Category Archives: Uncategorized

Compliance Alert Hotlines


Compliance alert hotlines for reporting a company or organization’s misconduct are common ways for employees to report unsafe conduct as well as law and policy violations. Employees can use these lines to anonymously make reports on their own time.

An organization benefits when they encourage early reporting through a hotline. This enables a company to solve a concern while it is small, before it intensifies into a large problem, well before too much damage occurs.

So hotlines are necessary for quickly conveying important information.

But are hotlines worth the investment of time and money to implement?

Hotlines are helpful in many ways

Reporters are often upset and scared. It has been shown that compliance reports tend to be more comprehensive and clear when live, experienced operators listen and make note of the complaint on a hotline as opposed to a web-based platform.

A reporting system operated by an outside organization is generally seen as more trustworthy than one operated by the employer. Additionally, third-party operators generally have more experience managing these calls, and will provide management with informative hotline data, as well as analyses of the hotline’s efficacy.

What kinds of improper conduct are reported to compliance alert hotlines?

  • 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

What about fear of retaliation? How do we implement a culture of compliance?

It is of upmost importance that reporters do not face identification, retaliation, or retribution at their organization. It is not enough to implement a third-party compliance line, but communication/training should occur that assures employees about what will happen after a report is made. Ensure that ethics and compliance trickles down from leadership. Only when an organization fosters a culture of compliance and ethical decision-making will employees feel safe to point out potential problems.

A positive reputation can be shattered in a moment

Protect your organization with a compliance alert line. Our compliance alert line supports behavioral health compliance programs by giving employees and stakeholders the option to report improper, unethical, or illegal conduct 24 hours a day. By calling the confidential and toll free Alert Line phone number, reports can be made anonymously without fear of identification, retaliation, or retribution.


The following is a testimonial from one of Brown Consulting’s Alert Line clients:

“Brown Consulting, Ltd., made reporting and tracking corporate compliance easy. They give our employees access to an impartial third party, trained in handling corporate compliance matters with confidentiality and sensitivity.

They are one of the many reasons we continue to provide quality, safe, and effective behavioral health services.”

-Kameshia Rogers, Regional Executive Director at Premier Care, Inc

Free Live Webinar from the American Society of Addiction Medicine

We are sharing the following information about a FREE webinar from the American Society of Addiction Medicine this Thursday, October 12th:


Addressing Addiction Issues Among Veterans 

Thursday, October 12, 2017

9:00 am pacific | 12:00 pm Eastern

Attend this webinar to gain insight into specific veteran issues within the context of addiction treatment. Understand the role physicians and other medical professionals can play to better serve this special population. The webinar will examine specific tools and resources for clinicians treating patients with substance use disorders, and is targeted toward clinicians, physicians, academicians, and other addiction medicine professionals who regularly interact with veterans.

Join ASAM and experts from the National Institute on Alcohol Abuse and Alcoholism (NIAAA) for this special learning opportunity.

Learn how to:

  • Explain the impact of the opioid epidemic on the veteran population
  • Describe the unique issues veterans may encounter during treatment
  • Appraise which treatment tools are available and appropriate for the veteran population
  • Discern comorbidities within the veteran population and specific tools to treat co-occurring substance use disorders
  • Grasp a veteran’s perspective on treatment of substance use disorders
  • Recognize the role of trauma and pain and the implications for treating and screening a veteran for substance use disorder


  • Anthony P. Albanese, MD, DFASAM, Affiliations Officer, Dept. of Veterans Affairs; Clinical Professor of Medicine, UC Davis School of Medicine
  • Ismene Leonida Petrakis, MD, NIAAA Institutional Research Training Program; Yale University School of Medicine
  • Raye Z. Litten, PhD, Acting Division Director, Division of Medications Development, NIAAA

Outsourcing QI Management Services

Outsourcing QI Management Services

Quality Improvement (QI) is a methodical approach to the evaluation of practice and efforts to improve practice. State departments and accrediting bodies (Joint Commission, CARF, COA) require and evaluate specific QI processes in behavioral healthcare organizations to help maintain a set foundation of quality treatment and health status outcomes.

