES & PROCEDURES, or at least to update your one with COVID-19 policies and protocols.  

(Based on Guidance noted in the HCS & ICF COVID-19 Response Plans                                                      

HCS-covid-response-plan.pdf     ICF-covid-19-plan.pdf

DEVELOPMENT OF EMERGENCY EVACUATION PLANS  In particular, so HCS/TxHmL providers are able to meet  compliance with Appendix K:  Emergency Preparedness and Response and COVID-19 Addendum

Appendix K-Emergency Preparedness and Response-COVID-19

Both of these items will most likely be requested of the provider, at some point during the survey process in the near future. (That’s if you have not already been asked to provide these items.)  This is especially true if the surveyor sees that you are not in compliance with HHSC’s COVID-19 Response Plan Guidance for the providers and CDC guidelines that are referred to in both of these documents.  These of course will definitely tie into TAC code citations and ICF Tags, particularly nursing and possibly ANE TAC codes for both programs (neglect in particular). 

For both of these services, contact us at:   We would be glad to invoice you or you can notify us to make arrangements and then make payment at 

OFF-SITE SERVICES TIME BLOCKS:  We now offer packages of 1 hr, 3 hrs, 6 hrs, 9 hrs and 12 hrs for those of you who need quite a bit of periodic off-site assistance services including but not limited to:: Question & Answer Sessions, Resources, Individual Policies or Procedures, Creating Forms,  and Other Inquiries.  Previously we only had 3, 6, and 9 hr blocks.  12-hr blocks purchased at one time will be at $60/hr (Total= $720)  For more information go to:   You may request an invoice or make direct payment instead to:

This does not include Complete/extensive Policies and Procedures, Employee Handbooks, CAPs/POC’s , DIT’s, Webinars, or Off-site TrainingPlease be sure to contact me directly if you have or are going to purchase online, and you would like to schedule some specific time for consultation 

OFF-SITE RN CONSULTATION:   RN only consultation is available for $75 per hr.  
This is an option to pre-purchase hours with our RN Consultant who specializes in assistance to HCS/TxHmL and ICF providers.
For those of you who need periodic assistance off-site, including but not limited to:: General Inquiries about nursing services and concerns in these programs (via phone calls, video chat, email or text).  If you would like to schedule a teleconference or video conference with our RN Consultant and your nursing department or other members of your team, please contact us at  This is a great way to prepare for a survey, discuss post-survey concerns, develop ideas for plans of correction, discuss nursing concerns about an individual prior to admission, or assist nurses with new admissions to the program.  
This service does not include:  the actual development of policy & procedure or assistance with writing plans of CAP’s/POC’s, DIT’s, Webinars, or Off-site Training.  Please contact us at if you need these services.

(This is for off-site assistance only with LON increase packets)
 As a provider often times you may realize that some of your individuals do not have the correct LON (Level of Need)/  Now you may be aware that you have to request a new level of need, but do you know how to go about requesting that increase in the level of need?  Do you know what goes into the LON increase request packet?  Even if you know what to do, do you have time to fool with completing one?   Let us help!  We will have you send your documents to a private and secure shared folder, or you may choose to fax your documents  We will review the items and discuss them with you: what documents are missing, incomplete, or issues that may need to be addressed, as well as and concerns we have about the individual.  We provide recommendations and a list of all the appropriate documents including the order to put them in, to the provider.  We also write your cover letter for the increase and fill out your IDRC.  The provider will be responsible for then putting copies of those items in a packet and sending it off to the Utilization Review Department at HHSC for review.   You may choose hourly rate of $80/hr or flat rate of $800 for each LON increase packet we assist with off-site.  Please be sure to contact me directly prior to payment, even if you are going to purchase the flat rate directly online, so we can discuss your arrangements for off-site services including shared file options. 

SCORING ICAPS: Some providers are brand new or may have a small number of individuals in their program.  Sometimes you just can’t afford the initial cost of purchasing the ICAP scoring system or you simply don’t know how to use the scoring system very well.  So if you have ICAP renewals due or are requesting a LON increase, for example, we will be glad to score your ICAP’s for you.  Please give us at least 5 days’ notice, if possible.  The cost is $25 per ICAP online if you purchase at our “Store”.

We can provide a discounted rate if you have more than 5 ICAP’s at one time that needs to be scored. Contact us at:   We would be glad to invoice you,

Nursing Peer Review Process-If your facility needs training on the Nursing Peer Review Process or needs help with performing a Nursing Peer Review, please let us help.  You can contact us at to request assistance.  Remember, the provider can often use this process to assist the nurse and to prevent the nurse from going before the BON (Board of Nursing) if it is determined that the issues can and should be addressed by the facility and the nurse.  The nurse uses a group of his/her peers to assess the situation, determine the seriousness of the concern or allegation, and recommend appropriate corrections and solutions by the nurse and the facility.  This process can be used to correct certain nursing citations as well and again, possibly prevent the nurse from being reported to the BON. 

