Arkansas Department of Human Services Stakeholder Webinar May 17, 2018
Agenda
• • • •
Provider Transition from RSPMI to OBH Behavioral Health Transformation Independent Assessment Update Beacon Update
LICENSURE AND CERTIFICATION PROCESS RSPMI TRANSITION TO OBHS Division of Provider Services and Quality Assurance Dept. of Licensure and Certification Sherri Proffer, RN May 17, 2018
Effective July 1, 2018, all RSMPI providers shall transition to OBHS or lose their ability to bill Medicaid. The Division of Provider Services and Quality Assurance(DPSQA) has the responsibility of the licensure and certification of all RSPMI providers “grandfathering” into OBHS. The current RSPMI provider shall notify DPSQA of their intent to transfer and the transfer date.
This meeting we are going to discuss frequently asked questions from previous transition teleconferences: 1. Can you decide and request additional certifications after you become OBHS? Yes, if you decide you want to obtain additional certifications for Partial Hospitalization, Therapeutic Community Level I or Level II, Acute Crisis Unit, Substance Abuse Tx Cntr or, Community Reintegration you may do so, by completing the form. DPSQA will then conduct a site visit to ensure compliance with the specific certification requirements. If approved, a certification will be mailed to the BHA. 2. If you are certified by The Joint Commission, does the DPSQA certification run until the recertification date of TJC? Yes, currently the license you receive at a BHA will have the expiration date as your TJC or other Accreditation Agency. 3. Do we need to turn in a form for each site and each program we have? Yes, DPSQA is requesting that each site fill out a transition form. We have each site listed separately and each licensure survey will be conducted on a site-by-site basis, instead of the main program site. So in this case, individual records will need to be kept at each individually licensed and certified site instead of the main office.
4. Are the Substance Abuse certification regs available yet? Yes, the Substance Abuse certification regulations can be downloaded at: http://humanservices.arkansas.gov/about-dhs/dbhs/publications 5. If we are already licensed to provide substance use services, will a site visit still need to occur? No, if you are already licensed to provide substance abuse then a site visit will not be required. However, if the currently licensed SA provider wants to bill Medicaid, then the SA provider shall first become a licensed BHA and then they will be certified to provide SA services. 6. If we are already licensed as a Substance Abuse Treatment Center and we DO NOT want to bill Medicaid, we are private pay and accept private insurance, will we need to become OBHS? No, if a currently licensed SA Tx Cntr does not intend on billing Medicaid for services provided, then the provider does not need to be a licensed BHA and certified. They will continue to follow the requirements in the SA licensure manual. 7. Who at DPSQA does the agency notify? Please complete your transition form and send to: Cindy Corbitt at:
[email protected] or you may call her at: 501.320.6415
8. We will be an OBH program. So if we have independently licensed professional that is a contractor with us, they CANNOT bill Medicaid, correct? Yes, correct. If the BHA contracts with the ILP, the BHA bills Medicaid and then pays the contracted ILP their negotiated contracted price. The ILP is working for the BHA in this instance, not for themselves. 9. We have several ILPs that have their offices in adjacent cities to BHA. Can they contract with our agency to provide services and provide them at their location with the agency billing for the service, or can we open a satellite office at their location? If the ILP contracts with the BHA, the ILP may provide services at the DPSQA certified ILP site and the BHA bills Medicaid and then pays the contracted ILP. If the BHA wants a satellite office, the office shall be licensed by DPSQA and the BHA provides the Tier 1 service and bills Medicaid. I’m not sure the BHA would want to open a satellite site there. Remember: BHAs that have licensed professional staff do not have to have ILPs, they have their own staff to perform Tier 1 services. 10. Can one individual own a company with many ILPs working all over the state? The intent of ILPs is so they can work independently in their own certified office and keep their records there in a locked, safe environment and provide services to their clients in a private office. It is not the intent for a broker to keep one office and have ILPs work all over the state. ILPs have to have an individual office they work out of. ILPs cannot work out of the back of their car.
