2014 Interpretive Guidelines for Review Prioritization of DOEA Services

Transcription

1 2014 Interpretive Guidelines for Review Prioritization of DOEA Services COMPLIANCE REQUIREMENT INTERPRETIVE GUIDELINES VERIFICATION ACTIVITIES PRIORITIZATION OF SERVICES (DOEA PROGRAMS) The AAA prioritized consumers for receipt of services in the required order of priority and as outlined in Florida Statutes, DOEA program contracts, Notices of Instruction, AAA/ADRC procedures, and Area Plans. The contractor (AAA/ADRC) will target services to the most frail elders. Higher ranked/ high-risk clients will receive services first and in greater percentages of lower ranks. Area plan implementation strategies will be logical action steps toward assuring services are provided according to priority requirements. Consumer enrollment in DOEA-funded programs is based on available funding, specific program eligibility, targeting, and prioritization criteria as stated in law, rule and DOEA contracts. Ref: Program and Services Handbook Chap. 2-13, DOEA Contracts and AAA Area Plan Instructions and P.VI, Goal 2, Objective 2.1 SERVICE PRIORITIZATION- ST. G.R. PROGRAMS Priority for services provided under DOEA contracts shall be given to those eligible persons assessed to be at risk of placement in an institution or who are abused, neglected, or exploited. Ref: DOEA Program Contracts, Attach. I, Sec. 1. Approval to begin the eligibility process for ADI, CCE, HCE, and LSP is determined by the availability of funds and the priority score or rank of individuals. The order of priority (except for CCE APS high-risk referrals-priority 8) is as follows: a. Individuals designated as Imminent Risk (Priority 7) of being placed in a nursing home (including individuals designated as Aging Out). b. Individuals designated as Aging Out (Priority 6); and c. Individuals with the highest priority score starting with individuals with a priority score or rank of 5. Ref: Program and Services Handbook Chap. 2-14; DOEA Program Contracts, Attach. I, Sec. 2, Manner of Service Provision. CIRTS client assessment and enrollment data/reports reflect that clients have been enrolled, and received services and assistance according to priority criteria. The AAA/ADRC had prioritization policies & operational procedures that institute requirements outlined in statute, contracts, and DOEA policies. These were submitted DOEA MQA staff at least once every three years or at such time they are revised. Procedure updates will reflect approval by the AAA board. The AAA ensured that service providers: are administering the appropriate DOEA assessment as required to all prospective clients. All assessed individuals have an assigned priority rank and the AAA/LEAs utilized CIRTS reports and priority rank data to determine order of enrollment, and ensured services were provided first to those clients in the highest risk priority categories (APS, Imminent Risk and Aging Out) and then to those with the highest priority ranks, taking into Review CIRTS prioritization report, New Active Enrollees by Assessed Rank, to determine if it appears higher priority clients were served prior to lower-priority clients. Request and review justification when lower priority ranked individuals were served when higher priority elders were on APCLs, and determine if reasons were justified and policy was followed. Additional CIRTS reports may be used as part of the review. Review AAA written policies and procedures used for determining prioritization for service delivery, to ensure they comply with DOEA policies and reflect the related action steps in the AAA s area plan. Interview AAA staff to confirm required CIRTS APCL/prioritization data has been utilized in determining enrollment priorities for services provided. Review supporting AAA documentation including tools the AAA/ADRC uses to decide the order of clients to be served. Verify prioritization procedures are being followed and that clients were served according to prioritization criteria, i. e., the highest ranked priorities and those on APCL the longest were served first. CIRTS reports that may be used include: New, Active Enrollees by Assessed Rank, Priority Ranking for APCL Clients, Assessments Due/ 1

