RSPMI Quarterly Training Presented by: ValueOptions /DMS/DBHS/HP 1
DBHS CONTACT INFORMATION Mailing Address: 305 South Palm Street Little Rock, AR 72205 Physical Address: 4800 W. 7 th Charlotte Carlson, M.Ed., M.S., J.D. Director of Policy and Certification Phone:(501) 683 6903 Email: Charlotte.Carlson@arkansas.gov Tullos (Tripp) Franks, LCSW Clinical Specialist of Policy and Certification Phone: (501) 683 6999 Email: Tullos.Franks@arkansas.gov 2
DBHS CONTACT INFORMATION Mailing Address: 305 South Palm Street Little Rock, AR 72205 Physical Address: 4800 W. 7 th Sarah Steppach Policy and Certification Assistant Phone:(501) 683 6971 Email: Sarah.Steppach@arkansas.gov Sabrina Raveendran Policy and Certification Assistant Phone: (501) 683 6971 Email: Sabrina.Raveendran@arkansas.gov 3
DBHS CERTIFICATION MANUAL AVAILABLE AT: www.arkansas.gov/dhs/dmhs/rspmi.htm ALSO AVAILABLE AT THE WEBSITE: ANSWERS TO FREQUENTLY ASKED QUESTIONS (FAQ S) 4
I. Updates on Re Certification Process under Current RSPMI Policy 5
UPDATES ON RE CERT COMPLIANCE TIMELINES & ASSURANCES See DBHS RSPMI Policy IV, A(page 5) A. Certified RSPMI providers in operation as of the effective date of this rule must comply with this rule within forty five calendar days. ACCOMPLISHING ASSURANCE ValueOptions Role as of March 23,2011 DBHS Review 6
Role of ValueOptions in DMS Compliance and DBHS Certification 7
Role I: Document Collector and Courier for DBHS 8
Document Collector and Courier for DBHS During on-site audits, the following documents are being collected by ValueOptions on behalf of DBHS: Provider Information Form (completed by Provider) Provider RSPMI Services Disclosure Form(s) Provider Policy for Family Engagement in Treatment for persons under age 18 Provider Policy for Emergency Services Documentation of Emergency Services Calls, Responses, Collaborations, and Outcomes and Documentation of Review by Clinical Supervisor or Emergency Services Director within 24 hours Documentation of Emergency Services Training for Professional and Paraprofessional Personnel Documentation of Supervision Provided for MHP and MHPP Personnel ** For the convenience of providers, the above list of documents is included in the ValueOptions Notification Letter sent two days in advance of the scheduled audit. 9
Document Collector and Courier for DBHS [CONTINUED] ValueOptions does not in any way recommend or participate in certification by DBHS. ValueOptions does audit for some items contained in the documentation collected on behalf of DBHS. [The draft Outpatient IOC Audit Checklist - Facility Review is available is on the ValueOptions web site] If providers do not submit the requested DBHS documentation to ValueOptions, it is noted in the audit report, and ValueOptions notifies DBHS. The currently requested documents are being collected only once--will not be requested again in future audits. 10 *** Except otherwise specified by DBHS, in which case, the provider will be notified on the ValueOptions Notification Letter.
