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DHCS DMC-ODS regulatory and compliance Masonic Center Nov 28 8:30-11:30 or 1:00-4:00 Substance Use Treatment Services Nov 27 8:30-11:30 or 1:00-4:00 Register: SCCLearn www.scclearn.sccgov.org

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Page 1: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

DHCS DMC-ODS regulatory and compliance

Masonic Center

Nov 288:30-11:30 or 1:00-4:00

Substance Use Treatment Services

Nov 278:30-11:30 or 1:00-4:00

Register: SCCLearnwww.scclearn.sccgov.org

Page 2: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

DMC-ODS

NOVEMBER 2018

Tianna D. Nelson, Ph.D., L.M.F.T. Behavioral Health Division Director

Steve Lownsbery, L.M.F.T.SUTS Clinical Standards Coordinator

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Page 3: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

DMC-ODS Documentation TrainingAM session PM session

8:00 Registration 12:30

8:30 Regulatory statutes and compliance issues 1:00

9:00 Assessment 1:309:30 Treatment Planning 2:00

10:00 Progress Notes 2:30

10:30 Clinical Justification for Services 3:0011:00 Discharge Planning and Continuing Care 3:30

11:30 Questions 4:00

Sign out and certificates

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Page 4: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 5: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Primary Sources

• Intergovernmental Agreement (IA) (also known as the SUTS contract with DHCS)

Disclaimer: The material on the IA is presented for the purposes of familiarizing the audience with its key features. The presentation does not cover the entire IA and does not claim to be comprehensive.

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Page 6: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Primary Source - IA• Preamble• Federal requirements• Program Specifications

• Includes covered services, access to services, coordination and continuity of care, authorization of services, continued certification of providers, defines the DMC-ODS modalities, case management, recovery services, cultural competency, describes the beneficiary problem resolution process, program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates, compliance records, program complaints, correction action plans, individual quality improvement programs and utilization management and performance measures.

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Page 7: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Foundations of the new world of MCP

• Provider Staff – Counselors, Licensed Practitioners of the Healing Arts (LPHAs), & Medical Director

• Substance Use Disorder Diagnosis & Medical Necessity

• Treatment Modalities

• Documentation Requirements

• Resources7

Page 8: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 9: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 10: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 11: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 12: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 13: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 14: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Regulation Compliance Clinical

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Page 15: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Page 16: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Licensed Practitioner of the Healing ArtsLPHAs include:

• Physician • Nurse Practitioners • Physician Assistants• Registered Nurses• Registered Pharmacists • Licensed Clinical Psychologists• Licensed Clinical Social Worker • Licensed Professional Clinical Counselor • Licensed Marriage and Family Therapists • License Eligible Practitioners working under the supervision of licensed clinicians 16

Page 17: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

The Role of the Medical Director/Physician

• Develop & Implement Medical Policies & Standards

• Ensure Physicians & LPHAs • trained to perform diagnosis & determine medical

necessity, within scope• receive five hours of continuing education related to

addiction medicine annually

• Physicians do not delegate their duties to non-physician personnel 17

Page 18: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Medical Necessity Criteria

• Beneficiaries must have one SUD diagnosis from the DSM

• Must meet the ASAM Criteria definition of medical necessity

for services based on the ASAM Criteria

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Page 19: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

• Place appropriate limits on a service - On the basis of criteria applied under the State plan, such as medical

necessity; or

• For the purpose of utilization control, provided that - The services furnished can reasonably achieve their purpose

- Must ensure that the services are sufficient in amount, duration or scope to reasonably achieve the purpose for which the services are furnished.

