The Benefits of a 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. For instance, the Accountable Care Act requires that all healthcare providers who receive Medicaid or Medicare payments have a compliance program. An effective compliance program demonstrates an organization is striving to achieve the highest standards of ethical conduct possible.

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.

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.

Complaints can include, but are not limited to:

• 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

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.

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

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 condition 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: Non-refundable application fee $750 (not applicable for reaccreditation).
• Accreditation Fee: Fees start at a minimum of $7,392 for an organization with revenue of $500,000 or less, and increase accordingly.
• 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: $400 annually.

For further information on the cost of COA accreditation, including a fee schedule, click on the following link: https://coa.my.salesforce.com/sfc/p/#300000000aAU/a/500000000Gjj/rVWbesQCUgaY33zMQ87xd1s3eecCLoKM6wu_TI48Ngk

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

TJC Behavioral Healthcare Updates

TJC, the not-for-profit organization which accredits and certifies nearly 21,000 health care organizations and programs in the U.S., has announced a change in their standards regarding Behavioral Health outcome measures. Beginning 1/1/18 Care, Treatment, and Services (CTS) Standard CTS 03.01.09 for accredited behavioral health care organizations requires the assessment of outcomes by using a standardized tool or instrument. The standard currently requires organizations to simply “assess” outcomes of CTS. Read more about the upcoming change here:

• https://www.jointcommission.org/approved_revisions_bhc_outcome_measures_standard/

TJC has also announced Phase 1 of 2 of their regular review project. The updates of their Behavioral Health standards, effective 7/1/17, are expanded on here:

• https://www.jointcommission.org/approved_phase_i_revisions_to_update_behavioral_health_care_requirements/

TJC’s mission is, “to continuously improve health care for the public, in collaboration with other stakeholders, by evaluating healthcare organizations and inspiring them to excel in providing safe and effective care of the highest quality and value”.

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.

Reference:

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

Utilizing a Behavioral Health Consultant

You work in Behavioral Health. Your work is successfully making an impact in your community. Why should you hire a Behavioral Health Consultant to assist your organization?

1. You have limited time and resources

You may be an expert on, for example, specific accreditation standards or Medicaid compliance. However, do you have time to ensure every detailed aspect of that project is carried out accurately and effectively? Maybe not. Hiring a Behavioral Health Consultant can free your time.

2. The world of behavioral health is constantly changing. It’s challenging to keep up!

Our consultants stay on top of the latest behavioral health news and trends. We use this knowledge to effectively address your organizational concerns.

3. You can focus more on what matters most….patients

Working in the field of mental health is meaningful. People pursue careers in this field because they find psychology and human behavior interesting. More than likely, they want to help others. Consultants can provide assistance with basic but essential tasks as well as a fresh approach to problem solving and/or pursuing new opportunities. Utilizing a consultant will open up your organization’s time to focus on the patients and community you serve.

Brown Consulting Ltd. specializes in behavioral services.

Brown Consulting controls the shifting landscape of behavioral health by thoroughly understanding the marketplace today and tomorrow. We offer strategy and solutions for our client’s concerns, including but not limited to:

• Accreditation Compliance (CARF, COA, TJC)
• Strategic Planning
• HIPAA Compliance
• New Program Feasibility Analysis
• Staff Recruitment services

Additionally, we offer customized services. Every state is different. Every organization is different. Every problem requires a unique combination of solutions. This is why, as consultants, we will approach your organizational needs individually and guarantee your satisfaction.

-Megan Phillips, M.A.

Mental Health in the U.S. 2017

Happy New Year! The holidays are over and it’s time to begin anew. So, what can behavioral service professionals expect in mental health in 2017?

The following are key findings from the State of Mental Health in America 2017 report:

• 1 in 5 Adults have a mental health condition.That’s over 40 million Americans; more than the populations of New York and Florida combined.

• Youth mental health is worsening. Rates of youth depression increased from 8.5% in 2011 to 11.1% in 2014. Even with severe depression, 80% of youth are left with no or insufficient treatment

• More Americans have access to services…Access to insurance and treatment increased, as healthcare reform has reduced the rates of uninsured adults. 19% of adults remain uninsured in states that did not expand Medicaid. 13% of adults remain uninsured in states that did expand Medicaid.

