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CMHSP/Provider Network Common Contract Comments from CMHSP or Providers

FY2018 REGION 3 COMMON CONTRACT of 22 FEEDBACK AND RESPONSE GRID April 27, 2017

Overall/Process Questions

Section Comment LRE Response

Genesee County Health System has a process for signing contracts that is electronic. Once the contract is signed you have the option to save the document and print it. It saves a lot of time and paper. There is a secured system that you have to log into.

Two of the five regional CMHSPs are currently utilizing Contract Logix software, which included electronic signature collections. The LRE will encourage the remaining three CMHSP members to consider adopting similar process. The LRE has investigated adopting the same software and will continue to explore options.

Our CMH contracts require us to provide interpreters for non-English speaking clients. While this makes sense, it does not make sense for providers to have to pay for it. A couple CMHs reimburse us for this but most don’t. The issue is that the cost of the interpreter alone exceeds what we get paid for an RBT that is working with a child so we actually lose money for each hour of services before even paying the RBT. If working with a psychologist or BCBA, the cost of the interpreter consumes anywhere from 60 to 80% of what we get reimbursed, so we again lose money once we pay the psychologist or BCBA. This is not sustainable for organizations and to me seems like an unreasonable requirement.

The LRE encourages providers to work with the contracting CMHSP to determine adequate rates for services provided. LRE will discuss within the Autism program the need for paying for interpreters.

A second issue is the billing requirements and systems are different for each CMH. This is very difficult for our billing department and sometimes for our BCBAs and psychologists. CMHs have different time frames for billing claims, their own systems (so our staff have to learn each of them, and also so don’t work well with things like secondary claims, etc.), the procedures are different for each, and there are even some differences in billing codes. I have a billing department with four staff and it is still very difficult. Wouldn’t it be more cost effective and efficient to have one system and one set of procedures/rules for all the CMHs in the LRE?

LRE IT Staff will connect with this provider to better understand this specific issue and work to assist in alleviating administrative burden where possible.



Boilerplate


2.4.2.2 To provide CMHSP with a copy of the accreditation notification letter or certificate. The survey report must be available to CMHSP upon request. - This should be an LRE function and done once by a provider to the LRE rather than for each CMHSP Contract.

The LRE supports this assertion and is engaged in ongoing dialogue with the CMHSPs for both short and long-term planning in an effort to realize areas of regional standardization and administrative efficiencies.

2.4.2.3 To notify CMHSP of any change or cancellation in accreditation status. - This should be an LRE function and done once by a provider to the LRE rather than for each CMHSP Contract.


Section 2.4.3 Financial Requirements

Language revision – “To annually obtain a financial audit when total fiscal year revenue from all sources for Provider is $500,000 or more. The American Institute of Certified Public Accountants Audits and Accounts Guides shall be used, as applicable. The following items are specific requirements:”

Language changes made

2.4.3.2 $750,000.00 or more This will be reviewed by the Finance ROAT and revisions made if deemed appropriate.

2.4.3.4 To submit the items above to CMHSP Financial Compliance Auditor within one hundred and fifty (150) days following Provider’s fiscal year end. Any deviation from this requirement must be requested in writing and in advance, and must be approved by CMHSP. – The LRE should be the central clearing house for all information required by CMHSPs for provider contracts.


2.4.3.5 To submit a copy of Provider’s Federal Form 990 – Return of Organization Exempt from Income Tax to CMHSP Financial Compliance Auditor within 30 days of submission to the Internal Revenue Service

The LRE supports this assertion and is engaged in ongoing dialogue with the CMHSPs for both short and long-term




(IRS), if Provider is required to file Form 990 under IRS regulations.2.8 Contract Monitoring/Performance Evaluation/Plan of Correction. - The LRE should be the central clearing house for all information required by CMHSPs for provider contracts.

planning in an effort to realize areas of regional standardization and administrative efficiencies.

2.4.3.6 Provider shall maintain all pertinent financial and accounting records and evidence pertaining to this contract based on financial and statistical records that can be verified by CMHSP and/or its auditors in accordance with CMHSP Retention Policy for financial and accounting records. Financial reporting shall be in accordance with Generally Accepted Accounting Principles (GAAP) applicable to State and local governments as promulgated by the Governmental Accounting Standards Board (GASB). - The LRE should be the central clearing house for all information required by CMHSPs for provider contracts and provider financial requirements.