Medical Necessity Criteria42 CFR 438.210(a)(4)

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Page 20: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Determination of Services Must be Medically Necessary

42 CFR 438.210(a)(4)

• Intake Assessments• ASAM – 6 Dimensions• DSM Criteria• 42 CFR 438.210(a)(4) (Adults)• 22 CCR § 51303 (Adolescents)

By – Medical Director or LPHA

Required professional reviews the initial treatment plan to determine whether the services are medically necessary. Shall type or legibly print name, sign & date treatment plan within 15 days of the therapist or counselor or within 30 days from admission, whichever comes first. 20

Page 21: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Substance Use Disorder Diagnosis

• Counselor – LPHA or Medical Director• required face-to-face review

• Medical Director or LPHA (working within their scope of practice)• SHALL document the basis of the diagnosis based on DSM criteria

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Page 22: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Intake and Assessment

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Page 23: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Intake and AssessmentPhysical Exam(PE): a) completed by M.D. / LNP / PA within 30 days of admit b) provides proof a PE done within the last 12 months c) Obtaining a PE is a Treatment Plan goal

HSQ and determination of medical eligibility w/in 30d of admit signed by MD w/lic, #, & dated

ASAM biopsychosocial assessment is completed within 30 days of admit

Documentation of the face-to-face/telehealth chart review by the counselor & LPHA

LPHA determines and provides justification for DSM5 diagnosis and appropriate Level of Care 23

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Intake and Assessment

Beneficiary Record shall include:Identifier (i.e., name, number)BirthdayGenderRace and/or Ethnic BackgroundAddressTelephone numberNext of Kin or Emergency Contact

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Page 25: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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nceIntake and Assessment

Documentation of all client demographics and emergency phone numberMonthly Medi-Cal eligibility is documentedYOUTH - Parental/guardian’s involvement in treatment is justified, sign & datedALOC reflects appropriate LOC for the treatment modality & is signed and datedALOC is completed at the "Intake" counseling session- ALOC reflects appropriate LOC, is signed & dated with QI authorizationConsent to Treatment is signed and datedThere is a written consent for psychiatric medications 25

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Admission Agreement is signed and datedProgram Rules are signed and datedAppropriate Release of Information (ROI) are completed, signed and datedBeneficiary Handbook given & Ack of Receipt of Grievance process signed & datedBeneficiary's Fair Hearing Rights are signed and datedBeneficiary's preferred language for treatment is documentedInterpretation services are documented when preferred language is not EnglishIdentifies client's strengths

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Intake and Assessment

Financial, educational, employment and legal history is documentedIndividual and family substance use history documentedFamilial, cultural and social factors are identifiedCase Management issues are summarizedDocumentation of coordination of care with other providersAdmit to Recovery Services is conditional on previously completing OS treatmentASAM biopsychosocial assessment is completed within 30 d of admitDiagnosis is supported by current symptoms and behaviorsMedical necessity is stated as a significant impairment or distress in life functioning 27

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Chapter 1 p. 63Chapter 2 pp. 11 & 13Chapter 3 p. 13Chapter 4 pp. 20, 23, 24 & 25Chapter 4 pp. 23 & 24 Chapter 5 p. 4 Chapter 5 p. 27 Chapter 6 p. 32Chapter 6 p. 34Chapter 8 p. 38

Intake and Assessment

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Treatment Plan Timeline and Requirements

Initial:• 30 calendar days from admission

–Counselor/LPHA–Beneficiary

• 15 calendar days from Counselor signature date

• Or within 30 days from admission, if documenting MN by approving the TP –Medical Director/LPHA 29

Page 30: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Reg

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ion • Problem Statements

• Goals• Action Steps• Target Dates• Description of Service; type and

frequency

Treatment Plan

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Page 31: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Reg

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ion • Assignment of Primary Counselor

• Beneficiary’s Diagnosis• Physical Examination Goals• Significant Illness• Assignment of primary counselor / LPHA

Treatment Plan

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Page 32: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Treatment Plan

LPHA name is printed, signed, license & # and dated

Client’s goal to obtain a PE is on the Treatment Plan (as needed)Plan has modality of SUD services and frequency

Problem statements identify areas of impairment or distress of SUD

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Page 33: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Treatment Plan

Goals and Action Steps have target dates

Client has name printed, signed and dated

Notation client was offered a copy of the TP

Primary Counselor's name is printed, signed, license & # and dated w/in 30d of admit

