Primary Care and Behavioral Health Integration: Co-location for Article 28 and Article 31 Clinics

Transcription

1 Primary Care and Behavioral Health Integration: Co-location for Article 28 and Article 31 Clinics IMPLEMENTATION TOOLKIT Implementation Planning for Co-located Primary Care and Behavioral Health Services (for Article 28 and Article 31 clinics) Last Updated: April 17, 2017 OneCity Health Services 199 Water Street, 31st Floor, New York, NY

2 CONTENTS How to use this Implementation Toolkit... 2 Implementation Planning Goals Checklist... 3 Overview: Primary Care and Behavioral Health Co-location... 4 Preparing for Implementation... 5 Establish Project Workgroup... 5 Implementation Planning... 6 Goal 1: Establish Clinical and Operational Standards for Co-location... 6 Goal 2: Conduct a Needs Assessment... 6 Goal 3: Explore Regulatory Options... 7 Goal 4: Conduct IT Assessment and Gap Analysis... 8 Goal 5: Evaluate Financial Impact of Co-location... 8 Goal 6: Develop Implementation Plan... 9 Appendix A: Standards of Care for Co-location of Primary Care and Behavioral Health Services 10 Appendix B: Needs Assessment Tools Tool for Article 28 Host Site: Needs Assessment and Estimation of Potential Patient Volume 13 Tool for Article 31 Host Site: Needs Assessment and Estimation of Potential Patient Volume 17 Patient Survey Tool: Needs Assessment and Estimation of Potential Patient Volume Reviewing and Interpreting Data (Delphi Method) Appendix C: Evaluating Regulatory Options Regulatory Decision Tree for Article 28 Host to Add Mental Health Regulatory Decision Tree for Article 31 Host to Add Primary Care Regulatory Decision Tree for Article 28 or 31 Host to Add Substance Abuse Appendix D: IT Assessment and Gap Analysis Appendix E: Implementation Plan Template

3 HOW TO USE THIS IMPLEMENTATION TOOLKIT This Implementation Toolkit: Primary Care and Behavioral Health Co-location was developed by OneCity Health to enable primary care and behavioral health partners/sites to plan for the integration and co-location of primary care and behavioral health services. The intended audience for this toolkit is Article 31 and/or Article 28 clinics. This toolkit also provides guidance on integrating substance abuse services (Article 32) into either an Article 28 and/or an Article 31 host site. This toolkit edition is intended for use in conjunction with on-site consultation support provided by OneCity Health. This toolkit provides guidance as to implementation planning for co-location, but is not intended to replace a health care organization s independent legal, regulatory, and financial analysis as part of its internal planning activities. In addition, please note that the legal, regulatory, and financial environment is subsequent to change over time. SYMBOL KEY Important implementation consideration ONECITY HEALTH SUPPORT DESK If you have any questions, please contact the OneCity Health support desk: Phone Number: ochsupportdesk@nychhc.org, with the subject line PCBH Co-location Question Hours of Operation: Monday through Friday from 9am to 5pm ET 2

4 Implementation Planning Goals Checklist PREPARING FOR IMPLEMENTATION Key Tasks Owner Deadline Establish a PCBH Co-location Workgroup IMPLEMENTATION PLANNING Implementation Planning Goals Owner Deadline Goal 1: Establish Clinical and Operational Standards for Co-location Goal 2: Conduct a Needs Assessment Goal 3: Explore Regulatory Options Goal 4: Conduct IT Assessment and Gap Analysis Goal 5: Evaluate Financial Impact of Co-location Goal 6: Develop Project Implementation Plan 3