Document Collector and Courier for DBHS [CONTINUED] Submission of DBHS Documents Providers may deliver the requested DBHS documents by: Hard (paper) copy, or CD 11
I. DBHS RSPMI Re Certification Process DBHS RSPMI POLICY XII: PROVIDER RE CERTIFICATION PAGE: 22 12
DOES YOUR CERTIFICATION EXPIRE THIS YEAR? 13
NEVER MIND FOR 2011!!!!! 14
Checklist for RSPMI Recertification: 1. DBHS Form #3 (RSPMI Recertification Form) 2. Attachment #1 (Provider Release of Information) 3. Accreditation Survey Report 4. Corrective Action Plan or Quality Improvement Plan 15
QUESTIONS? 16
II. Accurate Provider Information 17
ValueOptions Role 11: Site Location and Administrative Issues Reporting 18
Site Location and Administrative Issues Reporting The Arkansas Medicaid RSPMI Manual requires that providers with multiple sites must apply for enrollment for each site. (202.200) ValueOptions reports to DMS and DBHS, when in the course of business (audit, PA request, etc.), ValueOptions learns that a provider: is operating an uncertified site is pairing beneficiaries with a site other than the beneficiary s primary service site has moved a site to a new location without reporting the move to DBHS is using the incorrect certification number for a site has had a change in CEO that has not been reported to DBHS 19
ACCURATE PROVIDER INFORMATION See DBHS Policy XIII, A:2,3 (Page 22 23) 2. Assure that DBHS certification information is current, and to that end must notify DBHS within thirty (30) calendar days of any change affecting the accuracy of the provider s certification records; 3. Furnish DBHS all correspondence in any form (e.g., letter, facsimile, email) to and from the accrediting organization to DBHS within thirty (30) calendar days of the date the correspondence was sent or received except: a. As stated in XII; b. Correspondence related to any change of accreditation status, which providers must send to DBHS within three (3) calendar days of the date the correspondence was sent or received. c. Correspondence related to changes in service delivery, site location, or organizational structure, which providers must send to DBHS within ten (10) calendar days of the date the correspondence was sent or received. Providers must report all changes 20
MEDICAID RULES EYVONNE CARBAGE EMAIL: EYVONNE.SHE.CARBAGE@HP.COM PHONE: (501) 374 6609, EXT: 496 21
Provider Enrollment Provider must complete: Change of Address Change of Address Form or write a letter stating the address has changed (must be signed) Attach a copy of the letter from DBHS showing the certification transfers from the old address to the new address 22
Provider Enrollment CEO Change Provider must complete the following: Send a letter from the owner stating the change with signature and date Disclosure of Significant Business Transactions Form Ownership and Conviction Disclosure Contract 23
Provider Enrollment 24 Name Change Provider must complete the following: Send Articles of Incorporation Disclosure of Significant Business Transactions Form Ownership and Conviction Disclosure If non profit, attach copy of 501C3 in new name, or letter from IRS showing they received and accepted the name change If using a DBA (Doing Business As), attach a copy of the Secretary of State Showing the Legal and fictitious name registered Certification letter from DBHS showing the new name Contract
Provider Enrollment Change of Ownership (tax number, licensure or new owner) Provider must complete the following: Change of Ownership Form New application Disclosure of Significant Business Transactions Form Ownership and Conviction Disclosure Contract 25
Provider Enrollment All forms should be signed by one of the following: Owner, CEO, CFO, COO, President/Vice President of Facility, Director/Co Director of facility If the individual is not one of the above, you must also attach a copy of a letter from the CEO or minutes from the Board of Directors granting permission for the individual to sign off on all formal contracts with Arkansas Medicaid. 26
Provider Enrollment Applications are located on the Arkansas Medicaid website at https://www.medicaid.state.ar.us/. Click Provider at the top of the page or on the word Provider in the picture. Enrollment is on the left hand side of the screen. Click Provider Enrollment; then click Printable enrollment related forms. 27
28 Provider Enrollment
29 Provider Enrollment
30 Provider Enrollment
Provider Enrollment Contact Information Mailing Address: Provider Enrollment HP Enterprise Services PO Box 8105 Little Rock, AR 72203 Physical Address: Provider Enrollment HP Enterprise Services 500 President Clinton Ave, Suite 400 Little Rock, AR 72201 Phone Numbers: 800 457 4454 option 0, then 3 501 376 2211 31
32 Question & Answer