LPHA name printed, signed, license & # and dated w/in 15 days of counselor 33

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1. Interventions are clinically appropriate to reduce impairment, restore functioning or prevent significant deterioration

2. Problem Statements are correctly matched with the appropriate dimension

3. Case Management (CM) identifies specific linkage services4. Case Management (CM) is stated with range of frequency

5. Stage of Change is correctly matched with appropriate Problem

6. Goal(s) relate to the Problem Statement & match the Stage of Change

Treatment Plan

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a. Action Steps\Interventions are strength-basedb. Action Steps are stated in measurable terms (S.M.A.R.T.)c. Action Steps help achieve the Goal(s)d. Action Steps are strength-based

e. WM Care Plan signed by LPHA, license & # and dated w/in 48h of admit

f. PHS/RES - TP signed, by LPHA license & # and dated w/in 10 days of admit

g. OS/IOS/RS TP printed, signed by LPHA, lic & # and dated w/in 30d of admit

Treatment Plan

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Page 36: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Chapter 2 p. 15Chapter 3 pp. 20, 21, 22 & 23

Chapter 4 p. 23, 25, Chapter 5 p. 26, 28 & 30

Chapter 6 p. 32 & 34

Chapter 7 pp. 35, 36, &37

Chapter 9 pp. 40, 41, 42 & 45

Treatment Plan

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Page 37: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Progress Note• Topic of session OR purpose of the service• Actual treatment service or counseling session time is noted

distinctly from the documentation and travel time

• Description of progress OR lack of progress on treatment plan

• Attendance – date, actual start & end times– If break is provided, must document

• Identify if services were provided in-person, by telephone, or by telehealth

• If provided in the community, identify location and how the provider ensured confidentiality 37

Page 38: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Progress NoteDescription of type and summary of services provided

Location, if out of office

Each session has date and start & end time

Services are individualized based on the TP

CM services connected to the TP Goals

Counselor’s intervention(s) are stated with client’s response38

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Progress Note

Completed within 7 days of the session

Counselor’s name is printed, signed, license & #, and datedIOS - Adult - minimum of 9 hrs/wk / Youth - minimum of 6 hrs/wk

IOS - Breaks are separated from the hourly listing of service

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Page 40: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Progress Note

Reflects treatment progress or lack thereof based on TP goals

IOS - Youth sessions correspond to a minimum of 6 hours per week

IOS - Adult sessions correspond to a minimum of 9 hours per week

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Page 41: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Signature RequirementsLPHA or counselor shall:

Type or legibly print their name

Sign and date the progress note within 7 calendar days of the counseling session or treatment service

Counselor’s name is printed, signed, license & #, and dated

Signature shall be adjacent to the typed or legibly printed name

Progress Note

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Page 42: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Case Management

Beneficiary’s name

The purpose of the service

Narrative summary

Date, start & end times

How confidentiality was insuredIdentify if the service was provided in-person, by phone, by telehealth or in the community

Progress Note

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Page 43: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Case Management

Beneficiary’s name

The purpose of the service

Narrative summary

Date, start & end times

How confidentiality was insuredIdentify if the service was provided in-person, by phone, by telehealth or in the community

Progress Note

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1. No show or cancelations are documented

2. Services are individualized based on the TP3. Counselor's interventions reflect EBPs used

4. CM/phone - Has justification / rationale of treatment services

5. CM services are connected to the TP Goals, and Action Steps

6. CM field sessions have an explanation of how confidentiality is protected

Progress Note

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Progress Notea. OS & RS - completed within 48 hrs of the sessionb. IOS / PHS / WM / RES - DAILY documentation of

activities, services and sessionsc. PHS – treatment services correspond to a

minimum of 20 hours/weekd. RS - Minimum 1x monthly (face-to-face, telephone

or telehealth) e. RES - Bed census correspond to Treatment

services documented 7d/wkf. RES documentation of all treatment and activities

are a minimum of 20 hrs/wk 45

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i. Family therapy and/or family counseling appropriately claimed

ii. Notation if treatment services were provided in their preferred language

iii. Evidence of coordination of care with client's PCP

iv. Documentation of coordination of care with other providers

Progress Note

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Page 47: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Chapter 1 p. 13Chapter 2 p. 15Chapter 4 pp. 20, 22,23 & 24Chapter 6 p. 32Chapter 7 p. 37Chapter 9 pp. 42 & 43Chapter 9 p. 43Chapter 10 p. 5

