msdp training manual€¦ · child/adolescent comprehensive assessment (ca) 96 . iii...

MSDP STANDARDIZED DOCUMENTATION INITIATIVE 2009 Training Manual

MSDP Training Manual

Version

1

i

M A S S A C H U S E T T S

Standardized Documentation Initiative

Developed by the MSDP Standardized Documentation Team Compliance Review by the MSDP Compliance Review Team

Natick, MA For more information and updates on this initiative visit the MSDP UPDATE Website:

http://www.mtmservices.org/MSDP-Update.html

ii

Table of ContentIntroduction iv

S E C T I O N 1 : G E N E R A L I N F O R M A T I O N

Summary of the MSDP Initiative 1

• Stakeholders Guiding the MSDP Initiative 3

• MSDP Initiative – Operational Components Summary 5

• About the MSDP Training Manual 9

• Standardized Documentation Benefits 11

• MSDP Integrated Documentation Process Overview 14

• Pilot Study Supported Development Model 16

Documentation that Supports Quality Treatment 19

Clinical Focus of the MSDP Documentation Processes 24

Why is Person-driven Documentation Necessary? 28

Solution Focused/Motivational Interviewing Approaches 38

Satisfying Reimbursement and Compliance Requirements 40

Medical Necessity 40

Medicaid Definition of Medical Necessity 41

Medicaid Criteria for Payment of Medically Necessary Services 42

Medical Necessity in Mental Health/Substance Use Disorder Services 42

Medical Necessity and Recovery 43

Medical Necessity and Provider Documentation 44

MSDP Forms Support Medical Necessity 46

Medical Necessity Documentation Linkage Requirements 47

Signature Matrix for MSDP Documentation Process 55

MSDP Process Billing Strip Instructions 58

General Medicare “Incident to” Services Only Information 59

Use of the MSDP Compliance Grids – How To Interpret and Use 60

S E C T I O N 2 : U S I N G T H E M S D P A S S E S S M E N T G R O U P

D O C U M E N T A T I O N P R O C E S S E S / F O R M S Personal Information 64

Adult Comprehensive Assessment (CA) 67

Adult CA Update 89

Child/Adolescent Comprehensive Assessment (CA) 96

iii

Child/Adolescent CA Update 123

Mental Status Exam 129

Risk Assessment 134

Initial Psychiatric Evaluation 137

Tobacco Assessment 145

HIV Risk Assessment 147

Physical Health Assessment 150

S E C T I O N 3 : U S I N G T H E M S D P I N D I V I D U A L I Z E D A C T I O N

P L A N ( I A P ) G R O U P D O C U M E N T A T I O N P R O C E S S E S / F O R M S

Individualized Action Plan (IAP)

Expanded, Condensed, & Short with Multiple Goals 159

IAP Review/Revision 176

Psychopharmacology Plan 181

IAP Detoxification 185

Multi-Disciplinary Team Review/Response 192

Transfer/Discharge Summary and Plan 195

S E C T I O N 4 : U S I N G T H E M S D P P R O G R E S S N O T E G R O U P D O C U M E N T A T I O N P R O C E S S E S / F O R M S

Consultation/Collateral Contact Progress Note 201

Group Psychotherapy Progress Note 204

Health Care Provider Orders Progress Note 208

Intensive Services Progress Note 214

Monthly Progress Note 221

Outreach Services Progress Note 226

Psychopharmacology Progress Note 230

Psychopharmacology/Psychotherapy Progress Note 235

Psychotherapy Progress Note 240

Nursing Progress Note (Long) 245

Nursing Progress Note (Short) 249

Shift/Daily Progress Note 253

Weekly Services Progress Note 258

A P P E N D I X : R E S O U R C E S

A – MSDP Forms Compliance Grid Located at:

www.mtmservices.org/MSDP/2009Forms.html

iv

I N T R O D U C T I O N :

The statewide MSDP Standardized Documentation Initiative was developed as a proactive response to Goal Six of the 2003 New Freedom Commission Report and to the Executive Order to develop e-health initiatives to support a migration to Electronic Health Records (EHR) for all persons served. The critical first step to developing statewide capacity to electronically document mental health and substance use disorder services is to develop a standardized clinical documentation flow process that includes standardized data elements per type of form/process.

Historically, statewide provider agencies/programs have independently developed and used a wide variety of different versions of clinical and medical documentation processes. As a result, in current practice statewide, there are a significant number of different genres/styles of assessments, service plans and progress notes being used. The costs associated with developing a standardized electronic record based on using the multiple approaches being used would be significant for each provider/program individually. The ultimate goal of the MSDP initiative through the development of a standardized set of clinical documentation processes and data elements within each process is to be able to create open source code for electronic forms that can be developed at a much lower cost for use by all provider agencies/programs.

Further, the standardized documentation model is an appropriate response to the need to support a more person-centered assessment, planning and service delivery approach. In addition, the standardized documentation approach provides a positive response to the enhanced compliance requirements to adequately document qualitative support for Medical Necessity for services billed to Medicaid, Medicare and private insurance/third party payers. The standardized documentation process will provide a new systems learning capacity for continuously improving the quality of documentation statewide. Also, experience in other states using a standardized documentation model has demonstrated support for more objective audit/review outcomes.

Over 80 different programs representing over 25 different provider agencies statewide participated in the MSDP Pilot Study in 2008. The evaluation and feedback received from those individual direct care staff and participating programs was critically important to develop the final set of documentation processes that are contained within these manuals

M S D P S T A N D A R D I Z E D D O C U M E N T A T I O N T R A I N I N G M A N U A L

1

What is the MSDP Initiative?

What is the MSDP Initiative? It is an initiative to develop statewide standardized integrated clinical and medical services forms and processes that provide enhanced compliance and quality for mental health and substance use disorder service delivery throughout Massachusetts. All documentation processes were designed to accommodate and comply with the following documentation requirements:

1. State Payers: Medicaid/DMA; DMH; DPH-BSAS; and DPH-HCQ 2. Managed Care: MBHP and State MCOs 3. National Accreditation: JCAHO; COA; CARF; and NCQA 4. Federal Payers: Medicaid and Medicare 5. Medicaid/Medicare Documentation Support Focus: Medical Necessity; Person

Served Participation; and Person Served Benefit

What is the MSDP Statement of Purpose? The purpose is to design, develop and implement a standardized documentation process that includes identification of the required clinical processes and the specific data elements within each process. Further, the new process needs to adequately support the delivery of quality recovery focused services that are compliant with the requirements of all applicable funders and national accreditation bodies included in the scope of work. The secondary outcome of the MSDP will be to use the identified standard data elements to enhance the timely and cost efficient development of a standardized EHR.

What is the Scope of Work for the MSDP Initiative? The identified scope of work for the MSDP initiative includes documentation requirements for services identified below:

a. All Department of Mental Health community services b. Medicaid Mental Health acute services, regardless of health plan, carve out or Fee

For Service status c. Services purchased by the Bureau of Substance Abuse Services d. Substance Use Disorder Services purchased by Medicaid e. EATS, CBATS and Supported Education and Employment Services f. Programs that do not have an individual record will not be included in the scope of

work (i.e., Disaster Response, Training, Trauma Response, Consultation Programs, etc.)

Section

1


2

Within the context of the above services, the MSDP will support the development and implementation of the following scope of work:

1. Develop the data elements necessary in each clinical form type to support an integrated standardized documentation approach statewide based on Ohio’s SOQIC standardized documentation initiative refocused to Massachusetts requirements

2. Develop a data element dictionary and cross walk for all data elements in each form type

3. Provide compliance review to ensure the created form processes meet applicable state, federal and national accreditation requirements/standards

4. Develop a statewide documentation training manual based on the model used in the SOQIC initiative in Ohio

5. Use the MH/SA providers’ technical assessment level survey completed by MHSACM to develop interim documentation solutions for community providers based on possible paper processes, electronic forms and/or EHR specifications

6. Provide technical assistance for the development of an RFP to select a vendor to create EHR specifications for application statewide with all vendor types (i.e., XML code model, etc.)

7. Provide training to support the documentation model and data elements developed to facilitate an understanding of how to use the new processes to support:

a. Medical Necessity linkage requirements b. Recovery/Rehabilitation service delivery focus c. Move to more fidelity between “what we do versus what we write”

What does it mean for you? Several things… especially about documentation: • A consolidation of rules/requirements and a lessening of duplicative language and

paperwork • Standardized statewide forms for all mental health and substance use disorder

providers • Forms that will assure financial and clinical compliance and reduce opportunity for

rejection from auditors and payers • Forms that are compliant with JCAHO, CARF, COA and NCQA accreditation

standards • Structured forms (check boxes) to record less narrative and reduce completion time.

Why the statewide forms development initiative? • Lack of similarity in forms between agencies and within agencies. (Lack of

standardization, which has resulted in provider agencies using hundreds and hundreds of different form formats and data fields.)

• Difficult for auditors to find information required for reimbursement and clinical audits. • Huge federal fines and legal problems for providers in other states struggling with

adequate documentation. • Need to reduce paperwork so providers can dedicate more time to providing service

rather than documentation


3

• Requirement to move to statewide electronic health records in Massachusetts which can best be accomplished using one standardized documentation process.

What implementation timeline and support can we expect to experience? The MSDP Quality Management Council has developed a statewide implementation plan that will include statewide training and support. More information about specific training events will be distributed statewide as the events are scheduled.

What else? Programs statewide volunteered to serve as Pilot Study sites in March and April 2008, which was a key element of the final development process for the new documentation models. Feedback from their individual direct care staff and collective program level experience using the standardized forms in a variety of settings has resulted in improvements to the forms/documentation processes. In addition, data mapping work has been completed to support an electronic format for the MSDP standardized clinical documentation forms.

MSDP forms cover all of the most common clinical documentation requirements, including a Personal Information Form, Comprehensive Assessment, Comprehensive Assessment Updates, Individualized Action Plans, Initial Psychiatric Evaluation, Progress Notes, and the Discharge/Transfer Summary.

Stakeholders Guiding the MSDP Initiative The following stakeholders have participated in the MSDP initiative to help design the standardized documentation processes with a clear focus on the goals of improved quality of care, increased administrative efficiencies, and full legal, regulatory, and accreditation compliance:

Mental Health and Substance Abuse Corporations of Massachusetts (MHSACM)

Executive Office of Health and Human Services (EOHHS) Department of Mental Health (DMH) MassHealth Department of Public Health Bureau of Substance Abuse Services DPH/BSAS Massachusetts Behavioral Health Partnership (MBHP) Medicaid Carve Out Medicaid Managed Care Organizations (MMCOs):

o BMC HealthNet o Neighborhood Health Plan o Fallon Community Health Plan o Network Health

Consumer/Families and Advocate Organizations: o Parent Professional Advocacy League (PPAL) o National Alliance for the Mentally Ill of Massachusetts (NAMI) o The Consumer Quality Initiative (CQI) o Massachusetts Organization for Addiction Recovery (MOAR) o Massachusetts People/Patients Organized for Wellness, Empowerment

and Rights (M-Power)


4

MSDP Organizational Model:

The organizational model identified below was developed for the MSDP to provide an empowered and effective “top down” and “bottom up” support for the design, development and implementation of the statewide initiative.


5

MSDP Initiative – Operational Components Summary History of Team and Pilot Study Program Efforts In April 2007, the Quality Management Council (QMC) Standardized Documentation Team (SDT), the Compliance Review Team (CRT) and the Consumers, Families and Advocates Advisory Committee (CFAAC) of the MSDP initiative embarked on a lengthy and challenging journey to investigate and develop standardized clinical documentation forms. Having completed an inquiry and review of state and federal regulations, accreditation requirements, best practice standards, and generally accepted clinical and medical documentation styles, the teams began their work in May 2007 to develop a first-of-its-kind standardized documentation forms set and application process for the Massachusetts' Mental Health and Substance Use Disorder Service System. The SDT used the Ohio statewide standardized SOQIC Documentation Process and Training Manuals as a model that would be used to direct their efforts. Additionally, the SDT reviewed sample forms/processes being used in Massachusetts by MH and Substance Use Disorder providers. Further, the CRT created compliance matrices for each group of MSDP documentation processes (Assessments, Individualized Action Plans, Progress Notes and Transfer/Discharge Summary and Plan). The MSDP Compliance Grids will be addressed later in this section of the manual and all compliance grids are included in the Appendix Section. The compliance grid development efforts will provide each community program a quick reference as to why each data field was included in each form.

Importantly, the draft Pilot Forms were reviewed by CFAAC members to provide an opportunity for their feedback and recommendations. The recommendations included the name of the forms/processes, “person” or “person served” language used in all processes and support for a person-centered Individualized Action Plan approach to respond to the identified service needs in the Comprehensive Assessment.

Throughout the project, oversight and guidance has been provided by the members of the QMC, including providing stakeholder based leadership in the design of the initiative.

The development of MSDP statewide documentation model includes three final products that can be used by local providers as follows:

1. PDF Paper Forms Format: This format will provide a full set of MSDP documentation processes that can be printed or copied for manual recording of clinical information by local direct care staff.

2. E-form Electronic Format: This format will provide a Microsoft WORD e-form version of each form that can be used by local staff on their local computers. The e-form model will offer tab to next data element and expandable text field features, however this version does not provide any link to billing services.


6

3. Data Mapping of MSDP Data Elements: The data mapping of all data elements will be available to all providers and software vendors to assist in the design and development of electronic medical records (EMR) that include all of the required MSDP data elements and Medical Necessity Documentation Linkage requirements. Further, a software vendor certification program will be available to software vendors that want their EMR version certified as compliant with the MSDP processes. Additional information about the vendor certification process will be sent to all providers statewide by MHSACM.

Team Membership Below is a list of the members for each team that worked long hours to create a quality based, person-centered, recovery/resiliency focused, and compliant clinical and medical documentation form model for use statewide.