2.4.4 Solvency Provider shall be financially solvent (having assets in excess of liabilities) prior to commencing services required in this Agreement. Provider shall give immediate notice to CMHSP of any change in financial position material to such solvency and to continuing in operation as a going concern, at any time during the term of this Agreement. If Provider is financially dependent on another entity, the financial institution supporting Provider must demonstrate fiscal solvency. Proof of financial solvency will be provided at the time of contract initiation and annually thereafter. - The LRE should be the central point of contact for all information required by CMHSPs for provider contracts and provider financial requirements.


2.4.5.2 CMHSP shall be identified as an additional insured on the liability insurance policy required above to the extent that the additional insured is held responsible for the acts, omissions, or negligence of Provider pertaining to Provider’s work under this contract. The insurance company providing liability insurance to Provider shall be an authorized or eligible unauthorized State of Michigan insurer. Provider shall provide to CMHSP evidence of the liability insurance maintained by Provider. (See Attachment C: Insurance Requirements). - The LRE





should be the central point of contact for all information required by CMHSPs for provider contracts and provider financial requirements.

2.4.5.3 Provider shall give CMHSP written notice of any changes in or cancellation of the insurance policies required to be maintained by Provider at least fifteen (15) days before the effective date of such changes or cancellations. If Provider’s insurance coverage is at any time reduced or terminated during the duration of this Agreement, CMHSP may terminate this Agreement effective immediately upon delivery of notice of termination to Provider. - The LRE should be the central point of contact for all information required by CMHSPs for provider contracts and provider financial requirements.


2.4.6 Notifications Provider will notify CMHSP in writing when there is a change of status to one of Provider Panel Eligibility Requirements resulting in any of the following: 2.4.6.1 Loss of accreditation (if applicable) 2.4.6.2 Loss of insurance. 2.4.6.3 Qualified opinion on financial audit or financial review.


2.4.6.4 Pending or successful litigation claim against Provider. 2.4.6.5 Loss of SUD treatment, prevention, or DEA license or MDHHS certification. - The LRE should be the central point of contact for all information required by CMHSPs for provider contracts and provider financial requirements.


2.5 Provider, if delegated by CMHSP, shall annually provide all Individuals with information on recipient rights and protections as required by the MMHC. Documentation of providing this information must be recorded within the Individual’s case file. - The LRE should be the central point of decision making for who should be eligible to be delegated.


2.6 Provider, if delegated by CMHSP, shall ensure that Individuals are informed of their right to be free from any forms of restraint or seclusion used as a means of coercion, discipline, convenience, or retaliation. Documentation of providing this information must be

The LRE supports this assertion and is engaged in ongoing dialogue with the CMHSPs for both short and long-term planning in an effort to realize areas of




recorded within the Individual’s case file. - The LRE should be the central point of decision making for who should be eligible to be delegated.

regional standardization and administrative efficiencies.

2.8.1 TIER 2 ONLY

in whose Provider Manual? CMHSP? Updates made in all three tiers

2.8.1 The LRE and CMHSP will assign staff to engage in regular monitoring of and reporting on Provider’s performance, including taking action to ensure performance improvement, such as implementing plans of correction. The LRE and CMHSP will follow the monitoring and reporting procedures in Provider Manual and/or CMHSP Policies in order to ensure high quality services and compliance with contract requirements. 2.8.2 Provider agrees to cooperate with the LRE in carrying out compliance auditing and monitoring responsibilities, including producing the documents needed to assist with these functions. – This is very confusing and duplicative in understanding the role of CMHSP and LRE, especially as a provider trying to respond to interpretation of correction of action performance plans. The LRE should be the central point of contact for all audit performance evaluation/plans related to uniform expectations between CMHSPs in the region.

We recognize the LRE is completing the overall performance review for providers. This section intends to recognize that it may be necessary for the CMHSP to monitor certain functions such as claims and billing. The LRE and member CMHSPs are working cooperatively to ensure minimal duplication of oversight functions.

2.9.1 Provider will maintain policies and procedures to ensure that contracted physicians and other health care professionals (e.g. social workers, OT, etc.) are licensed by the State of Michigan and are qualified to perform their services. Provider must immediately notify the LRE and CMHSP if any license is terminated, revoked or suspended during the term of this Agreement. The LRE should be the central point and clearing house for notification of license changes.