Progress Note

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Page 48: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Group - Sign-In Sheets

• Establish and maintain a sign in sheet for every group counseling session to include:

• Typed or legibly printed name of LPHA and/or counselor and beneficiary

• Date of session• Topic of session• Start and end time of session

For IOS and Residential:– Provider shall have a sign-in sheet for patient education

and structured activities 48

Page 49: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Group - Sign-In Sheets

Group sign-in sheet lists between 2-12 participants

Group sign-in sheet has topic and date

Sign-in sheet has client's notation of start and end time Client’s name is printed and signed with time signed in to the group session

Counselor’s name printed, signed, license & # and dated 49

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Justification of a cofacilitator is noted

Group notes documented separately by a cofacilitator

Group

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Page 51: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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• 90 calendar days –From initial or prior treatment plan

• Unless there is… –A change in treatment modality –Or a significant event necessitating

a new TP (clinical justification)• Whichever occurs first

Updated Treatment Plan

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Page 52: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Updated Treatment PlanPlan has modality of SUD services, frequency, amount & target dates

Problem statement identifies areas of impairment or distress of SUD

Client’s name is printed, signed and dated

Primary Counselor's name is printed, signed, license & # and dated w/in 90d of previous TP

LPHA name printed, signed, license & # and dated w/15 days of counselor by day 90

Notation TP copy given to client 52

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1. Problem Statements identifies areas of impairment or distress of SU

2. 1st Problem Statements are correctly matched with the appropriate dimension

3. Stage of Change is correctly matched with appropriate problem(s)

4. Goal(s) relate to the Problem Statement & match the Stage of Change

5. Action Steps are stated in measurable terms (S.M.A.R.T.)6. Action Steps help achieve the Goal (s)

Updated Treatment Plan

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Page 54: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Chapter 2 p. 15

Chapter 4 p. 21 & 23

Updated Treatment Plan

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Page 55: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Continuing Services Justification (CSJ)

• Outpatient Services

• Intensive Outpatient Services

• Case Management

• Naltrexone Treatment

• Btwn 5th - 6th month from admin or last CSJ

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Page 56: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Continuing Services Justification• LPHA/counselor shall review

– Document recommendation of continuation of services • Determination of continued medical necessity shall be

documented by medical director or LPHA• Review and consideration of the following shall be

documented:− Beneficiary’s personal, medical, substance use history− Most recent physical exam− Progress notes & treatment plan goals− LPHA/counselor’s recommendation− Beneficiary’s prognosis

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Page 57: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Continuing Services Justification

Justification of Clinical Services describes treatment outcomes

Counselor/LPHA gives prognosis

Counselor’s name is printed, signed, license & #, dated

LPHA has narrative clinical justification for medical necessity for this LOC

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Page 58: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Continuing Services Justification

YOUTH - Notice of Parental/guardian’s is updated, justified, signed & dated

Signed by LPHA between the 5th & 6th / 11th & 12th month

LPHA name printed, signed, license & # and dated

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i. Describes treatment outcomeii. Counselor/LPHA gives prognosisiii. Counselor’s name is printed, signed, license & # and datediv. LPHA has narrative clinical justification for medical

necessity for this LOC v. YOUTH - Notice of Parental/guardian’s is updated, justified,

signed & datedvi. Signed by LPHA between the 5th & 6th / 11th & 12th month vii. LPHA name printed, signed, license & # and dated

Continuing Services Justification

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Page 60: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Chapter 4 p. 21

