IDHS,%20Division%20of%20Mental%20Health%20Provider%20Briefing:%20%20Changes%20to%20Provider%20Monitoring%20April%203,%2020092-3:30pm%20April%206,%20200910-11:30am

1
IDHS, Division of Mental HealthProvider
Briefing Changes to Provider MonitoringApril
3, 2009 2-330pmApril 6, 2009 10-1130am
2
Speakers

• Jackie Manker, LCSW Associate Director of
  Community Services, DHS/DMH
• Lee Ann Reinert, LCSW ASO Clinical Policy
  Manager, DHS/DMH
• Cathy Cumpston Chief, DHS Bureau of
  Accreditation, Licensure and Certification (BALC)
• Aissa Bell Director, Provider Relations, IL
  Mental Health Collaborative for Access and Choice
• Rusty Dennison, MA, MBA President, Parker
  Dennison Associates, Ltd.

3
Introduction

• Beginning in FY09, DMH incorporated Post Payment
  Reviews (PPR) into DMH/Collaborative provider
  monitoring site visits
• Current DMH/Collaborative site visits include
• - Post Payment Reviews- Clinical Practice and
  Guidance Reviews- Fidelity Reviews (PSR in FY09)
• DHS BALC is still performing Certification reviews

4
Introduction

• DMH reviewed and approved all policies, forms,
  and training materials implemented by the
  Collaborative for PPR
• At the time PPR was implemented, DMH instituted
  managerial oversight of the Collaboratives
  practices
• Weekly meetings with reviewers as well as the
  Collaboratives Provider Relations Director
• Made available DMH clinical staff and BALC staff
  to consult with the Collaboratives reviewers in
  the field
• Involved DMH Regional Contract Managers in
  reviews

5
Introduction

• Consistent with continuous quality improvement,
  DMH asked Parker Dennison to evaluate our
  provider monitoring process in February 2009
• Parker Dennison completed this analysis and has
  provided DMH with recommendations
• DMH has considered these recommendations and has
  begun to implement changes to the process
• Find the Parker Dennison report on the DMH
  website at http//www.dhs.state.il.us/page.aspx?
  item43483

6
BALC Coordination with DMH/Collaborative PPR

• Participation in development of PPR/monitoring
  model
• Participation in Collaboratives PPR staff and
  provider training
• Participation in weekly PPR Collaborative/DMH
  coordination and problem solving calls

7
PPR vs. Certification Differences?

• Example
• Post Payment Review
• Finds 50 of claims reviewed have no current ITP
  in record
• Outcome provider will lose value of those
  claims
• Certification Review
• Finds 5 of 10 records reviewed (50) have no
  current ITP
• Outcome provider will lose 42 points on
  certification
• As a result will have 422 of 464 points on their
  certification for a total score of 91

8
Parker Dennison Assessment of Post Payment Review

• Assessment conducted in January/February 2009
• Information sources included
• Focus group with 25 providers statewide
• Feedback from other stakeholders
• Review of policies, forms, training materials,
  protocols
• Review of Federal OIG reports from IL and other
  states
• Review of applicable state and Federal rules
• Analysis of audit results through 12/31/08
• Included 3,070 claims and audits from 32
  providers

9
Parker Dennison ReportFocus of Post Payment
Review

• All PPR elements consistent with those found in
  other OIG reports
• Some elements found in OIG reports are not
  present in IL PPR
• Federal OIG does identify some elements that can
  be deficient, need correction but not recoupment
• This is inconsistent even within different OIG
  audits
• Recommendations include
• DMH should periodically rotate in new/different
  elements (annually review/update)
• DMH can consider a limited amount of procedural
  designations, at least as a transition

10
Parker Dennison ReportTraining Communication

• Provider training was adequate compared to other
  states but not best practice
• Training was provided regarding Rule 132 (basis
  of PPR)
• Training was provided regarding the PPR tool and
  protocol
• Recommendations include
• Detailed interpretive guidelines
• On-going Frequently Asked Questions (FAQs)
• On-going feedback to providers about aggregate
  results, common problems, recommendations