ADMINISTRATION CHANGES DBHS RSPMI Manual VII: CEO (DBHS Policy VII, E:1. Page 9) Clinical Director (DBHS Policy VII, E:2. Page 9 10) CCO (DBHS Policy VII, E:4. Page 12) Medical Director (DBHS Policy VII, E:5. Page 12) Any Changes in Managerial Staff Require Disclosure Forms 33
Checklist for Change in Administration for an RSPMI Provider: A letter on agency letterhead notifying us of these changes and the date the change is effective Please verify that this is a full time (or equivalent) position A copy of new appointee s current resume A copy of any applicable licenses Copies of your notification to your accrediting agency Acknowledgement from you accrediting agency that this change has been made Disclosure forms DMS 675 and DMS 689 34
SITE MOVES/RELOCATIONS TRANSFERS & CLOSINGS See DBHS RSPMI Manual XI, E, 1, 2, & 3 for service site transfer timelines and requirements. 35
SITE TRANSFER E. Site Transfer: See DBHS Policy XI, E (Page 21 22) 1. At least forty five (45) calendar days before a proposed transfer of an accredited site, the provider must apply to DBHS to transfer site certification. The application must include documentation that: a. The provider notified the accrediting entity, and the accrediting entity has extended or will extend accreditation to the second site; or b. The accrediting entity has established an accreditation timeframe. 2. The provider must notify clients and families, DBHS, the Division of Medical Services, the Medicaid fiscal agent, and the accrediting organization at least thirty (30) calendar days before the transfer; 3. DBHS does not require an on site survey, nor does the Division of Medical Services require a new Medicaid provider number. The moving or transferring site form is available at: www.arkansas.gov/dhs/dmhs 36
Checklist for the Transfer of an RSPMI Service Site 1. DBHS Form #4 pages 1 2 2. Pictures of interior and exterior of new location 3. Notification from Provider to Accrediting Agency of move 4. Acknowledgment from Accrediting Agency that Accreditation has been transferred to new location 5. Change of Address form DMS 673 6. Last 2 pages of Medicaid Contract DMS 653 7. Disclosure forms DMS 675 and DMS 689 All providers are required to notify DBHS of all site relocations, openings, closings and transfers. All applicable forms are available in the appendix section of the RSPMI certification manual located at the DBHS website. 37
SITE CLOSINGS Note: Temporary Service Disruptions Caused by Inclement Weather or Power Outages are not Closings. 1. Providers must assure and document continuity of care for all clients who receive RSPMI at the site; 2. Notice of Closure and Continuing Care Options: a. Providers must assure and document that clients and families receive actual notice of the closure, the closure date, and any information and instructions necessary for the client to obtain transition services; b. After documenting that actual notice to a specific client was impossible despite the exercise of due diligence, providers may satisfy the client notice requirement by mailing a notice containing the information described in subsection (a), above, to the last known address provided by the client; and c. Before closing, providers must post a public notice at each site entry. The public notice must include the name and contact information for all RSPMI providers within a fifty (50) mile radius of the site. 38
Checklist for the Closure of an RSPMI Service Site: 1. A copy of the notification to your accrediting agency of the site closure/their acknowledgement of the closure. 2. DBHS form #4 for the closing of a site 3. A copy of your transition plan (if applicable) 4. Formal notification on agency letterhead requesting the (specific) billing # be turned off and an effective date. This needs to be an original signature from your CEO. 39
NAME CHANGES Involves Provider Enrollment and Program Integrity DBHS role: assist in coordination and documentation 40
ANNUAL REPORTS See DBHS RSPMI Policy XIII, B (Page 23) Providers must furnish annual reports to DBHS before July 1 of each year that the provider has been in operation for the proceeding twelve (12) months. Annual report shall be prepared by completing form provided by DBHS. The annual report form is available at www.arkanas.gov/dhs/dmhs and at Appendix 12 DBHS Form #6 41
PROGRAM INTEGRITY REPORT By January 21, 2011, providers are to notify the Program Integrity Unit of the names of covered health care practitioners who are providing RSPMI services. MHPPs are not considered covered health care practitioners. On or before the 10 th (tenth) day of each month, providers must notify the Medicaid Program Integrity Unit of the names of covered health care practitioners who are providing RSPMI services and whose names were not previously disclosed. If no changes, no report is required. 42