• …But most Americans still lack access to care. 56% of American adults with a mental illness did not receive treatment. Even in Vermont, the state with the best access, 43% of adults with a mental illness did not receive treatment.

• There is a serious mental health workforce shortage. In states with the lowest workforce, there’s only 1 mental health professional per 1,000 individuals. This includes psychiatrists, psychologists, social workers, counselors, and psychiatric nurses combined.

• Less access to care means more incarceration. Arkansas, Mississippi, and Alabama had the least access to care and highest rates of imprisonment. There are over 57,000 people with mental health conditions in prison and jail in those states alone. That’s enough to fill Madison Square Garden three times.

Knowledge is a tool. Understanding health disparities that affect our nation is the first step to taking action and providing service to communities in need. The 2017 State of Mental Health in America Report lists up to date facts, statistics and data (FREE copy can be downloaded here: http://www.mentalhealthamerica.net/download-2017-state-mental-health-america-report)

Best of luck this year with all your professional endeavors!

-Megan Phillips, M.A.

References:

Mental Health America (2016, December 14). The State of Mental Health in America 2017. Retrieved from http://www.mentalhealthamerica.net/issues/state-mental-health-america#Key

5 Tips for Behavioral Health Providers to Manage Holiday Stress

The holidays can bring fun, joy and togetherness. However, the holidays can also be a time of stress, anxiety and depression. Challenges include family demands, financial concerns, social commitment overload and more. Stress seems to be synonymous with the holidays. So, how do people, specifically Behavioral Health Providers, stay mentally strong during this wintry season? It’s a fact that when you are stressed and exhausted you have less energy to give to others. Even caregivers need reminders every now and again!

So, here are 5 tips for Behavioral Health Providers to maintain sanity over the holidays:

1.) Attend to your Basic Needs

Everyone who works in behavioral health knows about the basics of self-care. Eating nutritious food, getting enough sleep, moving your body by exercising, and maintaining your social connections with supportive loved ones are all essential. Stick with your normal routine as much as possible.

2.) Boundaries are your friend

Boundaries are simply what you accept and don’t accept in your life. Healthy boundaries are needed to avoid feeling overwhelmed and burnt out. Feel good about saying “no” to events or parties that you’re genuinely not interested in. Let your family and friends know when you’ll be available for visitors and don’t budge out of guilt. If you’re taking care of your needs, everyone wins.

3.) Check in with yourself regularly

With the constant hub-bub of the holidays it’s easy to go a million miles a minute and lose yourself in parties, shopping, family events, etc. Be sure to take the time for yourself to take a breath and really check-in with how your feeling. Do you feel tense? fatigued? joyful? What you need in this moment? Take the appropriate actions to ensure your wellness.

4.) Make a plan & set a budget

Set reasonable goals for holiday expectations such as shopping, cooking and entertaining. Don’t overextend yourself when buying gifts for others. By planning ahead and keeping a goal in mind you’re less likely to overdo it personally and/or financially.

5.) When all else fails, keep the laughter alive

Okay…this is a big one. Don’t take life too seriously! Keeping a sense of humor about all the stress of the season will readjust your perspective. Looking at a story and re-framing the view or meaning is one basic way therapists help their clients. Do this for yourself! Humor is the best medicine!

So there you have it. BE YOUR OWN CLIENT this holiday season and be well. Warm wishes from all of us at Brown Consulting, Ltd.!

-Megan Phillips, M.A.

The Details Behind HIPAA

Healthcare regulations are continually evolving. The Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule provides consumers with important privacy rights and protections in regard to their personal health information. Since President Bill Clinton signed HIPAA into law in 1996, it has been continually updated to keep up with changes in data exchange, including electronic health information.

HIPAA establishes “national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically” (https://www.hhs.gov/hipaa/for-professionals/privacy/).

The Act makes sense. Guaranteeing consumer privacy protections results in individuals trusting their health care providers and cultivates a willingness to seek needed services. These protections are especially important in the world of behavioral health where stigma associated with seeking services is pronounced. Furthermore, HIPAA outlines when health providers may or must disclose information such as for the health and safety of the patient or others.

However, at a time when healthcare is depending on the unrestricted flow of data to transform how care is delivered and paid for, HIPAA and its regulations have been viewed with frustration.

