Minnesota Department of Human Services Managed Care (MSHO MSC+) Elderly Waiver Care Planning Audit (as required under 7.1.4.D., 7.8.3, 9.3.7 of the 2016 MSHO/MSC+ contract) 2017 Audit Protocol (Final 7.17.2017) (Referred to as the Care Plan Data Collection Guide in the DHS Triennial Compliance Assessment (TCA) conducted by the Minnesota Department of Health) Goal: To facilitate an interdisciplinary, holistic, preventive approach to determine meet the health care supportive services needs of enrollees. Description: The Audit Protocol/Data Collection Guide is presented by element, first presenting outcomes related to assessment enrollment/disenrollment then followed by outcomes related to comprehensive care planning waiver services. It also incorporates person-centered planning requirements. The method acceptable evidence for determining outcome achievement is described for each desired outcome the criteria for achieving a met or not met score is outlined in the middle column of the matrix under the heading Method for measuring outcome achievement. This 2017 Audit Protocol was developed for use in auditing 2017 created care plans in CY2018. Currently, MSHO/MSC+ health plans use the LTCC for assessment. MnCHOICES is referenced only to reflect that at some point MSHO/MSC+ health plans will begin using MnCHOICES for assessment. DHS will inform health plans when MnCHOICES can be used for MSHO/MSC+. MCO sampling instructions: The sampling method is to be applied to each delegate under contract with the MCO for care coordination (MSHO) case management (MSC+). The sample can proportionately combine MSHO MSC+ enrollees assuming enrollees of both programs receive the same level of care coordination. 1
MCO sampling instructions: (continued) Each MCO will romly sample by delegate 30 eligible EW MSHO/MSC+ care plans for each delegate of which 8 will be romly selected for review 1. If any of the 8 records produce a not met score for any of the outcomes outlined in the Audit Protocol/Data Collection Guide, then the remaining 22 records will be examined for the outcome(s) resulting in not met findings. For delegates with fewer than 30 eligible care plans, then 8 care plans will be pulled from all eligible care plans. If a delegate has fewer than 8 eligible care plans, then all eligible care plans will be reviewed for that delegate. Because some elements pertaining to assessment apply to new enrollees (new enrollees within the last 12 months) others to existing cases (enrollees for more than 12 months), MCOs should ensure that they have an adequate number of cases to evaluate compliance per these elements. Sources of Evidence: Sources of evidence may include the following: Comprehensive Care Plan case notes to supplement Comprehensive Care Plan, MCO Health Risk Assessment (initial assessment conducted at time of enrollment), LTCC/MnCHOICES Assessment, HCBS service plan the Residential Services Tool Plan if applicable. Reporting: MCO reporting to DHS: MCOs will complete a report via Snap survey for MSHO MSC+ for each delegate under contract with the MCO for care coordination (MSHO) case management (MSC+) indicating the results of the audit. MCOs will prepare a summary of key findings recommendations. Findings are reported at the delegate level. Reports include corrective actions indicated opportunities for improvement identified as well as performance on specific requirements related to care plans. Additional follow-up information will be reported to DHS in such a manner that DHS can determine that corrective actions were implemented, including a plan for monitoring completion of required actions. Refer to the MCO 2017 Care Plan Audit Report Instructions for information about reporting findings in the MCO Care Plan Audit Report Format tool. 1 Additional cases are selected in the initial sampling for replacement purposes. 2
MDH sampling instructions for the Triennial Compliance Assessment (TCA): When conducting care plan reviews for the DHS TCA, DHS will romly sample 20 new care plans 20 existing care plans from the MCO s program population, resulting in a total of 40 sampled care plans. For elements pertaining only to new care plans elements pertaining only to existing care plans. For elements pertaining only to new care plans elements pertaining only to existing care plans, MDH will romly sample 8 from each sub-sample for those elements. After the completion of the elements unique to new existing, MDH will then sample four care plans from each subsample of new existing care plans for a total of 8 care plans. MDH will then review these 8 care plans. If any of the 8 care plans produce a not met score for any of the outcomes outlined in the Audit Protocol/Data Collection Guide, then 22 of the remaining care plans (combining new existing subsamples) will be examined for the outcome(s) resulting in not met findings. MDH reporting to DHS: MDH will prepare a summary report of the care plan review findings for DHS. DHS will respond to deficient findings as it determines appropriate. 3