PROBLEMS THAT MAY OCCUR WITH NON REPORTING Provider Notification emailed to CEO who left 3 months ago Phone call from individual seeking services: sent to a closed down building because site was moved or closed without notice. Accreditation has not been transferred; site is not certified Billing issues 43
QUESTIONS? 44
III. Medical Records 45
RSPMI Beneficiary Records: Components of a Proper Chart 46
RSPMI Regulations: Do not address chart order Do address clinical record contents (226.200) Do address specifics of required documents (226.200) 47
I. Demographic and Identifying Information Sufficient to clearly identify beneficiary Domestic status Medicaid number Social Security number (where applicable) 48
II. Admission Documents Consent for treatment (where applicable) Primary Care Physician (PCP) Referral [U 21 only] (217.100) Conformance with HIPAA regulations (226.200 G) * Authorizations for release of information (where applicable) * Signed HIPAA notice 49
50 III. Evaluations Mental Health Evaluation/Diagnosis (252.110) [service code 90801] Psychiatric Diagnostic Assessment (224.201, 252.110) [service code T1023] * For SED/SMI: within 45 days of entering care, then annually thereafter * For Non-SED/SMI: at the end of 6 months if still in treatment, and annually thereafter (by day 45, record must have physician documentation that beneficiary is Non-SED/SMI and PDA is not required ) Youth Outcome Questionnaire (YOQ) (217.101) * Initial: within 14 days of entering care * Subsequent: every 90 days thereafter to coincide with Periodic Reviews of Treatment Plan, and at discharge Any psychological, intelligence, or other test relevant to the beneficiary s ability to benefit from treatment
IV. Medications Some forms of Mental Illness can be resolved or managed without the use of medications--with psychotherapy only. Some forms of Mental Illness can be resolved or managed with an initial of short course of medications followed by psychotherapy. Some forms of chronic Mental Illness must initially be managed by medication and psychotherapy, followed by medication only. Some forms of chronic Mental Illness must be managed by continuous medication and continuous psychotherapy. Documentation must be present to support the appropriate circumstance. 51
V. Master Treatment Plan and Updates Master Treatment Plan (218.000, 252.110) [service code 90885] * Must be completed within 14 calendar days of entering care * Physician signature required within 14 calendar days of entering care * Can be done once annually Periodic Treatment Plan Review (218.100, 252.110) [service code 90885] * Must be completed every 90 calendar days * More frequently if there is documentation of significant change in acuity or change in clinical status requiring an update/change in the beneficiary s master treatment plan 52
V. Master Treatment Plan and Updates [CONTINUED] It is reasonable that Treatment Plans of individuals with the same diagnosis may be similar. However, treatment plans can be and must be individualized. Treatment Plans can easily be individualized if the following facts are kept in mind: Clusters of symptoms will vary in severity among individuals with the same diagnosis Rate of response to and progress in treatment will vary among individuals Expression of symptoms will vary in accordance with the individual s psychosocial stage of development Expression of symptoms will vary in accordance with the individual s gender or gender identity Expression of symptoms will vary in accordance with the individual s culture Expression of symptoms will vary among individuals in response to the nature of psychosocial toxicity in their environment 53
V. Master Treatment Plan and Updates [CONTINUED] When is it necessary to update a Treatment Plan more frequently than every 90 days? When a materially different diagnosis is made When a beneficiary succeeds or progresses much more rapidly than expected in treatment and services need to be substantially reduced for an extended period or throughout the remaining course of treatment When a beneficiary experiences a relapse, substantial regression, and/or severe impediment and services need to be substantially increased and/or altered for an extended period of time or throughout the remaining course of treatment 54
V. Master Treatment Plan and Updates [CONTINUED] When is it unnecessary to update a Treatment Plan more frequently than every 90 days? When a variation in diagnosis is made, and the variation does not impact the course of treatment When a beneficiary progresses in treatment as expected, and incremental decreases in frequency of service are appropriate When a beneficiary temporarily needs a time-limited increase in number of prescribed services 55