Quality Management Council Membership The role of the QMC is to provide leadership, vision, statewide stakeholder involvement in the management, decision making and implementation of the MSDP documentation process. Members of the QMC and their stakeholder affiliation are identified below:

QMC Member Affiliation Rita Barrette DMH Bruce Bird Vinfen Chris Busby Consumer Quality Initiatives, Inc. Vic DiGravio, Facilitator MHSACM Lauren Falls Network Health Carol Flinn-Roberts Wayside Youth & Family John Frazier MOAR Jim Frutkin ServiceNet Ruth Harrigan Advocates Frank Holt DPH/BSAS Jill Lack Neighborhood Health Plan Lisa Lambert Parent Professional Advocacy League Pat Lawrence NAMI MA/Family Member/Advocate Marsha Medalie Riverside Community Care Jackie Moore North Suffolk Mental Health Daniel Mumbauer High Point Treatment Center Divya Narayan EOHHS John Nestor Amesbury Psychological Center Kevin Norton CAB Health & Recovery Paul O'Shea Health & Education Services, Inc. Elizabeth Ross-Wong BMC HealthNet Plan Susan Schneider Member of MOAR Ronnie Springer Bay Cove Human Services Scott Taberner MBHP Kathy Wilson Behavioral Health Network


7

Compliance Review Team Membership The role of the CRT is to develop compliance grids for each clinical documentation process and review all draft forms/processes and supporting training manuals developed by the Standardized Documentation Team prior to the implementation of the Pilot Study and prior to the implementation of the final MSDP documentation process. Members of the CRT and their stakeholder affiliations are indicated below:

CRT Team Member Affiliation Paul Acford Beacon Health Grace Beason Department of Mental Health Madeline Becker Vinfen Judith Boardman Health & Education Services, Inc. Jane Eckert MSPCC Craig Gaudette Advocates Jim Haughey Behavioral Health Network Kathy Janssen, Facilitator Riverside Community Care Carol Kress MBHP Fran Markle High Point Treatment Center Marcy Morgenbesser Network Health Christine Paschal Wayside Youth & Family Michele Savage Bay Cove Human Services Michael Wagner North Suffolk Mental Health

Standardized Documentation Team Membership The SDT has been responsible for developing each documentation/form process and supporting training manuals, implement the MSDP Pilot Study, collect and review the evaluation feedback from participating pilot programs and complete final processes/manual. The SDT operates from a three sub group operational model that allows simultaneous development of all MSDP documentation processes. A list of the members within each sub group and their affiliation information is listed below:

1. Assessment Group Name Affiliation

Susan Abbott Vinfen Steve Chisholm CAB Health & Recovery Sherry Davis, Lead Bay Cove Human Services Porter May Advocates Dave Selden North Suffolk Mental Health

2. Individualized Action Plan Group Name Affiliation

Rita Barrette Department of Mental Health Jan Feingold High Point Treatment Center Jordan Oshlag Community Healthlink Stephanie Sladen, Lead Health & Education Services Michael Stuart Spectrum Health Systems


8

3. Progress Note Group Name Affiliation

Nancy Carlucci, Lead Network Health Dallas Gulley Riverside Community Care Joe Passeneau MBHP Anne Priestley Wayside Youth & Family

Consumers, Families and Advocates Advisory Committee Membership

CFAAC has reviewed the MSDP documentation processes and provided valuable recommendations regarding how to support a Person-Centered Recovery/Resiliency service delivery approach. CFAAC members and their respective stakeholder affiliation are identified below:

CFAAC Member Affiliation Karl Ackerman Transcom Chris Busby Consumer Quality Initiatives, Inc. Deborah Delman Transformation Center Maryanne Frangules MOAR Project Coordinator John Frazier MOAR Phil Hadley NAMI Massachusetts Lisa Halpern Vinfen Pat Lawrence NAMI MA/Family Member/Advocate Susan Schneider, Facilitator Member of MOAR Judith Siggins Learn to Cope

Consultation Team

Below is a list of the M.T.M. Services consultation team members and their email contact information if needed:

• David Lloyd, MSDP Project Manager – E-mail: [email protected] • Scott Lloyd, Lead SDT Consultant – E-mail: [email protected] • Mary Thornton, Lead CRT Consultant – E-Mail: [email protected] • Bill Schmelter, Ph.D., Clinical Consultant – E-Mail: [email protected]


9

About the MSDP Training Manual This manual provides an overview of this initiative, the forms and instructions for use, and supporting material to enable providers to:

Use the MSDP forms to effectively and efficiently document the individual treatment process for each person served

Be in compliance with rules, regulations and accreditation standards Apply good clinical practices to deliver quality, recovery/resiliency-based mental

health and substance use disorder services The terms person/person served are used throughout this manual, based on feedback from the Consumers, Families and Advocates Advisory Committee (CFAAC). It is recognized that different preferences exist surrounding the use of certain terms. While some prefer to use consumer, others prefer to use client or patient. Additionally, reference to Person-Centered is used where appropriate, when more specificity helps to provide more clarity. In cases where the person served is a child or adolescent, the convention of person/family is used, recognizing that children and adolescents will participate in a treatment process in the context of their family. How the MSDP Training Manual is Organized Each section of this MSDP Training Manual will provide uniquely different areas of information that will hopefully equip your team with key qualitative and compliance concepts used in the development of the forms. Also, the manual will focus on specific information regarding how to utilize the data fields and clinical flow of each form. A summary of each section of the manual follows:

Section 1: Simplifying and Standardizing the Mental Health/Substance Use Disorder Treatment Process. Contains background information about the MSDP effort, the Standardized Documentation and Compliance Review Teams, the forms development process, and the benefits MSDP documentation processes provide. Also, this section provides specific information regarding Medical Necessity, payer, signature and compliance requirements and a discussion of a person-centered Recovery/Resiliency approach to services. Section 2: Using the MSDP Assessment Group Documentation Processes/Forms. This section provides a sample of each Assessment form type, guidelines for the use of each form, and instructions for completion of the forms, including definitions for each data field. Section 3: Using the MSDP Individualized Action Plan (IAP) Group Documentation Processes/Forms. This section provides a sample of each Action Plan Group form type, guidelines for the use of each form, and instructions for completion of the forms, including definitions for each data field.


10

Section 4: Using the MSDP Progress Note Group Documentation Processes/Forms. This section provides a sample of each Progress Note form type, guidelines for the use of each form, and instructions for completion of the forms, including definitions for each data field. Section 5: Appendix This section contains supporting reference information. The ultimate purpose of the MSDP statewide forms initiative is to provide all community programs the opportunity to experience system learning and effective use of forms based on the ability of all direct care staff statewide to approach complex documentation requirements from the same perspective. Thank you for your support of the statewide documentation process.


11

Standardized Documentation Benefits The creation and utilization of statewide standardized documentation data elements and processes can serve to benefit mental health and substance use disorder providers at a variety of levels and in a variety of ways. While deliberation and further evaluation will continue to identify additional long term benefits, other similar initiatives have already observed some important benefits to this effort. Some specific benefits identified by the Standardized Documentation Team and the Quality Management Council include those listed below.

A. Clinical Care Benefits

1. Enhances Clinical Care Approach: The clinical focus utilized represents a shift in concentration on providing and recording a treatment-focused process with emphasis on problem, process and methodology of treatment to focus on the assessment and measurement of the clinical care and recovery/resiliency needs of the person served. Specific attention has been given in the clinical documentation to identify symptoms, behavior, and skills deficits that impact the person’s level of functioning which will help ensure the services ordered meet Medical Necessity requirements.

2. Client-Centered Recovery/Resiliency Focus: The new standardized forms/processes contain a more client-centered and recovery/resiliency based service focus on the person’s served needs and strengths that supports the assessment of peer/family support, employment, meaningful activity, power and control, community involvement, education and access to resource needs and preferences. Integrating the recovery/resiliency needs of the people we serve is critically important to improvement in the clinical care of persons served statewide that are addressed while at the same time blending in the need to demonstrate Medical Necessity and address important funding and regulatory requirements.

3. Reduction of Redundant Collection of Clinical Information: Persons served, families, and advocates representatives have provided excellent feedback regarding how the standardized processes have reduced redundant information gathering by eliminating multiple assessments and service plan development per person served, regardless of the number of clinical services he/she receives at the provider agency. The standardized forms/processes have at their core the principle, "Establish a documentation process that will commit to asking the person a question only once unless there is a justifiable clinical reason to ask the same question twice".

4. Enhanced Measurement and Duplication of Positive Outcomes: Standardized clinical documentation processes have demonstrated an improvement in the ability to measure clinical outcomes and enhance the


12

ability to duplicate positive outcomes. Individual clinician practice variance is exacerbated by multiple documentation processes in that practice variance virtually eliminates the ability to accurately measure clinical outcomes and duplicate any positive results that have been demonstrated.

5. Enhanced Accessibility to Services: Streamlining the intake process through reducing/eliminating redundant diagnostic assessment and service planning processes has produced a reduction in the total time it normally takes to admit individuals into services, which has also had a positive impact on reducing "intake no shows/drop outs".

B. Fiscal Benefits

1. Staff Retention:

Proactive adaptation of current service delivery processes to accommodate low redundancy standardized documentation models provides an ability for staff to "finish their work" at the end of each day resulting in higher morale.

2. Enhances Cost Efficiency of Standardized Process: With the current funding environment, it is imperative to develop more cost efficient documentation processes. A standardized low/no redundancy documentation process has proven to be more cost effective than historical program/unit based unique models that were replete with redundant recording of information from persons served. Additionally, standardized documentation forms/processes have dramatically reduced training costs.

3. E-Health Conversion of Forms: All final forms/processes will be provided to MH/SA providers in a data mapping format that will support time and cost effective EMR development.

4. Enhances System-wide Accountability:

Standardized documentation has proven that it will enhance system-wide accountability in the following areas: a. More objective determination of cost of services by virtue of utilizing

more standardized documentation processes and volume. b. Provides a much more objective comparison of clinical

processes/services delivered statewide. c. Provides persons served, families and advocates an ability to expect

the same clinical documentation process regardless of which provider agency in the state they access.

C. Enhanced Compliance Benefits

1. Meets Certification and National Accreditation Compliance Requirements:

All forms/processes will be reviewed in detail by a collaborative statewide compliance team to ensure compliance with state certification


13

requirements, JCAHO/CARF/COA/NCQA accreditation standards and Medicaid/Medicare documentation compliance requirements.

2. More Objective Reviews/Audits:

The move to standardized documentation has had a positive effect on minimizing a significant level of the historical subjective nature of site reviews.

3. Provides a Reduced Compliance Risk Environment:

More objective reviews due to use of standardized forms/processes within MH/SA centers provides a clinical service delivery environment that facilitates a higher level of compliance statewide.

4. Promotes a System Learning Environment:

Standardized documentation improves the ability to provide system wide change opportunities that promote compliance with Medical Necessity linkage documentation requirements, National Accreditation and state certification standards.

Hopefully, the above information provides additional reasons to support the statewide standardized documentation initiative. Together… we can make a difference for persons served, staff, programs and payers.


14

MSDP Integrated Documentation Process Overview (Note: Reprinted with permission from Chapter Six of How to Deliver Accountable Care written by David Lloyd and published by the National Council of Community Behavioral Healthcare) A common challenge continues to be reported by management teams and direct care staff providing services in Community Behavioral Healthcare Organizations (CBHOs): “Our staffs are just so busy already; we don’t see how we could take on one more documentation standard or requirement!” Having heard the “we’re very busy” theme many times since the early 1990’s, it seems important to identify the core challenges and focus attention on what might be an integrated solution. The “busy” documentation level concept is even more perplexing when integrated into the typical direct service staff billable hour annual standard of 1,200 hours per year. If the staffs are scheduled on a 40 hour per week clinical schedule, the 1,200 hour standard provides each direct care staff with five (5) work months a year that direct care staffs DO NOT have to see clients. This five month period each clinic year can be used for Annual Leave, Sick Leave, Holidays, documentation, meetings, training, etc. So the question that often arises is, “Why is five work months of non-billable time not enough to appropriately document clinical services?” Experience indicates that the “busy” documentation factor seems to be linked to the level of integration of the clinical documentation process across the provider agency versus the level of clinician/unit/program specific non-integrated documentation being used. The key element of busy documentation is the level of formal or informal redundancy designed into the current intake and action planning clinical model being used. For instance, a Silo or Unit Based Clinical Model typically provides clinical authority for each clinician within each unit to provide a full assessment (either formally or informally) and Individualized Action Plan for each person entering the unit or program. This means that each person entering service with the assessed need for multiple services within mental health and/or substance use disorder services will receive multiple unit based assessments and action plans. In one community provider agency of both mental health and substance use we provided consultation to during the past year, the average person served received 3.2 assessments and 2.8 action/treatment plans that were unit/service specific. The multiple redundant paperwork model has not proven helpful to:

• Persons being served in that multiple action plans with multiple goals/objectives have proven confusing and in some cases contraindicated.

• Direct care staff that are re-recording information that the provide agency has already collected in an earlier similar/identical process

• Qualitative compliance audits/reviews have been challenging due to variances in the diagnosis, assessed treatment needs, goals/objectives, etc.

Which funding source or state standard/regulation requires that we use a multiple assessment and action planning model of service delivery? Typically, the answer is “there is no state standard” for the redundant busy work model utilized. Only the need for units/programs to maintain clinical


15

authority to assess, develop individualized action plans and develop a diagnosis seems to drive the need to continue to deliver services in this manner. In fact, most states have requirements for a fully integrated approach to treatment. Addressing Multi-Layered Paperwork Requirements

There seems to be almost a “chicken or the egg” question regarding silo/unit based multi-layered intake/admission and service action planning processes and duplicity of documentation development. In many cases, the silos of care/unit based service delivery culture and the multi-layered admission gates have driven the need for more and redundant paperwork. On the other hand, it seems that the need for multi-layered paperwork is driven by the silos of care and/or the multiple admission gate process. The most effective standardized documentation outcomes are based on the ability to address duplicity of paperwork as an organization-wide challenge that can have enormous effects on providing fully integrated quality person-centered services, enhancing HIPAA compliance and increasing Medicaid/Medicare Corporate Compliance levels for documentation of Medical Necessity. The MSDP documentation process is designed to be used in a fully integrated service delivery setting. The Comprehensive Assessment, CA Updates, Individualized Action Plan and IAP Review/Revision processes support a truly integrated organization-wide assessment of needs using one assessment process and integrated clinical formulation of services/interventions ordered to support attainment of Goals/Objectives in the IAP. The MSDP documentation process can be used to provide a fully integrated solution to the need for a comprehensive assessment of mental health and substance use disorders, a five Axis diagnosis, an integrated action plan where all services needed by the person being served can be ordered regardless of the unit/program and a progress note model that will document the interventions provided and response to the interventions in all service types. The only requirement to using the integration potential of the MSDP documentation process is that each direct care staff/unit/program relinquishes some of their clinical authority to assess, develop a diagnosis and provide treatment/action planning to shift the documentation requirements to an organization-wide focus.


16

Pilot Study Supported Development Model The MSDP Project Management Plan incorporated an empowered “Top Down and Bottom Up” design and development model. An important part of the plan was for individual direct care staff and local program managers to use the draft pilot forms/processes developed by the project teams in daily service delivery environments. Local staff/program use of the MSDP documentation processes during a six week pilot in March and April 2008 provided an opportunity for participants in the study to share informed feedback and evaluation that guided the development of the final processes and training manuals. A MSDP Pilot Study Evaluation Plan was developed and approved by the QMC. This plan was implemented by the SDT and provided three levels and types of measurement as outlined below: A. Evaluation Levels and Tools

1. Assessment of each Local Program Pilot Training and ‘Kickoff’ Description: After the co-facilitators at each participating program in the MSDP Pilot conduct their local pilot training and kickoff, they will complete an instrument that evaluates the quality of the training and supports they received, as well as the success of their local training program. The instrument will also identify additional information and/or supports needed to successfully implement the pilot. Instrument and Tools: • “MSDP Local Program Pilot Implementation Survey” • “Program Type List” to insure correct classification of program type

2. Direct Care Staff Form “Mark-up” Process

Description: After using and becoming familiar with the pilot forms, each participating staff member will have the opportunity to make detailed suggestions for form improvement by making notations directly on blank forms.