11. Do we have to flip by 7/1/18 or can we work as an RSPMI until 12/31/18? No, if RSPMIs do not flip by 7/1/18, they will not be able to bill for any services. The RSPMI shall flip by 6/30/18. 12. The staff-to-client ratio in the Partial Hospitalization is 1to 5. Does this mean the 5 are professional staff or licensed staff or are para-professionals part of the 5 ratio? The staff to patient ratio is 1 staff person to 5 patients. Section 111.000 of the PH licensure regs state that the allowable staff are: Independently Licensed Clinicians, Non-Independently Licensed Clinicians, Registered Nurses, Advanced Practice Nurses and Physicians. Para-professionals are NOT included in the 1:5 ratio. 13. Can you clarify who the staff report needs to be emailed/mailed to OMIG every month? The report may be emailed to:
[email protected] 14. Will a provider with many sites have to have a Medicaid Provider number for each site? Yes, each site shall have their own Medicaid Provider number in order for them to bill for services.
15. If we become a new substance abuse provider, what will we need to do? If you are a RSPMI and flip to BHA, you will need to check the box Substance Abuse. We will then conduct a site review and if approved send you a SA certification. We will send you the SA certification standards and conduct an unannounced initial survey. You will then have six months to come into compliance with the regulations or have your certification revoked. If you are in compliance, there is a one time application fee of $1500.00 for new applicants. A $75.00 yearly certification fee will be required annually. 16. Will I be able to bill for RSPMI after June 30? No, if you are a current RSPMI provider and have not flipped by June 30, your Provider Number will be suspended and you will not be able to bill. 17. How will I be able to bill starting July1? Our office will notify Beacon of your transition to OBHS. You will need to notify Beacon when your RSMPI treatment plans started and ended and indicate a start/end date when your OBHS treatments plans start.
Once the current RSPMI provider decides to transfer to an OBHS provider as a Behavioral Health Agency, the provider shall notify DPSQA on the attached form and give DPSQA at least two weeks notice (for smaller Providers, e.g. 2 sites ). The Provider shall also notify the DPSQA of their intent to provide additional certification services such as : 1. Acute Crisis Unit 2. Community Reintegration Unit 3. Partial Hospital Unit 4. Therapeutic Community – Level 1 or Level 2 5. Substance Abuse Treatment Facility The provider shall check the additional certification on the transfer form. DPSQA shall conduct site visits before any additional certification is given. BHAs do not require a site visit.
Although the RSPMI will be grandfathered into OBHS, the Provider will need to notify DPSQA of when they intend to “flip” to OBHS as a Behavioral Health Agency. Once DPSQA is notified of the flip, we will send the Provider their License and any special Certification(s). Each Provider site will have a License and/or Certification with a unique vendor number(an identification number for our databases) listed on their License and/or Certification. Licenses will be good for one year or until their CARF Certification review date. The expiration date will be listed on your license. DPSQA will then mail the Provider their License and/or Certification and send a copy of the License and Certification and a copy of the Provider’s Transition Form to Beacon and Division of Medical Services (DMS). Beacon and DMS will authorize PAs and review Provider Numbers to ensure billing can occur as smoothly as possible. To ensure a smooth transition, we are requesting those Providers with multiple sites give DPSQA at least a 30-day written notice of their intent to flip. Please realize that if every Provider waits until June, we will not be able to process the applications in a timely manner, thereby delaying your ability to bill and delaying the authorization of services.
Independently Licensed Practitioners (ILPS) Independently Licensed Practitioner is an individual that is licensed to engage in private/independent practice by the appropriate State Board. The following licensure can qualify as Independently Licensed Practitioners: Licensed Certified Social Worker (LCSW) Licensed Marital and Family Therapist (LMFT) Licensed Psychologist (LP) Licensed Psychological Examiner – Independent (LPEI) Licensed Professional Counselor (LPC) Independently Licensed Practitioners may only provide Tier 1 services, and shall not have MHPPs. The expiration date is listed on the license.
ILPs may have multiple sites, but each shall fill out an application form and each site shall be certified. A site visit shall occur before each site is certified to ensure compliance with the certification manual. Each site shall have its own name e.g. Proffer Counseling Services, Little Rock; Proffer Counseling Services, Hot Springs, etc. Sites may have more than one ILP working in the office, but each ILP shall have their own office and space to provide private individual counseling. Each ILP shall have their own provider number. Each ILP shall have their own policies and procedures as outlined in the ILP Certification Manual. Multiple ILPs occupying one site may utilize the same policies and procedures, but shall list the individual ILP’s name on each P&P. Remember: ILPs are self-employed and work independently.
