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Top Findings From the

Community Behavioral

Health On-Site Reviews

BUREAU OF MEDICAID SERVICES

June 2012

How Do I Ask Questions

During this Teleconference?

§  Questions that arise before or during the teleconference

may be emailed to Melissa Eddleman at:

Melissa.Eddleman@ahca.myflorida.com

§  We will answer as many questions as possible during the

teleconference, in addition responses to questions will be posted at:

http://ahca.myflorida.com/Medicaid/e-library/index.shtml

2

Objectives

§ Share top compliance issues found during the community behavioral health on-site reviews

§ Provide key policy reminders

§ Increase compliance with Medicaid policy

3

FINDING #1

Treatment plans lack

measurable objectives.

4

Treatment Plan

Required Component

e treatment plan must contain measurable objectives.

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐15    

Measurable Objectives

Try SMART Objectives

§

Specific

§

Measurable

§

Attainable

§

Relevant

(2)

Examples of

Measurable Objectives

Objective:

Client will identify two (2) reasons for

forgetting to take medication and two (2)

negative outcomes as a result of not taking

medication.

7

Examples of

Measurable Objectives

Objective:

Client will identify and use a minimum of

two (2) methods or plans for remembering

to take medication as prescribed.

8

Examples of

Measurable Objectives

Objective:

Client will log any outbursts of anger she

has each week on her anger log; she will

decrease the number of outbursts of anger

she has each week from eight (8) to four

(4).

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FINDING #2

No target dates on

treatment plans.

10

Treatment Plan

Required Component

§

e treatment plan must contain target

dates. is is the anticipated date of

completing a measurable objective.

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐15    

FINDING #3

Treatment plans do not

specify the amount,

frequency, and duration

(3)

Treatment Plan

Required Component

The  amount,  frequency  and   duraGon  of  each  service  for  

the  duraGon  of  the   treatment  plan  are  required.  

13

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐15    

Treatment Plan

Amount, Frequency

and Duration

§ Do not combine services (e.g. individual/group therapy) when prescribing amount, frequency, and duration.

§ It is not permissible to use terms as needed, prn, or to use ranges such as x to y times per week.

14

Correct Example

15

Two (2) units of group

therapy two (2) days

per week for six (6)

months

FINDING #4

Claims not supported by

a treatment plan.

16

Examples of Findings

Claims not supported by a treatment plan due to:

• Not being signed by treating practitioner

• Signature not credentialed or dated

• No brief assessment/evaluation by a licensed

practitioner of the healing arts or a psychiatrist prior to completion of the treatment plan

FINDING #5

Services provided are

not prescribed on

(4)

Treatment Plan:

Required Components

§ Services must be rendered as prescribed on the treatment plan and authorized in writing by the treating practitioner.

19

Treatment Plan: Required Components, cont d

§ When it is medically necessary, Behavioral Health Overlay Service (BHOS) and erapeutic Group Care Service (TGCS) providers need to include therapeutic home visits on treatment plans.

§ TGCS must identify the clinician responsible for individual and group therapy.

20

FINDING #6

ere is no parent or

guardian signature and

no written explanation

for the omission on

treatment plans.

21

Treatment Plan:

Required Signatures

Signature of the recipient s parent,

guardian, or legal custodian (if the

recipient is under the age of 18) is a

required component of the treatment plan.

22

Required Signatures

§

If the recipient s age or clinical condition

precludes participation in the plan review

and signing, a written explanation and

justification of why the recipient is unable to

participate must be provided in the clinical

record.

Exceptions to Required Signature of Parent/Guardian

§

Recipient is less than 18 years of age

seeking substance abuse services from a

licensed provider.

§

Recipient is in custody of Florida

Department of Juvenile Justice (DJJ) and

has been court ordered into treatment.

(5)

Exceptions to Required Signature of Parent/Guardian, cont d

§

Recipient requires emergency treatment,

that if delayed would endanger the mental

or physical well being of client.

• However, the signature of parent/guardian must be

obtained as soon as possible aer emergency treatment is administered.

25

Exceptions to Required Signature of Parent/Guardian, cont d § Recipient is in the custody of the Florida

Department of Children and Families (DCF) or a Community Based Care (CBC); a DCF or CBC representative must sign treatment plan if it is not possible to obtain parent s signature.

• In cases where DCF is working towards

reunification, the parent should be involved and sign the treatment plan.

26

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐16    

Exceptions to Required Signature of Parent/Guardian, cont d § Recipients age 13 or older experiencing an

emotional crisis to the degree that client perceives the need for professional assistance.

• A recipient can request and give consent for mental health diagnostic evaluation services and outpatient crisis intervention services by a licensed practitioner of the healing arts, or in a state licensed mental health facility.

• Services will not exceed two (2) visits during any one (1) week period in response to crisis before parental consent is required for further services.

27

FINDING #7

Treatment plan reviews

do not demonstrate

progress related to goals

and objectives.

28

Example of

Findings

§ Progress documented as none, minimal progress, and moderate progress but documentation did not describe a recipient's progress specifically related to his/her individualized treatment plan goals and objectives.

§ Documentation indicated no progress or regression and changes were not made to treatment plan.

§ ere was no explanation as to why the plan should continue with no changes.

Documentation of Progress Related

to Goals and Objectives

§ Service documentation must contain updates regarding the recipient s progress toward meeting goals and objectives identified in the treatment plan.