Instruments and Tools:

1. Set of blank pilot forms 2. MSDP Pilot Form Markup Instructions and Cover Sheet 3. “Program Type List” to insure correct classification of program type

3. Program Level Pilot Evaluation:

Description: During the last week of the pilot, local program co-facilitators, with direct input from all participating program staff, will complete an evaluation of the pilot including structured and unstructured feedback about each piloted form. Prior to beginning the pilot, all participating staff will be given a “Staff Cue Sheet” designed to help focus staff on the kinds of information to track and attend to as they use the pilot forms. Instruments and Tools:

• MSDP “Program Level” Pilot Evaluation Summary • Staff Cue Sheet


17

B. Summary of Outcomes from MSDP Pilot Study

The MSDP Pilot Study provided excellent evaluation support for the required continuous quality improvement (CQI) development process that is being used to develop statewide standardized clinical documentation processes. Twenty-six MHSACM member provider agencies submitted a request to participate in the MSDP Pilot Study in March and April 2008. A total of 70 different local programs at these member agencies representing twenty-six different statewide funded program types participated and provided three levels of evaluation as outlined below: • Program Specific Evaluation: Seventy local programs completed and submitted program specific

evaluations that provided excellent feedback in eighteen focus areas within the survey instrument. Due to the length of the full survey results, please find below a sampling of composite responses to several of the survey questions that will provide an awareness of the participating programs in the pilot study: Question Four:

Question Eighteen:


18

Additionally, each program provided specific evaluation for each MSDP form type they used in the pilot study for the following survey questions: 1. For each form below, indicate the number if times the form was used during the pilot. 2. To what extent has staff at your program used the Pilot Training Manual? 3. To what extent does each form below collect the data elements you need to do your job well? 4. To what extent does each form below contain unnecessary data elements? 5. To what extent does each form below support compliance with regulations and payer

requirements (DMH, MBHP, Medicare, MCOs, CMS, etc)? 6. To what extent does each form below support compliance with accrediting body standards

(CARF, JCAHO, COA, NCQA, etc)? 7. To what extent does each form below support a ‘Person Centered, Recovery Oriented” approach

to services? 8. Please evaluate the overall clinical flow/clinical content of each MSDP form/documentation

process 9. Compare each new pilot form below with the equivalent form being used just prior to the pilot in

terms of Support for Quality Clinical/Recovery Focused Services - The new form is much worse, worse, same, better, or much better

10. Please indicate which of the new pilot forms you would choose to continue using after the pilot.

In addition to specific responses to each program level evaluation question, local programs provided narrative comments that further illuminated the findings reported. All narrative comments were reviewed by the Standardized Documentation Team prior to beginning the task of revising each MSDP form and training manual section.

• Direct MSDP Form Mark Up Evaluation: Clinical/direct care staff that participated in the pilot study

at the local program level provided invaluable direct “mark up” evaluation for each MSDP form type that they used during the pilot. After the first week of the pilot study which provided an opportunity for staff to use and becoming familiar with the pilot forms, each participating staff member was asked to make detailed suggestions for form improvement by making notations directly on a blank copy of each form. Also, while feedback comments were not restricted, the following focus areas were provided to staff to help ensure that these specific areas of interest were adequately addressed to support the CQI development process:

1. Missing data elements that staff members think should be included on the form. These can be entire sections, new questions, choices within questions, or prompts you think would be helpful.

2. Unnecessary data elements that staff members think could be eliminated without affecting the quality of information collected.

3. Redundant data elements. Collecting the same or very similar information more than once. 4. Space issues. This can include the need for more space or less space in any sections of the

form(s). 5. Any other suggestions or comments that you have regarding form improvement.

Participating staff submitted over 3,000 comments through the direct mark up evaluation process that were aggregated by MSDP form type, program type, and comment category (i.e., missing data elements, redundancy, space needs, etc.). All comments were reviewed by the Standardized Documentation Team prior to beginning the MSDP form and manual revision process.


19

Documentation That Supports Quality Treatment

The Value of MSDP Standardized Forms and Processes By: Bill Schmelter, Ph.D., M.T.M. Services and National Council Consultant

The MSDP Standardized Forms and Processes were designed to improve the “value” of clinical documentation for persons served, the staff that provide services, and the organizations that support service provision. Understanding the intended value of various aspects of the MSDP Standardized Forms and Processes is an important step in their optimal implementation for several reasons. First, an understanding of, “what’s in it for us and the people we serve” is necessary if staff are going to make the effort to fully learn and take advantage of the forms and processes as intended. Second, understanding the ‘why’ of the forms and processes design can improve the value that results from their implementation. There are many examples of well designed forms and processes that are misused, thus neutralizing their intended value. Well designed standardized clinical forms and processes can do much more than simply provide a format for recording information. This section discusses the potential value of the MSDP Standardized Forms and Processes in the following three areas:

1. Improved Service Quality and Compliance 2. Support for ‘Person Centered, Recovery/Resiliency Oriented Services’ 3. Improved system learning and responsiveness

1. Improved Service Quality and Compliance

Documentation compliance efforts are often viewed by direct provider staff as independent of, or even obstacles to, clinical quality. For example, staff frequently report that documentation requirements interfere with their ability to interact with the individuals they serve. A well designed set of forms and processes should assist and support staff and persons served as they navigate the recovery process together, not get in their way. The purpose of compliance standards is to ensure baseline levels of service quality and accountability. Any effort to improve compliance should maintain a focus on how those efforts will improve the quality of care provided. The MSDP Standardized Forms and Processes were designed to provide the most current support for compliance, to guide good practice, and to improve service quality and outcomes in the most efficient manner possible.


20

All forms in the MSDP Standardized Forms set, were cross referenced with applicable standards and regulations to insure compliance. In addition the structure and content of forms were designed to efficiently support core clinical and recovery processes. The Comprehensive Assessment promotes participation by the person being served and encourages an interactive dialogue. Through a carefully planned sequence of assessment focus areas and prompts, the Assessment supports the efficient collection and analysis of information to:

• Accurately determine and support diagnoses • Identify individual strengths, preferences, and personal goals • Identify social, environmental and other barriers to recovery • Identify available supports and resources • Establish baselines for symptoms, domains of functioning, skills and abilities • Articulate and prioritize needs and recommended services • Justify the medical necessity for the types and intensity of services to be provided • Lay the groundwork for development of a meaningful Individualized Action Plan

The Comprehensive Assessment Update is designed to ensure that: • Relevant new or updated information is incorporated into the Assessment • Current assessment data and conclusions directly support the current

Individualized Action Plan

The Individualized Action Plan is designed to efficiently: • Ensure active linkage to the findings and recommendations of the current

Assessment • Encourage collaboration between the provider and the person served • Encourage the meaningful consideration of strengths and preferences in the

development of goals and objectives • Support the development of meaningful Goals • Support the development of realistic, relevant, and measurable Objectives that are

changes to the baselines established in the Comprehensive Assessment • Support the clear articulation of interventions (methods), and service strategies

that are expected to help achieve stated objectives and can meaningfully direct staff activities

Progress Notes are designed to efficiently: • Ensure that Interventions/Methods remain focused on the Goals and Objectives

developed in the Individualized Action Plan. • Encourage description of interventions provided, the response/reaction to the

interventions by the person served, and progress toward Goals/ Objectives. • Articulate plans for activities recommended prior to the next session as well as the

focus for the next session. • Document pertinent new information that may trigger a Comprehensive

Assessment update and potentially require a change in the Individualized Action Plan


21

All other forms in the MSDP Standardized Forms set were similarly designed to support the underlying processes they reflect.

2. Support for Person Centered, Recovery Oriented Services

The MSDP Standardized Forms and Processes were designed to help move efforts to provide Person Centered, Recovery/Resiliency Oriented services from theory to practice. Person Centered Approach: A Person Centered approach involves a genuine partnership between a provider and the person being served throughout all aspects of the service process including assessment, action planning and service interactions. Person Centeredness is not just about ‘respect’ or good ‘customer relations’. These should be core elements of any responsible service orientation. Rather, Person Centeredness is about improving outcomes! Engaging in the recovery process takes significant and prolonged effort on the part of the recovering person. Unless individuals believe that providers fully understand their personal goals, strengths, obstacles, and what they hope to gain from services, motivation and engagement will suffer. Motivation and engagement are enhanced when individuals have real input into the development of goals and objectives that reflect personally desired change and can be easily related to the achievement of personal goals. Finally, ongoing service engagement will only occur if individuals understand how the services they receive are helping them reach the objectives both the persons served and their service providers committed to working on. Person Centered services ensure that Assessment and Action Planning are considered more than just paperwork, and that services provided are focused and of value to the person served. The MSDP Standardized Forms set provides significant support for Person Centered Services. Recovery Orientation: Recovery is another concept that has been difficult for many service providers to implement in a practical sense. One nationally accepted definition of Recovery is, “A personal process of overcoming the negative impact of a psychiatric disability despite its continued presence.” For obvious reasons the Person Centered approach discussed above is central to supporting recovery. In addition, a Recovery orientation requires a shift from a primary focus on symptom reduction to a focus on improvement in functioning, resilience and adaptation. The MSDP Standardized Forms and Processes are designed to support a Person Centered, Recovery Oriented approach. It is up to service providers to take advantage of that support. The Comprehensive Assessment is designed to efficiently prompt exploration of a wide range of issues. The focus is not limited to symptoms and diagnoses, but includes functioning domains, skills, strengths, preferences, available and needed supports, and


22

personal goals. It is important to encourage the persons being served to offer their perspectives in areas of importance to them and to ensure that they understand the purpose and value of the assessment. This is particularly important when developing identified needs that will form the basis for the Individualized Action Plan. The Individualized Action Plan is also designed to encourage the active participation of the person being served and to allow a focus on functioning. This is particularly important in the development of goals and objectives, which should be achievable, realistic and of value to the person. The opportunity to identify individual strengths and how they can be brought to bear to help achieve goals and objectives is also provided. Individual Action Plans should not be overly complex. It is difficult for most people (including provider staff) to maintain a focus on more than one or two goals and a few objectives at a time. By focusing on a few, relevant objectives, success is easier to achieve and measure thus further building motivation and engagement. The Progress Note is also designed to support this approach. It is important to maintain “Action Plan Awareness” when providing services. This means that it should be clear to the provider as well as the person served what the current intervention session has to do with the achievement of a particular objective(s) in their Action Plan. It is all too common to find progress notes that document conversations about current ‘mini crises’ or other ‘topics of the day’ with no obvious connection to the Action Plan. As providers, we have a responsibility to help maintain Action Plan Awareness and provide interventions that help the person achieve the agreed upon objectives or, based on changing conditions, modify the Action Plan in collaboration with the person served. For many of the people we serve, past experience with services has left them with low expectations. In their experience, Assessment and Action Planning may have been primarily paperwork exercises with little connection to the service interactions they have with provider staff. For these individuals, involvement in Person Centered, Recovery/Resiliency Oriented services will involve some relearning. This involves extra effort on the part of provider staff to help instill a sense of hope and engagement.

3. Improved System Learning and Responsiveness

The uncontrolled proliferation of forms is a common problem in behavioral health service settings. Frequently, no single person or entity is even aware of all the forms used within their organization. This situation, in addition to putting an unnecessary strain on an organization’s ability to train new staff or retrain existing staff for new assignments, makes responding to change a daunting task. Conforming to new regulations or accreditation standards can mean analyzing and making changes in dozens of forms. Similarly, any planning process for programmatic, quality improvement or other rapid cycle change initiatives will frequently identify the need to undertake complex and costly changes in documentation as a significant obstacle. Just the proposition of needing to make changes in numerous forms can sometimes derail an otherwise worthy undertaking.


23

A standardized set of forms and processes that have been specifically designed to meet applicable regulatory and accrediting body standards, as well as to support clinical practice, makes staff training easier, more consistent, and more effective. In addition, responding to changing conditions can be accomplished in a more efficient and coordinated fashion. Documentation standardization at the system (e.g. statewide) level greatly increases the benefits discussed above. While all behavioral health organizations have similar core missions and similar documentation change requirements to address evolving regulations and accreditation standards, they have historically been left to their own devices in terms of developing response. Organizations have not been able to take full advantage of the experiences of other providers (e.g. audit findings) because their core documentation forms and processes are significantly different. Supervision and monitoring systems also benefit from the adoption of standardized forms and processes. Because forms are consistent, supervisory, medical records, utilization review, and quality improvement staff can use more standardized approaches to supervision and documentation review and can benefit from the experience of others. Standardized monitoring tools can be developed so that benchmarking both within and among provider organizations becomes more practical. Another benefit of a collaboratively developed standardized form set is its value as a critical step for the potential conversion to an Electronic Medical Record (EMR) format. The biggest challenge organizations face when preparing for this transition is identifying and piloting the form elements and processes they want represented. The development of the MSDP Standardized Forms and Processes is a major step in preparing for EMR conversion for interested organizations. In addition, statewide system adoption of a common set of standardized forms and processes can create an economy of scale that greatly reduces the cost of EMR conversion and ongoing support for any particular organization. Adoption of the MSDP Standardized Forms and Processes will make it possible for all organizations to take advantage of the experience of other providers and to participate in and benefit from coordinated responses to change, training and support.


24

Clinical Focus of the MSDP Documentation Process The Massachusetts Standardized Documentation Project aims to create a standardized set of forms and processes, to be used as tools for documentation across the state, which are fully compliant with a wide variety of regulatory and payer requirements. The recent shift in the field towards electronic health records, prompted by the Federal mandate requiring all states employ electronic record formats by 2014, points to a pressing need for clinicians and practitioners to shift thinking about documentation itself. Along with the importance of demonstrating medical necessity and moving towards person and family centered planning and treatment, today’s behavioral health care provider must also use documentation to accurately capture the person’s assessed needs, goals for treatment, and work toward meeting the stated goals. As the persons we serve are not unchanging, neither can the documentation be a one-time-only, “snap shot”, of a person’s history, presentation, and goals. The form set and processes developed by the MSDP reflect this need and create a framework for a dynamic system of gathering and documenting the person’s treatment, response to treatment and movement toward chosen goals over time. The MSDP documentation process is one that is horizontal and integrated. It allows the provider to work collaboratively with the person served to continuously discover more about the person’s needs and to maintain a clear, but dynamic plan for working towards the person’s desired outcomes. The forms/processes allow for a logical and natural flow of information gathering and service documentation. When used as developed, as a “required record set”, they serve as synergistic tools to:

Assess the person in a comprehensive way, Ensure the determination of the medical necessity for treatment, Guide the development of treatment goals and objectives which meet the needs

and desires of the person served and Document the progress or lack thereof of the person’s course of treatment.