2.9.2 Provider will maintain policies and procedures to ensure that licenses and certifications are current and valid. The LRE should be the central point and clearing house for notification of license changes.





2.9.3 Provider will maintain policies and procedures to ensure that support care staff who are not required to be licensed are qualified to perform their jobs. The LRE should be the central point and clearing house for notification of license changes.


2.9.4 Provider agrees to immediately notify CMHSP of any State licensure or certification investigation. The LRE should be the central point and clearing house for notification of license changes.


2.9.5 For SUD Providers, organizations/programs must be licensed for SUD service provision. - The LRE should be the central point and clearing house for notification of license changes.


2.10.1 Provider will maintain policies and procedures consistent with LRE policy on personnel selection, credentialing, re-credentialing, and privileging, including job descriptions or similar documents that describe specific credentialing, privileging and other requirements for all staff that deliver services to Individuals and including mechanisms to ensure requirements are met by all staff consistent with MDHHS-PIHP Agreement Attachment P.7.1.1. Prior to provision of services by Provider staff, Provider will submit to the LRE verification of staff credentials. – Currently providers must re-submit the same credentialing, criminal background checks, and Medicaid felony or misdemeanor related information to each CMHSP. The LRE should be the central point of contact for all information required by CMHSPs for provider contracts and provider financial requirements.





2.10.4 Every 2 years for criminal background checks?? We ask for annual.

Contract states “a minimum” of every two years as agreed by PN ROAT, LRE Compliance Officer.

2.10.4 2.10.4 CBCs every 2 years? HealthWest and Ottawa use every year. Perhaps add something about fingerprinting is a one time thing where providers can sign up to receive reports from the federal government routinely.

Contract states “a minimum” of every two years as agreed by PN ROAT, LRE Compliance Officer.

2.11.2 We support the proposed change that allows more flexibility with the content of Provider QI Policy and Plan. Thank you for moving this direction.

Thank you

2.19 Conflict of Interest-Attachment G may be with the application packet.

It was determined during the 4/11 PN ROAT review of the FY2018 common contract (per 42 CFR 455.104 (c)(1)(i) through (iv)) that the Conflict of Interest MUST be signed at the time of application and the time of execution of the contract, so it will be in both.

2.20 Utilization Management Provider agrees to participate in the implementation of CMHSP’s Utilization Management program, including clinical protocols. Considering that there is an attempt to achieve uniformity across services in the region and that UM was an identified function to be performed by the LRE, why isn’t the contract stating that the provider would participate in the LRE UM program?

Language in Tier 1 & Tier 5 updated as follows: . . . participate with implementation of CMSHP and/or LRE Utilization Management program, including clinical protocol.

2.23.18 and 2.23.21 The protected classes listed here do not include sexual orientation or gender identity. These are protected classes under federal and state law. https://www.eeoc.gov/federal/otherprotections.cfm

LRE will request legal review by Corporate Counsel.

2.23.21 Provider shall not refuse to treat, nor will it discriminate in the treatment or referral of, any Individual under this Agreement based on the individual's source of payment for services, or on the basis of age, sex, height, weight, marital status, arrest record, race, creed, handicap, color, national origin or ancestry, religion, political affiliation or beliefs, or involuntary patient status.

The LRE has policies related to both Provider Grievances (Policy 4.7) and for Consumer Grievances and Appeals (Policy 6.1). Providers and consumers are encouraged to access these resources when there are concerns.

https://www.eeoc.gov/federal/otherprotections.cfm




FEED BACK: Due to the continuous issues we have with the lack of referrals for those individuals who reside in Muskegon county and meet the ASAM criteria for residential treatment, I would like to see contract language address and stress that the CMH’s be held accountable to provide the appropriate treatment referral regardless of where the treatment is located and of where someone lives.

2.25 Need to clarify the language. Assume it is by local CMHSP. Why would provider assume responsibility from outside CMHSP service area through a COFR? It would be the local CMHSP doing the COFR agreement with the outside CMH paying for the placement

This section is to assure that Individuals continue to be served until such time as COFR arrangements are secured.

2.25 COFR with Provider without CMH involvement? Not part of CMH contract for services.

This section is to assure that Individuals continue to be served until such time as COFR arrangements are secured.