5 OVERVIEW: PRIMARY CARE AND BEHAVIORAL HEALTH CO-LOCATION BACKGROUND In the United States, 29% of the adult population has both a mental health condition and a chronic medical condition. Medical and behavioral comorbidities are burdensome for patients and families and fragmented care results in poor outcomes and higher costs. Individuals with behavioral and/or substance abuse disorders often have untreated and preventable chronic illnesses like hypertension, diabetes, obesity, and cardiovascular disease that are aggravated by lack of access to appropriate primary care services and challenges navigating complex healthcare systems. Integrated, collaborative care is the systematic coordination of primary care and behavioral health services and the most effective approach to caring for people with multiple healthcare needs. Providing options for coordinated, accessible behavioral health and primary care services to meet a spectrum of patient needs across settings can improve both mental and physical health outcomes. Co-location of behavioral health services into primary care, and/or of primary care services into outpatient behavioral health settings, allows for greater co-location of services within a single setting. PROJECT OBJECTIVE The objective of this project is to integrate behavioral health, including mental health and substance abuse, with primary care to ensure coordination of care for both services. Colocation of behavioral health and primary care services can serve to: 1) identify behavioral and physical comorbid diagnoses early, allowing for more efficient and timely treatment; 2) ensure treatments for medical and behavioral health conditions are compatible and do not cause adverse effects; and 3) de-stigmatize treatment for behavioral health diagnoses. This toolkit supports implementation planning for co-located services to meet patient needs. The approach is applicable to both the co-location of behavioral health into primary care (Article 28 host site) and the co-location of primary care into behavioral health (Article 31 host site). The toolkit also provides guidance on integrating substance abuse services into either an Article 28 and/or Article 31 host site. 4

6 PREPARING FOR IMPLEMENTATION Establish Project Workgroup PCBH Co-location Workgroup As appropriate for your practice, establish a workgroup that includes individuals you think will be critical to your success in planning for implementation of this project. It will be important to include expertise from both primary care and psychiatry. Consider including workgroup members from a variety of backgrounds and roles, such as: Physician Nursing Social work Psychiatry Substance abuse specialists Care coordination/case management Pharmacy Health education Other relevant resources available in your setting Implementation Leader Identify an implementation leader to oversee the implementation. Specific tasks include: Engaging with clinical and administrative leadership to advocate for implementation and provide progress updates and reports Organizing workgroup and scheduling and facilitating meetings Ensuring that any necessary trainings are scheduled and attended Collaborating with OneCity Health to access support, training and materials Monitoring and troubleshooting implementation Ensuring that all steps of the project are completed on time Clinical Champion(s) A clinical champion must be well-positioned and able to engage, educate and lead others in the site-level implementation. Specific activities of the champion include: Engaging and advocating for co-location with clinical leaders Collaborating with clinical staff to ensure they have the tools and resources needed Working closely with the implementation leader to ensure that necessary training and support, including staff time, is in place Ensuring that the site s implementation planning is geared towards effectively improving patient outcomes 5

7 IMPLEMENTATION PLANNING Implementation Planning Goals Goal 1: Establish Clinical and Operational Standards for Co-location Goal 2: Conduct a Needs Assessment Goal 3: Explore Regulatory Options Goal 4: Conduct IT Assessment and Gap Analysis Goal 5: Evaluate Financial Impact of Colocation Goal 6: Develop Project Implementation Plan Implementation Toolkit Resources Appendix A: Standards of Care for Colocation of Primary Care and Behavioral Health Services Appendix B: Needs Assessment Tools Appendix C: Evaluating Regulatory Options Appendix D: IT Assessment and Gap Analysis (Financial model to be provided during onsite visit by consultant) Appendix E: Implementation Plan Template Goal 1: Establish Clinical and Operational Standards for Co-location As the work of implementation planning begins, the workgroup should begin to discuss clinical and operational standards of care. A framework for clinical and operational standards of care is provided in Appendix A. This framework addresses co-location of behavioral health services in primary care, co-location of primary care health services in behavioral health settings, and integration of substance abuse screening and treatment into both these settings. Review the Standards of Care for Co-location with your Workgroup to encourage a shared understanding of the goals for program design and planning. These standards may need to be adjusted to meet the needs and capabilities of your organization. The workgroup may wish to consider both aspirational goals for clinical and operational standards that the organization can work towards over time, and short-term goals that can be operationalized in the shorter term with available staff, space, and funding. Goal 2: Conduct a Needs Assessment PURPOSE A needs assessment will enable your organization to better understand the potential unmet demand for co-located services, and to estimate the percentage of patients with those needs who would be likely to engage the service. This projected volume will be used to plan for the number and type of staff required, as well as for space and equipment needed for co-located services. 6

