Inspection of Care for Independently Licensed Practitioners. [August 2018]

Transcription

1 Inspection of Care for Independently Licensed Practitioners [August 2018]

2 Changes in the Program Review Process Effective July 1, 2018, there is a new process to conduct reviews of Independently Licensed Practitioners (ILPs) by Beacon Health Options For Programs certified as of July 12, 2018 the following has occurred: Letters went out to Providers explaining the new process Follow-up phone calls will be made to providers in July and August to discuss: Any questions about the new process Obtain information about office/program hours and any closures or unavailable dates (example: holidays, days not open, staff trainings, etc.) Letters will be sent monthly as ILPs are certified for those certified after July 12, 2018 with phone calls to follow 2

3 On-Site Inspection of Care Regulations 3

4 Purpose of Review The on-site inspections of care of Outpatient Behavioral Health Services providers are intended to: Promote Outpatient Behavioral Health services being provided in compliance with federal and state laws, rules and professionally recognized standards of care Identify and clearly define areas of deficiency where the provision of services is not in compliance with federal and state laws, rules and professionally recognized standards of care Require provider facilities to develop and implement appropriate corrective action plans to remediate all deficiencies identified Provide accountability that corrective action plans are implemented Determine the effectiveness of implemented corrective action plans 4

5 Provider Notification of IOC The provider will be notified no more than 48 hours before the scheduled arrival of the inspection team. It is the responsibility of the provider to provide a reasonably comfortable place for the team to work. When possible, this location will provide reasonable access to the patient care areas and the medical records. 5

6 Program Activity Observation The reviewer will observe at least one program activity. 6

7 Beneficiary/Family Interviews The provider is required to arrange interviews of Medicaid beneficiaries and family members as requested by the IOC team, preferably with the beneficiaries whose records are selected for review. If a beneficiary whose record is chosen for review is not available, then the interview shall be conducted with a beneficiary on-site whose record is not scheduled for review. Beneficiaries and family members may be interviewed on-site, by telephone conference, or both. 7

8 Corrective Action Plans The provider must submit a Corrective Action Plan designed to correct any deficiency noted in the written report of the IOC. The provider must submit the Corrective Action Plan to the contracted utilization review agency within 30 calendar days of the date of the written report. The contractor shall review the Corrective Action Plan and forward it, with recommendations, to the DMS Behavioral Health Unit, the Arkansas Office of Medicaid Inspector General and Division of Behavioral Health Services. 8

9 On-Site Reviews/Desk Reviews 9

10 Notification of Review ILPs will receive 48 hours (two business days ) notification of a scheduled On-Site Visit ILPs will receive a follow-up phone call to establish: Arrival time Review the list of requested documents Give the provider an opportunity to ask questions 10

11 On-Site Review/Desk Reviews On-Site Facility Reviews will be conducted by the following: Mental Health Paraprofessional Mental Health Professional or Both The On-Site Facility Review will be completed within one day when possible. The On-Site Facility Review will include: Review of personnel records Policies and procedures Service/milieu observation Beneficiary/family interviews Staff interviews List of requested documents The provider will need to make space available for the Reviewer. 11

12 On-Site Reviews/Desk Reviews Upon arrival the Beacon Reviewer(s) will provide a list of requested documents to the provider A Clinical Record Review of 20 beneficiary records (or 100% of records if there are less than 20) will be conducted by a Mental Health Professional (MHP) via Desk Review. The MHP conducting the clinical record review will select the records from a list of the ILPs active Medicaid beneficiaries The provider will then make the records available electronically or will submit the records to Beacon for review within 48 hours *On occasion the Clinical Record Review may occur on-site 12

13 Independently Licensed Practitioner Desk Review/Onsite Visit Requested Documents Beneficiary Records for Clinical Desk Review List of ACTIVE Arkansas Medicaid beneficiaries; to include Beneficiary Name Medicaid Number Age Date of Admission 13

14 Independently Licensed Practitioner Desk Review/Onsite Visit Requested Documents Documents for Review Certification as an ILP Policy for Emergency/Crisis Services, which includes 24-hour emergency response capability and a site-specific emergency response plan 14

15 Independently Licensed Practitioner Desk Review/Onsite Visit Requested Documents Personnel Records for Review Current Licensure for professional staff Background Record Checks: Child Maltreatment Adult Maltreatment Criminal Background Evidence that provider meets the standards set forth by DBHS to provide Dyadic Treatment services to beneficiaries age 0-47 months, if applicable 15

16 Independently Licensed Practitioner Desk Review/Onsite Visit Requested Documents Interviews with Beneficiaries/Family Members of Beneficiaries and Staff Beneficiary/Family Member Interviews: Provider staff will be needed to assist Beacon in the beneficiary and family member interview process by providing contact information for the requested beneficiary/family member to interview. Beacon will interview 10% of beneficiaries (or their family members). Staff Interviews: Provider staff will be needed to assist Beacon in the staff interview process by arranging for staff to be available for interview in a timely manner and with minimal disruption. Beacon will need a private office/space to conduct interviews 16