11
Parker Dennison ReportAudit Staff Resources

• All Collaborative reviewers are LPHAs, including
  two who are also Certified Recovery Specialists
• Represents the highest standard of practice in
  audits
• Overall feedback was positive regarding
  professionalism and clinical knowledge
• Recommendations include
• Expand inter-rater reliability monitoring of
  reviewers
• Involve DMH contract managers for cross training
  where feasible
• Include reviewer competency training in training
  for new reviewers

12
Parker Dennison ReportPost Payment Review
Process

• Unannounced reviews are problematic
• Some inconsistency on provider staff involvement
• Lack of public interpretive guidelines
• Recommendations include
• Discontinue unannounced reviews (unless there is
  a provider-specific reason)
• Clarify provider staff involvement protocol and
  be consistent
• Include interpretive guidelines in provider
  training materials
• More detail on PPR report to providers

13
Parker Dennison ReportAnalysis of PPR Results
(12/31/08)

• Key statistics
• 32 providers
• 3,070 claims
• Avg. of 55 of claims unsubstantiated
• Value of unsubstantiated claims (no
  extrapolation) 101,937
• Avg. unsubstantiated claims per provider (no
  extrapolation) 3,186
• Average of two deficiencies per unsubstantiated
  claim
• Overwhelming majority of deficiencies confined to
  7 elements on PPR tool
• Only these 7 fell below 95 compliance level
• All 7 elements were cited in other Federal OIG
  reports

14
Parker Dennison ReportAnalysis of PPR Results
(12/31/08)

• Lowest compliance
• Q2 (66.87) MHA contains all required elements
• Q10 (81.14) Note contains description of
  interaction w/consumer including response and
  progress toward ITP goal(s)
• All other questions had compliance of 92 or
  greater
• Remediation of top 7 deficiencies would reduce
  statewide average to 12 unsubstantiated claims
  (from 55)
• No data demonstrating an inter-rater reliability
  issue

15
DMH Response

• Pleased with the overall assessment results of
  the Post Payment Review process
• Appears to be identifying targeted areas for
  improvement in moving the system forward
• Identified areas for improvement can be addressed
  in training
• Validates the risk and need for continued efforts
  for continuous improvement in compliance
• Will continue the established managerial
  oversight practices

16
DMH Changes to the Process

• Announce site visits (began 3/20/09)
• Improve communication with providers
• Post interpretive guidelines to website
• Provider alerts with summaries of issues and
  trends
• Analyze and use provider post-review survey
  feedback
• Collect provider questions through the
  dhsmh_at_dhs.state.il.us address
• Post provider FAQs to website
• Ensure reviewer consistency
• Strengthen inter-rater reliability and monitoring
• Continue weekly reviewer check-ins with DMH,
  BALC, and the Collaborative

17
DMH Changes to the Process (cont.)

• Change Post Payment Review scoring
• Split claim status into two parts claims
  disallowed and procedural deficiencies
• Begin requesting plans of improvement based on
  compliance (including all claims findings)
• Begin tracking the individual parts of the Mental
  Health Assessment in the database
• Allow some types of claims to be corrected
• Begin scoring changes going forward and re-score
  those already reviewed this fiscal year
• see the separate document Claims
  Guide

18
Feedback and Questions

• Available to Answer Your QuestionsThanks!
• Jackie Manker, LCSW Associate Director of
  Community Services, DHS/DMH
• Lee Ann Reinert, LCSW ASO Clinical Policy
  Manager, DHS/DMH
• Cathy Cumpston Chief, DHS Bureau of
  Accreditation, Licensure and Certification (BALC)
• Aissa Bell Director, Provider Relations, IL
  Mental Health Collaborative for Access and Choice
• Rusty Dennison, MA, MBA President, Parker
  Dennison Associates, Ltd.