Each required form in the set supports the documentation of key service delivery processes from intake to discharge. Each form within the “required” record set for any service type addresses some of the essential elements needed to comply with funder and payer requirements. Therefore forms should not be “pulled apart” from each other and used individually. If some of the MSDP forms types are used, but not all of the required forms, the clinical information may be incomplete and compliance with funder/payer requirements will not be attained. The chart below emphasizes the integrative design of the forms developed.


25

INTAKE Personal Information Must be completed at the time of initial contact with the person who is seeking services.

Reflects the minimum amount of demographic information to record for each person served.

Captures essential demographic, contact and insurance/billing information. This form can be completed by support staff or clinical staff.

CRISIS Risk Assessment Used to assess risk of harm to self or others as part of a comprehensive assessment or

when assessing a person in crisis. Gathers data on relevant risk issues and severity. Completed by a masters level clinician or a paraprofessional, under the supervision of a

licensed clinician; or a licensed clinician.ASSESSMENT Adult Comprehensive Assessment

Complete after the Personal Information form, as the person enters services, in compliance with agency policies and funding requirements.

The Adult Comprehensive Assessment provides a standard format to assess mental health, substance use and functional needs of persons served. This Assessment provides a summary of assessed needs that serve as the basis of Goals and Objectives in the Individualized Action Plan.

A qualified clinician must complete or oversee the completion of this form after interviewing the person served, face to face.

Child Comprehensive Assessment


The Child/Adolescent Comprehensive Assessment provides a standard format to assess mental health, substance use and functional needs of persons served. This Assessment provides a summary of assessed needs that serve as the basis of Goals and Objectives in the Individualized Action Plan.

A qualified clinician must complete or oversee the completion of this form after interviewing the person served, face to face.

Mental Status Examination

Use anytime to assess symptoms and behaviors. This is a data gathering tool, with multiple uses, to assess current symptoms and

behaviors. This is a component of the comprehensive assessment, or is completed as part of a risk assessment. Also it is provided as a stand-alone document.

A licensed practitioner as determined by agency policy must complete this form after interviewing the person served, face to face.

Initial Psychiatric Evaluation


Used to assess the bio-psychosocial health and service needs of the person served. Components of this evaluation are included in the comprehensive assessments. Also it is provided as a stand-alone document.

This form is to be completed by a psychiatrist, CNS or other APN with credential in psychiatry and prescribing privileges.

Tobacco Assessment Required for DPH licensed programs; completed in concert with the comprehensive assessments.

Optional for other programs following agency policies. Assesses current and past tobacco use and readiness to change. Completed by staff following agency policy.

HIV Risk Assessment Required for DPH licensed programs; completed in concert with the comprehensive assessments.

Optional for other programs following agency policies. Assesses current and past risk behaviors as well as willingness for testing and treatment. Completed by staff following agency policy.

Physical Health Assessment

Required for JCAHO certified programs and some DPH services; completed in concert with the comprehensive assessments.

Optional for other programs following agency policies. Assess current and past medical issues of the person served that may impact current

functioning. To be completed by qualified Medical Professional.


26

INDIVIDUALIZED ACTION PLANNING Individualized Action Plan To promote principles of recovery, this form serves as what most of us have known as a

treatment plan. The name, “Individualized Action Plan” reflects the recovery concept of shared decision making.

Used to document goals, objectives, and therapeutic interventions. Links to needs identified during the assessment phase or ongoing treatment. Serves as a tool to collaboratively build a treatment plan, which reflects both medical

necessity and the desired outcomes of the person served in his or her own words. The design encourages collaboration among programs and across agencies. Again supporting a recovery focus, transition/discharge planning is advised from the earliest

point in treatment possible. The section provided on the form assists in this process. Psychopharmacology Plan

Used for persons receiving outpatient psychopharmacology services only. Designed for ease of use and to capture all required information succinctly and accurately.

Detox Plan Used for persons receiving inpatient detoxification treatment. Modeled after the standard Individualized Action Plan and reflective of the ASAM

dimensions of treatment. Reflects and supports the short-term nature of this treatment modality.

MONITORING AND TRACKING Consultation/Collateral Contact Progress Note

Used for billable or non-billable face-to-face or telephonic consultation or collateral contacts Identifies next action step and responsible party

Group Psychotherapy Progress Note

Used to document therapeutic interventions and person’s response to the intervention(s) during a specific contact

Use for outpatient group psychotherapy Documentation links to specific goals in IAP

Health Care Provider Orders Progress Note

Required for Rehabilitative Treatment in the Community (RTC) This note is used when a person is either living in a DMH-funded residential program, such

as a group home, or is living in their own apartment and receiving DMH-funded Supported Housing Services.

This serves as an ongoing communication tool between the residential support staff and the health care providers, which may include outpatient behavioral health prescribers, primary care physicians/nurse practitioners, and dentists.

This can be used in outpatient behavioral health settings as the progress note for a medication visit for the outpatient chart.

This ensures thorough and current medication lists, as well as instructions for both the staff and the individual taking the medications.

Intensive Services Progress Note


Use for all individual and group services as part of Community Based Adolescent Treatment (CBAT), Intensive Community Based Adolescent Treatment (ICBAT), Partial Hospitalization Program (PHP), Detox, Intensive Outpatient Program (IOP), Structured Outpatient Addiction Program (SOAP) and Dual-Diagnosed Addiction Residential Treatment (DDART).

Documentation links to specific goals in IAP. This form incorporates all therapeutic services specifically provided by the program during the course of the day.

Monthly Progress Note Used for services requiring monthly documentation. Required for Residential Services (DMH) Summarizes progress made by the individual toward the IAP goals and significant changes

in the person’s environment over the course of the month. Documentation links to specific goals in IAP.

Outreach Services Progress Note

Used in home visit community support interactions with the person and family receiving services

Required for Community Rehabilitation Services (CRS), Community Support Program (CSP), Family Stabilization Team (FST), Flex Support Program, Program of Assertive Community Treatment (PACT)

Documentation links to specific goals in IAP MONITORING AND TRACKING Psychopharmacology Progress Note

Used by psychiatrists or Advanced Nurse Practitioner when member is seen only for outpatient medication management or as part of more intensive (bundled) service, such as when the psychiatrist meets individually with someone receiving services in a Partial Hospital Program.

Documentation links to specific goals in the Psychopharmacology Plan or IAP. Psychopharmacology/ Psychotherapy Progress Note

Used by psychiatrist or Advanced Nurse Practitioner when the prescriber provides service of outpatient med management and psychotherapy.

Documentation links to specific goals in IAP.

Psychotherapy Progress Note


Use for outpatient individual, couple or family psychotherapy Documentation links to specific goals in IAP


27

MONITORING AND TRACKING - Continued Nursing Progress Note (Long and Short Version)


To be completed by a LPN, RN, BSN or MSN. Use either the short or long version, whichever provides sufficient space to record the

information. The long version contains additional data fields to document additional information including a mini-mental status exam.

Required for Intensive Residential Treatment Program (IRTP) This form can be used as a shift note by a nurse in any Detox, SOAP or DDART program.

Shift/Daily Progress Note Required for Child Day Services, Crisis Stabilization Unit (CSU), Detox Level III, Intensive Residential Treatment Program (IRTP), Respite

Documentation links to specific goals in IAP. Weekly Services Progress Note

Used to document therapeutic interventions over the course of a week and person’s response to the interventions

Documentation links to specific goals in IAP Summarizes services/interventions and the person’s responses/progress. Required for Psychiatric Day Treatment and Transitional Support Services (TSS)

ACTIVE REVIEW AND RESPONSE Adult Comprehensive Assessment Update

This form saves time and effort. Used to update information in Comprehensive Assessment. Use whenever substantial change in person’s status occurs. A qualified clinician must complete or oversee the completion of this form after interviewing

the person served, face to face. Child Comprehensive Assessment Update

This form saves time and effort. Used to update information in Comprehensive Assessment. Use whenever substantial change in person’s status occurs. A qualified clinician must complete or oversee the completion of this form after interviewing

the person served, face to face. Individualized Action Plan Review/Revision

The Individualized Action Plan Review/Revision form has been created to document information from ongoing review(s), revision(s) of treatment goals and objectives and/or periodic rewrites. This form has been designed to minimize duplication of effort in creating subsequent action plans and maximize the documentation of information, which demonstrates evidence and/or rationale for revision.

Use the IAP Review/Revision form to update or modify the IAP in any of the following ways: • Revisions – to add a new goal; change goals, objectives or interventions; or change

the frequency or duration of services; • Reviews - to record the progress of the person served and • Rewrites - annually, after three interim revisions, or per agency protocol, a “rewrite”

of the actual IAP is warranted. This will facilitate the identification and tracking of treatment goals/objectives and progress made.

Use both pages of the Individualized Action Plan Review/Revision form for either a Review or Revision; additional goal and/or objective sheets should be added as necessary. If you are adding a new goal or objective, attach the goal and/or objective page(s) from the IAP form to the IAP Review/Revision form.

When a Rewrite is being completed, page 1 of the IAP Review/Revision should be used and the new IAP should be attached.

If a goal/objective is new and not currently supported by the most recent Comprehensive Assessment, it is important to also complete a Comprehensive Assessment Update form.

It is important to remember that as with the IAP, any IAP revisions should be completed in collaboration with the person served. This form requires evidence of collaboration in a number of ways. In all cases, if a person refuses to collaborate, does not agree to goals, or will not review goals, a separate progress note should be written to describe the person’s participation and the plan for moving forward.

Multi-Disciplinary Team Review and Response

As required, use this form to document the review of Individualized Action Plans and other necessary clinical documentation by a multi-disciplinary team.

This form is designed to be used as a tool to provide feedback regarding required actions by the primary provider.

TRANSITION AND DISCHARGE Transition/Discharge Summary and Plan

Use at the time of transition or discharge, including any movement throughout the continuum of care both internal and external.

Summarize treatment, reasons for transition/discharge, and plans for referral to assist the person in following through on aftercare recommendations.

Note: The forms stay true to their purposes of assessment, action planning, and documentation of progress. By monitoring and ensuring ongoing dynamic review of and response to CA Updates, IAP Review and Revision, and MDT Review and Response, the person’s needs are integrated formally into the treatment process.


28

Why is Person-driven Documentation Necessary?

This standardized record-keeping system and training manual guides clinicians and rehabilitation providers (in a variety of programs and throughout the state) toward meeting documentation requirements for medical necessity in a timely fashion. A standardized system is one remedy for the fragmentation of communication, resources and personal dreams that is often created by the current health and mental health care system. The forms themselves prompt for documentation of evidence-based services that are person-driven, goal oriented and a good fit for the individual’s cultural context.

WHAT is being Documented? Effective and high quality services have been described in a multitude of research studies and through personal accounts.1 In 2006, the Institute of Medicine made several recommendations for clinicians and organizations to improve the quality of mental health and substance use treatment services that included:

• incorporating informed, patient-centered decision making throughout their practices;

• adopting recovery-oriented and illness self-management practices that support patient preferences for treatment;

• maintaining effective, formal linkage with community resources to support patient illness self-management and recovery; and

• having policies that implement informed, patient-centered participation and decision making in treatment, illness self-management and recovery plans. 2

In this section of the manual, there are references to “person-centered”, “recovery-oriented”, “culturally competent”, “collaborative” and “sustainable” models of care. These approaches, as well as many others, rest on a common framework that we call “person-driven”. Language, structures and decisions that are driven and fueled by the person using services, the whole of the person, are essential to effective care. The surge of interest and funding for evidence-based practices in behavioral healthcare has affirmed the focus on person-driven treatment: 1 Slater, Welcome to My Country. Jamison, An Unquiet Mind and Touched with Fire: Manic Depressive Illness and the Artistic Temperament. Kaysen, Girl Interrupted. Millet, The Looney Bin Trip. Rogers, PhD., A Shining Affliction (extraordinary account by a therapist of her parallel recovery journey as client and clinician at the same time). Geller et al, (Ed). Women of the Asylum. Estroff, Making it Crazy: An Ethnography of Psychiatric Clients in an American Community. Stanford, L. Strong at the Broken Places: Overcoming the Trauma of Childhood Abuse. Styron, Darkness Visible: A Memoir of Madness. Manning, Undercurrents (journal of a therapist who uses ECT treatment to good effect). Beard et al., Nothing to Hide: Mental Illness in the Family 2 IOM (2006). Quality Chasm Reports: Improving the Quality of Health Care for Mental and Substance-Use Conditions.


29

“Evidence based medicine is grounded in the concept of person-centeredness … [meaning] acknowledging individual differences and characteristics, including different biology, culture, beliefs, values, preferences, history, abilities, and interests.” 3

How to document person-driven, recovery-oriented and sustainable services is described in more detail below. Each are illustrated with examples from the “golden thread” of one person’s hopes, dreams and goals as this thread shows itself in documenting medical necessity.

“Person-driven” Documentation

Background

Studies show that orienting health care around the preferences and needs of people using medical treatment has the potential to improve patients’ satisfaction with their care, as well as their clinical outcomes.4 In 2003, however, the nation’s mental health system was not guided by people’s life goals and ambitions. In July of that year, The President’s New Freedom Commission on Mental Health reported the following state of affairs:

• “Currently, adults with serious mental illnesses … have limited influence over the care they receive …”

• “The extreme fragmentation of the system of care means that many consumers of behavioral health services are … unable to fully participate in their own plans for recovery.”

• “…consumers and their families do not control their own care.”5

Person-centered planning is driven by the individual who is receiving services, but works best when it includes other people who can contribute valuable information to the process. During person-centered planning, an individual identifies his or her strengths, capacities, preferences, needs, and desired outcomes.6 The Institute of Medicine defines patient-centered care as:

“Health care that establishes a partnership among practitioners, patients, and their families (when appropriate) to ensure that decisions respect patients’ wants, needs, and preferences and that patients have the education and support they need to make decisions and participate in their own care... [Patient-centered care is] respectful of and responsive to individual patient preferences, needs, and values, and ensures that patient values guide all clinical decisions.” 7

3 Hyde, PS, Falls, K, et al, Turning Knowledge into Practice: A Manual for Behavioral Health Administrators and Practitioners about Understanding and Implementing Evidence-based Practices. 4 Agency for Healthcare Research and Quality, National Healthcare Quality Report, Dec. 2005. 5 Achieving the Promise: Transforming Mental Health Care in America: 6 Cook et al., 2004 7 Envisioning the National Health Care Quality Report


30

In 2006, The Institute issued ten rules to guide the redesign of health care. The first four of these expressly embrace the core values of person-driven care:

1. Care should be based on continuous healing relationships. 2. Care should be customized based on the person’s needs and values. 3. The person is the source of control. 4. There should be shared knowledge and a free flow of information.8

What does “person-driven documentation” look like?

Clinical and rehabilitation documents are also tools for increasing a person’s sense of themselves as a whole and capable person with a unique past, present and future. Paperwork driven solely by the provider or the system, however, can fragment an individual’s experience of their lives moving forward.

Questions, Prompts, & a Process for completing forms should help to…

Predict, give concrete examples, evaluate and plan for a continuum of services (prevention, treatment, life-long as needed). Such services should be consistent with the individual’s, family’s and community’s experience of integrity over time.

