Behavioral Health Accreditation Comparison: CARF, COA and TJC

Accreditation ensures quality care and services are provided to individuals in a safe manner. Onsite accreditation surveys demonstrate if programs and services are conducted in a manner that is consistent with established, field tested standards. It is a key way for behavioral health organizations to show commitment to quality as well as a possible conditions for federal and state regulatory compliance, grants, reimbursement for certain insurers or other payers, Medicaid certification, etc.

Accreditation can be a daunting task for behavioral health providers. Here are the major similarities and differences between CARF, COA and TJC Accreditation:

CARF- Commission on Accreditation of Rehabilitation Facilities

CARF International is an independent, nonprofit accreditor of health and human services. They accredit around 47,000 programs and services with more than 20,000 locations on five continents. CARF directly impacts over 8.3 million people through over 6,000 providers.

Website: http://www.carf.org/home/

Founded: 1966

Who they Accredit: Health and Human Service organizations. CARF accredits Aging Services, Behavioral Health, Child and Youth Services, Employment and Community Services, Opioid Treatment Programs, etc.

Length of Accreditation: Options include 3-Year Accreditation, 1-Year Accreditation, Provisional Accreditation, Non-Accreditation, Preliminary Accreditation.

Amount of Preparation Time Needed: 6-9 months for a new accreditation and for re-accreditation.

Cost of Accreditation: Application fee is $995. Survey Fee is $1,670 fee per surveyor, per day (i.e. 2 surveyors: $6,880 – All travel, hotel, etc. costs are included in the day rate).

COA- Council on Accreditation

The Council on Accreditation (COA) is an international, independent, nonprofit, human service accrediting organization. They currently accredit more than 2,200 organizations and programs serving more than 7 million individuals and families.

Website: http://coanet.org/home/

Founded: 1977

Who they Accredit: Human Service Organizations. COA accredits the full continuum of child welfare, behavioral health, and community-based social services.

Length of Accreditation: 3 years for Opioid Treatment Programs and 4 years for other programs.

Amount of Preparation Time Needed: 9-16 months.

Cost of Accreditation: 

• Application Fee: No Application Fee
• Accreditation Fee: Fees are based on an organization’s annual revenue, and start at a minimum of $9,712 for an organization with revenue of up to $500,000.  The fee increases accordingly in increments of $500,000 up to $20,000,000.
  • Example:
    • Annual revenue up to to $500,000 = $9,712
    • $500,001 – $1,000,000 = $11,871
    • $1,000,001 – $1,500,000 = $13,412

• Site Visit Fee: Flat fee of $2,200 per Reviewer for a two-day on-site review, plus $475 per day multiplied by the number of Reviewers for each additional day.
• Maintenance of Accreditation Fee: No maintenance fees

For further information on the COA accreditation process, click on the following link:  https://coanet.org/accreditation-process/

TJC- The Joint Commission

The Joint Commission (TJC) is an independent, not-for-profit organization that accredits and certifies nearly 21,000 health care organizations and programs in the United States.

Website: https://www.jointcommission.org/

Founded: 1951

Who they Accredit: Many types of health care organizations including hospitals, doctor’s offices, nursing homes, office-based surgery centers, behavioral health treatment facilities, and providers of home care services.

Length of Accreditation: 3 year accreditation.

Amount of Preparation Time Needed: 4-6 months.

Cost of Accreditation: Fee estimates vary and are based on current published pricing and information about services and service volume provided by your organization.

• Application Fee: Initial applicants must submit a non-transferable, non-refundable deposit of $1,700 with the application for survey.
• Annual Fee: A pro-rated annual fee is billed at the beginning of the quarter after which an initial application is received.

For further information click on the following link: https://www.jointcommission.org/assets/1/18/bhc_price_worksheet.pdf

We at Brown Consulting are specialists in Behavioral Health Consulting with an expertise in accreditation. Give us a call with any accreditation questions today: 1-800-495-6786.

-Megan Phillips, M.A.

References:

http://www.carf.org/home/

http://coanet.org/home/

https://coa.my.salesforce.com/sfc/p/#300000000aAU/a/500000000Gjj/rVWbesQCUgaY33zMQ87xd1s3eecCLoKM6wu_TI48Ngk

https://www.jointcommission.org/

https://www.jointcommission.org/assets/1/18/bhc_price_worksheet.pdf

Strategic Planning Tips

To accomplish anything great—completing college, moving across country, baking a delicious pie from scratch—you need a plan.  A strategic plan helps you brainstorm what a business can accomplish and narrows down exactly where to target your energy. In the unpredictable world of working in behavioral health, a solid strategic plan is essential for success.