VI. Progress Notes Required elements are listed in RSPMI regulations (226.200) Required elements and specifics for each service type are listed in the RSPMI Outpatient Procedure Codes service definitions (252.110) 56
VI. Progress Notes [CONTINUED] Concise, accurate documentation in progress notes can prevent questions regarding: Up-billing Medical Necessity for the service Service code adherence 57
VI. Progress Notes [CONTINUED] Progress notes must be contemporaneous. Arkansas Department of Human Services Division of Behavioral Health Services Certification Manual for Rehabilitative Services for Persons with Mental Illness (RSPMI) VIII. ADDITIONAL CERTIFICATION REQUIREMENTS B. Care and Services must: 3. Be established by contemporaneous documentation that is accurate and demonstrates compliance. Documentation will be deemed to be contemporaneous if recorded by the end of the performing provider s first work period following the provision of the care or services to be documented, or as provided in the RSPMI manual, 252.110, whichever is longer. 58
VI. Progress Notes [CONTINUED] Progress notes must be individualized: Arkansas Medicaid RSPMI Manual (226.200) ****************** Arkansas Department of Human Services Division of Behavioral Health Services Certification Manual for Rehabilitative Services for Persons with Mental Illness (RSPMI) VIII. ADDITIONAL CERTIFICATION REQUIREMENTS L. Providers must tailor all RSPMI care and services to individual client need. If client records contain entries that are materially identical, DBHS and the Division of Medical Services will rebuttably presume that this requirement is not met. 59
VII. Discharge Information Can be helpful in documenting treatment outcomes Can be helpful if beneficiary is readmitted for treatment Can be helpful in legal considerations 60
VII. Discharge Information [CONTINUED] Auditors and DMS do not recognize internal discharges A discharge is a release or removal from treatment authorized by a physician. Records of beneficiaries that are not discharged via ProviderConnect sm and/or have no documentation of authorization for discharge by a physician are subject to all documentation and timeframe requirements of active beneficiaries. When a beneficiary is discharged and later returns to treatment, the following documents must be completed anew: Initial Evaluation Psychiatric Diagnostic Assessment Master Treatment Plan 61
Messaging in Beneficiary Charts 62
What is messaging? Messaging is the A.C.E of clinical recordkeeping. In RSPMI beneficiary charts, messaging refers to: Accurate identification of services Clear identification of forms Exact description of services performed 63
Accurate Identification of Services Services other than RSPMI program services may be documented in RSPMI beneficiary charts, such as: Wraparound Services Targeted Case Management Services Substance Abuse Treatment Services Providers are responsible for clearly identifying these services distinctly so that they are not confused or misidentified as RSPMI program services. 64
Accurate Identification of Services [CONTINUED] RSPMI program progress notes and service documentation must identify the RSPMI service rendered. (226.200) Clearly identify RSPMI program services by RSPMI service name in both progress notes and on treatment plans. Avoid using other program service names interchangeably with RSPMI program service names. 65
Clear Identification of Forms All RSPMI documents should be labeled or titled by the label or title used in the Arkansas Medicaid RSPMI Manual. Avoid labeling or titling RSPMI program forms by names of services from other programs. Accurately name any agency form after the RSPMI services for which you plan to bill. 66
67 Exact Description of Services Performed RSPMI program services and other program services may not be documented in the same note. (Each program service must have its own service note.) In RSPMI program progress notes, avoid reference terms pertaining to excluded services and/or other program services. RSPMI program service notes must document that the criteria delineated in the RSPMI service definition has been met. In RSPMI service notes, the credential/title of the person who provided the service must be a credential/title authorized by the RSPMI Manual.
Indicators of Proper Chart Compilation and Maintenance 68
Indicators The continuous practice of T.E.A.R will prevent the shedding of many tears during internal operations and external audits. 69
70 T.E.A.R. Timely filing Result: contemporaneous documentation Efficient Medical Records Librarian Result: easy, rapid access to complete record Active security policy Result: compliance with confidentiality requirements Regularly scheduled internal audits Result: quality control
71 Questions?
Thank You Presented by: Nelda Michael, LCSW nelda.michael@valueoptions.com 501-747-3309 72