8 APPROACH TO NEEDS ASSESSMENT The site-specific needs-assessment process takes into account clinical data, current service utilization, and patient preferences. If the host site is an Article 31 behavioral health clinic, the needs assessment focuses on physical health conditions that would be triggers for utilization of primary care services. If the host site is an Article 28 primary care clinic, then the assessment focuses on behavioral health needs. Both Article 31 and Article 28 host sites should also consider the substance abuse treatment needs of their patients. Appendix B includes the following tools to conduct a needs assessment: 1. Tool for Article 28 Host Site: Needs Assessment and Estimation of Potential Patient Volume 2. Tool for Article 31 Host Site: Needs Assessment and Estimation of Potential Patient Volume 3. Patient Survey Tool: Needs Assessment and Estimation of Potential Patient Volume 4. Implementation Lead Facilitation Guide: Needs Assessment and Estimation of Potential Patient Volume Using the information gathered in the needs assessment, the anticipated patient volume and characteristics of the patient population should be used to estimate needed resources for staffing and space. When the ability to increase staffing or space is limited, the workgroup should consider approaches that target a manageable subset of the potential patient demand, for example, by focusing on subgroups of patients that clinical leadership identifies as being at higher risk of poor outcomes in the absence of co-located services. Goal 3: Explore Regulatory Options The workgroup should explore the various regulatory options that will facilitate co-location at their site. Practice sites have several regulatory options to support the co-location of primary care and behavioral health services: Existing license threshold limitations Integrated Outpatient Services (IOS) License DSRIP Threshold Waiver Establish a satellite clinic Partner with an outside organization 7

9 The following supporting materials are provided in Appendix C to help guide the site to understand their regulatory options and decide which option to pursue: Regulatory Option Decisions Trees The final decisions on regulatory options may not be made until further implementation planning is completed. Nonetheless, it is important to understand the regulatory options early in the implementation planning process. This toolkit provides guidance as to regulatory options, but is not intended to replace a health care organization s independent legal, regulatory, and financial analysis as part of its internal planning activities. In addition, please note that the regulatory environment is subsequent to change over time. Goal 4: Conduct IT Assessment and Gap Analysis The workgroup should conduct an IT assessment and gap analysis to determine if any modifications needs to made to the current IT systems to support co-location of services. The purpose of the Information Technology (IT) Assessment and Gap Analysis is to assess (1) readiness for clinical documentation of integrated services and (2) ability to provide information to the organization s billing system to enable claims submission. The IT Assessment also evaluates the ability of the system to support best practices for use of electronic systems, such as two level assessment (in which a positive screening tests automatically leads to initiation of a follow-up assessment tool). The IT Assessment and Gap Analysis can be found in Appendix D and is designed to be completed by a clinic administrator familiar with the operational use of the EHR. Goal 5: Evaluate Financial Impact of Co-location The financial impact of co-location will depend on site-specific factors including the result of the needs assessment, staffing models and related costs, and decisions about regulatory options. OneCity Health will provide an Excel-based financial model in the course of the on-site consultation engagement. The model allows organizations to test the impact of different colocation approaches on financial outcomes. The workgroup should explore various implementation scenarios using the financial model to refine the implementation model. 8

10 Goal 6: Develop Implementation Plan Based on the information gathered and the options that have been explored during this process, the workgroup should establish what model of integration the site would like to pursue and develop an implementation plan. The Implementation Plan Template found in Appendix E can be used to structure and document an implementation plan. 9