So, how should a mental health organization approach strategic planning? Brown Consulting, Ltd. has been working with behavioral health providers co-creating strategic plans for nearly 30 years. Here are our top tips:

1. Identify your strengths and weaknesses

This is more difficult than it seems. It is important to truly understand the inside and outside perceptions of your organization. This step additionally involves researching the environment surrounding your business, as well as the current marketplace. Also, it’s important at this stage to thoroughly evaluate your budget.

2. Specify what you want to achieve

Narrow down your most important goals. How do you want your organization to function over the next 1, 3, & 5 years? What is your current mission? How do you see this mission evolving over time? Then, brainstorm steps to achieve those goals. Identify which goals are priority and where you choose to focus your energy first.

3. Assign tasks to experts who will ensure goals are achieved

Putting the right people in the right places is an old business adage that still rings true. Similarly, this is the time to define who in your business is taking the reins with each goal in your plan. Discuss strategies, budgets and create an action plan for all steps leading to goal attainment.

4. Make your Strategic Plan a working document

Your plan is complete—or is it? Reviewing your plan regularly and often keeps your direction true. Take time to review the process of your plan. It is a strength to think of your strategic plan as a living document that is flexible to change, and therefore innovation.

A strategic plan is a necessary tool to help an organization thrive. We at Brown Consulting, Ltd. are behavioral health experts dedicated to helping behavioral health organizations succeed. Our strategic planning services assist our clients in identifying, planning, developing, implementing and monitoring strategic initiatives for future and continued success. The length of our strategic planning process typically lasts from three to six months.

The Initial Phase of the strategic planning process includes a full review of the industry trends (national, state and local), an organizational and operational analysis which includes evaluation of programs, product line, promotional/marketing and revenue sources so organizations can guide their strategic decision-making processes. Additionally, a market and competitive analysis is completed. Finally, strategic planning groups are conducted with various levels of the organization including Board Members, Executive Leadership, Management and Staff.

Best of luck and happy planning!

-Megan Phillips, M.A.

Mental and Physical Health are Equally Important

I have had a passion to help others with their mental health and well-being since I was a young child. Human psychology and behavior struck my interest when my close family member was diagnosed with Major Depressive Disorder. Even though this illness seemed to be worse than any health condition I was aware of at 10 years old,  it appeared to me that many people did not take depression seriously.

I didn’t know the definition of stigma as a kid, but I witnessed it.

I remember family members stating that this person needed to “snap out of it and stop being so selfish”. But, you see, I knew this person very well and believed them when they said they were feeling sick. This resulted in confusion.  I eventually learned that physical illness is collectively viewed as more legitimate than mental illness.

As an adult professional with a Masters degree in Counseling and Guidance working in behavioral health, I continue to witness stigma surrounding mental illness. It is frustrating.  Public perception is difficult to change. Kevin Cullen, a columnist from the Boston Globe, recently wrote a fantastic article that investigates this dialogue about the public perception of and access to mental health. Check it out here: https://www.bostonglobe.com/metro/2017/03/27/changing-attitudes-harder-than-changing-law/8zC7BnYq4mC3SC7amioU2M/story.html#comments

Working in behavioral health is challenging but vital. If it weren’t for supportive counselors, doctors, and friends I may have lost that family member.  It’s important as a behavioral health professional to put one foot in front of the other and do the work. It is crucial to continually use your voice to educate others and shape the collective attitude surrounding mental health. Every small step is significant when it is taken toward a culture that equally values mental and physical health.

-Megan Phillips, MA

Reference:

Cullen, K. (2017, March 27). Pretending we have equal coverage for mental and physical illnesses is a joke. Retrieved from https://www.bostonglobe.com/metro/2017/03/27/changing-attitudes-harder-than-changing-law/8zC7BnYq4mC3SC7amioU2M/story.html#comments

Compliance Alert Hotline

Compliance programs are internal plans and policy decisions made by an organization in order to meet standards set by government laws and regulations. A compliance alert hotline supports compliance programs by allowing employees and stakeholders to report improper, unethical or illegal conduct anonymously without fear of identification, retaliation or retribution.

