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Tags Posts tagged with "Bulletin"

Bulletin

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The Office of Long-Term Living (OLTL) Critical Incident Management Unit monitors provider compliance in the application of guidance specific to critical incident management. OLTL has identified compliance concerns and is issuing the following clarification.

This communication focuses on required critical incident notification by provider agencies to the participant’s assigned service coordinator and the documentation of such notification in the Enterprise Incident Management (EIM) entry. The OLTL Critical Incident Management Bulletin, which is also available on OLTL’s website, indicates the following:

  • Within 48 hours, the Managed Care Organization (MCO), Service Coordinator (SC), provider agency that discovers or has independent knowledge of the critical incident is to submit the First Section of the critical incident report to OLTL using OLTL’s critical incident management system. If the critical incident was discovered on a weekend or holiday, the 48 hours begin at 12:00 am on the first business day after discovery of the critical incident.
  • Providers must inform the participant’s SC within 24 hours of discovering or first learning of a critical incident.

Notification to the participant’s SC that a critical incident was discovered must not be made using the HHAeXchange system. The required notification to the participant’s SC must be made by telephone call, electronic mail communication, or any other method that is agreed upon by all parties involved, excluding the HHAeXchange system.

In addition, the notification by the provider to the participant’s SC that a critical incident was discovered must be clearly documented in the EIM incident report, specifically within the “Agencies Contacted” page. Instructions are below:

  1. Enter the first name of the SC in the Person Contacted (First Name) Field.
  2. Enter the SC’s last name in the Person Contacted (Last Name) Field.
  3. Enter the contact phone number. Note that the email address field is not mandatory; however, it should be completed when notification to the SC was made via email.
  4. Click the SAVE button when all information has been entered.

See an example of page completion below.

Providers who are experiencing difficulty meeting the Critical Incident Management Bulletin requirements may email concerns to the resource account. Additionally, questions related to critical incidents may be emailed to the Critical Incident Management team member identified in any case-specific communication.

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The Office of Long-Term Living (OLTL) issued a Critical Incident Management Bulletin, with indications that they and the Managed Care Organizations (MCO) will be enforcing these regulations. Per OLTL:

Investigation of critical incidents and its documentation is an integral part of a Service Coordinator’s (SC) responsibilities, not a stand-alone function. During the course of quality reviews, Office of Long-Term Living’s (OLTL) Incident Management staff has found that critical incident investigations are not consistently following the established policy and procedure. OLTL wants to reinforce the following requirements found in various OLTL policy and procedure documents, which remain unchanged. Non-compliance with these requirements is subject to corrective action by OLTL.

1. Investigation of Critical Incidents

a. According to the Critical Incident Management Bulletin dated 2/23/2023, Community HealthChoices (CHC) managed care organizations (MCO) and SC must begin investigating a critical incident within 24 hours of discovery or of learning of the incident. This requirement was also indicated in the 2015 version of the document. The bulletin reinforces the onsite visit requirement for fact finding. The critical incident facts, sequence of events, interview of witnesses, and observation of the participant and/or environment is required. The onsite investigation is not the same as a comprehensive needs reassessment or assessment of need, and it must be completed regardless of participant choice. The participant reserves the right to refuse involvement in the critical incident investigation. However, the onsite visit must be completed. The Telephone Investigation referenced in the Bulletin does not replace the onsite investigation requirement, and is meant for instances when more information is necessary to complete the incident report. For example, when a protective services investigation is occurring and the SC needs to gather details to ensure mitigation measures are in place. Please note that while required to cooperate in the investigation, SCs are not required to investigate reported allegations of abuse, neglect, or exploitation, which are referred to a protective services agency. However, SCs remain responsible for ensuring participants health, safety, and welfare by means of risk mitigation and appropriate service implementation.

b. The 24-hour requirement to initiate an investigation is not to be interpreted as one business day. The only time business days apply is when submitting a critical incident report in Enterprise Incident Management (EIM), which is required within 48 hours excluding weekends and holidays. Please note that while the investigation must be initiated within 24 hours of incident discovery/learning of the incident, the CHC-MCO and SC will still have 30 calendar days to complete the investigation. It is also important to note that the onsite visit does not necessarily have to occur within 24 hours of incident discovery as long as it occurs at a time that enables ensuring the health and welfare of the participant, and within the allotted 30 calendar days or extended due date in the case where a timely EIM report extension was requested.

c. The Critical Incident Management bulletin also indicates the following:
No further action is required when the critical incident report meets all three of the following conditions:

  1. The facts and sequences of events are outlined with sufficient detail; and
  2. Preventative action through the service plan is either not required or is implemented and documented; and
  3. The participant is not placed at any additional risk.