“Initial Screening & Assessment” Example

Caller: Can you help me? I am going out of my mind!

Person-driven

Screener: Yes, I will do my best to help you. My name is Judy. What is your name? Can you tell me what happened?

C: I went to the store and I’m sure that someone followed me home…

S: Thank you for telling me what you are dealing with. It sounds like you don’t want to be alone now. What would help you feel at ease for the rest of the day?

C: I do want to be alone! My cat is the only one that I can deal with right now.

S: Ok, I think I understand a little better. I know of 2 programs that your insurance might pay for that would give you time alone with your cat every day. They could help you over the next few days more than I can. Would you like to hear about those services?

Illness-driven

Screener: I can only help if you tell me what is wrong with you. What symptom are you experiencing?

C: I guess I’m paranoid…

S: It sounds like your medications don’t manage your schizophrenia very well. We might be able to get you into a bed at the local psych unit.

C: But I don’t want to go to the hospital! They follow me there, too.

S: I understand, but I want you to be safe while they change your meds. Please wait while I call the insurance company.

Concurrent Documentation 8 IOM (2006), Improving the Quality of Health Care for Mental and Substance-Use Conditions.


31

Documenting services at the time and in the place they are provided is an excellent way to ensure a person-centered documentation process. Concurrent documentation gives the provider a concrete tool for inviting the person to direct the language and description of their own treatment. At the same time, concurrent documentation depends on the provider’s expertise and the form itself to keep documentation of medical necessity on track. In addition, documenting at the time of service reduces stress for providers who are often chronically behind in documenting their work. More information is available about the use of concurrent documentation in New Hampshire and Alabama in Chapter 4 of Ohio’s SOQUIC “Implementation Support Manual.” http://www.mh.state.oh.us/cmtymh/soqic/publications/soqic.implementation.support.manual.pdf

“Recovery-oriented” Documentation

Background Quality care respects the nature of recovery; a holistic and often subtle process of personal change. The following points describe some key dynamics of recovery:

1. Over time, most people are successful in their recovery from psychological trauma, disability and addiction.

2. Recovery can be sustained only if it connects to the person's experience of power and wisdom.

3. It is impossible to know the timing or path of recovery in some else's life. 4. Professional expertise and systems can support or interfere with an individual’s

recovery. The personal nature of recovery, however, cannot be changed.

In 2006, SAMHSA issued a Consensus Statement on Mental Health Recovery, which identified ten fundamental components of recovery9:

• Self-Direction • Individualized and Person-Centered • Empowerment • Holistic • Non-Linear • Strengths-Based • Peer Support • Respect • Responsibility • Hope

In 2005, The American Psychiatric Association endorsed and affirmed the application of the concept of recovery to the comprehensive care of those with mental illness:

“The concept of recovery emphasizes a person’s capacity to have hope and lead a meaningful life, and suggests that treatment can be guided by attention to life goals and ambitions.”10

9 retrieved 1-19-08 at http://mentalhealth.samhsa.gov/publications/allpubs/sma05-4129/ 10 The American Psychiatric Association, Use of the Concept of Recovery Position Statement, July 2005


32

What does “recovery-oriented documentation” look like?

Clinical and rehabilitation documents can serve to increase the person’s attention, awareness, understanding, ownership and/or responsibility for their own, culturally congruent, treatment and recovery. Illness-oriented documents, however, overlook the benefits that the individual’s power and wisdom brings to his or her treatment.


Foster the person-driven assessment, planning and evaluation of progress or need in terms of: 1) strengths and skills; 2) hope, attributes, desires; and 3) connections, supports, resources.

1. Strengths and Skills

Describe the person’s choices and actions in the past or present that are: skillful, fun, successful, productive, satisfying, etc., OR that are intentional, purposeful, executed with skill, etc., even if they do not result in a desirable outcome.

“Progress Note” Example

Person: I don’t want to meet today. I really blew it at the store last week.

Recovery-oriented

Provider: Judy at ES said that you called them for help. What happened after that?

Person: Well, not much. She said I could either go to Partial or set up more visits with my outreach worker, so I met with the worker. But then I got more anxious and couldn’t work and started Partial anyway.

Provider: Ok, so you are still on track with your plan to take care of yourself rather than blow up at work. Can you see that?

Person: No, well, yes, but it doesn’t seem that important. I still haven’t gotten the raise I wanted and I don’t even know if they’ll hold my job.

Illness oriented

Provider: Yes, ES called to say that you ended up in Partial, I’m sorry about that. Has the new medication helped with your paranoia?

Person: A little, but I still can’t go back to work.

Provider: That’s ok; we can put your work plan on hold. You have to take care of yourself and your illness first. Have to tell MassRehab about your worsening symptoms?

Person: No, I don’t want them to know. Last time I lost a job they said I had to go to a day program for 6 months before they’d help me find another one.

2. Hope, Attributes, Desires

These aspects of life are hard to pin down in words and are not generally revealed through logical reasoning. They are the beliefs, dreams, personal qualities and characteristics that a person holds fast, values, or aspires to. They motivate learning, change and action.


33

Notice & Ask: about the people, stories, music, activities, religion, etc. that inspire someone to act or that the person looks to for guidance.

“Action Planning” Examples

“I noticed that you watch the shopping channel every day. What do you like about that channel more than the others?”

“I like how fast it changes and I don’t have to remember the story.” “What made you decide to donate $50 when the fireman’s auxiliary called?” “I hope that if I give them money, they will let me volunteer.” “Your phone bills have gone down because you’re calling your sister only on weekends. How has that changed things?” “It’s easier and cheaper for me, but my sister is more stressed on

weekends.”

These can often be uncomfortable dreams, desires or attributes that are difficult for the person to deal with and/or uncomfortable for others to be around and to acknowledge.

“Psychopharmacological Progress Note” Example Person: I’m going to show that guy at work what it is like to have your co-worker stab you in the back!

Recovery-oriented

Prescriber: I’ve never heard you so angry! What are you actually planning to do and why?

Person: I’m finally going to stick up for myself. I want to show him how it feels to be accused of something I didn’t do, to be betrayed.

Prescriber: I am sorry it has been that bad at work. You have told me about so many things that you like about your job, too. How has the recent decrease in your mood stabilizer influenced this conflict with your co-worker?

Illness-oriented

Prescriber: You seem so angry! Please don’t get out of control like you did at your last job. Are you feeling safe at work?

Person: I never did anything wrong at my last job, they just didn’t like me. I dread going to work lately.

Prescriber: I am concerned that you are thinking about hurting your co-worker. I think it would be wise to increase your mood stabilizer back to where it was. Do you think this is the right job for you?

3. Connections, Supports, Resources

These are interactive aspects of life, where people encounter each other, community activities and other resources outside themselves that can help them achieve their goals.


34

“Comprehensive Assessment” Example Person: I thought we were done with the paperwork. Why do you need to know about my past?

Recovery-oriented Provider: Everyone has relationships or information from the past that they can use to help solve problems now. What people or things have helped you get to grow up and be here today?

Person: I didn’t have anything, we were poor and my dad was an alcoholic. My uncle was ok, he was a mechanic. He and my sister helped me sometimes.

Provider: Can you think of any times when you were scared or hurt and one of them helped you deal with?

Illness-oriented

Provider: We are almost done. I just have to ask you about your history of trauma and abuse. Did anything like that ever happen to you?

Person: Sure, I was abused. It’s in my chart so I don’t want to rehash it. Didn’t the last therapist tell you about all that?

Provider: I have some information, but I’d like to learn about it directly from you. Why don’t I just go over this list and you can tell me if it applies to you.

“Sustainable” Documentation

Background This section attempts to bring together concepts from the chronic disease model of care11 and the fields of sustainable environmental and economic growth12, organizational development13, cultural diversity14 and adult learning15. These diverse bodies of work all recognize the value of establishing a goal and pursuing a purpose over time and in the context of the local community. Key elements of sustainability that apply to quality mental health and addiction services and medical necessity include the following:

• Adopt a long-range perspective for planning and achieving outcomes

• Be proactive rather than crisis-driven in framing issues and supporting others

11 Flaherty presentation, etc, posted on the Great Lakes Addiction Technology Transfer Center http://www.glattc.org/ 12 Abrams, John. 2005. The Company we Keep: Reinventing small business for people, community and place. 13 Cooperrider, et al (Ed). 2000. Apperciative Inquiry: rethinking human organization toward a positive theory of change. 14 Office of Minority Health, “What is Cultural Competency?” at http://www.omhrc.gov/templates/browse.aspx?lvl=1&lvlID=3 and http://www.mind.org.uk/Information/Factsheets/ for a variety of UK-based resources and translation of MH and addiction info into multiple languages. 15 Prochaska et al. 1994. Changing for good: a revolutionary six-stage program for overcoming bad habits and moving your life positively forward. Vella, Jane et al. 1997. How Do They Know They Know? Evaluating Adult Learning. Fisher, Andy. 2002. Radical Echopsychology: psychology in the service of life.


35

• Share knowledge across organizational, class and cultural divides

• Collaborate widely to maximize diverse resources and strengths

• Depend on local expertise to direct local improvements

• Build community resources and capacity and connect them with each other

• Organize on a small scale to maintain flexibility and familiarity.

• Work to protect, reduce harm and value each individual.

What does “sustainable documentation” look like?

Documents should rest on precise, human, person-first and future-oriented language, rather than on highly specialized words and concepts that are vague or emotionally charged. Assume that the person described in the document will be the next reader, and that that person is a family member close to your heart!


Express appreciation, respect and something meaningful to the person. Describe a clear picture of time, place and interactions to other service providers, the service user and to future readers. Use specialized terms only when required for documenting medical necessity and follow up with an explanation in everyday language. Avoid terms that are vague or culturally bound, for example: “decomped/decompensated”, “a borderline”, “requires treatment/ disabled forever”, “frequent flyer”, “in denial”, “compliant” and “appropriate”. Use clarifying details when using a diagnosis or acronym. Spell things out to describe the person in the context of her/his environment: specific behaviors in a specific situation at a specific time. Answer the question “what happened?” rather than “what is wrong with this person?” Affirm the individual’s power, control and human connections in the present and the future.

“Intensive Services Progress Note” Example

Person: If I don’t get back to work tomorrow, I’ll lose my job again.

Sustainable

Provider: It sounds like what we do at the program today is really important. Tell me again, what happened that you decided to come here for treatment?

Person: I freaked out at the store and the person at emergency services convinced me to come here for a week.

Provider: If you go to work tomorrow, how would that be? Is there a chance you’d freak out there?

Person: I’d be ok if that jerk wasn’t in the office.


36

Short-sighted

Provider: I understand there is a lot of pressure at work. Does your boss know that you have a chronic mental illness?

Person: Definitely not! I’d be out the door. What are you going to tell him?

Provider: I won’t call anybody, that’s up to you. If you comply with your medications and follow your therapist’s recommendation to come to the program, I think you’ll be less paranoid when you go to the store next time. So will you agree to stay for the full week of groups?

Person: I guess so. If they fire me, they fire me. The job sucks and it doesn’t pay much anyway.

Yes, but what if…? • The person does not have any goals they want to work on?

• We have to address the person’s harmful/risky behaviors with a treatment plan and they won’t agree to it?

• I see no strengths in the person?

• The person is not able or refuses to participate in planning? Treatment and recovery progress is experienced in various ways and paces over time. It makes sense that people will not always be willing or able to express goals and make changes for themselves when providers believe they should. Someone’s choice to not use treatment or rehabilitation in obvious or active ways is not necessarily a sign that they are not engaged in recovery. When it seems that someone is not involved in their treatment, providers can create and document their own goals and objects as they relate to the person. (i.e.: action planning for providers, an excellent way to role-model). Provider interventions and planning should be aimed at: 1) increasing the provider’s positive and future orientation with the person; 2) increasing the provider’s communication with and understanding of the person; 3) increasing the person’s motivation for contemplating positive change; and 4) decreasing medical necessity. Progress for provider plans would be measured by the provider’s actions. Revisions to the plan would be based on the person’s responses and feedback. Documentation of provider plans and interventions should include recommendations and evidence related to collaboration between treatment team members and other people that the person wants involved.


37

“Action Plan Review” Example

Person: I can’t do anything about my drinking, stop asking about it.

Sustainable

Provider: I see that you are discouraged. Even though it’s extremely difficult, I have no doubt that you can do whatever you decide to do about your drinking. Being sober more often is one of the things you wanted to do on your housing and your work plans. Can we sit together at the table to look at all of your goals?

Person: Sure, if we have to.

Provider: You know you don’t have to, but I do need to write an update about your goals on these forms. The first thing I can say about your “go to work sober” goal is that you came to this meeting sober. What made you decide to do that, even though you’re feeling bad about your progress?

Person: If I didn’t show, you might have gotten me in trouble with my psychiatrist. When he gets mad, he doesn’t give me my anxiety meds and then he’ll tell my landlord I’m still a drunk. I am a looser, like my girlfriend said.

Provider: Before we look at your goals, can we write up a plan that shows what my goals and the steps are for my work with you? Then you’ll know what I want to be able to say to people about you and why, and what I have to report to certain people and why.

Short-sighted

Provider: You said 3 months ago that you wanted to be sober more often because it will help your housing and work goals. Has something changed?

Person: No, I just can’t do it. I got so drunk last week and my girlfriend called me a looser, which I am.

Provider: But that doesn’t mean you have to give up on your goals. We can revise it so that you need to stay sober 4 days a week instead of 6 days a week. How would that be?

Person: Whatever you think. Does my psychiatrist know that I went drinking last week?

Ultimately, a transformed system uses documentation tools and practices that:

• Assume people can and do recover. • Provides self-directed services and supports. • Drives treatment with the goals and values of the person. • Addresses safety issues in a collaborative relationship between the individual

and the provider. • Allows people to make, and grow from, their own mistakes.

Marcia Webster has a clinical MA degree in Expressive Arts Therapy from Lesley University. She worked for 15 years as a service provider and program manager in the MA public mental health system and as a therapist in two private schools. Along with her experience as a provider, Marcia brings her lived experience of mental health and addictions treatment to her work as a peer researcher, educator and policy consultant. Marcia is a board member of the Massachusetts Psychiatric Rehabilitation Association and currently works for The Transformation Center from her home in Western MA. Marcia produced this chapter in collaboration with CFAAC members Susan Schneider, Christopher Busby and Deborah Delman.