What kind of improper conduct should be reported to a Compliance Alert Hotline?

• employee misconduct
• discrimination
• sexual harassment
• privacy/security issues
• inappropriate staff/patient relationships
• employee drug use
• medication diversion
• utilization issues
• improper billing practices and/or clinical documentation

How does a Compliance Alert Hotline work?

The Brown Consulting Compliance Alert Line service operates as follows: *Please note, THIS PROCESS IS ENTIRELY CONFIDENTIAL.

1. Compliance Alert Line posters describing process are provided to sites.
2. Improper, unethical or illegal conduct can be reported 24 hours a day by staff or stakeholders by calling the confidential and toll free Alert Line phone number. These calls can be made privately outside of normal working hours. 
3. Alerts are transcribed the same day they are received by Alert Line staff. Alert Line staff are experienced Behavioral Health professionals who are trained in fact-only information gathering and report writing. Complaints are transcribed quickly, without any bias or breaching of confidentiality.
4. Transcribed alerts are returned to the designated site Compliance Officer for in-house investigation ONLY. At this point, the site determines how best to remedy the complaint in-house.
5. Quarterly and annual reports are provided to sites identifying only the number of alerts and category or type of alert.

When ethical and/or legal problems arise in behavioral health organizations, an “Alert Line” option helps Compliance Officers and Supervisors address issues quickly. Complaints can be handled in-house before they spiral out of control and impact organization operations, reputation, and ultimately, overall performance.

Although behavioral health facilities may already have internal complaint processes, many are not large enough nor have the internal structure necessary to ensure the reporting of a compliant anonymously. Therefore, suspected concerns or violations can go unreported, leaving the organization at risk. Providing an Alert Line option to your employees serves as a reminder of your ethical and moral duty as professional behavioral healthcare providers. It also shows your community that your organization is dedicated to providing above par behavioral health services.

The following is a testimonial from one of Brown Consulting Alert Line clients:

“Brown Consulting, Ltd., made reporting and tracking corporate compliance easy.  They give our employees access to an impartial third party, trained in handling corporate compliance matters with confidentiality and sensitivity.

They are one of the many reasons we continue to provide quality, safe, and effective behavioral health services.”

-Kameshia Rogers, Regional Executive Director at Premier Care, Inc.

A truly beneficial service, the Brown Consulting Ltd. Compliance Alert Line is fully-confidential, cost-effective and a “Best Practice” approach to supporting the ethical integrity of your organizational compliance program. Furthermore, the Alert Line does not replace healthy human contact and conflict resolution, but assists managing supervisors at behavioral health organizations in maintaining Best Practices as well as allowing problems to be resolved in-house.

Think of the Alert Line as a second pair of eyes to help ensure responsibility and accountability in your behavioral health organization.

Interested in learning more about our Behavioral Health Compliance Alert Line? Contact us today: 1-800-495-6786

-Megan Phillips, M.A.

Reference: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/MLN-Compliance-Webinar.pdf

What should I expect during my CARF accreditation survey?

Today is the day. It’s been months of preparation. You are expecting a CARF surveyor to visit your organization. You are ready. Policies and procedures are updated. Files and other documentation have been triple checked for accuracy. All involved parties (board members, personnel and clients) are aware of the survey and available to participate. What should you expect?

What is the general CARF Surveyor process?

A CARF surveyor is a health and human services professional who will evaluate your organization for compliance with CARF standards. They will be onsite for 2-3 days reviewing files, interviewing staff and generally checking out your organization.

The CARF surveyor  will need a hard copy of your policies, procedures and other plan documentation to review when they arrive. A general meet-and-greet will take place with all involved parties. Then, the CARF surveyor will want to review the documentation (this includes client files) and possibly meet with and interview staff members who work in different areas of your organization. Be prepared to set up meetings with human resources, administrative professionals, finance, information technology, quality improvement, service providers etc.

Different CARF surveyors conduct site visits in differing ways, all with the same objective— assessing your organizational compliance with CARF standards. A report will be written about their assessment, which will also outline recommendations. These survey findings are noted areas in your organization lacking compliance and in need of improvement.

The accreditation decision is based on the balance of an organization’s strengths and needed areas for improvement. Organizations don’t have to meet all standards to be accredited. Even organizations who meet the maximum term of accreditation generally have survey findings to improve upon.