11 APPENDIX A: STANDARDS OF CARE FOR CO-LOCATION OF PRIMARY CARE AND BEHAVIORAL HEALTH SERVICES INTRODUCTION This section describes a suggested framework for co-location of behavioral health and adult primary care services. These standards of care address co-location of behavioral health services in primary care, co-location of primary care health services in behavioral health settings, and integration of substance abuse screening and treatment into both these settings. This suggested framework should be reviewed and adjusted to meet the needs of your organization. Principles that underlie this framework include: Organizations planning for co-location should define what populations they wish to serve in the co-located setting. Once the population health needs are described and quantified, the organization can define resource needs and plan a co-location program of the right size and type for that setting. For patients whose needs cannot be adequately met in the co-located setting, the organization should refer them to an appropriate setting for ongoing management or refer them for the discrete services that the co-located setting cannot provide. Organizations will benefit from defining parameters to inform decisions about appropriate referrals and from building relationships with colleagues who receive referrals. Organizations vary widely in characteristics such as the size and composition of the patient population, staffing models, space, and strategic priorities. This framework is intended to create a common framework while allowing organizations to operationalize co-location differently in terms of targeted patient population, use of staff, and balance between internally provided services vs. referred services. Co-located health care requires non-physician staffing roles, processes, and supplies, and organizations should plan for these needs in advance. In most primary care settings, the collaborative care model should be in place prior to embarking on co-location. The collaborative care model provides a foundation for integrative care processes and ensure that primary care teams are comfortable managing less complex behavioral health conditions. Successful co-location will be harder if the collaborative care model is not effective and fully engaged. 10

12 Over time, organizations may evolve their co-location models, for example, by broadening the scope of patients served by the co-located providers and/or creating internal resources for services that previously required referral. The framework views substance abuse services as critical for co-location into both primary care and behavioral health settings. PRIMARY CARE SETTING: TIERED APPROACH TO BEHAVIORAL HEALTH TREATMENT Patients with lower acuity behavioral health needs will be cared for in a collaborative care model supported by the primary care physician or mid-level in the primary care setting o Mild to moderate depression o Anxiety with mild symptoms o Severe mental illness (SMI) with stability o Uncomplicated substance abuse Patients with serious mental health disorders (e.g. schizophrenia, bipolar disorder, severe depression, psychoses) may choose to be seen by a co-located psychiatrist or psychiatric nurse practitioner, preferably supported by psychologist or social worker o Schizophrenia, bipolar disease, severe depression, psychoses Patients who are highly unstable and require substantial outreach will be offered care and may choose to be seen in a discrete behavioral health setting o Patients who would benefit from a broader array of therapeutic interventions, or who need access to specialized behavioral health care with high frequency BEHAVIORAL HEALTH SETTING: APPROACH TO PRIMARY CARE SERVICES Patients in a behavioral health setting who have no or limited ongoing engagement with primary care may benefit from initiating care in an integrated setting. The behavioral health clinic may choose to identify and prioritize specific types of patients who are most at risk for not receiving adequate primary care, and organize services to meet their needs. Patients are closely monitored and treated for side effects of drug therapy (e.g. cardiovascular disease and diabetes mellitus) Patients receiving primary care in the behavioral health setting should receive a standard range of primary care services either on site or via referral. Planning should address core primary care needs, such as: o Annual physical and health assessment, vital signs with pulse oximetry, lab work, EKG, peak flow o Age and risk factor driven disease screening and preventive care, including vaccinations 11

13 o Women s health, including Pap smears and contraception o Point of care testing as appropriate, such as pregnancy tests, stool occult blood, urinalysis, rapid strep testing, and blood glucose o Periodic monitoring of chronic health conditions per plan of care, with registry functions to support panel management approach as available o Episodic care of acute conditions such as upper respiratory infection, rashes, minor injuries, etc. o Referral and coordination of care by specialists as needed o Referral to care management resources as appropriate o Processes to address quality metrics, including those monitored by managed care organizations TIERED APPROACH TO CARE OF PERSONS WITH SUBSTANCE ABUSE ISSUES IN EITHER PRIMARY CARE OR BEHAVIORAL HEALTH SETTING Patients with lower acuity substance abuse needs may receive care by the primary care or behavioral health provider, in a collaborative care model with support as needed by an addiction specialist. o Implementation of screening tools requires staff orientation and training, and integration into clinic workflows Patients with more complicated substance abuse issues may have a warm hand-off to a co-located substance abuse professional who is embedded in the primary care or behavioral health setting Patients who are unstable and require substantial outreach will be offered an episode of brief treatment and encouraged to engage with a specialty substance abuse treatment clinic for ongoing care o Sites should identify addiction treatment services to which patients may be referred as appropriate for long-term or complicated substance abuse services. 12