The apparent crackdown of HIPAA audits, and the substantial fines issued when violations are found, has led to a great deal of anxiety among healthcare providers. This is the case especially for  small entities, such as mental health agencies, who don’t have the staff or technology to keep up with an ever-changing world of electronic health information and security. Failure to comply with HIPAA can result in not only the fines mentioned above but also criminal charges and civil action lawsuits as well as providers losing their credentials or licensure.

So, does HIPAA compliance in mental health differ compared to HIPAA compliance in other areas of healthcare?

Privacy rights and protection of health information take on distinct meaning in mental health care. This is because the stigma associated with mental health conditions, sensitive issues of family dynamics and/or a slew of other factors.

One exception to the Privacy rule is psychotherapy notes. These types of notes receive special protections under HIPAA. The following was found on https://www.hhs.gov/hipaa/for-professionals/privacy/:

The Privacy Rule defines psychotherapy notes as notes recorded by a health care provider who is a mental health professional documenting or analyzing the contents of a conversation during a private counseling session or a group, joint, or family counseling session and that are separate from the rest of the patient’s medical record. Psychotherapy notes do not include any information about medication prescription and monitoring, counseling session start and stop times, the modalities and frequencies of treatment furnished, or results of clinical tests; nor do they include summaries of diagnosis, functional status, treatment plan, symptoms, prognosis, and progress to date.  Psychotherapy notes also do not include any information that is maintained in a patient’s medical record.

Psychotherapy notes are treated differently from other mental health information both because they contain particularly sensitive information and because they are the personal notes of the therapist that typically are not required or useful for treatment, payment, or health care operations purposes, other than by the mental health professional who created the notes.

However, HIPAA treats the disclosure of mental health information to family members the same as with general health information. Unless authorized by the patient, a health care provider may only share or discuss information to the extent that family members need to know to assist in the patients care or payment of care.

Can Brown Consulting Ltd. help my organization ensure HIPAA compliance?

Yes! This specific consultation service includes conducting a full HIPAA Compliance Analysis. Our analysis involves reviewing and providing concrete examples of HIPAA Compliant:

• Plans
• Policies & Procedures
• Forms
• Contracts
• Notices
• Position Descriptions

Services provided also include:

• Interactive work-groups with staff
• Further education/training

Making sure your business in compliant with HIPAA regulations can be stressful. Let us at Brown Consulting Ltd. help you guarantee HIPAA compliance!

-Megan Phillips, M.A.

Strategic Planning

Does your organization have a strategic plan that is assessed and updated regularly?

Strategic Planning is essential to narrowing down and articulating why your organization exists and what you specifically need to achieve success. A strong strategic plan is not having a plan simply for plans sake. It involves identifying what your organization is doing well, opportunities for improving performance, clarifying roles for staff and stakeholders, creating specific goals and objectives expressed in measurable terms as well as a method to evaluate outcomes.

We at Brown Consulting, Ltd. specialize in customizing our clients’ strategic planning processes.

Within the 3-6 month strategic planning process we assist our clients in identifying, planning, developing, implementing and monitoring strategic initiatives for future and continued success. Generally, this is how our strategic planning process is conducted:

1. Full review of the industry trends (national, state and local)
2. Organizational and operational analysis
3. Market and competitive analysis
4. Strategic planning groups with various levels of the organization
5. Present full Strategic Plan including initiatives, goals and objectives, performance measures, resource requirements and budget.

A strategic plan is a participatory planning process that allows your organization to successfully implement a shared vision in an organized, step-by-step manner. Let Brown Consulting, Ltd. help you get there!

Thanks for reading and remember at Brown Consulting, Ltd. we provide results—not promises!

-Megan Phillips, M.A.

Welcome to the Brown Consulting Ltd. Blog

Brown Consulting, Ltd. is excited to have this new way of connecting YOU to relevant behavioral health industry information.

We at Brown Consulting, Ltd. have been nationally-recognized as a leader in behavioral health consulting. Since 1987, we have developed significant relationships with hundreds of national, regional and state behavioral health organizations. We specialize in a full range of services– from Accreditation Compliance Analysis to Strategic Planning and more! Our specialists understand industry trends and help our clients build strategies for success.

This blog will include general behavioral health information, industry updates and guest testimonial expertise to help you navigate the world of behavioral health.

Thanks for reading, and please remember to check out our Facebook and LinkedIn pages for further information.

At Brown Consulting, Ltd. we provide results–not promises!

-Megan Phillips, M.A.