Where can I read further regarding the CARF standards and accreditation process?

“CARF offers a series of educational and training sessions to assist service providers to prepare for accreditation, help them remain current with changes in the standards and learn about new standards, and discuss current field practices. CARF also offers web-based educational events. The training dates are listed on this events page.” (http://www.carf.org/Accreditation/AccreditationProcess/FAQ/)

How can I best prepare for the CARF process?

Since 1987, Brown Consulting, Ltd. has assisted hundreds of behavioral health organizations achieve accreditation. We are recognized nationally as “Specialists in Accreditation”. Call us today and your organization can be CARF accredited in less than a year! Let us help you achieve your goals!

-Megan Phillips, M.A.

References:

http://www.carf.org/Accreditation/AccreditationProcess/FAQ/

New Ohio Licensing Requirements

The American Society of Addiction Medicine (ASAM) emailed information regarding a recent Ohio policy update:

Prescribers treating more than thirty individuals for opioid dependence or addiction using a controlled substance now required to obtain a license

On August 4, a regulation from the State of Ohio Board of Pharmacy will go into effect that requires any location where a prescriber is treating more than thirty individuals for opioid dependence or addiction using a controlled substance to obtain a license as a terminal distributor of dangerous drugs with an office-based opioid treatment classification. While the deadline for licensure is not until August, we believe the Board plans to open the licensing process in the spring to allow enough time for those impacted to obtain licensure.

The Board has created a guidance document to provide information on the regulation for those who will be impacted. It can help answer questions on exemptions to the license requirements and provides further explanation on the other provisions of the regulation, such as physician ownership and criminal records checks. There are links to additional resources on this regulation in the document as well.

Please do not hesitate to contact Brad Bachman, Manager of State Government Relations, at bbachman@asam.org or (301) 547-4107 if you have any specific questions.

Reference:

American Society of Addiction Medicine State Advocacy, e-mail communication, February 28, 2017

America’s Deadly Opioid Epidemic

It’s no secret the country has been suffering from an ongoing opioid epidemic.  Overdose deaths from prescription and illicit opioids, including heroine, have increased drastically over the past decade. According to data released by the Centers for Disease Control and Prevention (CDC), overdose rates have quadrupled since 1999.

Why opiates?

Chemistry, not moral failing, accounts for addiction to opiates. Farid Sabet, M.D., Chief Clinical Officer of the ADAMHS Board of Cuyahoga County, stated, “It’s a brain disease that can lead to physical changes like depression, personality changes, G.I. problems, and general infections. When the drug is ingested into the body, it lights up a feeling of euphoria in our brain, and works to mimic many of the body’s systems. After a user’s first time getting high, it takes a higher and higher dose to recreate the feeling.”  http://adamhscc.org/en-US/heroinaddiction.aspx

What are the statistics?

According to the National Center for Health Statistics, the number of overdose deaths involving opioids rose from 28,647 in 2014 to 33,091 in 2015. In 2015, the five states with the highest rates of death due to drug overdose were West Virginia (41.5 per 100,000), New Hampshire (34.3 per 100,000), Kentucky (29.9 per 100,000), Ohio (29.9 per 100,000), and Rhode Island (28.2 per 100,000). https://www.cdc.gov/drugoverdose/data/statedeaths.html

-Heroin overdose deaths rose from 10,574 in 2014 to 12,990 in 2015, an increase of 23 percent.

-Overdose deaths involving synthetic opioids other than methadone rose from 5,544 in 2014 to 9,580 in 2015, an increase of 73 percent. This category of opioids is dominated by fentanyl-related overdoses, and recent research indicates the fentanyl involved in these deaths is illicitly manufactured, not from medications containing fentanyl.

-Taken together, 19,885 Americans lost their lives in 2015 to deaths involving primarily illicit opioids: heroin, synthetic opioids other than methadone (e.g., fentanyl), or a mixture of the two.

-Overdose deaths involving prescription opioids, excluding the category predominated by illicit fentanyl, rose only slightly from 16,941 in 2014 to 17,536 in 2015, a 4% increase.

 NOTE: A portion of the overdose deaths involved both illicit opioids and prescription opioids.

Source: https://www.cdc.gov/drugoverdose/epidemic/index.html

What’s going on at the local level?