14 APPENDIX B: NEEDS ASSESSMENT TOOLS BACKGROUND There are no validated or even practice-tested tools for estimating the number of patients who are likely to utilize integrated services. Sample data collection tools for Article 28 and Article 31 host sites are available in this Appendix. This Appendix also describes a suggested process using the Delphi Method to review the locally collected data to a panel of experts for interpretation and thereby estimate the expected level of engagement and service utilization by patients in the newly offered services. Tool for Article 28 Host Site: Needs Assessment and Estimation of P otential Patient Volume Instructions: Collect the data described in criteria from the description of potential data sources listed. You may use additional or alternative sources of data you feel may be relevant. The findings should be discussed with clinical and administrative leadership encourage consensus around the estimated potential patient volume. When the host clinic is an Article 28 primary care clinic, seeking to integrate behavioral health services, use the following tool to estimate potential patient volume: Criteria Suggested Data Sources Site s Data Source Findings Notes Patients who screen for behavioral health issues and not under care for these issues Report from electronic health record system of routinely utilized behavioral health When clinic has a collaborative care program, seek data on how many of these patients are engaged in program screens such as PHQ-9 Collaborative care program referral and enrollment data 13

15 Criteria Suggested Data Sources Site s Data Source Findings Notes If site has a collaborative care program, patients who screen for behavioral health issues, not under care for same, and who are not eligible for inclusion in program (e.g. acuity, not in covered payer class, etc.) Collaborative care program referral and enrollment data Patients who are in collaborative care program and would benefit from a higher intensity of services, and would be likely to choose them Services already provided by behavioral health professionals in clinic under current threshold allowances Patients who indicate difficulty with engagement with behavioral health provider Additional Criteria: Reports of referrals from the collaborative care program to behavioral health services outside of the Article 28 clinic Consult volume reports of psychiatrists, psych nurse practitioners, or psychologists already providing services in the clinic Patient Survey Sample survey available in Appendix B 14

16 Criteria Suggested Data Sources Site s Data Source Findings Notes Additional Criteria: If your Article 28 host site seeks to also integrate substance abuse services, use this tool to estimate potential volume of patients likely to utilize the expanded service: Criteria Suggested Data Sources Site s Data Source Findings Notes Patients who screen for substance abuse issues and not under care for same When clinic has a collaborative care program for substance abuse, seek data on how many of these patients are engaged in program If site has a collaborative care program for substance Report from electronic health record system of routinely utilized substance about screens such as the SBIRT, AUDIT, DAST, etc. Collaborative care program referral and enrollment data Collaborative care program referral and enrollment data A study shows these tools yielding 20% of a primary care clinic population and can be used as a proxy if screening data is unavailable 15

17 Criteria Suggested Data Sources Site s Data Source Findings Notes abuse, patients who screen for substance abuse issues, not under care for same, and who are not eligible for inclusion in program (e.g. acuity, not in covered payer class, etc.) Services already provided by substance abuse professionals in clinic under current threshold allowances Patients who indicate difficulty with engagement with substance abuse provider Additional Criteria: Consult volume reports of substance abuse specialists already providing services in the clinic Patient Survey Sample survey available in Appendix B Additional Criteria: 16

18 Tool for Article 31 Host Site: Needs Assessment and Estimation of Potential Patient Volume Instructions: Collect the data described in criteria from the description of potential data sources listed. You may use additional or alternative sources of data you feel may be relevant. The findings should be discussed with clinical and administrative leadership encourage consensus around the estimated potential patient volume. When the host clinic is an Article 31 behavioral health clinic, seeking to integrate primary care services, use the following tool to estimate potential patient volume: Criteria Suggested Data Sources Site s Data Source Findings Notes Patients without an annual wellness visit The electronic health record system of the clinic often has a report for patients missing documentation of an annual health or medical assessment. The site may also have quality assurance reports tracking this Percentage of patients with selected physical health conditions (e.g. diabetes, hypertension, hyperlipidemia, coronary artery disease, obesity, etc.) information. From site claims data or EMR data extraction, determine percentage of population represented in each of the selected health condition groups These percentages, when compared to the community averages in the available hospital or DSRIP community needs assessment, offer insight into how the clinic populations need compares to the community as a whole, 17