FYI-If you have 10 or more nurses working for your program (ICF, HCS, TXHmL, etc….), the BON requires the facility to have a “Nursing Peer Review Committee” to review Nursing Infractions and all facilities could benefit greatly from having some kind of “Nursing Peer Review Process” in place.

 [NPR §303.0015 ]

“Any person or entity that employs, hires, or contracts for the services of 10 or more nurses (RNs, LVNs or any combination thereof) must have a Peer Review Plan; however, peer review of RNs is not mandatory if the facility employs less than 5 RNs. A person or entity required to have nursing peer review may contract with another entity to conduct nursing peer review.”

 What is Peer Review? [Nursing Peer Review (NPR) §303.001(5)]

Peer review is the evaluation of nursing services, the qualifications of a nurse, the quality of patient care rendered by nurses, the merits of a complaint concerning a nurse or nursing care, and a determination or recommendation regarding a complaint including:

  1. the evaluation of the accuracy of a nursing assessment and observation and the appropriateness and quality of the care rendered by a nurse;
  2. a report made to a nursing peer review committee concerning an activity under the committee’s review authority;
  3. a report made by a nursing peer review committee to another committee or to the Board as permitted or required by law; and
  4. implementation of a duty of a nursing peer review committee by a member, an agent, or an employee of the committee.

A Peer Review Committee may review the nursing practice of an LVN, RN, or APN (RN with advanced practice authorization).

There are two kinds of nursing peer review:

  1. Incident-based (IBPR), in which case peer review is initiated by a facility, association, school, agency, or any other setting that utilizes the services of nurses; or
  2. Safe Harbor (SHPR), which may be initiated by an LVN, RN or APN prior to accepting an assignment or engaging in requested conduct that the nurse believes would place patients at risk of harm, thus potentially causing the nurse to violate his/her duty to the patient(s). Invoking safe harbor in accordance with rule 217.20 protects the nurse from licensure action by the BON as well as from retaliatory action by the employer.

See revised rules 217.19 (Incident-Based Nursing Peer Review and Whistleblower Protections) and 217.20 (Safe Harbor Peer Review and Whistleblower Projections){}

We are sorry to say, that our plan to start providing training again with Nursing CNE’s has been put on hold, due to the Pandemic (COVID-19).  We will keep you posted.

 Provider Specific Training offered by Twogether Consulting

  • Training (Off-site) to Providers concerning Direct Care staff’ssurvey interviewer interaction with Surveyors during interviews and how this can affect the provider, particularly the nursing department, as well as preparing for the survey in general.  (HCS, TXHmL, and ICF)
  • Training (Off-site) to Providers concerning “Expectations of The Nurse Part I and II”  (HCS, TXHmL, and ICF)
  • Training (Off-site) to Providers concerning Nursing Staff’s interaction with the Surveyors, particularly during the interview process with the nurse.  (HCS, TXHmL, and ICF)
  • Training (Off-site) Other Direct Care staff training such as Abuse Neglect & Exploitation Reporting and Follow-Up for HCS/ICF, including PPT handouts,  Quiz and Inservice Sheet for your records or Certificates of Completion. This training does meet the new requirements listed in the current HCS TAC Code 9.175     Geared towards CM’s, QIDP’s, Nurses, Quality Assurance, Program Managers and  other Administrative Staff                                                   

  • Other Direct Support Staff Training Webinars:  We continue to offer DIT’s (Directive Inservice Trainings) for ICF as well as General Direct Support Training for HCS/TxHmL/ICF providers.  Here are just some of our training webinars currently available live and/or via pre-recorded sessions:
  • Abuse/Neglect/Exploitation-specific to Direct Support Staff
  • Direct Support Documentation (Service Delivery Logs/Residential Notes, Incident Reports, Behavioral Support Documentation and Data Collection, and Training Data Collection),
  • Elements of the Behavior Support Plan & The Importance of Your Documentation,
  • Expectations From the Nurse of The DSP (Includes discussion of Medical Documentation as well-MARS, Medication Errors, Treatment Sheets, Significant Observations)
  • When and What to Report To The Nurse,
  • SAM’s Training (Self-Administration of Medications Training To Staff-General Routes, Tasks, documenting), ,
  • Host Home/Companion Care Service Provider Responsibilities,
  • What The Nurse Expects from the HH/CC Provider and/or CRA, and many other training webinars.