38

Solution Focused/Motivational Interviewing Approaches Listen to the conversation in most staff meetings today and you will invariably hear some comment about paperwork. “There is too much, it is not in line with our clinical approach, it seems just silly, repetitive, and burdensome and takes us away from providing direct work.” As the demand for evidence based, outcome supported work increases, the need for specific documentation to support our clinical work has also increased. Overlay this on an industry that is short on resources and facing an ever increasing demand for services, and the result is a profound sense of needing to move the therapeutic process along rapidly; rushing the people we serve. Feeling rushed does not enhance the therapeutic alliance we all strive for with the people we serve. We know both through research (Miller, S. 2000) and our own experience, the therapeutic alliance is a key factor in fostering a successful treatment encounter. The goals of the MSDP are to provide tools for collecting clinical information that are both relevant to our work and assists us in documenting this work in a way that supports medical necessity and compliance standards. Like most tools, if not used as intended, misuse of the forms can be counterproductive. As with other tools that support our clinical work, when we employee them, we need to remember one of the basic tenants of our training – follow the person we are serving. The founders of Solution Focused Therapy, Insoo Kim Berg and Steve deShazer, emphasized in their teaching and writing (deShazer, 1985) that the questions you ask become the focus of the work and important to the person served, therefore, we need to be very careful what we help to focus on by the questions we ask. The intake process has taken on many goals; gather and impart information, establish a contract for the work to be done, begin to build the therapeutic relationship, establish a diagnosis, determine assessed needs, establish at a minimum the beginning of working goals, and of course, complete the myriad of forms. It is important to remember that these are our (our supervisor’s, our agency’s) goals, not the goals of the people we serve. The people that we serve are coming to us for help – not to complete forms. The most efficient manner to complete the assessment forms would be to lead the person served from the start to the end, utilizing mainly closed-ended questions. But efficiency and building the therapeutic alliance are not often synchronized. To say that the balance of following the person served and gathering the information needed to fulfill all of the goals of the first encounter is challenging, is an understatement. Experience shows that gently guiding people from “what brings you here today?” to an open-ended question that helps to elicit goals (i.e. the miracle question in solution focused therapy, developing discrepancy in Motivational Interviewing), will in fact reveal a significant amount of the information needed to accomplish our goals of the first encounter while maintaining rapport. The information that is not offered/gathered as part of the narrative can always be gathered at the end, once the therapeutic alliance has been established. Machine-gunning the person with questions and avoiding reflecting listening will help you to produce a complete and thorough diagnostic assessment. However, without taking the time to


39

establish true rapport, your efforts will be in vain as the chances of the person returning for a subsequent session are greatly diminished. One Motivational Interviewing manual (Matino, S. et al, 2006) suggests using a “motivational interview sandwich outlined” in which you begin with open-ended motivational interviewing questions, move into your agency’s assessment questions, and return at the end to motivational interviewing. This approach recognizes and operationalizes the importance of balancing rapport building and remaining client-centered, with information gathering. During the intake, we must also work with the person served to distinguish between those goals that are important, and those that are important and medically necessary. Just because a goal is important to the well-being of the person and well formed, does not mean that it meets the current requirements of medical necessity and therefore will be eligible for reimbursement from Medicare and Medicaid. A reality of the work we currently do is that there is a sixth axis to the DSM – insurance/funder. As stated elsewhere in this manual, the foundations of medical necessity are found in the assessment. deShazer, S. (1985). Keys to Solution in Brief Therapy. New York: W.W. Norton and Company. Martino, S., Ball, S.A., Gallon, S.L., Hall, D., Garcia, M., Ceperich, S., Farentinos, C., Hamilton, J., and Hausotter, W. (2006) Motivational Interviewing Assessment: Supervisory Tools for Enhancing Proficiency. Salem, OR: Northwest Frontier Addiction Technology Transfer Center, Oregon Health and Science University. Miller, S. & Duncan, B. (2000). The Heroic Client: Doing client-directed, outcome-informed therapy. San Francisco: Jossey – Bass Resource: http://www.motivationalinterview.org/library/MIA-STEP.pdf


40

Satisfying Reimbursement and Compliance Requirements Clinical documentation serves many purposes, among the most important purposes are:

• Clinical: management of the treatment process, especially where a treatment team is involved.

• Provider Agency: management of best practices, utilization management and resource allocation, and utilization review, audit trail for claims to third parties.

• Payer: determination of medical necessity, covered services, and the post or pre-payment review of claims for payment.

The integrated MSDP forms were designed to enable providers to fulfill key compliance and reimbursement elements, which include:

• Medical necessity for each service provided • Documentation linkage requirements, especially the linkage of services to the plan

of treatment or action plan. • Signature and credentialing requirements to make sure all services are properly

ordered as well as provided by appropriately credentialed individuals.

The MSDP forms were developed to allow providers/programs’ to successfully meet the documentation requirements of state and federal regulations, accreditation standards, and major payers, including;

1. State Payers: Medicaid/DMA; DMH; DPH-BSAS; and DPH-HCQ 2. Managed Care: MBHP and State MCOs 3. National Accreditation: JCAHO; COA; CARF; and NCQA 4. Federal Payers: Medicaid and Medicare 5. Medicaid/Medicare Documentation Support Focus: Medical Necessity; Person


Good clinical practice and use of the MSDP documentation process will assist both providers and programs to meet payer requirements and high quality medical recordkeeping practices. The forms, when properly completed’ will substantiate diagnostic and service eligibility requirements, functional deficits where they are critical to supporting rehabilitative services, and treatment goals and treatment strategies all within an umbrella of recovery-based programming and person-centered planning.

The consistent use of the MSDP documentation across Massachusetts’ mental health and substance use disorder delivery system, positions providers/programs to mitigate reimbursement and compliance-related risk.

Medical Necessity The concept of medical necessity is a critical one for providers/programs to grasp. Medical necessity is:

A payment concept that requires that services must be both directed towards a medical problem and a necessary service in order to be reimbursable

Medicaid, Medicare and most third party payers’ standard for determining payment of claims


41

A claims based model that requires that each service on a stand-alone basis demonstrate its medical necessity

The concept is sometimes viewed as applicable only to a medical model. However, Medicaid and Medicare both insist that rehabilitative as well as recovery-based services that they pay for meet these standards as well.

Medicaid Definition of Medical Necessity Medical necessity starts with a practitioner who based on a comprehensive evaluation of an Individual determines that the Individual has a mental health or substance disorder AND either current signs and symptoms or current problems with daily functioning caused by the impact of their disorder/illness that are necessary in order to help the individual recover from or better manage their disorder/illness. Key here for purposes of medical necessity is an understanding of payer rules (and they often are different) as to who can diagnose mental illness and substance use disorder and who can order services. Most payers will rely minimally on state licensure laws that determine scope of practice for each license but in some cases payers will require more experience and higher credentials than even state law. If the service is not ordered by the appropriately credentialed person the first test of medical necessity is not met.

For example:

A social worker cannot order medication management services to be provided by a physician. They cannot by state law either provide or supervise medication management services and so, therefore, cannot determine if these services are medically necessary.

The second test of medically necessary services is that they must be considered to be reasonable and generally effective for the specific diagnosis and clinical picture of the individual. They must help them either get better, prevent them from getting worse, or prevent new problems that are threatened by the Individual’s diagnosis(es). Services, therefore, must be directed at signs and symptoms or functionality that is directly related to the diagnosis. So, for example, Medicaid will not pay for general parenting training because this service would not be considered to be specific to a particular diagnosis or generally considered to be effective for treatment of a mental illness or substance use disorder. Medicaid will, however, pay for specific parenting training that is directed at how parenting must change in order to manage or support a child with a particular diagnosis.

The third test of medical necessity is that the service provided be a covered service under the insurance benefits package the Individual has. All payers define their service packages and services that are therapeutic but are not covered because they are not considered to be medically necessary.

In order to meet the conditions above, Medicaid is also concerned that payer documentation support that the services are: • Delivered at an intensity that is appropriate and that will likely be effective • Provided in the lowest level of care that is reasonable and safe

Please also remember that diagnostic services must also be medically necessary and the services ordered to assist in a diagnostic assessment period must be capable of providing unique, essential and appropriate information that cannot be obtained in an interview process. This would include services like, psychological testing, neurological consults, lab work, etc.


42

Medicaid Criteria for Payment of Medically Necessary Services Even though a service may be medically necessary, it may still not be reimbursable. Criteria that Medicaid uses to determine whether medically necessary services can be paid include:

Outpatient services are voluntary and initiated by the Individual , or the Individual’s family/guardian (Note: Payers believe with some justification that people who come freely to services and are actively involved in developing their individualized action/service plans are more likely to participate actively in their treatment and to comply with their treatment regimen.) In some cases, inpatient admissions can be involuntary and these criteria would not need to be met.

The Individual’s right to select both the provider agency and the specific providers of their choice. Again, this promotes the active participation of the person served in his/her own care and is a fundamental right addressed in the State Medicaid Manual. In some cases, as in Massachusetts, federal Medicaid waives the requirement for absolute choice by allowing managed care entities to limit their provider pools.

The services are provided by an eligible provider. In addition to ordering the service, an eligible provider must also render the service. (Note: Most payers list the credentials they require for the provider of each service covered under their benefit plans. For most payers credentials include a combination of licensure (if required), education, and experience. Providers are expected to comply with these credentialing requirements as a condition of payment.)

The service must be provided in compliance with the Medicaid definition for the service as defined by the eligible service codes in the CPT or HCPCS code books. Although some states have been quite liberal in their use of a code and expanded on some definitions, providers should be careful to maintain internal coding integrity.

The service must be the lowest cost service that effectively addresses the problem of the person served.

Medical Necessity in Mental Health and Substance Use Disorder Services In Massachusetts the state Medicaid agency is the Department of Medical Assistance. They define medical necessity as follows:

450.204: Medical Necessity

The MassHealth agency will not pay a provider for services that are not medically necessary and may impose sanctions on a provider for providing or prescribing a service or for admitting a member to an inpatient facility where such service or admission is not medically necessary.

(A) A service is "medically necessary" if:

(1) it is reasonably calculated to prevent, diagnose, prevent the worsening of, alleviate, correct, or cure conditions in the member that endanger life, cause suffering or pain, cause physical deformity or malfunction, threaten to cause or to aggravate a handicap, or result in illness or infirmity; and

(2) there is no other medical service or site of service, comparable in effect, available, and suitable for the member requesting the service, that is more


43

conservative or less costly to the MassHealth agency. Services that are less costly to the MassHealth agency include, but are not limited to, health care reasonably known by the provider, or identified by the MassHealth agency pursuant to a prior-authorization request, to be available to the member through sources described in 130 CMR 450.317(C), 503.007, or 517.007.

(B) Medically necessary services must be of a quality that meets professionally recognized standards of health care, and must be substantiated by records including evidence of such medical necessity and quality. A provider must make those records, including medical records, available to the MassHealth agency upon request. (See 42 U.S.C. 1396a(a)(30) and 42 CFR 440.230 and 440.260.)

(C) A provider's opinion or clinical determination that a service is not medically necessary does not constitute an action by the MassHealth agency.

What this means in operational terms is that:

1. The individual must have one or more diagnoses – either ICD-9 CM or the latest version of the DSM and that diagnosis must currently “endanger life, cause suffering or pain, cause physical deformity or malfunction, threaten to cause or to aggravate a handicap, or result in illness or infirmity”. In other words, a diagnosis is not enough. There must be manifestations of the diagnosis in the clinical picture of the individual for services to be medically necessary.

2. The services provided must be the lowest cost and most conservative that are both appropriate AND available.

3. The services or help provided by the mental health or substance use disorder systems of care can be directed towards: a. Diagnosing mental illness or substance use disorder. b. Preventing the worsening of the diagnosed illness. c. Alleviate the symptoms or other manifestations of the diagnosed illness. d. Correct or cure the diagnosed illness.

4. The service must be documented in a medical record that is available to Medicaid for review.

Medical Necessity and Recovery

Recovery-based service models with their rehabilitative focus also must meet medical necessity criteria if they are going to be billed to a third-party payer who covers rehabilitative services. Federal Medicaid law defines a rehabilitative service as “any medical or remedial services (provided in the facility, a home, or other setting), recommended by a physician or other licensed practitioner of the healing arts, within the scope of their practice under State law, for the maximum reduction of physical or mental disability and restoration of an individual to the best possible functional level.”1 Medical necessity, therefore, is not just based on diagnosis (with its attendant signs and symptoms) but also on functional criteria. This federal definition is very compatible with the description of the Rehabilitation Model found in the IAPSRS2 publication, Best Practices in Psychosocial Rehabilitation. This rehab model “focuses on the functioning of the individual in the normal, day-to-day environment, and looks at the strengths and skills people bring to the rehabilitation


44

process and supports in the community. Although an individual may still be symptomatic, the rehabilitation process helps a person learn ways to compensate for the effects of the mental illness through environmental supports and coping skills. The person with the mental illness becomes the expert in managing the disability.”3

Both the federal and IAPSRS definitions focus on improving the functioning of the individual. Both also make it clear that the services are directed toward keeping the person served in the community setting and, therefore, contemplate the necessity for services to be provided in multiple settings in order to maximize benefit to the person. In addition, the IAPSRS definition stresses the active participation of the person served. The person served must actively participate in the development of their individualized action/service plan and they must become the experts in their own recovery. IAPSRS is also specific about their expectations of benefit to the person served, using a strengths-based model to promote: • Greater functionality • Independence • Integration into their community and support network

The rehabilitation option model, therefore, uses a functional test as the base for a medical necessity determination for covered services, and then adds the generally accepted criteria of benefit, participation and individual planning.

What is clearly very important about the rehabilitation option and its coverage by Medicaid is the difference in the approach to services and the impact this has on the overall model of care. For example: Recovery is a holistic treatment process that deals with all aspects of a person’s life. Under this model, the person served becomes knowledgeable about his/her mental illness/substance use disorder, works with other community and environmental supports toward self-defined realistic goals, and eventually manages his/her mental health/substance use disorder. Community providers support the person’s efforts using their training, research and knowledge.

Some of the services included in a recovery model are not reimbursable under the Medicaid program’s rehabilitation option, or under most third-party payers’ benefit plans. Providers must be clear about which services: • Do meet Medicaid criteria and, can be appropriately billed • Do not meet Medicaid criteria and, therefore, must be funded by alternative sources.

In particular, Providers should pay attention to state and federal regulations and service definitions about educational, vocational, recreational, social, and peer services.

The Massachusetts Department of Mental Health has been a vocal advocate of recovery models of care and has used its array of resources to support the development of these models. Medicaid is one of these resources that, with judicious use, can assist persons served and providers in making recovery/resiliency programs possible.

Medical Necessity and Provider Documentation

One of the primary means for determining medical necessity is the review of the provider’s documentation. The “big three” areas of documentation that support medical necessity are the


45

1. diagnostic assessment and any updates or additional diagnostic testing done at the outset or during the treatment episode,

2. the Individualized Action Plan and any reviews, updates or modifications, 3. each and *every progress note which must describe an ordered, covered service

that is necessary to realize the clinical outcomes of treatment.

Together, all of these documents make the initial and continuing case for the medical necessity of the services being delivered and billed. Documentation is a requirement of all payers, and in particular, all Medicaid/Medicare providers are required to keep such records as are necessary to establish medical necessity and to fully disclose the basis for the type, extent, and level of the services provide. In reviewing documentation for medical necessity, the reviewer looks for key elements in the documentation, such as the following:

1. Is there a diagnosis that meets payer criteria? Is there sufficient documentation in the initial assessment or additional diagnostic work that provides evidence that this is the correct diagnosis?