2 Service priority for applicants shall be determined utilizing a priority rank/score calculated from DOEA client assessment administered to each applicant. First priority will be given to applicants with the highest ranking (see above). For individuals assessed at the same rank, priority will be given to applicants with the lesser ability to pay for services. Ref: DOEA Program Contracts, Attach. I, Sec Regarding those receiving case management and with dual program status codes set to APCL and ACTV (in G.R., OAA or MW): regardless of priority score or rank, they will be reassessed annually using a 701B. Individuals receiving OAA registered services, OAA ACTV and APCL for any other DOEA program will be reassessed with 701A annually. Individuals APCL only and not enrolled or receiving DOEA services are to be re-screened annually using Form 701S. Other Ref: Chapter (5), , (12) Florida Statutes; Program/Services Handbook, Chap. 2-12; AAA Area Plan P.VI, Goals & Objectives; DOEA NOIs #041708, #020209, #083112, # and # ADULT PROTECTIVE SERVICES (APS) REFERRALS from DCF The contractor will ensure that pursuant to Section (5), F.S., those elderly persons who are determined by DCF/ Adult Protective Services to be victims of abuse, neglect, or exploitation who are in need of immediate services to prevent further harm and are referred by DCF/APS, will be given primary consideration for receiving Community Care for the Elderly Services. As used in this subsection, "primary consideration" means that an assessment and services must commence within 72 hours after referral to the DOEA or as established in accordance with DOEA contracts by local protocols developed between DOEA service recipients and adult protective services. Ref: DOEA Program Contracts, Attachment I, Sec , and Program and Services Handbook Chap. 2, Sec.2 consideration those at the highest risk of institutionalization, the highest financial need and those waiting on APCLs the longest. The AAA reviews CIRTS and client data to ensure individuals on program APCLs have received the appropriate assessment type, in the appropriate setting (e.g., by phone or in person) and that assessments are administered timely, completely and accurately. The AAA ensured services were provided to APS clients within 72 hours of receipt of their high-risk referral from DCF. The AAA had a system for routinely tracking APS clients and used CIRTS exception reports, the ARTT database, and other methods to ensure high-risk referrals from DCF were assessed, and crisis-resolving services identified by DCF were provided timely. (Different services may be agreed upon between DCF/APS investigator and the LEA case manager supervisor but this must be documented.) Case management services alone do not satisfy the 72-hour crisis-resolving requirement. Overdue/ or Not Done, New Enrollments in a Time Range, and others providing data pertaining to client waitlists, assessments, enrollments, and the prioritization and delivery of services to clients. DOEA APCL monthly reports (archived dates) from the Intranet page may be used to determine the numbers of clients with high priority ranks during past enrollment periods, especially if there are concerns for large numbers of lower ranked enrollees at a certain point in the review period. Review PSA APS Exception reports for required actions by AAA, Aging Network providers, and the APS Performance Outcome Measure report. Review CIRTS reports and compare to ARTT records to identify patterns of exceptions or discrepancies between the databases for APS clients referred, and other CIRTS reports for APSrelated issues (e.g., APS Repeat Referrals in a Time Range, Active Clients with an APS Referral, APS Outcome report, etc.). Review corrective action and follow-up documentation for satisfactory or improved timeliness of assessment and service for APS clients, and improved timeliness/consistency for 2

3 Each provider agency shall conduct at a minimum an annual in-service training of six hours and will document the duration and content in case management staff records. Minimum standards include: Adult Protective Services (APS) Training on the Abuse Registry Tracking Tool (ARTT) and the APS Operations Guide (on-line). Contractor shall ensure APS Intermediate and Low-Risk referrals receive an assessment, at a minimum, and that those who are enrolled in a Medicaid LTC program at the time of the referral be referred to the LTC provider. Related Ref: Chapter F.S.; DOEA NOI #121907, #020808, # and #120512; DOEA APS Operations Manual; DOEA Program and Services Handbook, Chap. 2 and DOEA Contracts, Attachment I, Sec Establish and maintain collaborative relationships with other entities to reduce the rate of abuse, neglect and exploitation recidivism through education, outreach, and the provision of services; outline strategies for achieving these objectives. AAA Area Plan Instructions & P.VI, Goal 4, Objective 4.5 IMMINENT RISK OF INSTITUTIONALIZATION Contractors will ensure that pursuant to Section (12) F.S., those elderly persons determined, through a CARES assessment, to be a resident who could be cared for in a less