2.26 2.26.1 2.26.2 2.26.3

Provider agrees: To assist the LRE and CMHSP with the planning and management of the system of care. The goal of this partnership is to ensure quality services to Individuals, ensure timely and proactive decision making, and to enhance community involvement in the system of care. To assist in the design and implementation of a services system that is responsive to Individual’s needs.

To engage with CMHSP in ongoing Quality Improvement (QI) processes by being an active participant in systemic QI projects for clinical and cultural process improvements, engaging in training opportunities to develop clinical and cultural competencies, and to support efforts to move CMHSP system forward in providing culturally competent, evidence-based, effective services to all Individuals. This section is not clear on what the different roles would be. It seems imperative to uniformity of services and a regional approach that the LRE take some role of coordinating a joint

The language has been revised in this section to more clearly articulate the contractual arrangement between the Provider and the CMHSP.




planning process. This section does not clearly identify what to expect from each entity.

3.3 Delegation 3.3.1 3.3.2 3.3.3

The provisions of the Balanced Budget Act (hereinafter BBA) of 1997, allow states to establish Medicaid beneficiary protections in areas such as quality assurance, grievance rights, and customer service. CMHSP is required by contract to oversee and be accountable for any administrative function or responsibility that it delegates to any subcontractor. 42 CFR 438.230 (a) (1). CMHSP is required to provide for the revoking of delegation or the imposition of other sanctions if its subcontractor’s performance is inadequate.42 CFR 438.230(B) (ii).

LRE and CMHSP may conduct periodic formal scheduled reviews of Provider’s activities. The Site Review will include monitoring of administrative functions delegated to the Provider. The quality audit will include monitoring of administrative functions delegated to the Provider as described in Attachment D: Contract Monitoring, if applicable. How will the CMHSPs and LRE be coordinating their oversight on these issues? As a provider how will we know what to expect from each entity and how will the information be shared among them?

Section 3.3.3 has been revised to more clearly articulate the contractual arrangement between the Provider and the CMHSP Section 3.3.4 has been created to spell out the Site Review process the LRE will perform on an annual basis at the Provider.

3.4.1 E-1 and E-2? Was one of them changed?? Good catch! Will make appropriate edits.



Attachment A-1


I had provided this feedback earlier this month but want to reiterate (since it is going out soon) that the Service Description Guidelines should be verbatim from the Medicaid Provider Manual. Literally a “cut and paste” without any variance.

Service descriptions will be reviewed to ensure that language is reflective of the Medicaid Provider Manual

I wasn’t sure if you wanted to include some language about HCBS. The service descriptions for the B3 services may need to include that the services must be compliant with the Home and Community Based Services Rule by March of 2019.

This will be a conversation in the coming year in the PN ROAT. The region is still waiting for confirmation from MDDHS and CMS with regard to transition planning. Language related to HCBS Final Rule may be part of a FY2018 contract amendment and/or incorporated into the FY2019 Common Contract.

Personal Care Service Description

A few months back N180 and Lakeshore issued some duplicative requirements for the way we handle Personal Care orders. N180 indicated providers must complete this section of an updated PCP form (Attached)

Currently this has not been a topic of conversation. This will be added to a future Provider Network ROAT agenda for consideration.



N180 then created the Authorization for Personal Care form to be completed with the plan every year. (Attached) The Authorization for Personal Care form appears to be a condensed version of the dch-3803 form which we built into our system (attached). We have a number of ways to do the exact same thing for both N180 and LRE. Is there a coordinated effort between N180 and Lakeshore to try to simplify this process or allow us to use forms we already have? This is the type of work that wipes out our IT time to work on modifications to help staff, so we’re hoping to eliminate some of the work and avoid duplication. Appreciate any assistance you and your team can provide in assisting in avoiding duplication. Thanks.



Attachment A: Service Descriptions


Behavior Treatment Plan Review

5.b: written special consent-recommend changing to written informed consent or clarify what constitutes a “special” consent.

Refer to MDHHS/PIHP contract Attachment P1.4.1 for “special consent” definition.

Behavior Treatment Plan Review

incomplete sentence Reviewed and appropriate changes made.

Supports Coordination

Consider adding something regarding determination of medical necessity to supports coordinator functions.

Service descriptions are taken from the Medicaid Provider Manual

Supports Coordination

Providers are prohibited from exercising the agency’s authority to authorize or deny the provision of services. Please clarify “agency”-Is this the LRE? MDHHS? CMHSP, Provider agency?