All BHAs and their additional certification sites providing specialized services shall be licensed and certified separately. For example, if a BHA has a Community Reintegration site, a Partial Hospital site and an Acute Crisis Unit, all additional certification sites shall have a site visit conducted before certification, meet all the certification requirements for each specific certification site and receive a separate certification for each site. Remember, the Provider with several BHAs may not bill under one provider number, each site shall have a separate provider number. Substance Abuse Treatment Programs Substance abuse treatment services shall be provided only in a licensed substance abuse treatment program and the services only be provided within their scope of service by a MHP.
Each BHA and additional certification site shall comply with the licensure and certification regulations for each licensed and certification type. BHAs and those specialty certifications shall comply with physical plant, staffing and other requirements outlined in the licensure and certification manuals, Medicaid Manual as well as any applicable city, state, county requirements as well as the AR Fire Prevention Code. The most stringent of each requirement shall be maintained. Partial Hospitalization Providers requesting a Partial Hospitalization certification in addition to their BHA license shall not provide educational services at their site. Educational services shall be provided at the school as the Partial Hospitalization site is not authorized to provide services other than those services outlined in the OBHS Medicaid Manual and Licensure/Certification Manual .
REMINDER: all RSPMI providers shall notify the Division of Provider Services and Quality Assurance of their intent to transfer to OHBS as a BHA with additional certifications, if applicable, and fill out the transition form notifying DPSQA of their intent to transition and give DPSQA at least two weeks for small Providers and at least 30 days for larger Providers notice. An individual applying as an ILP shall fill out the required transition form within two weeks of their intent to become an ILP. Both the BHA and the ILP shall send their notification by emailing: Cindy Corbitt at
[email protected] or mail to Division of Provider Services and Quality Assurance, PO Box 8059, Slot S408, Little Rock, AR 72203 or fax to : Attention DPSQA, Cindy Corbitt at (501) 682-8551. DPSQA website will soon have the form available in a fillable PDF format and you may email the completed form to:
[email protected]. All BHAs and additional Certified Specialty units shall be in compliance with administration of medications, storage of medications, documentation of medications (this includes scheduled narcotics), destruction of medication (and the results of prn medications), as required by the AR State Board of Nursing(ASBN), the ASBN’s position statements and the Department of Health Pharmacy regulations and requirements. In addition, all BHAs and ILPs shall have appropriate Policies and Procedures as outline in the designated licensure and certification manuals.
All ILPs, BHAs and their certified Specialty Units shall abide by the applicable requirements. Failure of the ILP, BHA and Certified Specialty to follow the licensure, certification and Medicaid manual shall result in a deficient practice. The provider shall receive a Statement of Deficiency (SOD) identifying the deficient practice. The Provider shall provide the Division of Provider Services and Quality Assurance or their designated representative with a with a Plan of Correction within the required time frame. Failure to provide an acceptable Plan of Correction to the Division within the required time frame shall result in additional remedies. The Provider does have the option of disputing the SOD as required by law.
Should you have any questions, please contact: Sherri Proffer, RN Assistant Director Division of Provider Services and Quality Assurance PO Box 8059, Slot 408 Little Rock, AR 72203
[email protected] 501.320.6192 Or Cindy Corbitt Licensure and Certification Unit Division of Provider Services and Quality Assurance PO Box 8059, Slot 408 Little Rock, AR 72203
[email protected] 501.320.6415
Initial roll out of Independent Assessment process began in September 2017. As of today, more than 20,000 Behavioral Health (BH) assessments have been completed.
◦ Claims data shows about 18,000 unique beneficiaries receive Tier 2 or Tier 3 like services in any given month.
Optum is currently averaging over 550 BH assessments per day. DHS and Optum have resources and plans in place to meet previously stated completion amounts by June 30, 2018.
