PRESENTED BYLIZZY DROBNICK, MPH/MA

SENIOR ASSESSOR

Preparing for a ROCA:Health and Wellness Common

Concerns and Tips

Overview

Purpose of the ROCA

Report Card Data from ROCAs

Common Concerns Recommendations Easy fixes

Tips for next ROCA

Purpose of ROCA

What is the Regional Office Center Assessment (ROCA)? Job Corps Regional Offices (ROs) are charged with the

responsibility of providing federal oversight of the Job Corps program to ensure that it is delivered with compliance, quality, and integrity. A ROCA is part of this oversight.

The ROCA is a thorough evaluation of Job Corps centers that occurs on a need-based and risk management schedule. Every center shall have two full assessments during the life of a contract that are ideally conducted during years 2 and 5 of the life of a contract, according to the recent PRH Change Notice 15-08.

The health and wellness portion of a ROCA examines the health and wellness programs for compliance with the PRH, as well as applicable state and federal laws.

Who’s Who?

Assessors:

Lois Sacher, RNPat Jackson, RN

Cheryl Walker, APRN, MSN, MBAGary Strokosch, MDLizzy Drobnick, MPH

Who’s Who? Region 1 – Boston

Shannon Bentley, RNJohn Kulig, MD, MPHDavid Kraft, MD, MPHMaria Acevedo, PhDKevin Avery, DMD, PhDDiane Tennies, PhD

Region 2 – PhiladelphiaShannon Bentley, RNJohn Kulig, MD, MPHValerie Cherry, PhDKevin Avery, DMD, PhDDiane Tennies, PhD

Region 3 – AtlantaMelissa Cusey, RNGary Strokosch, MD, MPHSuzanne Martin, PsyD, MPHKevin Avery, DMD, MPHChristy Hicks, MSW

Region 4 – DallasShannon Bentley, RNDrew Alexander, MDLydia Santiago, PhDKevin Avery, DMD, MPHChristy Hicks, MSW

Region 5 – ChicagoMelissa Cusey, RNGary Strokosch, MDHelena Mackenzie, PhDPamela Alston, DDS, MPPChristy Hicks, MSW

Region 6 - San FranciscoMelissa Cusey, RNSara Mackenzie, MD, MPHVicki Boyd, PhDPamela Alston, DDS, MPPDiane Tennies, PhD

Job Corps uses a Program Rating System (PRS) as a qualitative measure of performance for center/OA/CTS operations (PAG, pg 4, Aug 2008).

Take home message: A satisfactory program meets PRH requirements.

Scoring

Report Card 2014

Total number of centers reviewed: 62

Exceptional3%

Very Good21%

Satisfactory55%

Unsatisfactory2%

Marginal 19%

Health and Wellness Scores 2014

Exceptional2% Very Good

23%

Satisfactory44%

Unsatisfactory3%

Marginal 29%

Oral Health and Wellness Scores 2014

Exceptional5%

Very Good31%

Satisfactory41%

Unsatisfactory2%

Marginal 21%

Mental Health and Wellness Scores 2014

Exceptional12%

Very Good12%

Satis-factory

43%Unsatisfactory

6%

Marginal 27%

TEAP Scores 2014

Report Card 2015

Total number of centers reviewed: 47

Very Good26%

Satisfactory48%

Marginal 26%

Health and Wellness Scores 2015

Exceptional2%

Very Good24%

Satisfactory59%

Unsatisfactory2%

Marginal 13%

Oral Health and Wellness Scores 2015

Exceptional9%

Very Good24%

Satisfactory52%

Unsatisfactory2%

Marginal 13%

Mental Health and Wellness Scores 2015

Very Good20%

Satisfactory43%

Unsatisfactory4%

Marginal 33%

TEAP Scores 2015

Significance of ROCAs

Identify problems on center level

Influence policy

Assess impact

Shape trainings

Definitions

Challenge/Weakness/Concern – refers to components that are non-compliant with the PRH or applicable state and federal laws

Notable Positives/Strengths – refers to Best Practices that go above and beyond PRH requirements

Observations – suggestions that can improve quality of program

IF IT’S NOT DOCUMENTED,

IT WAS NEVER DONE!

Common Concerns:Findings and Recommendations

Concern #1

Medication management violates state statutes or regulations: PRH states [see 6.10, R1 (i)]: “Access to prescription medications” PRH states [see 6.12, R5]: “are subject to prevailing state laws”

How is compliance determined? Interview Wellness staff and subcontractors Review of state statutes and regulations Review of student health records and medication logs

Recommendation: Print and have available for review your state’s Physician, Nursing, and Pharmacy Practice Acts for assessors. Speak with your administration (CD, applicable staff, corporate liaison) in advance of ROCA about compliance [see PIN 15-27].