Continuing Services Justification

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ion – Within 30 days of last face-to-face service

• Required elements:– List of relapse triggers– Plan for avoiding relapse when faced with triggers– Support plan - how to assist / avoid

• People• Organizations

• During last face-to-face, LPHA/counselor and beneficiary, shall type or legibly print printed, signed, license & # and dated on the discharge plan

• A copy must be provided to beneficiary & documented

Discharge Plan

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Page 62: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

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Discharge Plan

1. Detailed progress and goals (achieved or not)

2. Details client’s Continuing Care Support Plan

3. Has client’s name printed, signed and dated

4. Client notification of a NOADB - IF Involuntarily terminated given 10 day prior to D/C

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Discharge Plan

1. Notes either reason of Voluntary or Involuntary discharge2. Detailed progress and goals (achieved or not)

3. Details client’s Continuing Care Support Plan4. States value and referral to Recovery Services5. Treatment / Residential / Recovery Services Plan is current

at discharge

6. Client notification of a NOADB - IF Involuntarily terminated given 10 day prior to D/C

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ion • Required for an unexpected lapse in treatment services for

30+ days

• Completed by LPHA/counselor within 30 days of last face-to-face

• Required elements:– Duration of the treatment episode– Reason for discharge– Narrative summary of the treatment episode– Prognosis

Discharge Summary

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Discharge Summary

Involuntarily terminated client’s Fair Hearing Rights are advised

Client notification of a NOADB - IF Involuntarily terminated is given 10 day prior

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Discharge Summary

Chapter 4 pp. 21, 23, & 24 & 26

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Page 67: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

Regulation Compliance Clinical

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Page 68: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

SUTS System of Care audits• Contract Monitoring

• Fiscal• Personnel• Facilities

• Intergovernmental Agreement• Drug MediCal-ODS

• Clinical 68

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SUBSTANCE USE TREATMENT SERVICES

UTILIZATION REVIEW PROCESS 1. U.R. will take place quarterly on the last Monday of the month. In the event of a holiday it will

occur on the 3rd Monday of the month.

2. Although there is no State ADP requirement, Medi-Cal charts will typically be brought on a random basis, having a 10% sample of the total number of open charts of the site to be reviewed quarterly.

3. Clinicians will be notified one week prior to the U.R. process in order to allow time for them to

complete the top portion of the U.R. “Quarterly Chart Review” prior to bringing the chart to U.R. 4. The “Period Reviewed” will be the three-month period prior to the U.R. as per the State

calendar. 5. Clinicians conducting the U.R. are expected to review content for any disallowances related to

provider services. (i.e. medical review, meeting target dates, individual/group progress notes match type of service provided; assessment is complete; all consent forms are signed etc.)

DISALLOWANCES

A. A disallowance will occur for the following reasons: 1. Physical Exam documentation does not occur prior to the 30 day window of Treatment Plan

(TP) development. 2. OR Physical Exam, as a client’s goal, is not documentation the TP.

3. TP is not developed within 30 days or 5th visit from admission.

4. M.D. does not sign the TP within 15 days after Counselor’s signature 5. A Request for the Six Month Extension of Treatment is prior to the fifth or after the sixth

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UTILIZATION REVIEW (UR)

SANTA CLARA COUNTY DRUG MEDI-CAL

Client: ID #: Counselor: PROGRAM: Diagnosis: ,

Admit Date: 9/1/18 Discharge Date: 10/1/18 REVIEWED From: Date: 10/31/18 to Date: 10/31/18

DRUG MEDI-CAL - DISALLOWANCE COMPLIANCE ISSUE Intake and Assessment P NP P NP

Physical Exam a) completed by MD/LNP/PA within 30 days of admission date b) proof a PE done within the last 12 months

YOUTH Notice of parental/guardian’s involvement in treatment is justified

Admission Agreement/Program Rules are included and signed Health screen (HSQ) done within / 30 days of Admit

Date:

HSQ signed by M.D. Date: 5/1/15

ASAM assessment is completed within 30 days of Admit ASAM assessment is Signed by MD

Primary Counselor of Medi-Cal services is noted Substance Use Disorder criteria is delineated

Initial Treatment Plan P NP P NP Initial Treatment Plan (TP) is submitted within 30 Date: 5/1/15

days of Admission date Client physical health issues as noted per the HSQ (Dim 2) are on

the Treatment Plan

States a Substance Use Disorder diagnosis Short and long term goals noted

Lists SUD treatment services, frequency and target dates Action steps are clearly defined and measurable

Client’s name is printed, signed and dated

Counselor’s name printed, signed, & dated within 30 days of Date: ____________ Admit

M.D. name printed, signed, and dated within 15 days of Date: ____________ counselor

Progress Note P NP P NP Has counselor’s signature and

date Time and Duration

Completed within 7 days of the counseling session Progress or lack of per TP goals Crisis session is substance use related and justified Counselor’s intervention noted

Second Service Same Day is documented per DMC standard Client’s response stated Second Service Same Day DHCS MC 6700 form is completed & in

the chart Stage of change recorded

IOP Sessions correspond to a minimum of 3 days a week 3 hours each day per week

Collateral is with a nonprofessional IOP Second Service Same Day is ONLY a Crisis and is

documented per DMC standard

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SUTS

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SUTS

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75

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Primary Sources - Regulatory authority citations• IA - Intergovernmental Agreement for Santa Clara County• STC - Standard Terms and Conditions• AOD Cert. Standards - Alcohol and/or Other Drug Program Certification

Standards (May 1, 2017) Alcohol and/or Other Drug Program Certification Standards• DMC - Drug Medi-Cal Certification Standards for Substance Abuse Clinics (July

1, 2004• DTS - Standards for Drug Treatment Programs (September 1982)• Title 9 - California Code of Regulations, • Title 9 - Narcotic Treatment Programs• Title 22 - California Code of Regulations • Title 22 - Drug Medi-Cal (as amended by Emergency Regulations)• WIC - Welfare and Institutions Code• Perinatal Service Network Guidelines 2016-2017• SUTS CPM - Substance Use Treatment Services Clinical Performance

Measures76

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does not address • How to fill out a GRS, RRS, TRS or a CRS

• an ALOC• CalOMS – Clinician's Guide to CalOMS• Admit paperwork

• Billing Procedures - SUTS Biz Ops or DHCS Billing Manual • HIPAA or 42CFR, CFR 45 or 438• Beneficiary Rights and Grievance procedures • Beneficiary Handbook• SUTS Clinical Documentation Manual• Client Satisfaction Survey• Title 9 NTP/OTP or MAT

• Other specific clinical trainings, eg., ALOC, DSM5 diagnostic differentials, Stages of Change, Treatment planning, or use of EBPs77

Page 78: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

SCCo SUTS Contract with DHCS

• Changes the terms and conditions of SUTS relationship with DHCS

• By signing the contract SUTS agrees to take on a dual role:• Operating an organized delivery system (ODS) • Functioning as a managed care plan (MCP)

• Signing the contract makes SUTS contractually obligated to comply with IA terms

The Intergovernmental Agreement (IA)

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Page 79: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

The IA – SCCo SUTS Contract with DHCS

• The IA is composed of two main sections; a general section and a county-specific section

• The provisions in the general section applies to all waiver opt-in counties

• The general section contains 28 different provisions and a 29th

section that defines key terms in the IA• The general IGA provisions are based mainly on 42 CFR Part

438, which regulates the operation of managed care plans

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Page 80: DHCS DMC-ODS regulatory and compliance...program integrity requirements, quality management, state monitoring, contractor monitoring and reporting requirements, training program mandates,

County – specific provisions in the IA

• Provisions of Section 30 are unique to each county’s waiver proposal submitted to DHCS

• Section 30 lists key elements of SUTS waiver proposal submitted to & accepted by DHCS (& CMS)