The embedded assessment process is for existing clients (those that are currently receiving services that will be contained in Tier 2 or Tier 3) . Providers are and have been encouraged to continually review their open referral list and remove beneficiaries who do not receive Tier 2 or Tier 3 like services. DHS reviewed all open BH referrals against active Prior Authorizations (PAs) containing Tier 2 and Tier 3 like services and closed approximately 12,000 referrals . These actions support focusing on the clients who would lose services that are currently being provided when provider flips to OBH. Updated referral lists were sent to providers 5/14 to help them identify their beneficiaries who at least have an active PA for Tier 2 or Tier 3 like services. Further alignments are scheduled as DHS continues to monitor open referrals against active PAs as well as claims data and service provisions. Your assistance in identifying beneficiaries on your open referral list who are not currently accessing Tier 2 and Tier 3 like services will minimize future alignment efforts and help prioritize assessments for those who are currently accessing them.
DHS is dedicated to ensuring opportunities for Independent Assessment are provided to all current recipients of BH Tier 2 or Tier 3 like services. The Embed process continues to show success of completion and opportunity. The Call Center process will follow upon exit of provider Embeds. DHS will continually monitor PAs and claims data, and will analyze occurrences of existing recipients having not received opportunity.
Arkansas Independent Assessments DBHS Stakeholder Meeting May 17, 2018
Update on Behavioral Health Assessments • Over 20,000 Behavioral Health Assessments as of EOD 5/15/18 • Over 100 Assessors in the field • Over 2,600 Assessments per week being completed • Embedded at over 40 provider locations across the state • Extended hours and Saturday hours are being utilized • Liaisons assigned to each provider to accommodate ongoing communications and logistics
Key Points for Providers •
If your organization is interested in Saturday or extended hour assessor ability, please let your provider liaison know immediately.
•
Please communicate any concerns with your provider liaison, Optum leadership is meeting two times a day with the assessor team leadership to ensure all situations are addressed timely.
•
Please ensure that any beneficiary who would benefit from a preassessment supplemental form has one submitted ASAP.
•
Optum will be continually aligning resources to ensure that all existing beneficiaries who have a referral for an independent assessment will be provided an opportunity to have an independent assessment completed.
•
DHS and Optum will be reviewing embedded assessor utilization and making any needed shifts to accommodate the efficiency possible. 26
Beacon Update
May 17, 2018
27
OBH Confirmation Request In order to provide Tier 2 or Tier 3 OBH services, a Treatment Plan must be submitted to Beacon for verification of beneficiary Tier determination and receipt of a confirmation number for submission with provider claims. This confirmation number will be requested through ProviderConnect, much like a prior authorization request is completed. Confirmation Number will be given for those OBH services as ordered on the Treatment Plan but may not be in excess of ½ of the annual benefit. An Extension of Benefit is available via medical necessity review.
28
Process for Transition RSPMI Treatment PA Submitted If an RSPMI Treatment Plan Review and PA request has been submitted for services to be provided through June 30, 2018: • Upon receipt of beneficiary Tier determination for Tier 2 or Tier 3 level of eligibility, the provider may submit an OBH Treatment plan at any time thereafter with a start date of July 1, 2018, or the date of OBH flip. • Treatment plan will cover services through Dec. 31, 2018. • The treatment plan must contain: • Services to be provided in OBH through Dec. 31, 2018, including frequency and duration. • Dated signature of MD.
29
Process for Transition RSPMI Treatment PA Not Submitted If an RSPMI Treatment Plan Review and PA request has not been submitted for services through June 30, 2018: • Upon receipt of beneficiary Tier determination for Tier 2 or Tier 3 level of eligibility, the provider may submit an OBH Treatment plan with a start date of July 1, 2018, or the date of OBH flip, via ProviderConnect for verification of Tier determination and to receive confirmation number for OBH services. • Treatment plan will cover all services including RSPMI services through Dec. 31, 2018. • The treatment plan must contain: • Dated signature of MD • RSPMI Services to be provided through June 30, 2018 and • OBH Services to be provided from July 1, 2018 or date of OBH flip through Dec. 31, 2018
• This final RSPMI request must contain documentation of progress/regression. 30
Questions?