2. Is there an assessment of functioning for the person served? Are there sufficient symptoms, behaviors and functional deficits or the threat of developing deficits to support the level of care ordered?

3. Is there an Individualized Action Plan, signed by the appropriate provider, for an array of services that are generally accepted as being appropriate for the diagnosis and functional level of the person served?

4. Are the services rendered in accordance with the Individualized Action Plan and with payer definitions? This is called “active treatment” and includes the requirement that services are rendered by the appropriately credentialed provider.

5. Is there evidence of participation by the person served? There are two issues here. First, the person must have the cognitive ability to be able to participate in treatment and to benefit from it. And, second, the person served must be willing to participate in treatment and, therefore, benefit from it. For example, persons with early Alzheimer’s may be able to benefit from talking therapies for depression and other mental illnesses until their disease has progressed to the point where there is no potential for therapeutic progress. Individuals with severe or profound mental retardation are generally not covered for talking therapies either but can be covered for medication management if warranted and medically necessary to control behaviors. In any case where services that are not “generally accepted” as beneficial to a person served with certain diagnoses are being provided the practitioner should expect that auditors and payers will expect an explanation and will look for it in the clinical documentation.

6. Is the person “committed” to outpatient treatment? This is very different than a situation where a judge tells an Individual that they can choose between jail or treatment and are effectively being coerced into treatment. In these cases, medically necessity must be determined independent of any court decision or recommendation for a third party payer to be billed. A commitment to outpatient treatment is different than the choice between jail or treatment. In these cases the Individual chooses one form of treatment over the other and there is usually sufficient evidence of the need for mental health services. And, so even though the court stands behind the individual with powerful punitive tools should the Individual be non-compliant, services can still be considered voluntary and therefore eligible for third party reimbursement.


46

7. Is there evidence that the person being served is actually benefiting from treatment? This is a critical issue in medical necessity. Most services are directed towards improving the health status of an Individual. Medicaid and other third party payers want to see that improvement recorded in the medical record or want to know why they should be continuing to pay for services that do not appear to be effective. There is also a concept in medical necessity that considers situations where, especially with significant chronic conditions, where services may be primarily directed towards the prevention or the slowing down of further deterioration and the need for higher levels of care. However, again there must be evidence in the medical record that these “maintenance” services are necessary and that they constitute the lowest cost service for this individual and their particular clinical picture.

The forms developed by MSDP have been designed to encourage the complete and accurate documentation of the diagnosis/condition, functional level and/or deficits, treatment goals, and level of care decision-making for the person served. There are cues to remind providers to document the individual’s participation and benefit from treatment. And, there are places for providers to sign, date, code, and time the interventions so they may be appropriately and accurately billed. As with all forms, they cannot make up for sloppy or inadequate content, but they do help the writer organize their information in ways that make it easier for reviewers to locate and to determine medical necessity. MSDP Forms Support Medical Necessity

The MSDP forms are an integrated documentation toolset that is designed to: Facilitate the complete and accurate documentation of the condition, functional level

and/or deficits, treatment goals, and level of care decision-making for the person served.

Provide linkage between the Comprehensive Assessment, the Individualized Action Plan and the Progress Notes, as well as the Comprehensive Assessment Update and Individualized Action Plan Review/Revision to demonstrate on-going progress and medical necessity.

Contain cues to remind providers to document the participation and benefit from treatment for each person served.

Contain fields for providers to date, code, and time stamp the interventions so they may be appropriately and accurately billed.

Contain fields for all required signatures and credentials of individuals authorizing/recommending treatment and action plans.

_________________________________ 1 Social Security Act, Section 1905(a)(13) 2 International Association of Psychosocial Rehabilitative Services 3 Hughes, R. and Weinstein, D. editors, Best Practices in Psychosocial Rehabilitation, IAPSRS, 2000, p. 42.


47

Medical Necessity Documentation Linkage Requirements (Note: Reprinted with permission from Chapter Seven of How to Deliver Accountable Care written by David Lloyd and published by the National Council of Community Behavioral Healthcare) The common thread of concern and findings within qualitative audits is that the documentation model utilized does not continuously support the need for the intensity, frequency and duration of the service(s) being provided to the Medicaid and/or Medicare eligible person. A key issue in the audit findings is the lack of a link (Golden Thread of Necessity) between the assessed therapeutic needs that result in specific goals supported by measurable objectives with specific therapeutic interventions ordered to be provided by specific clinicians within specific service modalities/locations (outpatient individual, group, IOP, Residential, Psychopharmacology, etc.) within the provider organization. The Five major linkage processes that are designed into the MSDP form documentation system to support compliance with qualitative reviews are identified below. 1. Comprehensive Assessment (CA) – Identifies Treatment Recommendations/

Assessed Needs 2. CA Updates – Identifies New Treatment Recommendations/ Assessed Needs 3. Individualized Action Plan (IAP) – Links goals to specifically numbered Treatment

Recommendations/Assessed Needs 4. IAP Review/Revision - Links goals to specifically numbered Treatment

Recommendations/Assessed Needs and/or changes in Objectives, Therapeutic Interventions, Frequency, Duration and/or Responsible Type of Provider.

5. Progress Notes – Links interventions being delivered to specific Goal(s)/Objective(s) and identified client response and outcomes/progress towards Goal(s)/Objective(s).

Each of these primary documentation processes should be designed and implemented at the same time within the community provider organization in order for each of them to serve as very important support for medical necessity linkage requirements. Outlined below are the primary linkage and support functions for each process: Purpose of Comprehensive Assessment in Medical Necessity Linkage Requirements

1. Establishes a baseline measurement for the Symptoms, Behaviors, and

Skills/Needs Deficits of the person served and documents how each of these areas impact the person’s ability to function, which is the basis for developing the individualized action plan.

2. The more specific/objective the information gathering process during the assessment, the easier it is to demonstrate the necessity for treatment.


48

3. Use of standardized assessment tools (BASIS 32, CAFAS, ASI, GAF, etc.) in conjunction with initial assessment will help support the assessed functioning baseline and help justify continued necessity.

4. The assessment contains an integrative summary of prioritized therapeutic treatment needs of the person served that can be the only supportive medical necessity basis of goals in the action/service plan.

Figure 1 below provides the Treatment Recommendations/Assessed Needs section of the MSDP Comprehensive Assessment and the CA Update forms is illustrated below: Figure 1:

Purpose of Comprehensive Assessment Updates In Medical Necessity Linkage Requirements The key “dis-link” observed in the typical chart is the lack of current, continuous updates of newly assessed therapeutic needs identified by the person served and/or direct care staff after the initial comprehensive assessment is completed. In many cases the Progress Note has been used to record any additional assessed needs after the initial assessment is completed which makes it the “primacy” documentation in the chart. The challenge with the Progress Note being the primacy documentation tool in the chart is that it is very difficult to demonstrate to reviewers the qualitative assessed basis for the services ordered in the IAP if the additional assessed needs are buried in hundreds of Progress Notes. The Progress Note is not designed to support the qualitative weight and data elements needed to provide an updated assessment of treatment needs/’recommendations, diagnostic changes and a prioritized summary of assessed therapeutic needs and justification for treatment that can be linked to Goals in the Individualized Action Plan. The standardized CA Update (adult and child versions) is an appropriate assessment form to record additional assessed information after the treatment process has begun that will provide a direct link between the assessed therapeutic need and the goal(s) in the Individualized Action Plan.


49

Purpose of Individualized Action Plan and IAP Review/Revisions in Medical Necessity Linkage Requirements

1. Goals: Utilizes assessed prioritized therapeutic needs from the comprehensive

assessment (or subsequently dated CA Updates) to link to a corresponding goal in the IAP. The Goal linkage section from the MSDP Individualized Action Plan is shown below (Figure 2). As indicated, each numbered Goal in the IAP can be specifically linked to a numbered assessed Treatment Recommendation/Assessed Need from the Comprehensive Assessment, or CA Update, or Risk Assessment or Initial Psychiatric Evaluation. The linkage occurs by entering the Treatment Recommendation number, form date and checking the specific MSDP form type adjacent to the specifically numbered Goal. Each goal needs to reflect the person served desired outcome for the assessed therapeutic needs. (i.e., if the assessed therapeutic need is anger management, the person’s desire may be, “I would like to stop losing my cool all the time!” and this desire, in the person’s own words, becomes the basis of a goal in the action plan.

Figure 2

By establishing this link to the Treatment Recommendations/Assessed Needs from the Comprehensive Assessment/CA Update(s), the IAP fully supports an integrated clinical formulation that effectively addresses the assessed symptoms, behaviors and functional needs of the person served.

2. Objectives: Develops measurable Objectives that support step by step attainment

of each goal. Objectives that end in “ing” (i.e., “increasing”, “decreasing”, or “improving”, etc.) usually do not have the ability to specifically measure attainment. Perhaps the best and most humorous example of the need to develop very specific and measurable objectives was a handwritten notation from an auditor beside of an objective that read “Improving client’s relationships”. The auditor’s note read “With NATO? With Mexico?” Difficult to know if and when the objective was achieved. In training staff, the concept of writing very specific objectives produces a level of anxiety in that in many cases objectives have historically been more general/non-measurable, which has provided a lower goal/objective attainment rate. The more the Goal in the plan is formulated to be a broad long term achievement effort, the more objective and measurable the objectives supporting that goal need to be in order to show attainment and benefit to the person served from the services provided to support ongoing Medical Necessity determination. Figure 3 provides the MSDP IAP Objective Section that includes the measurable/attainable objective, the start date and duration, efforts the person


50

served will take, his/her family/others, if clinically appropriate, the therapeutic intervention methods (see item three following), the service description/modality, frequency and providers responsible.

Figure 3:

3. Therapeutic Interventions Methods: The concept of documenting specific therapeutic interventions as the method that will be used to support attainment of each Objective seems to create a significant change in practice. In many cases, Therapeutic Intervention Methods and Services have been used interchangeably. The service such as individual therapy is not the intervention method, but rather the service location/modality that is being ordered in the plan where the therapeutic interventions will be provided. The ability to order specific interventions in the clinical formulation of the Individualized Action Plan provides needed support/clinical guidance to provide and document the specific therapeutic interventions provided in the structured Progress Notes. This linkage from the progress note to the IAP is a critical Medical Necessity documentation linkage requirement. (i.e., If the assessed therapeutic need is Anger Management as evidenced by…, and the corresponding Goal in the plan is, “Like to stop losing my cool all the time”, and the measurable Objective is “Reduction of anger episodes per week from 10 to 7 based on person’s self report”, then the therapeutic intervention could be, “Help consumer identify anger triggers”. The ordered service (location) could be Outpatient Therapy or Anger Management Group, etc.

4. Services: The IAP will serve as the order for therapeutic interventions and

services if the following elements are incorporated:

a. Goals and Objectives with start date and target date of completion b. Service Code or Descriptor link to specific therapeutic interventions for

each Objective c. Disposition to specific Clinical staff with appropriate credential to deliver the

ordered interventions in the service location/type ordered d. Indication of Frequency and Duration of Services ordered


51

Purpose of IAP Review/Revision in Medical Necessity Linkage Requirements In many cases the Progress Note has been considered an adequate IAP Update. When the need to utilize an IAP Review/Revision is presented, numerous times staff will respond, “It’s in the Progress Note and, therefore, it is in the Chart which has been good enough in the past!” Typical historical quantitative audit standards perhaps allowed the practice of “if the documentation is in the chart that is adequate”, however, qualitatively if the intervention being provided is not linkable to a specific objective and goal in an Individualized Action Plan (or subsequently dated IAP Review/Revision) then it is not ordered and not reimbursable. Therefore, the use of an IAP Review/Revision is essential with the usual reasons for use being:

1. Attainment of Goal and/or Objective that requires the development of an additional Goal(s) or Objective(s)

2. Need to increase the Frequency and/or Duration of an ordered intervention 3. Need to modify or add therapeutic interventions in number or intensity 4. Need to modify or add an ordered service/modality

The standardized IAP Review/Revision form is a critical part of maintaining a Medical Necessity Linkage between the assessed therapeutic need and the documentation of the interventions provided that are appropriately linked to a specific goal(s)/objective(s). Purpose of Structured Progress Notes In Medical Necessity Linkage Requirements

The Progress Note provides an opportunity to provide specific linkages between the therapeutic interventions provided in the service to the IAP (IAP Review/Revisions) by requiring that the Goal(s) and Objective(s) being addressed in the service session be clearly identified within the note. In many cases, staffs have indicated their inability to record the specific Goal(s)/Objective(s) they are addressing in the Progress Note as a result of not having the IAP available or completed. Again the practice of providing services without a plan and/or without the ability to link the interventions provided in the session to specific Goal(s) and Objective(s) in the IAP seemed to meet most quantitative review requirements. However, in most cases this practice does not meet current qualitative reviews criteria. The MSDP standardized structured progress notes for individual psychotherapy, group psychotherapy, psychopharmacology services, nursing services, intensive service activities, etc. have been designed to address the need for specific elements of information that to be recorded on each note. Figure 4 provides the critical linkage portion of the standardized Progress Notes which is the section entitled “New Issues Presented Today”. If the person served shares totally new information with the clinician that was not included in the original assessment and the clinician assesses that the information shared constitutes an ongoing therapeutic need then one of two actions is required:


52

Figure 4:

This section of the Progress Note provides two check box indicators - “None Reported” and “CA Update Required,” that are to be used as follows:

1. If the person served does not share any new information/issues at the session being documented, check “None Reported”.

2. If the person served shares new information/issues during the session that are assessed by the clinician to not constitute a continuing treatment need, record the information in this section of the Progress Note. The CA Update is not required.

3. If the person served shares an issue that can be resolved within the session of service, briefly identify the issue, indicated the interventions provided and the response in the appropriate sections of the Progress Note.

4. If the person served shares new information/issues during the session that were not included in the original Comprehensive Assessment, (or an earlier CA Update), and the clinician determines that the information shared does constitute a continuing treatment need, the linkage requirements are:

a. Indicate on the Progress Note that person has self-reported new information as “recorded on the CA Update”. The new information provided by the person served should be recorded on the CA Update by checking the appropriate element of the Assessment that is being updated, then writing the element and the information in the open narrative section of the form. Figure 5 provides this section of the CA Update. Figure 5:

Figure 6 below provides the important linkage element on the second page of the CA Update which provides a place to record the Prioritized Assessed Needs with Justification for Treatment or indicate that there are no additional recommendations clinically indicated.


53

Figure 6:

Figure 7 provides a linkage section to cue the clinician to determine if an existing Goal(s) and Objective(s), therapeutic interventions, services/modalities, provider type, duration and frequency addresses the newly identified assessed therapeutic needs. If yes, then the clinician should go back to the Progress Note and check the appropriate Goal and Objective and provide interventions ordered.