1. INITIAL HEALTH RISK ASSESSMENT Desired outcome: All enrollees new to the MCO or product 2 within the last 12 months have an initial Health Risk assessment completed within required timelines. 1.1 Timeliness: a. Date HRA completed is within 30 calendar days of enrollment date; or An explanation is documented if HRA attempted but not completed within 30 calendar days of enrollment date when: - enrollee refused completion of the initial HRA, or - enrollee was admitted to a hospital before the 30 th calendar day, or - enrollee was admitted to a nursing facility for a short-term stay of 30 or fewer days before the 30th calendar day after enrollment date 1.2 Complete: a. All (100%) of the fields relevant to the enrollee s program are completed with pertinent information or noted as Not Applicable or Not Needed as appropriate; b. HRA results are included in/attached to the enrollee s Comprehensive Care Plan. The above stated requirements are not met per each sub-element. Not applicable: If enrollee has been an enrollee for more than 12 months. LTCC or MnCHOICES assessment. 6.1.4(A)(1) 6.1.5(B)(1) 2 For example, enrollee moves from MSHO to MSC+ or vice versa. 4
2. ANNUAL HEALTH RISK ASSESSMENT Desired Outcome: All enrollees who have been an enrollee of the MCO 12 months or more have an annual Health Risk Assessment completed within required timelines. Note: For EW enrollee - Measure only if MCO conducts an HRA separate from the LTCC/MnCHOICES Assessment; otherwise, see number 4 - Reassessment of EW. 2.1 Timeliness: a. Date annual HRA completed is within 365 calendar days of previous HRA; or HRA is completed but not within 365 days, the explanation for not completing within 365 days is present. 2.2 Complete: a. All (100%) of the fields relevant to the enrollee s program are completed with pertinent information or noted as Not Applicable or Not Needed as appropriate; b. HRA results are included in/attached to the enrollee s Comprehensive Care Plan. The above stated requirements are not met per each sub-element. Not applicable: If enrollee has been an enrollee for less than 12 months. LTCC or MnCHOICES assessment. 6.1.4(A)(1) 6.1.5(B)(1) 5
3. INITIAL ASSESSMENT - LONG TERM CARE CONSULTATION Desired Outcome: An LTCC/MnCHOICES assessment was completed within required timelines for all enrollees opened or re-opened 3 to EW by the MCO in the past 12 months. Note: Completion of the assessment also serves to meet various person-centered planning requirements related to discovery activity/learning about the enrollee as reflected in Outcome 5 below. 3.1 Timeliness: a. LTCC/MnCHOICES Assessment was completed within 20 calendar days of a request or referral. 3.2 Complete: a. All (100 %) items within each domain in the assessment are completed, or noted as Not Applicable or Not Needed as appropriate. Sections in ( ) are comparable sections from DHS Form 3428A: (1) Section A - Assessment Information (Section A) (2) Section B - Information About Me (Section B) (3) Section C - Assessment Information (Section C) (4) Section D - My Everyday Life (Section N) (5) Section E - Relationships Community Connections (Section D) (6) Section F - My Health (Section L) (7) Section G - Taking Care of Myself (Section M) (8) Section H - My Emotional Mental Health (Section E) (9) Section I- My Safety (Section F) (10) Section J - Assessment Results (Section G) (11) Section K - Service Plan Summary (Section H) (12) Section O - Caregiver Assessment (Section P) b. Results of the LTCC/MnCHOICES Assessment are included in/attached to the enrollee s Comprehensive Care Plan. 3 Re-opened to EW means an EW participant who previously exited from EW who has returned to EW. 6
3. INITIAL ASSESSMENT - LONG TERM CARE CONSULTATION (continued) The above stated requirements are not met per each sub-element. Not applicable: If enrollee is not new to EW in the past 12 months. DHS LTCC Assessment Form 3428 or 3428A, or MnCHOICES assessment. 6.1.24(A)(8) 6.1.4(A)(2) 6.1.5(B)(4) 6.1.14(B) 7