19 Criteria Suggested Data Sources Site s Data Source Findings Notes and can serve as a proxy for likely unmet needs. Number of patients who show lab values or other signs of having significant side effects of psychotropic medications such as diabetes, cardiovascular disease, etc. Patients who indicate difficulty with engagement with primary care provider Additional Criteria: When the Article 31 clinic is licensed for and provides health monitoring, data from the nurse or other staff engaged in this activity is useful for understanding the scope of issues. Their insights into the success of patients engaging with outside primary care providers for addressing these issues is also useful. Patient Survey Sample survey available in Appendix B Additional Criteria: 18

20 If your Article 31 host site seeks to also integrate substance abuse services, use this tool to estimate potential volume of patients likely to utilize the expanded service: Criteria Suggested Data Sources Site s Data Source Findings Notes Patients who screen for substance abuse issues and not under care for same When clinic has a collaborative care program for substance abuse, seek data on how many of these patients are engaged in program If site has a collaborative care program for substance abuse, patients who screen for substance abuse issues, not under care for same, and who are not eligible for inclusion in program (e.g. acuity, not in covered payer class, etc.) Report from electronic health record system of routinely utilized substance about screens such as the SBIRT, AUDIT, DAST, etc. Collaborative care program referral and enrollment data Collaborative care program referral and enrollment data A study shows these tools yielding 20% of a primary care clinic population and can be used as a proxy if screening data is unavailable 19

21 Criteria Suggested Data Sources Site s Data Source Findings Notes Services already provided by substance abuse professionals in clinic under current threshold allowances Consult volume reports of substance abuse specialists already providing services in the clinic Patients who indicate difficulty with engagement with substance abuse provider Additional Criteria: Patient Survey Sample survey available in Appendix B Additional Criteria: 20

22 Patient Survey Tool: Needs Assessment and Estimation of Potential Patient Volume Instructions: Survey a convenient sample of patients (for example, these questions could be addressed to all patients seen on one day in clinic) to learn about their satisfaction with and level of engagement with primary care or behavioral health providers. The sample size should be at least 30 patients. You may want to add additional questions to this survey, to focus on particular areas of potential need for your population. When the host clinic is an Article 28 primary care clinic, seeking to integrate behavioral health services, a questionnaire for patients use the following or similar questions to estimate potential patient volume should be used: Recommended Questions Data Notes Q1: Do you currently have a counselor or psychiatrist who you can see for a behavioral health need if you had one? Q2: If yes, have you seen them within the past year? Q3: If you could switch to see a behavioral health counselor or psychiatrist here, would you do so? When the host clinic is an Article 31 behavioral health clinic, seeking to integrate primary care services, a questionnaire for patients use the following or similar questions to estimate potential patient volume should be used: Recommended Questions Data Notes Q1: Do you have a doctor who takes care of your ongoing medical needs (such as annual physical exams, medications for ongoing medical problems, and visits for when you are sick? Q2: If yes, have you seen that doctor within the past year? Q3: If you could switch to receive your medical care in this clinic, would you do so? When an Article 28 or an Article 31 clinic is seeking to integrate substance abuse services, a questionnaire for patients use the following or similar questions to estimate potential patient volume should be used: 21