Ohio, in particular, has been experiencing devastating effects of this epidemic. Cuyaohoga County alone is projecting nearly 600 overdose deaths in 2017. Recently, Cleveland City Council passed Resolution No. 35-17 that declared the epidemic as a public health emergency.

Treating this dilemma the same way a state/county would treat any other crisis, by declaring it as a public health emergency, allows for the request of additional funding from state and federal government to address the issue. The declaration also has the influence to empower work being done at the local level by cutting through red tape and encouraging EVERYONE to respond to this problem.

The Resolution No. 35-17 can be found here: http://files.constantcontact.com/…/8c123534-2809-4fa2-b90d-…

How is the country responding?

Late in 2016 Congress passed the 21st Century Cures Act, which provides new funding ($1 billion) to fight the opioid epidemic, mostly by expanding access to substance use disorder treatment. Furthermore, the CDC stated there needs to be improvement in prescribing opioids, expansion of the treatment of addiction as well as a reduction of access to illegal opioids. Recommendations include the following:

–Improve opioid prescribing to reduce exposure to opioids, prevent abuse, and stop addiction.

-Expand access to evidence-based substance abuse treatment, such as Medication-Assisted Treatment, for people already struggling with opioid addiction.

-Expand access and use of naloxone—a safe antidote to reverse opioid overdose.

-Promote the use of state prescription drug monitoring programs, which give health care providers information to improve patient safety and prevent abuse.

-Implement and strengthen state strategies that help prevent high-risk prescribing and prevent opioid overdose.

-Improve detection of the trends of illegal opioid use by working with state and local public health agencies, medical examiners and coroners, and law enforcement.

Source: https://www.cdc.gov/drugoverdose/epidemic/index.html

The emotional and physical agony connected with addiction is intense. Addiction impacts family, friends, the community and society as a whole. Providing quality care, intervention and effective treatment not only save lives, but whole communities as well.

-Megan Phillips, M.A.

References:

http://adamhscc.org/en-US/heroinaddiction.aspx

https://www.cdc.gov/drugoverdose/data/statedeaths.html

https://www.cdc.gov/drugoverdose/epidemic/index.html

ASAM Announces New Legislation Tracking Module on Website

ASAM recently announced a new legislation tracking module located on the their website. The tracker, located on each advocacy issue page, shows legislation related to specific issues sorted by state. ASAM’s website states they focus their advocacy efforts on “federal and state legislation and regulation that impact the field of addiction medicine”. ASAM advocacy issues include:

• Opioids
• Marijuana
• Tobacco
• Health Insurance Parity
• Prevention
• Confidentiality (42 CFR Part 2)

Take a look at this new resource on ASAM’s website to see what legislation has been introduced in your state.

-Megan Phillips, M.A.

References:

http://www.asam.org/advocacy/issues?utm_medium=email&utm_campaign=ASAM%20Advocacy%20February%202017%20Recap&utm_content=ASAM%20Advocacy%20February%202017%20Recap+CID_8e7c90f7217c7f84e53bf7e55286e7f0&utm_source=Campaign%20Monitor%20marketing%20software&utm_term=Read%20More

TJC Accreditation Process Webinars

TJC, the not-for-profit organization which accredits and certifies nearly 21,000 health care organizations and programs in the U.S., recently posted webinars regarding basic information about the TJC accreditation process and the new SAFER Matrix, which describes changes to the TJC Survey process.  The webinars can be found here:

Brown Consulting, Ltd. can help your organization with TJC Accreditation Compliance!

Information about the Accreditation Compliance Analysis offered through Brown Consulting Ltd. can be found on the “Our Services” page on our site:

• http://www.danbrownconsulting.com/our-services/

-Megan Phillips, M.A.

References:

https://www.jointcommission.org/webinar_replay_feb_14_accreditation_basics_bhc/

https://www.jointcommission.org/about_us/about_the_joint_commission_main.aspx

Ohio Behavioral Healthcare Redesign Updates

Attention Ohio Behavioral Health providers:

Updated Behavioral Health Redesign Resources are available! Refer to the list below, e-mailed on 2/13/17 from Eric R. Wandersleben, Director of Media Relations & Outreach at the Ohio Department of Mental Health & Addiction Services.

-Megan Phillips, M.A.

Reference:

E. Wandersleben, e-mail communication, February 13, 2017