• SUTS is contractually obligated to provide services proposed in the waiver plan

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FEDERAL REQUIREMENTS• 42 CFR Part 2

– Confidentiality of Alcohol and Drug Abuse Patient Records• https://www.gpo.gov

• 42 CFR Part 438– Managed Care Subparts A-J

• https://www.gpo.gov/fdsys/granule/CFR-2011-title42-vol4/CFR-2011-title42-vol4-part438/content-detail.html

• 45 CFR– HIPAA Privacy Rule

• https://www.hhs.gov/hipaa/for-professionals/privacy/index.html81

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DMC-ODS RESOURCES • FAQs, Fact Sheets & Information Notices• Special Terms and Conditions• Technical Assistance• Webinars

• DMCODS webpage: – (http://www.dhcs.ca.gov/provgovpart/Pages/Drug-Medi-Cal-Organized-

Delivery-System.aspx)

• Submit a form for all DMC-ODS Waiver questions:– (http://www.dhcs.ca.gov/services/adp/Pages/DMC-Answers.aspx)

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DHCS Additional Resources

• MHSUDS Information Notices–http://www.dhcs.ca.gov/formsandpubs/Pages/M

HSUDS-Information-Notices.aspx

• State Health Information Guidance (SHIG)–http://www.chhs.ca.gov/ohii/pages/shig.aspx

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• SUD County Complaint• [email protected]• Required within 2-business days of completing the investigation.

• Program/Counselor Complaints• http://www.dhcs.ca.gov/individuals/Pages/Sud-Complaints.aspx• Public Number: (916) 322-2911• Toll Free number: (877) 685-8333

• Certifying Organization Complaints• [email protected] 84

COMPLAINTS

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• Certifying Organizations

• http://www.dhcs.ca.gov/provgovpart/Pages/CounselorCertificationOrganizations.aspx

• Counselor Certification• DHCS Revoked and/or Suspended Counselor List• http://www.dhcs.ca.gov/provgovpart/Pages/CounselorCertification.aspx

• Licensed Professionals• http://www.mbc.ca.gov/Breeze/License_Verification.aspx

85

CERTIFICATIONS & LICENCE

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• DHCS Medi-Cal Fraud Website• http://www.dhcs.ca.gov/individuals/Pages/StopMedi-

CalFraud.aspx

• 1-800-822-6222

[email protected]• Medi-Cal Fraud Complaint – Intake Unit

Audits and InvestigationsPO Box 997413, MS 2500Sacramento, CA 95899-7413

86

Medi-Cal Fraud

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SUD Medical Directors are required to take 5 hours of continuing in “addiction medicine” annually.

Medical Directors also have required Continued Medical Education (CMEs) credits either online or in person.

Additional websites that provide information on physician Continuing Medical Education (CME):• http://cmelist.com/addiction-substance-abuse-cme.htm• http://www.audio-digest.org/CME-Series-Specials/substance-abuse• http://www.abam.net/become-certified/earning-cme-for-the-2014-

examination-application/• http://www.csam-asam.org/online-cme• http://psychiatry.ufl.edu/education/addiction-medicine-cme-program/ 87

Medical Director required training Resources

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• California Association of DUI Treatment Programs (CADTP)• Website: http://www.cadtp.org/

• California Consortium of Addiction Programs and Professionals (CCAPP)

• Website: https://www.ccapp.us/

• DHCS Certifying Organization (CO) Webpage• http://www.dhcs.ca.gov/provgovpart/Pages/CounselorCertificat

ionOrganizations.aspx88

Certifying Organizations

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• Counselor/Registrant• Certifying Organization Website – Registry• DHCS Revoked and/or Suspended Counselor List • DHCS Counselor Certification Page

http://www.dhcs.ca.gov/provgovpart/Pages/CounselorCertification.aspx

• Licensed Professionals• Department of Consumer Affairs (BreEZe)

http://www.mbc.ca.gov/Breeze/License_Verification.aspx

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License Status Verification

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QUESTIONS?

90