restrictive setting or who do not meet the criteria for skilled or intermediate care in a nursing home, will be given primary consideration for receiving services. Ref: DOEA Program Contracts, Attachment I, Sec. 2 The AAA ensured APS referred elders, regardless of risk level, receive timely and appropriate assessments to evaluate for their immediate safety and needs. The AAA ensures APS Intermediate and Low-Risk referrals who are enrolled in a Medicaid LTC program at the time of the APS referral are referred to the LTC provider timely, and according to APS Operations Manual and DOEA policies. The AAA followed up with CCE providers where deficiencies or exceptions were indicated, providing technical assistance and requiring corrective action as needed to ensure timely assessment and assistance to atrisk clients, required reporting and data input into DCF & DOEA databases. The AAA has collaborative relationships with other entities and has developed joint strategies to reduce the rate of abuse, neglect and exploitation recidivism in the PSA through education, outreach, and the provision of services. The AAA prioritized clients at imminent risk of nursing home placement for receipt of services in the required order of priority and as outlined in Florida Statutes, DOEA program contracts, Notices of Instruction, AAA/ADRC procedures, and Area Plans. required input into the ARTT and CIRTS databases. Review AAA training records to verify all staff involved with APS referrals have completed the required in-service training, which includes at a minimum, usage of the Adult Protective Services (APS) Abuse Registry Tracking Tool (ARTT) and the APS Operations Guide (on-line) core training areas as required in the DOEA SCBS handbook. Analyze New, Active Enrollees by Assessed Rank report to discern that APS high-risk referrals are receiving priority for services and are enrolled in proportionate numbers to overall new enrollments. Review CIRTS reports (Active Clients Receiving an APS Referral, and other data or reports) to verify any active in LTC programs when referred by DCF as APS were handled according to policy. Review AAA documentation that displays their collaborative work with other entities in achieving the AAA s area plan strategies for reducing the rate of abuse, neglect and exploitation recidivism throughout their PSA. Review CIRTS and CARES reports to determine if data shows the ADRC and subcontractors have satisfactorily prioritized clients at imminent risk of nursing home placement, as their funding allowed. Verify using CARES Referrals Not Acknowledged by Aging Network report that providers are acting timely to referrals in CIRTS (referrals must be acknowledged within one week) 3

4 Prompt and appropriate community-based services will be provided to elders at risk of nursing home placement or institutionalization. Community services will be provided as needed to help elderly persons maintain independence and prevent, or delay, more costly institutional care. Ref: Area Plan P.VI; Chap (12), (5), F.S.; DOEA policy memo and DOEA NOIs #102403, # & # AGING OUT individuals at age 60/referred by DCF Individuals transitioning from DCF CCDA and HCDA to DOEA community-based programs will be prioritized for services only after DCF/APS high-risk referrals and elders at Imminent Risk of institutionalization. Ref: DOEA GR Contracts, Attachment I Sec (5) & Attach. A, Programs and Services Handbook, Chap 2, Sec 2. AAAs will develop written protocols for transitioning DCF Aging Out referrals into aging network programs. The AAA/Lead Agency case manager will ensure that a full assessment is performed on elders referred from DCF, and identified as Aging Out clients from DCF CCDA and HCDA programs. Ref: DOEA NOIs #081204, #100208, #032709, #070209, #092809, # & issued quarterly to date; DCF/DOEA Interagency Agreement Clients at imminent risk were high priority, and were prioritized for service second only to APS high-risk referrals, as funding allowed. AAA reviewed CIRTS reports and data, and submitted Prioritization/Imminent Risk and Surplus/Deficit Reports, including figures on Imminent Risk numbers, to DOEA Contract Manager as required. The AAA developed written protocols for transitioning DCF identified Aging Out individuals into DOEA service programs according to the inter-agency agreement (DOEA & DCF). AAA providers conducted full and timely assessments and provided appropriate and timely services to individuals identified on Aging Out referral lists issued to AAAs on a regular basis. When services were not available they were assessed and placed on APCL s, and prioritized (rank 6) according to required criteria. All required