Adult 1915(i) Annual Policy Update Indiana FSSA/DMHA Adult 1915(i) State Evaluation Team October 22, 2020
Purpose This annual policy update provides us the opportunity to review policy changes that have been made throughout the year, provide notification for upcoming changes and what to expect, and answer questions about 1915(i) programming.
DMHA State Evaluation Team (SET)
Garnet Holsapple Centerstone, Regional, Swanson, Meridian, Northeastern, Southwestern Amanda Huff LifeSpring, Gallahue, Adult and Child, Park Center, Grant-Blackford, Hamilton Alexis Pless Oaklawn, Edgewater, Sandra Eskenazi, CMHC, Valley Oaks, Community Howard Elaine Trepanier Aspire, Bowen Center, Four County, Samaritan, Cummins, Porter-Starke
Kudos
Changing of the Guard Starting May of 2019, the SET began to look a little different. By October we had a whole new crew and now finally have a full team as opposed to one person for the entire state . This shift has resulted in an increased ability for oversight and allows us all to do our jobs better and closer to the expectations of CMS. We have greatly appreciated your grace, understanding, and patience.
Improvements in Critical Incidents Reporting SFY19 SFY20 Percentage Change Reported Timely 117 189 38% Overall Reported 167 220 24% Timely Reporting 70% 86% 18% Percentage LIFE HAPPENS , especially when working with high-needs populations. We expect CIRs and they are an expectation of federal safety and well-being requirements. Continue the great work reporting these incidents and always reach out with any questions. The following are considered critical incidents and must be reported: Serious Bodily Injury Elopement Death • • • • Fire/Explosion • Police response • Assault • Suicide Attempt • Alleged exploitation, • Seclusion and restraint abuse, or neglect • Emergency Room Visit • Medication Error • Suicide *If you are unsure if a situation constitutes a critical incident, please reach out to the SET for clarification before the expiration of the timeframe requirements*
Improvements in BPHC Applications NOTE : We are overseen by CMS and are liable to have records audited for accuracy, completeness, and fidelity to federal requirements. We ensure that BPHC applications properly demonstrate service need. We have noticed a decrease in pended applications in the following areas: Describe the maladaptive behaviors caused by the client’s Dx-associated Justifications symptoms and how those behaviors prevent effective, independent healthcare management Objectives Action items that support client achievement of self-identified health goal(s) Describes how BPHC Case Management service activities will support client in Strategies achieving self-identified health goal(s) If you are ever unsure about an application component, please email the SET.
SFY ‘20 QA Process, Changes, and Results This past year, the SET made changes to the Performance Measures evaluated during audits. These changes have made the auditing process more stringent but allow us to better ensure that high quality services are being provided. Despite these changes, we did not see a significant rise in CAPs for the SFY ‘20 audit period, with 19 CMHCs not requiring CAPs! Thank you for all the hard work you do to serve your clients to the highest possible standard and we will continue to support you in providing AMHH and BPHC services.
HCBS Successes Putting the HOME in Home- and Community-Based Services This past year we have added six new HCB residential settings! Thank you for committing to creating safe, community-integrated spaces for our members to live in. Going Virtual Due to COVID restrictions, in-person site visits have been suspended and replaced with virtual visits. We have successfully completed 5 virtual visits so far. Ahead of Schedule The deadline for the Statewide Transition Plan has been extended to March 17, 2023 – a deadline we are well able to meet due to your collaboration!
Response to COVID We know this public health crisis caught us all off guard, so we wanted to extend an especially huge and sincere THANK YOU to all providers for unwaveringly continuing forward to provide necessary services to clients all while incorporating new COVID-related practices into the workflow.
Impact of COVID-19
COVID-19 Impact Public Health Emergency January 31, 2020, CMS declared a Public Health Emergency (PHE) related to the emerging outbreak of COVID-19, making certain powers available to states so long as the PHE remains in effect. Among these, CMS has temporarily disallowed activities that would result in the loss or reduction of Medicaid coverage. To this end, auto-renewals of expiring Medicaid program packages, including BPHC, have been instituted. All other relevant program policy requirements must be met The current PHE extension is set to expire 1/21/2021 Please be mindful that an abrupt change in coverage status for clients maintaining coverage due to the PHE is possible.
COVID-19 Impact BPHC Auto-renewals If a BPHC client is approaching the end of their package date with no renewal application submitted in DARMHA, a renewal will automatically be generated and processed through to DXC to ensure no lapse in coverage occurs. For clients planning to continue utilizing the BPHC service, the process associated with a typical application is still required to be completed. Updated RSST Review and update of BPHC IICP with progress note confirming face-to-face or client involvement – Please note if completed remotely due to safety precautions ANSA with progress note confirming face-to-face or client involvement – Please note if completed remotely due to safety precautions – Confirm SuperUser review Attestation documentation – Please indicate verbal agreement in application and documentation
COVID-19 Impact Remote Audits In the interest of safety, the SET is conducting audits remotely until further notice. We will require the submission of documentation via email. For the package period being reviewed, documentation requests will include all clients for whom charts should be pulled. We will require all associated documentation for the application of the period being audited to be submitted – this documentation should be dated prior to the beginning date of the package period. Period Reviewed ANSA IICP Review Submission EXAMPLE DATES 10/12/2019- 9/20/2019 9/30/2019 10/2/2019 4/11/2020 Progress notes for all billed BPHC services for the package period are required. Progress notes for services delivered outside of the package period should not be submitted.
BPHC Updates
Trends in BPHC Critical Incident Reporting Reporting Timely Agencies with Quarter Reporting No CIRs Filed SFY20 Q1 87% 10 SFY20 Q2 86% 11 SFY20 Q3 90% 9 SFY20 Q4 76% 10 SFY21 Q1 86% 5 We are consistently seeing agencies not reporting Critical Incidents and not reporting timely – we have struggled to stay above the 86% minimum standard for reporting timeliness.
Trends in BPHC Critical Incident Reporting Reporting Timely Agencies with Quarter Reporting No CIRs Filed SFY20 Q1 87% 10 SFY20 Q2 86% 11 SFY20 Q3 90% 9 SFY20 Q4 76% 10 SFY21 Q1 86% 5 We expect Critical Incidents – please do not avoid reporting If waiting for clarification on the details of an event, please submit a CIR with known information and Incident Resolution and/or Agency Plan of Action-Steps that will be taken to follow-up or resolve Otherwise, the report will be considered untimely.
Trends in BPHC Community Connection As a Home and Community Based Service, the heart of BPHC is a consumer’s connection to their community. In the past year of audits, we have observed few examples of evidence of community connection in IICPs. We understand that with high-needs clients there may be barriers to regular forays into the community and that personal preferences will come into play, but HCBS philosophical tenets prioritize increasing a member’s community connection and access to resources as often as possible.
Trends in BPHC Strengths and Goal Progress Services should relate back to SFY20 Audit Performance Measure Average identified goals Interventions should be built upon Goal Progress Identified 85% strengths identified in ANSA and Strength Incorporation 80% existing natural supports Identifying Goal Progress: Ensures that the services being provided are the most appropriate as supported by fostering improvement Guarantees person-centeredness in planning by bringing focus back to the client-identified health goal with every service provided Prompts introspection into potential needs of client Incorporating Strengths: Identify the member’s functional strengths using ANSA or from rapport Identify how these strengths relate to the client’s health goals Use these functional strengths in the plan and throughout treatment to support achieving their desired changes Make note of what strengths and natural supports were utilized or developed with each service progress note
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