best practices for corporate compliance, part 1documents.hcplus.com/version/best practices for...

BEST PRACTICES FOR CORPORATE COMPLIANCE, PART 1

August 22nd, 2013

Best Practices for Compliance August 2013

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NY Webinar Series

Welcome to the 9th in our webinar series for

our NY clients!

We will begin momentarily…

In the meantime, if you have a question please key it into

the bottom of your screen, or send email to

[email protected]

mailto:[email protected]


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Introduction

Your Hosts today:

● Rossana Follender – Speaker

● Franklin Boyd – Facilitator

Today’s webinar will run approximately 45 minutes, including Q&A. In the lower right corner of your screen you will be able to type in questions. Time permitting, our facilitators will answer them near the end of the session.

This is the 9th of Sandata’s monthly training Webinars for the New York Market.


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AGENDA 1. Electronic Visit Verification (EVV)

2. Manually Verified Visits

3. Managing your Conflict of Hours report

4. Field Staff Compliance


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Verification Organization Requirements

The Office of the Medicaid Inspector General (OMIG) requires:

Use of Electronic Visit Verification

Exceptions ● Flagging of exceptions

● Documentation of exception resolutions

Caregiver Location Conflicts ● Monthly reports

● Investigation

● Resolution

Tracking of Registration and Credentialing of Aides

Full list of requirements available at:

NYS OMIG Website >Resources>Home Health Requirements

http://www.omig.ny.gov/images/stories/HomeHealth/nysmedicaidrequirementsforhomehealthprovidersandverificationorganizationsver1-0.pdf

ELECTRONIC VISIT VERIFICATION (EVV)


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Policies for Employee Attendance Verification

● Electronic Visit Verification

● Clients who do not have a phone line (or does not allow aides to use their phone line.)

● Exceptions

– Example: The aide could not call in because the client was on the phone.

Procedures ● Supports the policies

● Who, What, When, Where

EVV – Set the Rules


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Distribute materials: ● Policies and Procedures.

● Call Reference Guides.

Review at Orientation but also make EVV part of your in-service program!

Make practice calls.

Ensure your staff knows the tasks they need to perform and report on.

EVV – Inform your Staff


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Identify weaknesses: ● For example: aides that

always forget to clock out or does not enter all the tasks.

● Coordinators and Reports can help you detect patterns of non-compliance

Correct the course, based on your policies and procedures:

● Consequences for high-incidence of exceptions.

● Incentives for low or zero incidence of exceptions.

Electronic Visit Verification (EVV)

MANUALLY VERIFIED VISITS


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Use of Electronic Visit Verification.

Exceptions: ● Flagging of exceptions.

● Documentation of exception resolutions.

Caregiver Location Conflicts: ● Monthly reports.

● Investigation.

● Resolution.

Tracking of Registration and Credentialing of Aides.





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Exceptions

According to OMIG, an exception should be created when: ● Scheduled visits don’t have a matching visit

● Services are late

● Services are missed

● The visit duration exceeds the authorized schedule duration

Sandata’s EVV system identifies these exceptions

Agencies are responsible for: ● Investigating

● Resolving

● Documenting


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Pre-Verification Strategy

Be aware and take action!

Identify

• No Shows

• Unscheduled Visits

• Unknown Employees

• Unknown Clients

Research

• Call the client or their representative

• Call the aide

Document

• Take advantage of the Notes Functionality in the system


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Obtaining the Reports

Step 1 – Once you’ve logged in to HC Plus, click “Daily Functions”.

Step 2 – Click “Santrax Daily Reports”.


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Obtaining the Reports, continued…

Step 3 – Select your Santrax Account and click “Santrax Daily Reports”

Step 4 – Select the reports to run and click “OK”


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In this example, we are documenting how we researched a no show exception by calling the client. We are using the note type: “Exception Research”

Using the Notes Module


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Notes Reports

Print Individual Notes Print all notes of a particular type Main Menu > Reports > Notes Report


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OMIG requirements: ● Who verified the

visit?

● Why did the exception occur?

● Why is this a legitimate claim?

The system records: ● Username of the

person verifying the visit.

● Date and Time of verification.

Manually Verified Visits


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Document “Why?”

Reason Codes drop-down list; predetermined values ● Note: Some contracts require the use of specific reason codes.

Notes free-form text

Reason Codes and Comments


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Before you Verify a Visit…

Review all documentation: ● Notes.

● Time sheets signed by the client.