For many behavioral health organizations, outsourcing QI management services is a cost-effective and time saving decision that far outweighs the stress of dealing with demanding requirements by themselves. At Brown Consulting, Ltd., we specialize in Quality Improvement. We not only guarantee the implementation and management of a “Best Practice” QI culture, but we ensure full compliance with required regulations. Furthermore, we ensure the QI system we implement is sustainable and embraced by all key stakeholders. All staff are involved in the interactive process of developing, adopting, and managing the organization’s QI plan.

The Brown Consulting Ltd. Quality Improvement process encompasses a full spectrum of service. First, Brown consultants provide QI education and training to staff to assure that a QI culture to be implemented within the system is understood and embraced by all key stakeholders. Then, we utilize an interactive process with clinic staff to develop, adopt, and articulate the organization’s QI philosophy and plan. We make sure to articulate the full written QI Plan to include important aspects of care (i.e. consumer satisfaction, access, client outcomes, etc.), monitoring activities, indicators, thresholds, data collection and interpretation, trend analysis, and comparative data sources. Detailed attention is given to all regulatory requirements.

Once implemented, we manage the QI program, provide all QI functions and ensure responsibilities are articulated in a QI plan. We conduct all scheduled Quality Improvement (QI, Safety / Risk Management) monitoring evaluation and trend analysis activities to address:

  • Access
  • Client satisfaction
  • Employee satisfaction
  • Referral source satisfaction
  • Incident reports
  • Outcome effectiveness
  • Clinical peer reviews (records)

We design and produce quarterly required QI reports for your organization, and continually upgrade the QI Program. We ensure the performance and effectiveness of your organization’s QI program results in meaningful improvements within the organization and meets regulatory standards.

Quality Improvement measurement is complex and evolving rapidly. Continuous efforts are required from an entire organization to achieve stable processes. However, outsourcing QI management services can help lift this burden from your organization. Outsourcing this responsibility to the expert consultants at Brown Consulting Ltd. will allow your organization to tap into needed skills and resources without expending the time and money used on new staff. Outsourcing allows your organization to stay focused on what matters most—the mental health of patients.

5 Steps to Cultivating Regulatory Compliance and Quality Improvement at your Behavioral Health Organization

5 Steps to Cultivating Regulatory Compliance and Quality Improvement at your Behavioral Health Organization

Behavioral health agencies across the nation face ever-changing compliance and quality improvement standards. Adhering to these rules is important not only for providing a safe environment for patient care, but also for assuring that operations are as efficient and ethical as possible.

Maintaining compliance and keeping well-informed about continuously evolving standards, regulations, and requirements can be a burdensome task. This often requires a full-time commitment from one or more of your staff members. No staff member is free from the implications of the compliance process, and it is important that everyone working at your behavioral health organization is up-to-date on quality standards and protocols, at all times.

Here are five steps to developing regulatory compliance and quality improvement at your behavioral health organization:

  1. Train your staff about ongoing compliance and quality improvement standards
    • Train your staff at their new employee orientation, and maintain an ongoing training schedule.
  2. Work together to implement the proper processes
    • Conduct an annual or 6-month review your policies and procedures. Do significant changes need to be made? Would a few brief modifications suffice? Be objective. It is important to assess where your organization is, and where there are opportunities to improve.
  3. Assure your staff is consistently reminded of standards and requirements
    • Offer open meetings that allow staff members the opportunity to learn and ask questions. Hang posters reminding your team of standards. Implement a weekly organizational newsletter or email blast that offers instructive tips. Where do you have opportunities to provide this information?
  4. Evaluate your documentation procedures
    • Conduct an annual or 6-month internal audit of patient documentation to confirm that everything is complete and accurate. Review your policies and procedures to ensure your team is following all of the right guidelines. Meet with counseling supervisors about their training methods and provide them support when needed.
  5. Train your staff on how to interact with accreditation representatives
    • Prepare staff to answer compliance and quality improvement questions “on the spot”. Set aside time to conduct a survey run-through where your team engages in an accreditor/staff role-play scenario. Practice. Practice. Practice.