“Provider” changed to “Supports Coordinator”

Behavior Treatment Review, Section 3 d, f, g

We recommend revisions for these sections as they are confusing. Does this language refer to “the provider” as the author of the behavior treatment plan or as the CLS staff? We would not expect the author of the behavior treatment plan to keep training records for the CLS staff they are training.

There is no section 3d, f or g in the BTR Service Description – please clarify.

Fiscal Intermediary, Section 2 Practice Principles d

We recommend this section be removed because it does not fit with the service of FI. At a minimum, the last sentence should be removed because FI’s do not create the IPOS.

Changes have been made to the Service Description.

Fiscal Intermediary, Section 4 Service Requirements a

The FI does not have and does not need a full copy of the IPOS on site. The FI does have the individual budget and can obtain documents needed for a Medicaid verification audit from the supports coordinator. The FI does not need clinical information and we would have HIPAA concerns in providing it. We recommend deleting the last sentence of this section.


Fiscal Intermediary, Section 4 Service Requirements b

We recommend deleting this section. FI services are indirect and usually done at the FI’s office.


Fiscal Intermediary, Section 4 Service Requirements c

We recommend deleting this section. FI services do not have anything to do with coordinating care.





Fiscal Intermediary, Section 4 Service Requirements e

Does this apply to documentation of FI services? We believe the requirement is an invoice with consumer ID, month of service, and the rate being billed for T2025. We recommend this section be rewritten.


Fiscal Intermediary, Section 4 Service Requirements h

Section does not fit with the practice at Network180 and does not appear to be required by the FI technical requirement. We suggest the following: The Provider shall assist each individual with assuring all necessary employment readiness document is in place, including, but not limited to, all applications paperwork and agreements required by the CMHSP and especially a 42 CFR 431.107 Agreement between each service provider and the CMHSP, application for employer identification number (Federal and State EIN), workers’ compensation insurance as required, I-9 for each employee and employer tax forms for each employee. Holder of record must maintain copies of all of these documents.


Fiscal Intermediary, Section 4 Service Requirements i

This does not fit with the practice at Network180 and does not appear to be required by the FI technical requirement. We suggest the following: The Provider shall disburse funds to vendors and providers after obtaining verifying that provider contracts and employment agreements have been completed. Provider shall not disburse funds to any vendors or providers who are not compliant with training requirements.


Housing Assistance, Section 4 Service Requirements a Definitions vi, Insurance

This should apply only where not paying the premium could result in loss of the home or not getting the home in the first place.


Housing Assistance, Section 4 Service Requirements a Definitions vii, Living expenses

Food is covered only if it is a package deal (e.g., room and board) when the person is transitioning to an independent/integrated setting. This is very rare. There are other community resources for food.

Language has been removed from the service description.




Housing Assistance, Section 4 Service Requirements a Definitions

Can back taxes be paid for an individual through Housing Assistance? No.

OBRA, Section 4 Service Requirements, part g I and ii

Does this section mean a PAS assessment needs to be done within 4 working days and an ARR assessment within 14 calendar days?

Modifications will be made to be consistent with Medicaid Provider Manual Requirements

OBRA, Section 4 Service Requirements, part g iv

OT and PT were omitted Medicaid Provider Manual does not indicate OT/PT as identified practitioner to complete assessments.

OBRA, Section 4 Service Requirements, part g xiii

MDHHS has indicated that provider is not to do a psychological assessment if an old one can be uploaded or if guardianship documents can be uploaded. A psychological is done only when neither is available and the 3877 states the individual has an I/DD diagnosis.

Follow up information will be requested related to exact reference.

OBRA, Section 4 Service Requirements, part i

We provide an explanation of the evaluation to the individual if they do not have a guardian. The OBRA manual states the legal representative can decline the explanation of the evaluation to the individual

Service descriptions indicates explanation be provided to the individual or the individuals legal representative.

OBRA, Section 4 Service Requirements, part j

OBRA Manual strongly suggests, but does not require, the appeal information being provided during a face-to-face contact with the individual or the legal representative.

Language has been updated.

OBRA, Section 6 Eligibility Criteria, b

It is our understanding if the individual will be in the nursing home long term he/she should be taken off any waivers due to no longer receiving/needing HSW services.

Agreed.