Note: There will be a webinar on Medication Management on Feb. 18th

Concern #2

Case management of chronic health problems not documented: PRH states [see 6.10, R1 (b,4)]: “Students identified as having

chronic health problems during the cursory or entrance physical shall be monitored as directed by the center physician or other appropriate center health-care provider.”

How is compliance determined? Review of student health records (chronic care management plans,

documentation in chronological medical record or SF-600) Student interviews

Recommendation: Document case management in student health record. Documentation should include regular monitoring and education regarding the importance of self-responsibility and how chronic illness may affect maintaining employment.

Concern #3

Missing documentation from off-center referrals: PRH states [see 6.10, R1 (j)]: “An off-center specialist

referral system”

How is compliance determined? Review of student health records

Recommendation: Request documentation from all referral sources to ensure that information on the current health status of the student is complete and available. Send a signed authorization for release of information along with the student when he/she goes off center for medical reasons.

Concern #4

Authorizations and/or health care guidelines (HCGs) are not up to date PRH states [see 6.12, R9 (a,b,c)]: “All health care guidelines shall be

approved and signed annually by the center physician, CMHC, or center dentist, as appropriate. Current signed and dated HCGs shall be kept in the Health and Wellness Center. Annually, each center shall submit a memorandum to the Regional Office indicating which HCGs have been modified. Copies of any individual health staff authorizations and health care guidelines that have changed shall be sent to the Regional Office for approval.”

How is compliance determined? Review of health care guidelines This includes review of all authorizations, treatment guidelines, and

symptomatic management guidelines

Recommendation: Update health care guidelines as new ones become available. Have new subcontractors sign authorizations. Have a copy of the signed and dated memorandum from the Regional Office.

Concern #5

Inadequate staffing: PRH states [see 6.12, R1(a,b)]: Ensure that health services staffing is in

compliance with the staffing levels presented in Exhibit 6-5 and the minimum staff qualifications identified in Chapter 5, Exhibit 5-3b. Employ or subcontract with medical, dental, TEAP, and mental health professionals subject to the prior approval of the RO, in consultation with the Regional HS.”

PRH states [see 6.12, R5]: “subject to prevailing state laws”

How is compliance determined? Review of staffing charts Interview of Wellness staff Review of credentials, licenses, waivers, and other materials Review of state statutes and regulations

Recommendation: Hire staff that meet PRH requirements and if an exception is made obtain a waiver from the Regional Office. Print and have available for review your state’s various Practice Acts for assessors [see PIN 15-27]. Speak with your administration (CD, applicable staff, corporate liaison) in advance of ROCA about compliance.

Note: There will be a webinar on State Practice Acts on Feb. 10th

EASIER FIXES

Other Common Concerns and Observations

Other concerns – 6.10 Student Health Services

Oral Health and Wellness Program Treatment plan not developed or documented – See

6.10, R2(c) No documentation that students have been informed

about the elective oral examination (observation) No documentation that students consent to basic oral

care – See 6.12, R5(b,d) Mental Health and Wellness Program

No documentation of case conferences - See 6.10, R3(d,5)

Document!

Other concerns – 6.11 Related Health Programs

TEAP – See 6.11, R1(b,2): CDP, CTP presentations are not done

TUPP – See 6.11 , R3(f): Minor students are not provided with a referral to TUPP from staff outside of

Wellness. Family Planning Program – See 6.11, R4(c,2):

The CP in conjunction with an OBGYN provider and the student do not agree on a care-management and separation plan.

HIV/AIDS – See 6.11, R5(a,4): HIV testing is not done when a student is diagnosed with a newly contracted

STI. HEALs – See 6.11, R7(c,2):

Lack of weight management program

Document!

Other concerns – 6.12 Health Administration

Professional Standards of Care – See 6.12, R5(d) Dentist, CMHC, or TEAP specialist do not document on the

main chronological record or progress note (SF-600) Lack of problem list or not consistently updated

FECA/OWCP – See 6.12, R8 Students sign form that says injuries from horse play are

not coveredContinuous Quality Improvement – See 6.12, R15

Centers must have regular student surveys, chart audits, and CQI activities.

Document!

Tips for your next ROCA

Review this webinar: Preparing for a ROCA: Health and Wellness

Review common concerns and make sure they are addressed

Have pre-ROCA forms complete and available to assessors prior to ROCA

Review and print federal, state, and local laws and regulations to ensure compliance

List Best Practices!Document, document, DOCUMENT!

CONTACT INFORMATION:

LIZZY DROBNICK, MPH/MALIZZY.DROBNICK@HUMANITAS.COM

Questions?