Remember, compliance standards are established for the purpose of delivering quality patient care. Your organization and patients will benefit if you make regulatory compliance and quality improvement a priority.

Brown Consulting, Ltd. can help you guarantee compliance and quality improvement

We have over 30 years of experience helping behavioral health organizations with compliance and quality improvement. Our extensive experience in behavioral healthcare consulting lends itself to understanding the necessary regulations and guidelines state by state. Our Regulatory Compliance services can be found here.

-Megan Phillips, M.A.

Our Need for Ethics and Fraud Prevention

Our Need for Ethics and Fraud Prevention in the Behavioral Health Treatment Industry

The alcohol and addiction treatment industry has been receiving a great deal of attention the past few years around fraudulent patient recruitment and billing practices. Nationally, major organizations like the National Association of Addiction Treatment Providers (NAATP) have focused on providing leadership and sparking a dialogue on this topic of ethical treatment practices (NAATP code of ethics). However, generally speaking, the industry is troubled.

Current State

Loopholes have allowed unethical drug treatment centers to bill insurance companies for millions of dollars’ worth of counseling and assessment fees, without necessarily helping addicts recover. When coupled with the recent opioid epidemic, some addiction treatment centers have wrongly acted on this opportunity to profit from the increased number of clients struggling with addiction.

The general population is becoming more and more aware of this unscrupulous conduct, as increased attention from the media has brought troubling treatment practices to light. Responding to the current state of affairs, the NAATP has moved beyond pledging to actually enforcing ethical treatment practices. The theme of the most recent NAATP conference could be summarized as, if our industry doesn’t change practices, and soon, it will implode.

Some of the top unethical practices NAATP and other leading organizations are hoping to eliminate moving forward include:

Patient brokering:

Unethically steering a patient with certain insurance coverage to a particular facility, and compensating from this practice. Art VanDivier, chair of the NAATP’s Ethics Committee, said the going rate to steer a patient with Affordable Care Act coverage to a particular facility is now $7,000. That sounds like a lot of money, but the clinic can bill the insurer $15,000 to $30,000 for a month of treatment, charge for lucrative drug tests along the way, and then bill for eight or so weeks of intensive outpatient treatment” (Grim, Huffington Post, 6/17/16).

Bribing clients to relapse:

“And if the patient relapses and fails a drug test, that process can start all over again, still covered by insurance. Not surprisingly, stories of patient brokers bribing people to relapse were rampant at the [NAATP] convention. The fee for that ran between $500 and $1,000” (Grim, Huffington Post, 6/17/16).

Manipulative online marketing practices:

“Third-party sites that present themselves as independent aggregators of information are often run by a single treatment center, and every phone number routes to it rather than to the various clinics the site purports to link to. “Closers” on the other end of the line are charged with persuading the family in crisis to send their loved one to that single center – even if they may be located far away” (Grim, Huffington Post, 6/17/16).

Sound treatment programs have adjusted to this new wave of enforced proper ethical conduct, responding by changing questionable practices and cleaning up their business models. However, the reputations of many programs have yet to catch up with their behavior. Currently, service providers struggle with finding balance and answering questions such as, what is appropriate compensation for marketing our program? And, how can we best work around barriers to treatment for individuals who are dealing with financial problems and/or homelessness?

Future Implications

It’s important to remember that many clients seek addiction treatment on the worst day of their life, and, when brave enough to seek treatment, they deserve to be met with respect and ethical care. Many behavioral health providers believe this and are optimistic about their industry, with hope that change is possible.


Brown Consulting, Ltd. can help you guarantee compliance

We have over 30 years of experience helping behavioral health organizations with compliance. Our extensive experience in behavioral healthcare consulting lends itself to understanding the necessary regulations and guidelines state by state. Our Regulatory Compliance services can be found here.

-Megan Phillips, M.A.