Personal Care (?) A few months back N180 and Lakeshore issued some duplicative requirements for the way we handle Personal Care orders. N180 indicated providers must complete this section of an updated PCP form (Attached). N180 then created the Authorization for Personal Care form to be completed with the plan every year. (Attached) The Authorization for Personal Care form appears to be a

Currently this has not been a topic of conversation. This will be added to a future Provider Network ROAT agenda for consideration.




condensed version of the dch-3803 form which we built into our system (attached). We have a number of ways to do the exact same thing for both N180 and LRE. Is there a coordinated effort between N180 and Lakeshore to try to simplify this process or allow us to use forms we already have? This is the type of work that wipes out our IT time to work on modifications to help staff, so we’re hoping to eliminate some of the work and avoid duplication. Appreciate any assistance you and your team can provide in assisting in avoiding duplication.

Support and Service Coordination, Section 4 Service Requirements – From Provider

Section i should not be its own bullet, not a subsection of j. Clarification needed.

Attachment B: Codes and Rates: NO FEEDBACK COMMENTS RECEIVED

Attachment C: Insurance Requirements


C-2 and 1 • I have never checked for “one of the four “A” ratings by the The A.M. Best Company.”

• Commercial liability has been 1 mil/1 mil for HealthWest.

• Auto: misspelled “owned” at the end of the first line.

• Auto insurance and Motor Vehicle insurance is duplicative and can be combined into one category.

• Employee Dishonesty insurance should say “required for SUD contracts only.”

• Can have different professional liability insurance coverages depending on coverage of licensed employees versus unlicensed (AFC homes).

No response MMRMA has determined 1/3 Corrected This has been reviewed and approved by the finance ROAT Added C2 applies to independent family homes (AFC’s).



Attachment D: Contract Monitoring


3.a: We suggest less frequent monitoring, or if annual quality reviews are required by MDHHS, then please consider a brief quality review rather than full quality reviews based on previous year’s performance. Also, consider findings from CARF or other accreditation results to inform quality review focus.

The LRE has completed the first year of site reviews. We continue to find ways to improve the process for efficiencies and consideration will be given to reducing the review frequency requirements for those providers who continually score well on their reviews.

Attachment E: Recipient Rights


Recommendation: for the Offices of ORR to agree to allow for the online rights training to be used throughout the region, as both an option for the annual update as well as an option for new employees to take immediately until such time as they can get into the face to face class. N180 currently allows the online class for new employees with follow up of face to face within 6 months. This flexibility is very much appreciated and reciprocity around this aspect throughout the region would be helpful.

The training reciprocity group continues to discuss regional training options through the on-line platform. The LRE does not have jurisdiction over the ORR and we encourage providers to address their concerns with the individual CMHSPs.

Attachment E-1 MH

O. On the CMHSP website?

Changed.

Attachment E-2 SUD #J. p. 2 last sentence eliminate CA again and add thirty (30) days. Changed

Attachment F: Performance Indicators


Customer Services Area of Compliance

The addition of another customer satisfaction survey is incredibly labor intensive, very challenging and difficult. WMCMH completes the MISIP, ACT and a satisfaction survey developed by WMCMH for the IDD population using the MISIP as a guide. Can these surveys be used since they are already required. WMCMH has concerns if

The regional Satisfaction Survey tool was developed by the QI ROAT with input from members from each CMHSP. As a PIHP, the LRE is required to conduct a comprehensive survey regularly.




portions of the MISIP will be used, what does that do to the validity of the information gathered if only portions of the tools are used?

Financial Management

In the financial management area of compliance, WMCMH recommends the addition of clean claims to the performance indicator column

“Clean Claims” language is included

Recipient Rights Recipient Rights is the responsibility of each individual CMH,

reporting directly to MDHHS. It feels redundant that this information is reported again as a part of the contract.

This contract is between the CMHSPs and Providers – we believe that CMHSPs want the Providers to adhere to Rights standards and this clarifies the relationship between the Parties.

Supports and Services

We are concerned that Provider is responsible for data collection-annually. This isn’t a change from current contract but it’s not clear what data is wanted, what the data collection and reporting method will be, etc. As currently written, this has the potential to require reporting on each individual’s IPOS. Could this be monitored during the LRE clinical chart reviews.

LRE is scoring this during the annual site review process. However, it is an expectation of the Provider that services are consistent with the IPOS. This does not require an additional data pull, but there must be evidence that services are being delivered in accordance with the IPOS.