4. ANNUAL REASSESSMENT OF EW Desired Outcome: A LTCC/MnCHOICES reassessment is completed within 365 days of prior assessment or with change in condition, is verified for completeness for enrollees open to EW who have been an enrollee of the MCO for more than 12 months. 4 Note: Completion of the reassessment also serves to continue to meet various person-centered planning requirements as described in Outcome 5 below. 4.1 Timeliness: a. Date re-assessment completed is within 365 days of previous assessment; or An explanation is documented if completed but not within 365 days of previous assessment. 4.2 Complete: a. All (100 %) items within each domain in the assessment are completed, or noted as Not Applicable or Not Needed as appropriate. Sections in ( ) are comparable sections from DHS Form 3428A: (1) Section A - Assessment Information (Section A) (2) Section B - Information About Me (Section B) (3) Section C - Assessment Information (Section C) (4) Section D - My Everyday Life (Section N) (5) Section E - Relationships Community Connections (Section D) (6) Section F - My Health (Section L) (7) Section G - Taking Care of Myself (Section M) (8) Section H - My Emotional Mental Health (Section E) (9) Section I- My Safety (Section F) (10) Section J - Assessment Results (Section G) (11) Section K - Service Plan Summary (Section H) (12) Section O - Caregiver Assessment (Section P) b. Results of the LTCC/MnCHOICES Assessment are included in/attached to the enrollee s Comprehensive Care Plan. 4 Completion of the EW reassessment will also serve as the completion of an HRA. 8
4. ANNUAL REASSESSMENT OF EW (continued) The above stated requirements are not met per each sub-element. Not applicable: If enrollee is newly enrolled within past 12 months. LTCC/MnCHOICES assessment. 6.1.14(C) 9
5. PERSON-CENTERED PLANNING - Assessment Desired Outcome: The enrollee has an opportunity during assessment to identify what is important to, what is important for, them. Note: This outcome replaces previous Outcomes 18-1, 18-2, 18-3, part of 18-7 related to housing, 18-9. For both initial assessments reassessments: 5.1 Opportunities for choice in the enrollee s current environment are described. a. There is a specific description of the enrollee s opportunities to make meaningful choices in their daily life (need to mention choice or a similar word), as identified in LTCC assessment items. Items in ( ) are comparable items from DHS Form 3428A: (1) E.4 (D.4) (2) E.5 (D.5) (3) E.8 (D.8) (4) E.11(D.11) (5) E.12-Housing) (D.12) b. If there are areas in which opportunities for choice are limited, these are listed. (Person-Centered Planning Comments, Sections E I; in DHS Form 3428A, Sections D F). 10
5. PERSON-CENTERED PLANNING - Assessment (continued) 5.2 The enrollee s current rituals routines are described. a. There is a general description of the enrollee s daily rituals routines, which includes quality, choice, preferences, predictability, in general, as identified in: (1) E.4 (D.4) (2) E.5 (D.5) (3) F.26 (L.26) (4) F.27 (L.27) (5) F.28 (L.28) b. Enrollee has described the social, leisure, or religious activities s/he wants to participate in. (E. 6-11 or D.6-11 on DHS Form 3428A); c. There is a statement regarding how this information was gathered (E.1 or D.1) 5.3 a. The enrollee s decision about employment/volunteer opportunities has been identified in: a. The enrollee s decision about employment/volunteer opportunities has been documented as identified in: (1) D.12 (N.12 in DHS Form 3428A) (2) D.12a (N.12a) (3) D.13, (N.13, ) (4) D.14 (N.14) The above stated requirements are not met per each sub-element. Noted in each sub-element using 3428 or 3428A. 6.1.14(B)(4) 11
6. COMPREHENSIVE CARE PLAN - Timeliness Desired Outcome: Enrollees receive a completed Comprehensive Care Plan within 30 calendar days of a completed LTCC/MnCHOICES Assessment. at least one of the following): a. Comprehensive Care Plan is completed sent to member within 30 calendar days of the date of a completed LTCC/MnCHOICES assessment; or If attempted but not completed, an explanation of status is documented; or Enrollee was admitted to a hospital or nursing facility before the 30th calendar day following assessment; or Enrollee/legal representative/guardian/family chose a date more than 30 calendar days after completion of the LTCC/MnCHOICES assessment. None of the above stated methods to meet this requirement are documented. Comprehensive care plan, care coordinator notes. 6.1.4(A)(2) 6.1.5(B)(4) 6.1.14(B) 12
7. COMPREHENSIVE CARE PLAN Identified Needs Addressed Desired Outcome: The Comprehensive Care Plan (CCP) addresses enrollee needs preferences, reflects an interdisciplinary, holistic preventive focus. a. Enrollee s identified needs concerns related to primary care, acute care, long-term care, mental health, behavioral, social service needs concerns are addressed in the care plan; b. The need for services essential to the health safety of the enrollee is documented; c. If essential services are included in the plan, a back-up plan for provision of essential services is also documented; d. There is a plan described for community-wide disasters, such as weather related conditions included. The above stated requirements are not met per each sub-element. Care plan. 6.1.4(A)(2) (3) 6.1.5(B)(4) 6.1.14(B) 13