Riordan Seville, L., Rappleye, H., Schecter, A., (2017, June 26). How to Find a Good Drug Treatment Program and Avoid the Bad Ones. Retrieved from

Grim, R. (2016, June 17). Addiction Treatment Industry Worried Lax Ethics Could Spell Its Doom. Retrieved from

Is Your Organization HIPPA Compliant?

The Details Behind HIPAA

Healthcare regulations are continually evolving. The Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule provides consumers with important privacy rights and protections in regard to their personal health information. Since President Bill Clinton signed HIPAA into law in 1996, it has been continually updated to keep up with changes in data exchange, including electronic health information.

HIPAA establishes “national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically” (

The Act makes sense. Guaranteeing consumer privacy protections results in individuals trusting their health care providers and cultivates a willingness to seek needed services. These protections are especially important in the world of behavioral health where stigma associated with seeking services is pronounced. Furthermore, HIPAA outlines when health providers may or must disclose information such as for the health and safety of the patient or others.

However, at a time when healthcare is depending on the unrestricted flow of data to transform how care is delivered and paid for, HIPAA and its regulations have been viewed with frustration.

The apparent crackdown of HIPAA audits, and the substantial fines issued when violations are found, has led to a great deal of anxiety among healthcare providers. This is the case especially for  small entities, such as mental health agencies, who don’t have the staff or technology to keep up with an ever-changing world of electronic health information and security. Failure to comply with HIPAA can result in not only the fines mentioned above but also criminal charges and civil action lawsuits as well as providers losing their credentials or licensure.

So, does HIPAA compliance in mental health differ compared to HIPAA compliance in other areas of healthcare?

Privacy rights and protection of health information take on distinct meaning in mental health care. This is because the stigma associated with mental health conditions, sensitive issues of family dynamics and/or a slew of other factors.

One exception to the Privacy rule is psychotherapy notes. These types of notes receive special protections under HIPAA. The following was found on

The Privacy Rule defines psychotherapy notes as notes recorded by a health care provider who is a mental health professional documenting or analyzing the contents of a conversation during a private counseling session or a group, joint, or family counseling session and that are separate from the rest of the patient’s medical record. Psychotherapy notes do not include any information about medication prescription and monitoring, counseling session start and stop times, the modalities and frequencies of treatment furnished, or results of clinical tests; nor do they include summaries of diagnosis, functional status, treatment plan, symptoms, prognosis, and progress to date.  Psychotherapy notes also do not include any information that is maintained in a patient’s medical record.

Psychotherapy notes are treated differently from other mental health information both because they contain particularly sensitive information and because they are the personal notes of the therapist that typically are not required or useful for treatment, payment, or health care operations purposes, other than by the mental health professional who created the notes.

However, HIPAA treats the disclosure of mental health information to family members the same as with general health information. Unless authorized by the patient, a health care provider may only share or discuss information to the extent that family members need to know to assist in the patients care or payment of care.

Can Brown Consulting Ltd. help my organization ensure HIPAA compliance?

Yes! This specific consultation service includes conducting a full HIPAA Compliance Analysis. Our analysis involves reviewing and providing concrete examples of HIPAA Compliant:

  • Plans
  • Policies & Procedures
  • Forms
  • Contracts
  • Notices
  • Position Descriptions

Services provided also include:

  • Interactive work-groups with staff
  • Further education/training

Making sure your business in compliant with HIPAA regulations can be stressful. Let us at Brown Consulting Ltd. help you guarantee HIPAA compliance!

-Megan Phillips, M.A.

Ohio BH Redesign Updates!

Ohio BH Redesign Updates!