data on the referred clients were maintained in the CIRTS data system. Review other CIRTS data/reports and Imminent Risk Referrals Outcome Measure performance rates to verify that action steps were followed as identified in the AAA s area plan to prioritize and serve clients at risk of nursing home placement or institutionalization, and that explanation for exceptions are documented. (IRR Outcome report may include NH Transition cases with lengthy response times, skewing rates.) Review AAA and provider written protocols and procedures that specify steps for responding to Aging Out referrals from DCF to verify they are assessed, prioritized and served according to the inter-agency agreement, AAA & local procedures, and DOEA policies and instructions. Review quarterly Aging Out lists of DCF referred clients and CIRTS reports to verify the AAA and providers are following criteria outlined in DOEA contracts and inter-agency agreement with DCF for transitioning Aging Out individuals. Review CIRTS current assessment, enrollment and service data of DCF referred clients who Aged Out (turned age 60) in the MQA review period to verify timely and appropriate responses to referrals as outlined in policy and the DCF inter-agency agreement. Client files and AAA records may also be reviewed. 4

5 APCL MAINTENANCE & PRIORITIZATION OF ENROLLMENTS When enrollment in a program for service funded by DOEA is not available, the AAA/ADRC will ensure that APCLs (assessed priority consumer lists) are utilized and maintained in CIRTS. Ref: DOEA NOI # Trained and certified staff will conduct assessment activities of potential clients as the first step to APCL enrollment. The assessments entered in CIRTS will automatically generate a priority ranking score for individuals waiting on the APCL. Ref: Program and Services Handbook, Chap. 2 Sec. 2, APCL Maintenance and DOEA NOI # The AAA must ensure that all with a CIRTS Enrollment Screen program status code set to APCL, and not enrolled or receiving services in any DOEA-funded program, is rescreened annually using Form 701S (at a minimum). Regarding those screened using Form 701S who received a priority score or rank of 3, 4 or 5 when APCL, and are subsequently assessed using a 701B and receive a new lower rank of 1 or 2: ADI, CCE & HCE are returned to the APCL; When no longer waiting for services, the appropriate program status code must be appropriately modified to show reason for termination from APCL, e. g., no longer able or interested in receiving services, or has begun eligibility process or receipt of services. Ref: NOI # (update to #041708); Program and Services Handbook, Chap. 2, pgs (APCL Maintenance & Prioritizing Enrollments). Approval of individuals to begin the eligibility process for GR and LTC services is determined by their priority ranking and the availability of funds. AAAs will maintain APCL list accuracy through timely assessments and updates, and updating enrollment tables on a quarterly basis. Ref: DOEA NOI# ; Area Plan Instructions P-III, Goal E-2. The AAA ensured that in cases where service funding is not available, potential clients were given the option to be assessed and placed on a program APCL with a CIRTS assigned priority rank. The AAA ensures case management and other staff conducting client assessments have been trained and passed tests that show an understanding of DOEA policies. The ADRC managed the APCL ensuring that clients received appropriate and timely assessments and re-screening, and APCL data was current and accurate (Auditor General report #s and Recommendations). The AAA ensured compliance with Assessment requirements and timeframes in DOEA contracts, the HCBS Handbook and DOEA policies, assuring clients APCL status were reflected accurately. Review CIRTS reports Assessments Due/Overdue /Missing Reports along with other pertinent reports, and AAA documentation to determine the accuracy of client APCL data and compliance with assessment criteria and timeframes for clients on APCLs only, ACTV, ACTV and on APCL, etc. Training records verify training of all staff that have conducted client assessments, that includes all required core training areas in SCBS handbook A test of client records or files may be performed to determine the accuracy of the clients program status as shown in CIRTS, e.g., still eligible and in the area, not institutionalized or deceased, etc. Review Vital Statistics Date of Death data and other CIRTS reports with enrollment and program status data, to verify APCL status accuracy of clients in the PSA. Review AAA/ADRC APCL management policies & procedures documentation for compliance with DOEA assessment/re-assessment requirements. 5