● Other documentation required by your agency (for example: aide statement.)

Check that the tasks entered match the plan of care.

Check that you are only verifying services provided.

CONFLICT OF HOURS REPORT


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Verification Organization requirements



Exceptions: ● Flagging of exceptions.

● Documentation of exception resolutions.

Caregiver Location Conflicts: ● Monthly reports.

● Investigation.

● Resolution.






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Conflict of Hours Report

What is the Conflict of Hours Report?

Identifies overlapping visits across agencies, where the same aide provided services at two different locations at the same time.

Verified visits only.

Frequency: Weekly and Monthly: – Weekly Run every Friday, after 9:00pm and will be available to you the

next Monday morning.

– Monthly Run on the second Friday following the end of the month, after 9:00pm and will be available to you the next Monday morning.


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How to Run the Conflict of Hours Report

Archive Once you’ve logged in to Archive, click “New Conflict Report”.

Santrax Once you’ve logged in to Santrax, click “Reports” at the top of the screen


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Select “Date Range Report” to run the Monthly Conflict Report or “Daily Reports” for the Weekly version.

How to Run the Conflict of Hours Report – continued…


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Sample Monthly Conflict of Hours Report


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What Should You Do?

1. Have policies and procedures in place.

2. Designate staff to run and investigate this report.

3. Run the report every month.

4. Conduct your own investigation.

5. Contact the representative from the other agency and request an investigation of the conflict. ● Consult the directory of agencies available in the NY Reference Library.

6. Prepare a report.

7. Take appropriate action based on your findings.


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How to Obtain the Directory of Agencies

Step 1 – Once you’ve logged into Citrix, click “NY Business Reference Library”

Step 2 – Click “Directory of Agencies – Conflict Resolution Report”


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Directory of Agencies – Conflict of Hours Report

Send changes to: [email protected]

mailto:[email protected]


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What Should the Investigation Report Contain?

1. Details of the conflict, as they appear in the report.

2. Documentation on the visit: ● Time Sheets.

● Screen prints of schedule verification, notes, etc.

● Signed statement from the aide.

3. Outcome of your investigation.

4. Correspondence with the other agency and outcome of their investigation.

5. Conclusion detailing action taken.

FIELD STAFF COMPLIANCE


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Exceptions: ● Flagging of exceptions

● Documentation of exception resolutions

Caregiver Location Conflicts: ● Monthly reports

● Investigation

● Resolution






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Compliance Module

Warn or prevent, when trying to schedule an aide who is out-of-compliance.

Keep track of the compliance status of your aides and expiration dates for recurring items. ● For example: immunizations and certifications.

Be proactive! Forecast who will be out-of-compliance.

Keep track of in-service hours.

Report on the compliance status of your aides.

Note: Always keep all documentation provided by your aides in their personnel file.


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Influenza Immunization and Procedure Masks

Required by NYSDOH as of 7/31/13 for the 2013-2014 Influenza season: ● Keep track of vaccination status of your aides.

● Unvaccinated staff should wear a mask when in contact with the client.

NYSDOH Website: ● Requirements

● Frequently Asked Questions.

Sandata will send a communication regarding this compliance item in the next few days

http://www.health.ny.gov/diseases/communicable/influenza/seasonal/providers/prevention_of_influenza_transmission/

http://www.health.ny.gov/diseases/communicable/influenza/seasonal/providers/prevention_of_influenza_transmission/frequently_asked_questions.htm


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Documentation Required

Scenarios Aide Agency

The aide is not vaccinated or cannot provide proof.

• Counts as “No”.

The aide was vaccinated.

• Must provide written proof of vaccination.

• Keep proof provided in employee’s file.

• Track whether the aide was vaccinated at the agency or at another location.

• Count as: “Yes”.

The aide declines to be vaccinated.

• Must provide a “Declination of Influenza Vaccination” statement.

• Keep documentation on file. • Supply masks. • Count as: “Declined”.

The aide declines to be vaccinated due to medical reasons.

• Must provide a “Influenza Vaccine Medical Exemption Statement for Health Care Personnel” form.

• Keep documentation on file. • Supply masks. • Count as: “Medical-Declined”.

http://www.health.ny.gov/prevention/immunization/toolkits/docs/hospital_pg154.pdf

http://www.health.ny.gov/prevention/immunization/toolkits/docs/hospital_pg154.pdf

http://www.health.ny.gov/forms/doh-4482.pdf





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THANK YOU FOR YOUR TIME!

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