Ohio’s Behavioral Health (BH) Redesign DID NOT go into effect on July 1, 2017, in deference to the legislative budget process. The Ohio Department of Medicaid (ODM) and the Ohio Department of Mental Health and Addiction Services (OhioMHAS) provided the following updated timeline for behavioral health redesign implementation resulting from the final version of Ohio’s 2018-2019 biennial budget, Amended Substitute House Bill 49:

Aug. 1, 2017:


o   Ohio hospitals may begin delivering and billing for Medicaid behavioral health outpatient services using the new code set. This initiative is intended to increase access to behavioral health services for Ohioans in need, especially for children and multi-system youth. Early implementation by hospitals is possible because the Medicaid claims system for hospitals is separate from that used by community BH providers who are certified by OhioMHAS. This initiative is authorized by Ohio Administrative Code Rule 5160-2-75 which was reviewed by the Joint Committee on Agency Rule Review (JCARR) on July 17 for an Aug. 1, 2017 effective date. Click HERE for more details.


Oct. 1, 2017:


o   ODM rules for Medicaid community BH services will be final filed for a Jan. 1, 2018 effective date. In addition, final versions of provider manuals, coding sets and workbooks regarding the new BH code set will be publicly available. The most up-to-date versions of these documents are currently posted HERE.


Jan. 1, 2018:


o   Providers of Medicaid community behavioral health services (provider types 84 and 95 in MITS) will begin to render and bill for services using the new behavioral health coding structure and benefit package.

o   For clients enrolled in Medicaid managed care, behavioral health services will be “carved in” to Ohio Medicaid managed care plans and services will be billed directly to the individual’s plan.

o   For clients who are not enrolled in a managed care plan, services will continue to be paid through the Ohio Medicaid fee-for-service system (MITS).


For more information on Behavioral Health Medicaid Redesign, visit We value your feedback and questions. 



E. Wandersleben, e-mail communication, July 26, 2017

Is the Integrity Gap Widening in Behavioral Health?

Is the Integrity Gap Widening in Behavioral Health?

It wasn’t too long ago that Behavioral Health received little attention with respect to integrity of our industry. However, with increased attention of the Department of Health and Human Services (DHS) and the Office of Inspector General (OIG), Behavioral Healthcare leaders, like other healthcare leaders, must re-examine their internal operations and practices to protect their organizations from fraud and abuse.

With Behavioral Healthcare billing millions and millions of dollars to Medicaid, Medicare and other healthcare programs each year, the growing attention received from the Federal Government is not likely to go away. Has fraud and abuse increased in the Behavioral Health Industry? We hear more and more about incidents occurring across the country including inaccurate claims, billing fraud and a range of unethical practices. Is the “Integrity Gap” widening in Behavioral Health?

The “Integrity Gap” refers to the “distance” between our day-to-day conduct and the ethical standards of the organization. If an organization operates unethically, the organization moves further away from its ethical code and widens the “Integrity Gap”.

To protect the integrity of the organization, the leader must be committed to establishing an internal compliance program to prevent fraud, abuse and other unethical practices. As leaders, we must insure a culture of integrity and manage the “Integrity Gap” within our organization.

To do so, we should develop compliance programs with internal controls to manage these risks. Effective compliance programs will consist of: 1) Statement of Conduct (organizational ethics), 2) Compliance Officer, 3) Compliance Hotline (insures anonymity of whistleblowers), and a process for 4) Internal Investigation.

Several high risk areas for abuse and fraud include inaccurate billing/claims, contractual relationships (internal/external), over-billing Medicare/Medicaid (In the past, it’s been reported that some financially struggling providers have used this technique to “float loans” to the organization until external audits require paybacks which in many cases don’t occur for several years).

Needless to say, internal controls with respect to inaccurate billing are essential in your compliance program as this is the area that receives the primary attention from external regulators. However other areas critical to the integrity of your organization should not be overlooked nor viewed as less important. Contractual relationships, Conflict of Interest, vendor/referral relationships, fundraising and so on – if mismanaged can seriously impact the integrity of your organization, widen the “integrity gap” and impact your ability to service your community.

Brown Consulting, Ltd provides Toll-free “Employee Action Line” to support your in-house Corporate Compliance Program. For additional information, call 800-495-6786.

Dan Brown, President

Brown Consulting Ltd. Launches Improved Website

For more than 30 years, Brown Consulting has helped behavioral health organizations improve their operational foundations—from strategy, to policy, to accreditation, and more—in order to provide their patients with superior care.