8. COMPREHENSIVE CARE PLAN Goals Desired Outcome: The enrollee s goals or skills to be achieved are included in plan, are related to the enrollee s preferences how the enrollee wants to live their life, there is a plan to achieve their goals. Note: This Outcome replaces 18.4 18.5 for PCP, moves items related to goals from the original Outcome 6 to this Outcome. a. Goals skills selected by the enrollee to be achieved are clearly described; b. Action steps, including services or supports needed, are identified describe what needs to be done to assist the enrollee to achieve the goals or skills; c. Plan for monitoring progress towards goals is included; d. Target dates for completion are included (at least month year); e. Outcome/achievement dates are included; f. People/providers responsible for assisting the enrollee in completing each step are identified. The above stated requirements are not met per each sub-element. Care plan item F.9a related to training on assistive devices. Provider care plan/summary. Citation(s): 42 CFR, Section 441.725, contract cite for compliance with federal requirements 6.1.4(A)(2) (3) 6.1.5(B)(4) 6.1.14(B) 14
9. COMPREHENSIVE CARE PLAN - Choice Desired Outcome: The enrollee is provided information related to, makes informed choices about, long-term care services providers. Note: This item replaces previous Outcomes 12 (Enrollee Choice X HCBS & NF), 13 (Choice of HCBS Providers) 18.7 (Services offered). a. The enrollee indicates their choice between HCBS nursing facility services; b. The enrollee was offered choices among HCBS services; c. The choices offered are documented; d. The enrollee was given information to enable the enrollee to choose among providers of HCBS services chosen. Care plan signature section. Services Summary Section K or H of LTCC (e-docs #3428 or #3428A respectively) or MnCHOICES Assessment Form or equivalent document. No evidence of choice in each desired outcome is found. 6.1.14(B) 6.1.14(L) 6.1.24(A)(10)(a) 15
10. COMPREHENSIVE CARE PLAN Safety Plan/Personal Risk Management Plan Desired Outcome: The enrollee has a plan to address identified safety issues risks. a. Discussion between care coordinator enrollee regarding safety concerns/risks is documented; b. The plan for managing risks discussed is included in the care plan or It is documented that no plan for managing risks is needed. The above stated requirements are not met per each sub-element. Care plan section. 6.1.14(B)(1) 6.1.4(A)(2)(b) 16
11. COMPREHENSIVE CARE PLAN Informal Formal Services Desired Outcome: The enrollee receives a description of their formal informal services that contains all required elements. The enrollee s comprehensive care plan includes: a. type of services to be furnished; b. the amount, frequency, duration cost of each service; c. the type of provider, name of provider if known, furnishing each service including non-paid care givers other informal community supports or resources; or If not all elements completed, an explanation of status must be present documented. The above stated requirements are not met per each sub-element. Care plan. 6.1.14(B)(1) 17
12. COMPREHENSIVE CARE PLAN Caregiver Support Desired Outcome: Informal caregivers are identified supported in the plan. If a non-paid caregiver is identified in the LTCC/MnCHOICES Assessment, then met is determined by all of the following: a. The Caregiver Planning Interview/Caregiver Assessment in LTCC is attached; or Caregiver declined interview as documented in the assessment; b. Caregiver services supports are incorporated in the care plan, if assessment was completed. The above stated requirements are not met per each sub-element. LTCC/MnCHOICES Caregiver Interview. Care Plan - Service Plan. 6.1.14(A) 6.1.14(B) 18
13. COMPREHENSIVE CARE PLAN Housing Transition Desired Outcome: The enrollee has a transition plan to support housing choice. Note: This outcome replaces Outcome 18.10. a. The LTCC assessment items related to housing choices support are completed, including follow-up questions; b. If the enrollee indicates they want assistance in exploring housing options, the transition plan reflects a goal, steps to be taken, potential barriers; c. The transition plan is attached to the Care Plan. The above stated requirements are not met per each sub-element. DHS Form 3428: Section E., items E.12, E.13, E.13a; or DHS Form 3428A, Section D, items D.12, D.13 D.13a. Preparation of transition plan that meets transition plan requirements (action steps). My Move Plan. Citation: 42 CFR, Section 441.725 Contract Citation: 6.1.24 19
14. COMMUNICATION OF CARE PLAN/ SUMMARY - Physician Desired Outcome: The enrollee s primary care physician receives a Care Plan Summary. a. Evidence of care coordinator communication of care plan elements with Primary Care Physician (PCP). Evidence not present of communication of care plan summary to PCP. Care plan. 6.1.4 (A)(2)(a) 6.1.14(B)(5) 20
15. COMMUNICATION OF CARE PLAN/SUMMARY Enrollee Providers Desired Outcome: The support plan is signed dated by disseminated to all relevant parties. a. The care plan is signed dated by the enrollee or authorized representative; b. The care plan reflects the enrollee s choice of individuals who are to receive the care plan/summary; c. Documentation indicates the care plan/summary was sent to the provider(s) within 30 days of the completion of the care plan, including date method; d. Documentation indicates that the care plan/summary was sent again, including date method, to providers who have not returned the communication tool within 60 days of the completion of the care plan. The above stated requirements are not met per each sub-element. Not applicable: Care plan/summary is not required to be forwarded to purchased-items providers (formerly Tier 3) for signatures. Care plan. CDCS Plan. Residential Services tool. Copies of provider communication tools. Citation: 42 CFR, Section 441.725 21
16. COMPREHENSIVE CARE PLAN Enrollee Requests for Updates Desired Outcome: The plan includes a method for the individual to request updates to the plan, as needed. a. The Care Plan includes how the individual can request changes to the plan. The care plan does not include how the individual can request changes to the plan. Care plan. Citation(s): 42 CFR, Section 441.725, contract cite for compliance with federal requirements 6.1.4(B)(5) 6.1.5(B)(16)(d) 22
17. CARE COORDINATOR FOLLOW-UP PLAN Desired Outcome: Enrollees have a care coordinator follow-up or contact plan related to identified concerns or needs 5, the plan is implemented. a. Care Coordinator documents their plan for enrollee contact; b. Care Coordinator documents contact with enrollee according to plan; or Documents the reason the plan was not followed. The above stated requirements are not met per each sub-element. Care plan. 6.1.4(B)(6) 6.1.5(B)(16)(e) 5 Follow-up plan must address: Identified preventive care concerns including but not limited to annual physical, immunizations, screening exams such as dementia screening, vision hearing exams, health care (advance) directive, dental care, tobacco use, alcohol use. Identified long-term care community support concerns including but not limited to caregiver support, environmental personal safety (e.g. falls prevention), home management, personal assistance, supervision, long-term health-related needs (e.g., clinical monitoring, special treatments, medication monitoring, palliative/hospice care). Identified medical care concerns including but not limited to the management of chronic disease such as hypertension, CHF/heart disease, respiratory /lung disease, diabetes, joint/muscle disease. Identified mental health care concerns including but not limited to depression, dementia, other mental illness. 23
18. ANNUAL PREVENTIVE HEALTH EXAM Desired Outcome: Enrollee engages in conversation about the need for an annual, age appropriate comprehensive preventive health exam with care coordinator. a. Documentation is present in enrollee s Comprehensive Care Plan that substantiates a conversation was initiated with enrollee about the need for an annual, age-appropriate comprehensive preventive health exam. No evidence of conversation about the importance of annual preventive health care present in enrollee s Comprehensive Care Plan. Care plan. 6.1.4(B)(2) 6.1.5(A)(2) 6.1.6(B) 24
19. ADVANCE DIRECTIVE Desired Outcome: Enrollee has opportunity for annual discussion about /or completion of an Advance Directive. any of the following): a. Advance Directive exists; or Care coordinator documents annual initiation of conversation about Advance Directive; or Care coordinator documents enrollee s refusal to complete an Advance Directive; or Care coordinator documents reason why Advance Directive conversation was not initiated. None of the above stated methods to meet this requirements are documented. Care Plan. 6.1.4(A)(2)(c) 6.1.5(B)(4) 25
20. APPEAL RIGHTS Desired Outcome: Enrollee receives information about their appeal rights. a. Completed signed care plan indicates receipt of appeal rights; or Other MCO signed documentation in enrollee file indicates receipt of appeal rights. No documentation that the enrollee received information about their appeal rights. Care plan, other signed documentation. 3.4.G 26
21. DATA PRIVACY Desired Outcome: Enrollee receives information about data privacy. a. Completed signed care plan indicates receipt of data privacy information; or Other MCO signed documentation in enrollee file indicates receipt of data privacy information. No documentation that the enrollee received information about data privacy. Care plan, other signed documentation. 6.1.4(B)(13) 6.1.5(B)(16)(l) 6.1.4(A)(2) 6.1.5(B)(4) 27