•  Does the treatment plan review document progress related to the treatment plan goals and objectives?

(6)

FINDING #8

Psychosocial Rehabilitation

Services:

Daily notes are lacking

specific interventions.

31

Psychosocial Rehabilitation

Services

Specific Documentation Requirements

A daily service note that describes what activities the rehabilitation counselor did to enhance/support the recipient s skills of:

•  pre-vocational and transitional employment training

•  independent living and social skills

32

Psychosocial Rehabilitation Services, cont d

Specific Documentation Requirements •  daily medication use

•  housing

•  social support and networking •  food planning

•  money and life management

33

Psychosocial Rehabilitation

Services, cont d

Specific Documentation Requirements

e monthly progress note must reflect:

• how the services are linked to the goals and objectives of the recipient s treatment plan; and

• the recipient s progress relative to the treatment plan.

34

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐31  

FINDING #9

Documentation

Deficiencies

Documentation Requirements

Service documentation must contain all of the following:

§ Recipient s name;

§ Date the service was rendered;

§ Start and end times for procedures with specified minimum time frames and procedures billed on a per unit basis;

(7)

Documentation Requirements, cont d

§ Identification of the setting in which the service was rendered;

§ Identification of the specific treatment plan related problem, behavior, or skill deficit for which the service is being provided;

§ Identification of the service rendered, including the specific intervention;

37

Documentation Requirements

cont d

§ Documentation must be legible;

§ Documentation must clearly distinguish and reference

each separate service billed;

§ Documentation must support a service was rendered on

the date it was billed;

38

Documentation Requirements

cont d

§ Updates regarding the recipient s progress toward

meeting goals and objectives identified in the treatment plan; and

§ Original, legible signature and credential (e.g., licensed

clinical social worker) or functional title (e.g., treating practitioner) of the person rendering the service.

Community  Behavioral  Health  Services  Handbook  page:  2-­‐1-­‐2    

39

Limited Service Authorization

§

A temporary deviation from the prescribed

services or frequency of services must be

reported using the Limited Service

Authorization form.

 

40

Limited Service Authorization

§ is form may also be used for documenting the need for services already provided when a recipient leaves treatment prior to completion of the treatment plan.

• When used for this purpose, the form must be completed within 45 days of intake.

§ A completed Limited Service Authorization form must be placed in the recipient s clinical record.

Claims

Findings

(8)

Claims Findings

Treating practitioner not

linked or enrolled in

Medicaid

43 Enrollment of the Treating Practitioner Descrip(on       Provider  Type

TreaGng  physicians   25  or  26

TreaGng  licensed  pracGGoners  of  the  healing  arts  

(LPHA)   07

Licensed  PracGGoners  of  the  Healing  Arts  (LPHA)  

must  also  be  affiliated  with  a  group  provider  (provider  type  05)    to   be  reimbursed  as  an  individual  provider  type  07.  

 

44

Claims Policy

§  A group must have at least one (1) provider type 25 or 26 linked to your group in order to be a Community Behavioral Health Provider.

• Only provider types 25, 26, & 07 are allowed to be

linked to a provider type 05 group.

45

Claims Findings

Remember:

§  To submit a Group Membership Authorization form for every treating provider who will be rendering services and for whom you will be seeking reimbursement for under your group number.

•  Non-treating providers, such as: behavioral health tech, certified addictions professional or behavior analyst, etc., are not enrolled.

46

Group  Membership  AuthorizaGon  Form   Example  of  a  

properly   completed   group   authorizaGon   form  to  link  an   individual   provider  to   your  group   number.  

Summary

§ e treatment plan must contain measurable objectives.

§ e treatment plan must contain target dates.

§ e amount, frequency and duration of each service for the duration of the treatment plan are required.

§ Services must be rendered as prescribed on the treatment plan and must be authorized in writing by the treating practitioner.

(9)

Summary, cont d

§ Signature of the recipient s parent, guardian, or legal custodian (if the recipient is under the age of 18) is a required component of the treatment plan.

§ Service documentation must contain updates regarding the recipient s progress toward meeting goals and objectives identified in the treatment plan.

49

Summary, cont d

§ Verify that the treating practitioner is enrolled

into the group.

§ Follow Medicaid policy as stated in the Medicaid Handbooks.

§ Contact your Medicaid Area Office or Magellan Medicaid Administration if you need help.

50

51

       

The  Agency  has  thirteen  Medicaid  Area  Offices  in  eleven  areas   throughout  the  state  that  serve  as  the  local  liaisons  to  providers   and  recipients.    The  area  offices  help  with:  

 

•  Provider  relaGons  and  training.   •  Consumer  relaGons.  

•  ConducGng  site  visits  to  providers  and  potenGal     providers.  

•  Handling  excepGonal  claims  processing.                       h;p://www.mymedicaid-­‐florida.com/   51  

Online Information

All Medicaid handbooks, fee schedules, forms, provider notices, and other important Medicaid information are available on the Medicaid fiscal agent s Web Portal at:

http://mymedicaid-florida.com

Click on Public Information for Providers, then on Provider Support, and then click on Provider Handbooks, Forms, or Provider Notices.

52

Thank You

Please email any questions to Melissa Eddleman:

Melissa.Eddleman@ahca.myflorida.com

Responses to questions will be posted at:

References

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