Excellence is a journey, not a destination. Brown Consulting is here to help our clients in that journey, and we also are seeking ways to improve our own services. With that goal in mind, we are pleased to announce the launch of our new website.

When you visit you will find it easier than ever to access the specific service in which you are interested, such as:

  • strategic planning
  • operational consulting
  • regulatory compliance
  • turnkey program development

There are quick and easy online forms where users can immediately request resources, a personal contact, or to schedule a free consultation. Additionally, the new design has been optimized for better viewing and navigation on mobile devices such as smart phones and tablets.

There is also a new “Who We Work With” page with information about some of the respected and satisfied clients that we have been privileged to serve. The news page will provide the latest on our services, and the ever-changing behavioral health landscape.

Our mission is to provide clients with results, not promises. Our improved website is a direct result of our commitment to superior customer service.

Effective Leadership

Effective Leadership

In a lot of discussions today, many administrators, leadership groups, management teams and even consultants talk about the most critical aspects of organizations today. Is it Human Resources, QI Culture or MIS capabilities? I believe all these aspects are important – even critical – but the most critical are the organization’s leaders. Who are its leaders and how effective are these leaders?

When I define what an effective leader is, do we look at the bottom line (profit/loss)? Longevity? Proficiencies, etc.? While it is obvious that each is important, having the opportunity to consult with nearly 300 organizations, I’ve learned that every leader is unique in style, personality and focus. Therefore, I believe the only true measure of effective leadership is how effective the organization is. If the organization is not functioning well, it has to go back to its leaders – not only the CEO, but all its leaders. Administrative Leadership Group strategies and even senior staff. Anyone who influences others is a leader within your organization.

Today I am seeing more and more executive leadership groups struggling with their organization, certainly in our economy. Where our organizations are at in the Business Development Cycle and on supportive staff impart our ability to lead. Let’s look at effective leadership – what are they made up of.

How do today’s leaders develop and maintain organizations that are motivated, creative, innovative, legal and committed?

Effective leaders are the following:

Leadership Characteristics: I often ask participants to take a few minutes and think who was their most important leader – what were their characteristics? Ethical? Passionate? Positive? Innovative, etc. It’s no different for your followers. They look to you for the qualities. How do you see yourself?

Directional Clarity: Strategic Tasks move people from where they are to where they they’ve never been. Sounds simple? But isn’t that what strategy is really all about? Does your strategy, your vision get your employees excited or does it just sit on a wall. Strategic Planning is the most critical area which will leverage every other area of your organization.

Complex Change Management: Given the economy, business cycle technology and so on, the primary challenge for leadership is to develop a foundation, framework and culture that will be change friendly. This is the primary challenge that all else stems from.

Human Resources: Create an environment of overachievers. Effective leaders know the cost of turnover in their organizations and in performance. Recognize changing needs of employees, the changing workforce and competition. They want the best talent and know how to keep it.

Training: The most effective leaders train. Recognizing this is where you convey your standards, establish your expectations, improve relations, reduce staff turnover and support supervisors. Effective leaders know the importance of recognition.

Succession Planning: By far the majority of managers are better at putting fires out, which reminds me of the 80/20 rule. 80% of managers are reactive and not proactive. We need to expect our managers to lead and train them to lead. Effective leaders do not pick one person to succeed, but conduct complete leadership assessments on all and develop leadership development plans for each. Many use 360 Assessment worksheets to provide a balanced look at the needs of each manager.

Optimization: For years I’ve been talking about optimization and mastery and encouraging exponential growth. These concepts are not new, but even through intellectually we understand, we do not apply. Basically, we all perform certain capabilities, yet some we never master (like a black belt vs. a white belt in Karate).  Others just continue leveraging. Each competency leverages or influences positively or negatively another competency. Master Strategic Planning and it will leverage every aspect of your organization. Master Human Resources and it will leverage the quality of more. Master your budget and it will improve your budget for estimated improvements. 

-Dan Brown, President of Brown Consulting, Ltd.