Therefore, CHC-MCOs and SCs must ensure that, prior to submitting the Final Section of the incident report in EIM, the participant is aware of the critical incident, its resolution, and the measures taken to prevent recurrence. This includes determining whether a comprehensive needs reassessment or assessment of need must be conducted, based on the requirements outlined in OLTL’s policy and procedure documents. The SC must also ensure thorough documentation in the critical incident report of all actions taken to ensure participants health and welfare.

2. Notice to Participant

The Critical Incident Management Bulletin indicates that:

  1. The agency staff that discovered or first became aware of the critical incident is to notify the participant (and representative if requested by the participant) that a critical incident report has been filed. This notice must be provided to the participant within 24 hours and in a cognitively and linguistically accessible format. If the participant’s representative is suspected to be involved in the critical incident, the representative should not be notified.
  2. Within 48 hours of the conclusion of the critical incident investigation, the SC must inform the participant of the resolution and measures implemented to prevent recurrence.

CHC-MCOs and SCs must ensure the required notifications are made to the participant, and document completion within the Referrals and Notifications page in the EIM critical incident report.

OLTL encourages all CHC-MCOs and SCs to review the Critical Incident Management Bulletin to ensure all requirements are met.

If you have any questions, please contact Fady Sahhar.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-05 Peer Support Services (PSS) Bulletin and PSS Provider Handbook, updating the requirements for Peer Support Services. OMHSAS significantly reorganized the existing language in the Handbook to better clarify which requirements apply to OMHSAS licensure and which apply to Medical Assistance payment. Along with these formatting changes, OMHSAS-24-05 includes the following updates:

  • Staff Qualifications and Requirements for Certified Peer Specialists (CPS)
    • The requirement for a CPS to have a high school diploma or GED has been removed.
    • The requirement for a Serious Mental Illness (SMI) or Serious Emotional Disturbance (SED) has been replaced with a requirement to have a mental health diagnosis. Please note, to be eligible to receive PSS services, there is still a requirement for “the presence or history of an SMI or SED.”
    • The clause requiring CPSs “to attain certification through the PCB within six months of hire” has been removed, as the certification examination is now available on-demand, eliminating the need for a grace period for testing to be completed.
  • Staff Qualifications and Requirements for CPS Supervisors
    • Adding a new qualification category for individuals with an associate degree.
    • Supervisory meetings held in an audio-only format shall not be considered supervision.
    • Supervisory meetings shall be provided at a minimum of one hour each week.
  • Telehealth
    • The prior requirement that only 25% of total services provided per beneficiary per calendar year can be delivered by telephone has been removed.
    • PSS may be provided via telehealth technology, including audio-only service delivery, when it is clinically appropriate to do so.
    • PSS providers must ensure that the preference of individuals receiving services (or their legal guardian) is given a high priority when determining the appropriate service delivery modality.

Please review all other revisions to OMHSAS-24-05 here.

Comments and questions regarding this bulletin should be directed to:
Office of Mental Health and Substance Abuse Services, Bureau of Policy, Planning and Program Development,
P.O. Box 2675,
Harrisburg, PA 17105
General Office Number: 717-772-7900
Email

If you have any questions, please contact RCPA COO and Mental Health Policy Director Jim Sharp.

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The Centers for Medicare and Medicaid Services (CMS) has released an informational bulletin, as well as a slide presentation, that are related to continuity of coverage for individuals receiving home and community-based services (HCBS). The purpose of the bulletin is to highlight the federal renewal requirements and available flexibilities to promote continuity of coverage.

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The Pennsylvania Department of Human Services released Medical Assistance Bulletin 99-24-03 on May 28, 2024, detailing updates to the Medical Assistance (MA) Program Fee Schedule based on the 2024 Healthcare Common Procedure Coding System (HCPCS) changes. These updates include new codes such as 90867, 90868, and 90869 for transcranial magnetic stimulation (TMS) treatment billing, along with additional modifications to other procedure codes, setting of limitations, fee adjustments, and new prior authorization requirements effective from the same date. This bulletin applies to all providers serving MA beneficiaries under the Fee-for-Service system and those in the MA Managed Care system should contact their respective organizations for specific billing guidance.

For more detailed information, read the full bulletin here.

If you have any other questions, please contact RCPA COO and Policy Director Jim Sharp.

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The Office of Developmental Programs (ODP) has shared ODPANN 24-051. The purpose of this communication is to announce the release of the ISP Manual that includes information from the Consolidated, