American Society of Addiction Medicine (ASAM) Update

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ASAM Announces New Legislation Tracking Module on Website

ASAM recently announced a new legislation tracking module located on the their website. The tracker, located on each advocacy issue page, shows legislation related to specific issues sorted by state. ASAM’s website states they focus their advocacy efforts on “federal and state legislation and regulation that impact the field of addiction medicine”. ASAM advocacy issues include:

  • Opioids
  • Marijuana
  • Tobacco
  • Health Insurance Parity
  • Prevention
  • Confidentiality (42 CFR Part 2)

Take a look at this new resource on ASAM’s website to see what legislation has been introduced in your state.

-Megan Phillips, M.A.

References:

http://www.asam.org/advocacy/issues?utm_medium=email&utm_campaign=ASAM%20Advocacy%20February%202017%20Recap&utm_content=ASAM%20Advocacy%20February%202017%20Recap+CID_8e7c90f7217c7f84e53bf7e55286e7f0&utm_source=Campaign%20Monitor%20marketing%20software&utm_term=Read%20More

The Joint Commission (TJC) Accreditation Process Webinars

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TJC Accreditation Process Webinars

TJC, the not-for-profit organization which accredits and certifies nearly 21,000 health care organizations and programs in the U.S., recently posted webinars regarding basic information about the TJC accreditation process and the new SAFER Matrix, which describes changes to the TJC Survey process.  The webinars can be found here:

Brown Consulting, Ltd. can help your organization with TJC Accreditation Compliance!

Information about the Accreditation Compliance Analysis offered through Brown Consulting Ltd. can be found on the “Our Services” page on our site:

-Megan Phillips, M.A.

References:

https://www.jointcommission.org/webinar_replay_feb_14_accreditation_basics_bhc/

https://www.jointcommission.org/about_us/about_the_joint_commission_main.aspx

 

Attention Ohio Behavioral Health Providers

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Ohio Behavioral Healthcare Redesign Updates

Attention Ohio Behavioral Health providers:

Updated Behavioral Health Redesign Resources are available! Refer to the list below, e-mailed on 2/13/17 from Eric R. Wandersleben, Director of Media Relations & Outreach at the Ohio Department of Mental Health & Addiction Services.

On Jan. 31, the Ohio Department of Mental Health and Addiction Services (OhioMHAS) and the Ohio Department of Medicaid (ODM) released updated resources for the Medicaid Behavioral Health Redesign. These documents can be found on the Behavioral Health Redesign website here. The resources include:

Drafts of Ohio Administrative Code Rules for Behavioral Health Redesign

Draft versions of the Ohio Department of Medicaid Ohio Administrative Code (OAC) rules regarding Medicaid behavioral health service definitions, coverage, payment policy, and recipient and provider eligibility are posted HERE. The ODM rules also propose consolidating Medicaid MH and SUD rules into a single OAC chapter. In addition to the regular Common Sense Initiative (CSI) and Joint Committee Agency Rule Review (JCARR) public rulemaking process, ODM will also accept informal stakeholder input through close of business on Monday, Feb. 20.  Please submit written comments to this email address: BH-Enroll@Medicaid.Ohio.Gov.

The Ohio Department of Mental Health and Addiction Services (OhioMHAS) will be releasing updated/new Ohio Administrative Code rules via the CSI and the JCARR public processes. The OhioMHAS specific rules also support the reframing of OhioMHAS certification with a focus on recognition of practitioner scopes of practice as recognized by the professional regulatory boards, as well as on patient health, welfare and safety standards and finalizing merging of the ODADAS and ODMH regulatory frameworks into a single chapter. The OhioMHAS rules may be found HERE.

Behavioral Health Provider Manual

The latest draft of the BH provider manual contains critical information for provider staff regarding service definitions, units, eligible providers, billing codes, modifiers, payment rates, etc. The manual may be found HERE.

IT System Guidance

ODM staff have developed several documents to assist provider agencies in making needed modifications to their information technology systems to be in compliance with the revised Medicaid behavioral health benefit package.  The resources include several very detailed spreadsheets and documents providing specifications and guidance.  The IT System Guidance documents may be found HERE under the “IT Resources” heading.

Specifically, these documents include:

·         Rendering/Supervising/Ordering claim field specifications

·         Crosswalk showing the interactions of procedure codes

·         Services allowed in conjunction with ACT/IHBT Diagnosis code groups

·         Services billable to Medicare

·         MITS System edits/audits
For more information on Behavioral Health Medicaid Redesign, visit http://bh.medicaid.ohio.gov.

To subscribe to OhioMHAS e-updates, visit http://mha.ohio.gov/Default.aspx?tabid=483

 

-Megan Phillips, M.A.

Reference:

E. Wandersleben, e-mail communication, February 13, 2017

The Benefits of a Compliance Alert Hotline

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The Benefits of a Compliance Alert Hotline

Compliance programs are internal plans and policy decisions made by an organization in order to meet standards set by government laws and regulations. For instance, the Accountable Care Act requires that all healthcare providers who receive Medicaid or Medicare payments have a compliance program. An effective compliance program demonstrates an organization is striving to achieve the highest standards of ethical conduct possible.

A compliance alert hotline supports compliance programs by allowing employees and stakeholders to report improper, unethical or illegal conduct anonymously without fear of identification, retaliation or retribution.

How does a Compliance Alert Hotline work?

The Brown Consulting Compliance Alert Line service operates as follows: *Please note, THIS PROCESS IS ENTIRELY CONFIDENTIAL.

  1. Compliance Alert Line posters describing process are provided to sites.
  2. Improper, unethical or illegal conduct can be reported 24 hours a day by staff or stakeholders by calling the confidential and toll free Alert Line phone number. These calls can be made privately outside of normal working hours. 
  3. Alerts are transcribed the same day they are received by Alert Line staff. Alert Line staff are experienced Behavioral Health professionals who are trained in fact-only information gathering and report writing. Complaints are transcribed quickly, without any bias or breaching of confidentiality.
  4. Transcribed alerts are returned to the designated site Compliance Officer for in-house investigation ONLY. At this point, the site determines how best to remedy the complaint in-house.
  5. Quarterly and annual reports are provided to sites identifying only the number of alerts and category or type of alert.

When ethical and/or legal problems arise in behavioral health organizations, an “Alert Line” option helps Compliance Officers and Supervisors address issues quickly. Complaints can be handled in-house before they spiral out of control and impact organization operations, reputation, and ultimately, overall performance.

Complaints can include, but are not limited to:

  • employee misconduct
  • discrimination
  • sexual harassment
  • privacy/security issues
  • inappropriate staff/patient relationships
  • employee drug use
  • medication diversion
  • utilization issues
  • improper billing practices and/or clinical documentation

Although behavioral health facilities may already have internal complaint processes, many are not large enough nor have the internal structure necessary to ensure the reporting of a compliant anonymously. Therefore, suspected concerns or violations can go unreported, leaving the organization at risk. Providing an Alert Line option to your employees serves as a reminder of your ethical and moral duty as professional behavioral healthcare providers. It also shows your community that your organization is dedicated to providing above par behavioral health services.

A truly beneficial service, the Brown Consulting Ltd. Compliance Alert Line is fully-confidential, cost-effective and a “Best Practice” approach to supporting the ethical integrity of your organizational compliance program. Furthermore, the Alert Line does not replace healthy human contact and conflict resolution, but assists managing supervisors at behavioral health organizations in maintaining Best Practices as well as allowing problems to be resolved in-house.

Think of the Alert Line as a second pair of eyes to help ensure responsibility and accountability in your behavioral health organization.

Interested in learning more about our Behavioral Health Compliance Alert Line? Contact us today: 1-800-495-6786

 

-Megan Phillips, M.A.

 

Reference: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/MLN-Compliance-Webinar.pdf

Behavioral Health Accreditation Comparison: CARF, COA and TJC

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Behavioral Health Accreditation Comparison: CARF, COA and TJC

Accreditation ensures quality care and services are provided to individuals in a safe manner. Onsite accreditation surveys demonstrate if programs and services are conducted in a manner that is consistent with established, field tested standards. It is a key way for behavioral health organizations to show commitment to quality as well as a possible condition for federal and state regulatory compliance, grants, reimbursement for certain insurers or other payers, Medicaid certification, etc.

Accreditation can be a daunting task for behavioral health providers. Here are the major similarities and differences between CARF, COA and TJC Accreditation:

CARF- Commission on Accreditation of Rehabilitation Facilities

CARF International is an independent, nonprofit accreditor of health and human services. They accredit around 47,000 programs and services with more than 20,000 locations on five continents. CARF directly impacts over 8.3 million people through over 6,000 providers.

Website: http://www.carf.org/home/

Founded: 1966

Who they Accredit: Health and Human Service organizations. CARF accredits Aging Services, Behavioral Health, Child and Youth Services, Employment and Community Services, Opioid Treatment Programs, etc.

Length of Accreditation: Options include 3-Year Accreditation, 1-Year Accreditation, Provisional Accreditation, Non-Accreditation, Preliminary Accreditation.

Amount of Preparation Time Needed: 6-9 months for a new accreditation and for re-accreditation.

Cost of Accreditation: Application fee is $995. Survey Fee is $1,670 fee per surveyor, per day (i.e. 2 surveyors: $6,880 – All travel, hotel, etc. costs are included in the day rate).

COA- Council on Accreditation

The Council on Accreditation (COA) is an international, independent, nonprofit, human service accrediting organization. They currently accredit more than 2,200 organizations and programs serving more than 7 million individuals and families.

Website: http://coanet.org/home/

Founded: 1977

Who they Accredit: Human Service Organizations. COA accredits the full continuum of child welfare, behavioral health, and community-based social services.

Length of Accreditation: 3 years for Opioid Treatment Programs and 4 years for other programs.

Amount of Preparation Time Needed: 9-16 months.

Cost of Accreditation: 

  • Application Fee: Non-refundable application fee $750 (not applicable for reaccreditation).
  • Accreditation Fee: Fees start at a minimum of $7,392 for an organization with revenue of $500,000 or less, and increase accordingly.
  • Site Visit Fee: Flat fee of $2,200 per Reviewer for a two-day on-site review, plus $475 per day multiplied by the number of Reviewers for each additional day.
  • Maintenance of Accreditation Fee: $400 annually.

For further information on the cost of COA accreditation, including a fee schedule, click on the following link: https://coa.my.salesforce.com/sfc/p/#300000000aAU/a/500000000Gjj/rVWbesQCUgaY33zMQ87xd1s3eecCLoKM6wu_TI48Ngk

TJC- The Joint Commission

The Joint Commission (TJC) is an independent, not-for-profit organization that accredits and certifies nearly 21,000 health care organizations and programs in the United States.

Website: https://www.jointcommission.org/

Founded: 1951

Who they Accredit: Many types of health care organizations including hospitals, doctor’s offices, nursing homes, office-based surgery centers, behavioral health treatment facilities, and providers of home care services.

Length of Accreditation: 3 year accreditation.

Amount of Preparation Time Needed: 4-6 months.

Cost of Accreditation: Fee estimates vary and are based on current published pricing and information about services and service volume provided by your organization.

  • Application Fee: Initial applicants must submit a non-transferable, non-refundable deposit of $1,700 with the application for survey.
  • Annual Fee: A pro-rated annual fee is billed at the beginning of the quarter after which an initial application is received.

For further information click on the following link: https://www.jointcommission.org/assets/1/18/bhc_price_worksheet.pdf

We at Brown Consulting are specialists in Behavioral Health Consulting with an expertise in accreditation. Give us a call with any accreditation questions today: 1-800-495-6786.

-Megan Phillips, M.A.

 

References:

http://www.carf.org/home/

http://coanet.org/home/

https://coa.my.salesforce.com/sfc/p/#300000000aAU/a/500000000Gjj/rVWbesQCUgaY33zMQ87xd1s3eecCLoKM6wu_TI48Ngk

https://www.jointcommission.org/

https://www.jointcommission.org/assets/1/18/bhc_price_worksheet.pdf