Supports and Services

It used to say “no greater than 25% variance” but that was replaced with “Per IPOS/Treatment Plan”. It is not clear what the expectation is. There is most often some variance from the IPOS due to a child being sick, weather, vacations, staff issues, etc. With Per IPOS, what is the expectation and what is acceptable for variance?

The MDHHS Plan of Correction to the LRE requires that services are delivered as outlined in the IPOS with no variance identified. We recognize that there are circumstances that impact treatment. However, MDHHS has determined this requirement.

Training Requirements

Training Requirements area of compliance: Is the 2 month performance indicator consistent with training committee requirement in this same area?

Language has been modified.




Attachment F

Mostly okay as changed. Customer Satisfaction- I would change the percentage satisfied to 90% or greater.

Percentage was determined by the QI ROAT

Attachment F Supports and Services – it used to say “no greater than 25% variance” but that was replaced with “Per IPOS/Treatment Plan”. It is not clear what the expectation is. There is most often some variance from the IPOS due to a child being sick, weather, vacations, staff issues, etc. With Per IPOS, what is the expectation and what is acceptable for variance?

The MDHHS Plan of Correction to the LRE requires that services are delivered as outlined in the IPOS with no variance identified. We recognize that there are circumstances that impact treatment. However, MDHHS has determined this requirement.

MMBPIS – changed benchmark for clinical chart reviews from 90% t0 95%. That isn’t much room for error. How does that rate fit with the chart reviews from the past year?

This percentage is consistent with MDHHS contractual requirements

Training requirements – changed the performance indicator from “will meet all training requirements within a two month period following notice of non-compliance” to “new hires and annually as specified in Attachment 1. Notice of non-compliance as specified in the provider quality report”. We are not exactly sure what this means as far as expectations. We try to get all the trainings done within the expected times. There are times that the trainings aren’t offered or classes are full and we can’t meet that due to factors outside our control. Clarification would be helpful.

Language changes made.

Attachment G: Conflict of Interest


We need to rewrite the Attachment G to mirror LRE policy 9.12 and 42 CFR 455.104-106. Make Disclosure of Ownership and Controlling Interest Statement form the Attachment G?

Changes to be made

Attachment H: Delegated Functions: NO FEEDBACK COMMENTS RECEIVED

Attachment I: Training Requirements




Where the grid states training could be “as approved by CMH” I believe this should be “as approved by LRE” since it is the LRE training grid. It would also be helpful to have a simple, clear process for obtaining approval so providers know how to move these approvals forward

Contracts are between the CMHSP and the Provider. The LRE worked with the CMHSPs to develop the regional training grid as part of a uniform common contract.

Grievance and Appeals Training

As stated this training would be required prior to any new staff working independently with an individual served. The 2 options on how to obtain list LRE classroom or options as approved by CMHSP. My feedback is that whatever is approved needs to be something that can happen quickly. Depending on previous experience, our new staff may begin seeing clients independently within a week. A classroom requirement seems very unrealistic to be able to meet that need. The “as approved by CMHSP” is vague enough that it is hard to know how that might fit our needs. Currently, we have staff complete this training on their first day with us which is mostly an orientation day. It is a PowerPoint training that was developed by Stacy Coleman followed by a short quiz.

The issues of resources for completing this training within the required time frames has been shared with LRE Leadership.

Grievance and Appeals Training

The LRE grid indicates that this is a requirement for all, however, currently there is no module available from the LRE. Also, this would be a new requirement for direct support professionals. The language in the grid is somewhat loose to support agencies to use their own resources if they have them. We strongly believe, and would like to advocate, that direct support professionals (for their role) are getting necessary exposure to this topic during their ORR training, and should not be required to take this additional training


Recipient Rights

This has been difficult to gain reciprocity around as the ORR Directors have been unable to reach consensus. The mechanisms allowed to receive this training still vary from county to county. We strongly recommend finding a way to gain consensus on this process and support for the online rights training for updates (for staff who have already had a face to face training). From our perspective of working in four counties, the system for

The training reciprocity group continues to work toward a standard rights training. The LRE is in support of this goal.




ORR training works well in Kent county and I believe they have some data to support the effectiveness (presented at a recent N180 Board meeting). Given the shortage of direct care employees, any support for trimming where it makes sense to on line training, (like for updates) is essential

Benchmark is set at 100%, which includes annual updates. Many classroom trainings have been canceled or unavailable due to classes being full; CMH classes are limited and fill up quickly. Consider either lowering the benchmark or addressing the need to collaborate with CMH’s on options for more available training.