23 Recommended Questions Data Notes Q1: Do you have a doctor or other professional who assists you with issues related to alcohol or drug use? Q2: If yes, have you seen that doctor or professional within the past year? Q3: If you could switch to receive your substance care in this clinic, would you do so? Reviewing and Interpreting Data (Delphi Method) Step 1: Identify Your Experts The Delphi technique relies on a panel of experts. An expert is, any individual with relevant knowledge and experience of a particular topic. 1 In this case, the experts should be clinic leaders or staff who have a good understanding of the patient population, their needs, and their usual patterns of service utilization. The panel should include 6 to 12 members. Step 2: Define the Problem Estimating how many patients need the planned co-located service that are likely to engage and use the service. Step 3: Round One Question Ask the panel of experts: Of the patients identified as being in need of the service to be colocated at the host site, what percentage would be likely to follow up on referrals for needed services in the currently non-integrated model? Step 4: Round Two Questions Ask the panel of experts: Of the patients identified as being in need of the service to be integrated into the host site, what percentage will be likely to engage and utilize the service when the service is offered in an integrated model? Step 5: Analysis Hone in on the areas of agreement, dropping off outliers. You may wish to have more rounds of questioning to reach a closer consensus. After these rounds of questions, your experts will reach a consensus on a projected volume of patients likely to utilize the service. 1 Cantrill JA, SibbaldB, Buetow S. The Delphi and Nominal Group Techniques in Health Services Research. International Journal of Pharmacy Practice 1996;4:

24 APPENDIX C: EVALUATING REGULATORY OPTIONS Regulatory Decision Tree for Article 28 Host to Add Mental Health This toolkit provides guidance as to implementation planning for co-location, but is not intended to replace a health care organization s independent legal, regulatory, and financial analysis as part of its internal planning activities. In addition, please note that the legal, regulatory, and financial environment is subsequent to change over time. 23

25 Regulatory Decision Tree for Article 31 Host to Add Primary Care This toolkit provides guidance as to implementation planning for co-location, but is not intended to replace a health care organization s independent legal, regulatory, and financial analysis as part of its internal planning activities. In addition, please note that the legal, regulatory, and financial environment is subsequent to change over time. 24

26 Regulatory Decision Tree for Article 28 or 31 Host to Add Substance A buse This toolkit provides guidance as to implementation planning for co-location, but is not intended to replace a health care organization s independent legal, regulatory, and financial analysis as part of its internal planning activities. In addition, please note that the legal, regulatory, and financial environment is subsequent to change over time. 25

27 APPENDIX D: IT ASSESSMENT AND GAP ANALYSIS Instructions: Complete the IT Assessment and Gap Analysis with clinic administrator or other individual who is familiar with the system capabilities and operational use. If a question or category of questions do not relate to the site or the intended integrated services, nonapplicable is selected (N/A). If the person being interviewed is unsure of the system s capabilities, unsure (??) is selected. Any areas of concern or gaps in functionality should be flagged in the gap analysis and an appropriate mitigation should be developed. Site Date Completed Scope of Care Primary Care Services Mental Health Substance Abuse Provided Planned N/A Electronic Documentation EMR System Paper Documentation Hybrid Documentation PRIMARY CARE IT CAPABILITY No. Primary Care IT Capability 1.01 System is able to secure sensitive areas of documentation with role specific access (e.g. Psychiatry notes only accessible to Psychiatrist) *Critical 1.02 System has preformatted templates for primary care assessments 1.03 System has integrated screening tool for mental health 1.04 System has integrated screening tool for substance abuse 1.05 System has capability and is configured for two level screen single question assessment, triggering longer assessment if positive 1.06 System has the ability and is configured to flag and alert for periodic reassessments (e.g. annual screen for substance abuse, vaccines, mammography) 1.07 System has preformatted template for primary care treatment plan YES NO?? N/A Notes 26

28 No. Primary Care IT Capability 1.08 System has preformatted template for primary care follow up visits 1.09 System has the ability and is configured for provider to view the schedule and availability of another provider 1.10 System has the ability and is configured for primary care provider to schedule a contiguous visit with integrated care provider 1.11 System has the ability and is configured to track referrals 1.12 System has the ability and is configured to provide billing system with necessary data to produce merged claim for single or multidiscipline integrated services same date *Critical 1.13 System is able to migrate level I ordered ancillary services to claim as applicable to host & site *Critical YES NO?? N/A Notes MENTAL HEALTH IT CAPABILITY No. Mental Health IT Capability 2.01 System is able to secure sensitive areas of documentation with role specific access (e.g. Psychiatry notes only accessible to Psychiatrist)*Critical 2.02 System has preformatted templates for mental health care assessments 2.03 System has capability and is configured to track annual health assessment &/or health monitoring and smoking cessation 2.04 System has integrated screening tool for substance abuse 2.05 System has capability and is configured for two level screen single question assessment, triggering longer assessment if positive 2.06 System has the ability and is configured to flag and alert for periodic reassessments (e.g. annual screen for substance abuse) YES NO?? N/A Notes 27