17 Independently Licensed Practitioner Desk Review/Onsite Visit Requested Documents Observation of Service/Milieu Beacon will observe one service during the On-Site Visit: Group therapy session Group activity Staffing or milieu Beacon will not observe Individual therapy Family therapy Provider staff are needed to assist in planning for observation, based upon schedule of activities. Beacon will tour the ILP office site. 17

18 Clinical and Personnel Records Review, Beneficiary/Family Member and Staff Interviews Type of Review/Interview Number/Percentage Clinical Records Reviewed 20 (100% if less than 20 beneficiaries) Personnel Records Reviewed: Staff Interviews: Beneficiary/Family Interviews: 10% of current personnel (minimum of 2, unless there is only one) 10% (minimum of 2, unless there is only one) 10% of current beneficiaries (minimum of 2, unless there is only one; generally, a maximum of 5) 18

19 Submission of Clinical Records for Desk Review Clinical Records may be reviewed onsite or off-site via Desk Review Must be made available/submitted to Beacon within 48 hours after the list of chosen records is given to the provider (if records will be reviewed offsite) The provider will be required to make available the documents requested for each selected clinical record via one of the following: Remote access to provider s Electronic Medical Records (EMR) Uploaded directly to ProviderConnect Scanned and submitted via fax or Desk Review Fax Cover Sheet ARInspectionofCare@beaconhealthoptions.com Please advise the On-Site Beacon Reviewer which method will be used to provide the Clinical Records to Beacon 19

20 Submission of Clinical Records for Desk Review Each beneficiary record should be submitted separately from other beneficiary records in order to remain HIPAA compliant Please submit each beneficiary record in batches: Batch #1 PCP referrals (two most recent) [Counseling Level services only] Mental Health Diagnosis Batch #2 If there is a Master Treatment Plan with treatment goals/objectives [not required] Any Reviews, if any, of Medical Necessity and Treatment Goals and Objectives Batch #3 Progress ([identified date] to present) Missed Appointment notes ([identified date] to present) Communication notes ([identified date] to present) 20

21 Exit Interviews/Conferences Exit Interviews will only be conducted if the Clinical Record Review is conducted on-site. There will be no exit interview conducted for Desk Reviews. 21

22 Reports, Reconsiderations, and Corrective Action Plans 22

23 Report and Corrective Action Plan (CAP) Submission Upon completion of the On-Site Program Review and Clinical Record Review: The Program Review Report and Request for CAP will be submitted to the provider within 30 calendar days of receipt of the provider s clinical records The provider will still be required to submit a CAP within 30 calendar days (unless a reconsideration has been requested) Beacon will track provider submissions and submit received CAPs to the Arkansas DHS Division of Provider Services and Quality Assurance 23

24 Reconsiderations and Appeals The provider may request a reconsideration of a deficiency within 30 calendar days of receipt of the Review Report. Beacon will review the request for reconsideration and determine if the deficiency will be upheld or overturned Beacon will submit the results to the provider via Upon receipt of the reconsideration determination, the provider must submit to Beacon a CAP reflecting those results within 30 calendar days. There is no need to submit a CAP until the results of the reconsideration are received. 24

25 Review Checklists 25

26 Outpatient Behavioral Health Services Checklist Clinical Record Review 26

27 Outpatient Behavioral Health Services Checklist Clinical Record Review Please note that only Questions 1-11 on the Clinical Record Checklist are applicable to ILP providers. 27

28 Outpatient Behavioral Health Services Checklist Clinical Record Review Please note that only Questions 1-11 on the Clinical Record Checklist are applicable to ILP providers. 28

29 Outpatient Behavioral Health Services Checklist Clinical Record Review 29

30 Outpatient Behavioral Health Services Checklist Clinical Record Review 30

31 Outpatient Behavioral Health Services Checklist Clinical Record Review 31

32 Outpatient Behavioral Health Services Checklist Clinical Record Review 32

33 Outpatient Behavioral Health Services Checklist Clinical Record Review 33

34 Outpatient Behavioral Health Services Checklist Clinical Record Review 34

35 Outpatient Behavioral Health Services Checklist Clinical Record Review 35

36 Outpatient Behavioral Health Services Checklist Facility Review 36

37 Outpatient Behavioral Health Services Checklist Facility Review Please note that only Questions 1, 2, 6, 9, and 10 on the Facility Review Checklist are applicable to ILP providers. 37

38 Outpatient Behavioral Health Services Checklist Facility Review Please note that only Questions 1, 2, 6, 9, and 10 on the Facility Review Checklist are applicable to ILP providers. 38

39 Outpatient Behavioral Health Services Checklist Facility Review 39

40 Contacts 40

41 Beacon Contact Information Janice Malone, Manager Clinical Services April Bale, Clinical QA advisor Kerri Brazzel, Project Director 41

42 Thank you 42