Attachment I-Training requirements: by service

Grievances and Appeals: It’s not clear where the source is for this requirement for direct care staff since this is covered as part of rights training


Attachment I-Training requirements: by service

Trauma informed care is a new training requirement. I don’t disagree with the need for this; it’s an addition from the previous contract. Consider that Mandt may fulfill the Trauma Informed Care training requirement since there is a module on Trauma Informed Care

Day 1 of Mandt training will meet this requirement. If Provider wishes to employ alternate TIC, training they may do so as approved by the CMHSP.

Attachment I-Training requirements: frequency and method

Grievance and Appeals: We have to question the availability of this training. There’s no on-line course, no classroom option and yet this training is required for all service providers. We encourage the development of an on-line course.


Attachment I-Training requirements: frequency and method

Recommend that there is a defined process for how agencies receive approval for agency internal trainings that includes time lines for CMH response to agency request/submission.

The process for submitting trainings for approval will be identified during the next Training Reciprocity Workgroup meeting (May, 2017).

WM does not currently have a “training department” and thus does not provide classroom training. Not all required trainings have a resource for them on the Lakeshore LMS. (Knowledge of First Aid, Trauma Informed Care – examples of trainings that WM does not have capacity to provide.) It would be ideal if the Grievance and Appeal training was developed for the LMS as well. Can WM do that, yes, but it’s another resource. Our

Knowledge of First Aid is being developed as an LMS module. Trauma Informed Care can be through Mandt or other approved training process.




providers are not accustomed to classroom trainings so the option of having the LRE doesn’t fit for WM.

Grievance and Appeals has been forwarded for review to LRE Leadership.

• Grievance and Appeals- how to get this training?

• Trauma Informed- how to get this training?

• If Mandt is not listed for Childrens Crisis Residential, that means we can approve another CMHSP’s non-physical management training? Seems like it should be a required training.

• Why is MANDT not needed for ABA? ACT? Assessment? Clubhouse? Crisis Intervention? You never know what you are going to have presented to you during an assessment or crisis intervention. ABA is with Autistic kids, Clubhouse and ACT are mostly SMI adults.

• Why isn’t Grievance and Appeals required for Crisis Residential?

• Why isn’t Self-Determination needed for Fiscal Intermediary?

• Why isn’t MANDT required for HBS? (Same as ABA, SED kids.)

Some trainings say CMH classroom training if available, and also say Lakeshore LMS online course. I am assuming our staff can do either of these for those trainings?

Please review training grid to ensure which can be face-to-face and which can be on-line (initial, annual review, etc.)

Changing the requirement for ABA and Assessment from certification in first aid and CPR to Knowledge of First Aid was a good move

Thanks

Grievance and Appeals is only offered as an LRE Classroom training. The positive thing about that is that the LRE trainer was willing to come to our locations and do the training after our kids’ sessions were done. If it is not possible to do this training online, then this is a much better option than having to go to a CMH. The main issue is for new hires as we hire new RBTs monthly. What is the best way to get these individuals promptly trained?


Recipient Rights is only offered as a CMH classroom training. This makes it difficult as we have so many employees we can’t get them all in. Plus we have to cancel a lot of therapy sessions. It seems like Recipient Rights would be able to be trained online. If not, then training at our locations

The training reciprocity group continues to work toward a standard rights training. The LRE is in support of this goal.




after kids’ sessions would be more cost effective and disrupt treatment less. Online would be best

Trauma informed care training was added. Given the number of clients affected by trauma this is a good idea. The only listed training is by CMH classroom training (Mandt Conceptual). For ABA and Assessment our staff don’t take Mandt training. Trauma Informed Care could easily be an online training. If that won’t be allowed, I would like to know how to get something As otherwise approved by CMH approved. It would be good to have the LRE actually approve these so each CMH does not come up with their own requirement for this. One training should work for all CMHs. I have a specialist in Trauma Informed Care who does trainings all around the state and is active in developing Trauma Informed Communities. She would be able to provide our staff with Trauma Informed Care training easily, and could even create an online version. How would I get that approved?

Trauma Informed Care can be through Mandt or other approved training process. The process for submitting trainings for approval will be identified during the next Training Reciprocity Workgroup meeting (May, 2017).

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