Figure 7:

b. If there is not an existing Goal and Objective that meets the newly assessed needs or if an existing Goal and Objective needs to be changed/revised to add new interventions, service/modalities, frequency, responsible staff, duration, etc. then clinician can complete an IAP Review/Revision. The newly created Goal and Objective(s) in the IAP Review/Revision can be noted on the Progress Note as interventions are delivered for the newly created Goal/Objective(s).

MSDP Integrated Documentation Approach In addition to the primary link based clinical documentation processes, there are several others that were simultaneously developed by the MSDP Standardized Documentation Team to ensure that appropriate linkages are designed into the total documentation process. Each process is supportive of another and the total clinical documentation process is utilized to continuously document support for and an update of Medical Necessity. The documentation processes that constitute the MSDP forms model are outlined below:

1. Personal Information 2. Adult Comprehensive Assessment (CA) 3. Adult CA Update 4. Child/Adolescent Comprehensive Assessment (CA) 5. Child/Adolescent CA Update 6. Mental Status Exam 7. Risk Assessment 8. Initial Psychiatric Evaluation 9. Tobacco Assessment 10. HIV Risk Assessment 11. Physical Health Assessment 12. Individualized Action Plan (IAP) 13. IAP Review/Revision


54

14. Psychopharmacology Plan 15. Detox Plan 16. Multi-Disciplinary Team Review/ Response 17. Transfer/Discharge Summary and Plan 18. Consultation/Collateral Contact Progress Note 19. Group Psychotherapy Progress Note 20. Health Care Provider Orders Progress Note 21. Intensive Services Progress Note 22. Monthly Progress Note 23. Outreach Services Progress Note 24. Psychopharmacology Progress Note 25. Psychopharmacology/Psychotherapy Progress Note 26. Psychotherapy Progress Note 27. Nursing Progress Note (Long) 28. Nursing Progress Note (Short) 29. Shift/Daily Progress Note 30. Weekly Services Progress Note

The structured nature and documentation linkage capacity of each process shifts the emphasis from recording narrative summaries with the hope that each clinician/direct care staff will remember each time he/she documents to an integration of recording each required element using an objective check off/short narrative that supports the documentation linkage needs.


55

Signature Requirements Matrix for MSDP Documentation Process Each Provider Agency must independently determine its own policy and procedures regarding signature requirements for each of the MSDP forms. Most of the forms provide for multiple provider and/or supervisory signatures to accommodate Provider Agencies’ internal policies/procedures. (See MSDP Signature Matrix at the end of this section as well as various payer rules for different types of services) The development of each form was guided by state and federal regulations as well as the standards of the major accrediting bodies in allowing for provider, person served, and supervisory signature lines. Signature Instructions

Signature instructions for all forms universally require a legible signature. This is critically important. Federal and state auditors will throw out perfectly good claims on an audit if they cannot determine who provided the service. Additionally, day-to-day practice requires an understanding of who had an interaction with a person served, and subsequently entered information into the medical record. JCAHO standards require that Provider Agencies develop a register of provider names and their signatures in order to be able to identify particularly obscure or sloppy signatures. (This is good practice regardless of your accrediting body.) Additionally, signature instructions universally require that a provider’s or supervisor’s signature be accompanied by their credentials and the date of the signature. This is both a payer/payment issue, as well as a risk management issue.

• Most states have laws regarding the licensure of professionals and the services or service array they are eligible to provide as a result of their licensure.

• Some states may issue certification requirements or licensing requirements for facilities that also are concerned with the credentials of providers and the services they are allowed to provide.

• Most payers have very specific standards for the type of provider credentials they will allow to reimburse for specific services.

• In many cases, both the state and the payers have similar requirements. In some cases, payer standards are more stringent than state law or may cover providers who are not the subject of state laws, such as paraprofessionals. In those cases, payer rules must be followed in order to bill for a service.

• Provider Agencies may issue their own requirements that exceed and state and payer requirements, but cannot allow for lesser credentials.

Signature instructions also require that each provider date their signature. This may or may not be the date of service. Providers should not, under any circumstances, back-date their signature to match the date of service. Credentials Instructions

In listing the credentials of the Provider, it is recommended that the following generally accepted conventions apply:


56

1. If the Provider is licensed, he/she should list next to his/her name the highest level of

licensure achieved that is related to the service being recording. For example; if an individual who is an RN, and is also an independently licensed social worker, is providing psychotherapy, then social work credentials would be recorded. If a medical-somatic service is being provided, the RN credentials would accompany the signature.

2. If the Provider is not licensed and the service requires a certain educational degree, record the degree, e.g. B.A.S.W., B.S.R.N., B.S.

3. If the provider is not licensed and the service requires specialized training and certification, record the certification, e.g. CADAC.

4. If the Provider is not licensed and the service requires that the provider have a certain amount of educational or specialized training or experience that is not easily recorded as credentials, then agency policy/procedure should be followed regarding the credentials that should accompany the signature. For example: “The provider must have 2 years of experience in providing services to the seriously mentally ill population.” In many cases, the provider should also list or abbreviate his/her job title; such as, CSW or Community Support Worker, CM or case manager, DSWI or DSWII or Direct Service Worker Level I or II. Providers are encouraged to consult state laws, regulations and certification standards to define internal policy for signatures and credentials required to authorize services. In all cases where licensure, training, education, and/or experience are required, the documentation that provides proof of this should be kept in the Provider Agency’s personnel files and available to auditors.

Using the MSDP Signature Grid

The MSDP forms contain multiple signature lines to accommodate multiple signature possibilities. The MSDP Signature Grid is intended only to show the signatures that each form accommodates. The signatures required on the forms are determined by rule, licensure and scope of practice. In general, the provider authorizing and delivering a service is required to sign the clinical documentation for that service. Providers may “order” services only for those services for which they are licensed. Certain services, if provided by paraprofessional staff, must be reviewed and signed for by the supervisor. Person served and/or family signatures are required by DMH and many of the accrediting bodies on Individualized Action Plans and are suggested as a good practice for all persons served. New rules issued by federal Medicaid indicate that they are also very interested in the Individual’s signature and their participation in developing the action plan and this may soon be a federal requirement. Obtaining signatures from the person served on Comprehensive Assessments, CA Updates, Individual Progress Notes and Group Progress Notes are suggested as a good practice. For further clarification on signature requirements refer to: • The Compliance Grids (see Appendix) • The appropriate regulations or accrediting body standards. • Your agency’s policies on signatures


57

Grid Key: XO = Optional Signature for Person Served and Family/Parent/Guardian XR = Required signature for Person Served X = Signature space provided on form type as per appropriate regulations/ standards/local

policies

Type Form

# Form Name

Pers

on S

erve

d

Fam

ily/P

aren

t/ G

uard

ian

Prov

ider

Co-

Prov

ider

Prov

ider

Ren

derin

g D

iagn

osis

Supe

rvis

or

Nur

se

Phys

icia

n/A

PRN

Assessment 1 Adult Comprehensive Assessment (CA) XO XO X X X Assessment 2 Adult CA Update XO X X X Assessment 3 Initial Psychiatric Evaluation X X Assessment 4 Mental Status Exam X X Assessment 5 Tobacco Assessment X X Assessment 6 Personal Information X Assessment 7 Physical Health Assessment X X Assessment 8 HIV Risk Assessment X X

Assessment 9 Child/Adolescent Comprehensive Assessment (CA) XO XO X X X

Assessment 10 Child/Adolescent CA Update X X X Assessment 11 Risk Assessment X

Treatment Plan 1 Individualized Action Plan (IAP) XR XO X X X X Treatment Plan 1a Objective Sheet X Treatment Plan 2 IAP Review/Revision XR XO X X X X Treatment Plan 3 Psychopharmacology Plan XR XO X X X X Treatment Plan 4 Detox Plan XR XO X X X X Treatment Plan 5 Multi-Disciplinary Team Review/ Response X X X X

Progress Notes 1 Outreach Services Progress Note XO X X

Progress Notes 2 Consultation/Collateral Contact Progress Note

X

X

Progress Notes 3 Group Psychotherapy Progress Note XO X X Progress Notes 4 Intensive Services Progress Note X X X X Progress Notes 5 Monthly Progress Note X X Progress Notes 8 Psychopharmacology Progress Note X Progress Notes 9 Psychotherapy Progress Note XO X X X

Progress Notes 10 Psychopharmacology/Psychotherapy Progress Note

X X

Progress Notes 11 Shift/Daily Progress Note X X Progress Notes 12 Weekly Services Progress Note X X Progress Notes 13 Nursing Progress Note (Long) X X Progress Notes 14 Nursing Progress Note (Short) X X Progress Notes 15 Health Care Provider Orders Progress Note X

Transition 1 Transition/Discharge Summary and Plan X X X X


58

MSDP Process Billing Strip Instructions

Below are the instructions for completing the Billing Strip on all MSDP09 forms. Individual sections of the Training Manual will not repeat these instructions. Standard Billing Strip Sample:

Date of Service

Provider Number

Loc. Code

Prcdr. Code

Mod 1

Mod 2

Mod 3

Mod 4

Start Time

Stop Time

Total Time

Diagnostic Code

Instructions to complete the Billing Strip:

Data Field Billing Strip Completion Instructions

Date of Service Date of session/service provided Provider Number Specify the individual staff member’s “provider number” as defined by the

individual agency.

Location Code Identify Location Code of the service. Providers should refer to their agency’s billing policies and procedures for determining which codes to use.

Procedure Code Identify the procedure code that identifies the service provided and documented. Providers should refer to their agency’s billing policies and procedures for determining which codes to use.

Modifier 1, 2, 3 and 4

Identify the appropriate modifier code to be used in each of the positions. Providers should refer to their agency’s billing policies and procedures for determining which codes to use for Modifiers 1, 2 3 and/or 4.

Start Time Indicate actual time the session started. Example: 3:00 PM Stop Time Indicate actual time the session stopped. Example: 3:34 PM Total Time Indicate the total time of the session. Example: 34 minutes Diagnostic Code Use the numeric code for the primary diagnosis that is the focus of this

session. Providers should use either ICD-9 or DSM code as determined by their agency’s billing policies and procedures.


59

General Medicare “Incident to” Services Only Information Medicare provides for payment for certain services that are provided “incident to” the services of a physician or “certain non-physician practitioners such as clinical psychologists, nurse practitioners, clinical nurse specialists, and physician assistants”.

Incident to services are those that are integral to the services of the professional but are not provided directly by them. This allows in certain cases for providers not eligible to bill Medicare directly to bill for their services provided under the direct supervision of an eligible supervising professional.

There are a number of rules that must be followed in order to bill services “incident to” and the Medicare Carrier for Massachusetts, NHIC should be contacted in order to make sure all requirements can be met.

One of the most important of the incident to rules is that each and every service must be provided under the “direct” supervision of a Medicare eligible professional. These professionals can only supervise services they can either provide or supervise under their scope of practice under state law. They must also be available and in the office suite at the time the service is provided.

The MSDP forms allow for the provider to document compliance with the direct supervision rule with a checkbox to alert billing that the service was provided “incident to” and the name and credentials of the supervising professional. Medicare will be easily able to audit compliance with this requirement and providers will have sufficient back up for the claim. Below are the MSDP forms that contain the Medicare “Incident to” checkbox:

1. Group Psychotherapy Progress Note 2. Psychotherapy Progress Note 3 Intensive Services Progress Note 4. Nursing Progress Notes

Standard Medicare “Incident to” Services Only box:

Medicare “Incident To” Name and credentials of Medicare Provider on Site:

Instructions for Completing the Medicare “Incident to” Services Only Box

Data Field Billing Strip Completion Instructions Medicare “Incident To” Services Only

Check the box when service is to be billed using the “incident to” billing rules.

Name and credentials of Medicare Provider on Site:

Enter the name of the supervising professional who provided the on-site supervision of the “incident to” service. Note: The presence of an appropriate licensed supervising professional is one of the key requirements for an “incident to” service. In some cases, the service is billed under the number of the supervising professional. In others, the attending professional’s number should be used. Providers should consult with their Medicare Carrier’s Local Medical Review Policies.


60

MSDP Compliance Grids

Compliance Review Team Develops Data Element Grids to Support Form Development Process The Reasons for the Compliance Grids The Compliance Grids can be found in Appendix A of the Manual. The Compliance Grids were developed by the MSDP Compliance Review Team (CRT) as a way to monitor development of the clinical forms. The Compliance Review Team was charged with ensuring that the forms once completed would allow a provider to successfully meet the clinical documentation requirements of the major accreditors: JCAHO, CARF, COA and NCQA, as well as the documentation requirements of the major payers for community mental health and substance use disorder services in the Commonwealth of Massachusetts. Although every private payer was not consulted, the CRT believes that the Medicare standards also fairly represent the documentation requirements of many commercial payers who use Medicare’s guidelines for their audit standards.

The compliance grids list the areas of information that need to be documented within each MSDP form type and provide information on which payers and/or accreditors require the information for clinical documentation purposes. These grids look only at the actual standards or regulations, they do not consider quality of the documentation or other indicators that might also create audit risk for agencies and providers. Accreditors are generally looking at clinical documentation for evidence that provider agency policies and procedures related to documentation and also clinical care of the persons served are being followed and are resulting in quality care and positive clinical outcomes.

After the grids had been developed by the CRT for its own review purposes and to provide form development guidance for the MSDP Standard Documentation Team, it was felt that the information contained in the grids might be useful for provider agencies in understanding the purpose of many of the data elements/fields identified in the MSDP forms and for future staff training purposes. Therefore, a decision was made to include the grids in this training manual. The grids cite the most recent standards available to the CRT from both payers and accreditors at the time of the publication of the grids in this version of the manual. Future changes to rule, regulation and standards may make the information contained in the grids dated and less useful for training and/or other purposes.

How to Interpret and Use Compliance Grids The grids list each area of information required for each MSDP form type and cite, if applicable, the particular regulation, rule or standard of the state payers, managed care organizations, national accreditors, federal payers including Medicaid and Medicare. (Please refer to Compliance Grid Table below).

Compliance Grid Table: 1. State Payers: Medicaid/DMA; DMH; DPH-BSAS; and DPH-HCQ 2. Managed Care: MBHP and State MCOs 3. National Accreditation: JCAHO; COA; CARF; and NCQA


61

4. Federal Payers: Medicaid and Medicare 5. Medicaid/Medicare Documentation Support Focus: Medical Necessity; Person


The MSDP Compliance Grids are designed as follows: • Column 1: The number given to the element identified by the CRT. • Column 2: The name of the documentation element. • Column 3 – 6: State payer columns – Medicaid/DMA, DMH, DPH BSAS and DPH

HCQ. • Columns 7 – 8: MBHP and State MCO’s Managed Care Requirements • Columns 9 - 12: Accreditor column – JCAHO, COA, CARF and NCQA • Columns 13-14: Federal Payer Requirements: Medicaid and Medicare • Column 15: Comments and clarifications

To use the grid, find the form you are interested in, read down the left side of the form to find the documentation area, read across to find the citation in the state payer’s regulations, managed care, the accreditation standard, and the federal payers, if any. And finally read the comments relating to that area.