29 No. Mental Health IT Capability 2.07 System has preformatted template for mental health care treatment plan 2.08 System has preformatted template for mental health care follow up visits (E/M, psychotherapy individual & group) 2.09 System has the ability and is configured for provider to view the schedule and availability of another provider 2.10 System has the ability and is configured for primary care provider to schedule a joint visit with integrated care provider 2.11 System has the ability and is configured to track referrals 2.12 System has the ability and is configured to provide billing system with necessary data to produce merged claim for single or multidiscipline integrated services same date *Critical YES NO?? N/A Notes SUBTSANCE ABUSE IT CAPABILITY No. Substance Abuse IT Capability 3.01 System is able to secure sensitive areas of documentation with role specific access (e.g. Psychiatry notes only accessible to Psychiatrist) *Critical 3.02 System has preformatted templates for substance abuse health care assessments 3.03 System has capability and is configured to track annual health assessment 3.04 System has integrated screening tool for mental health issues 3.05 System has capability and is configured for two level screen single question assessment, triggering longer assessment if positive 3.06 System has the ability and is configured to flag and alert for periodic reassessments (e.g. annual screen for depression) YES NO?? N/A Notes 28

30 No. Substance Abuse IT Capability 3.07 System has preformatted template for substance abuse care treatment plan 3.08 System has preformatted template for substance abuse care follow up visits (individual and group counseling-med admin) 3.09 System has the ability and is configured for provider to view the schedule and availability of another provider 3.10 System has the ability and is configured for primary care provider to schedule contiguous visits with integrated care provider 3.11 System has the ability and is configured to track referrals 3.12 System has the ability and is configured to provide billing system with necessary data to produce merged claim for single or multidiscipline integrated services same date *Critical YES NO?? N/A Notes OTHER STANDARDS No. Other Standards YES NO?? N/A Notes 4.01 Ability to document duration of service or ST/SP time as required for service or clinic regulations 4.02 Ability to set global alert for UR/ QA reviews per regulatory standards as applicable GAP ANALYSIS AND MITGATION PLAN Gap Analysis No. Issue Critical or Workable Mitigation Recommendation Mitigation Plan Resources Needed for Mitigation 29

31 APPENDIX E: IMPLEMENTATION PLAN TEMPLATE Scope Goal Planned Action Steps Regulatory Site will apply for [Insert action steps] selected regulatory option to support colocation Staffing Space Equipment and supplies Information Technology Site will develop a staffing plan and budget for the colocation activities including both professional and ancillary staff Based on the space needs identified, site will develop a plan and budget to prepare the necessary treatment, counseling, or group rooms required Based on the colocation activity to be pursued, anticipated volume, and the number of rooms required by the implementation plan, site will develop an equipment/supply plan Site will develop a plan for the utilization of the current information [Insert action steps] [Insert action steps] [Insert action steps] [Insert action steps] Site Resources Identify key person at each site who is responsible for regulatory license application submissions Involve the applicable leadership, clinic administrator, ambulatory care nursing administrator and the site administrator responsible for allocation of resources for staffing Involve the applicable leadership, clinic administrators, and facilities administrator Involve the applicable leadership, clinic administrators, and supply chain administrator for pricing Involve the applicable leadership, clinic administrators, and IT administrator 30

32 Scope Goal Planned Action Steps technology platform to document and communicate for integrated care Billing for Services Site will develop a plan [Insert action steps] for the development of the necessary workflows and processes required to bill for the new colocation activity Clinical Workflow Site will develop [Insert action steps] clinical workflow plans for the co-location activities incorporating standards of care, meeting key quality indicators, and processes for screening, referral, treatment, tracking, and follow up. Plan to include related activities such as process for after-hours support, prescription renewals, etc. Site Resources Involve the applicable leadership, clinic administrators, and revenue cycle administrator Involve the applicable leadership, clinic administrators, and nursing administrator for ambulatory care 31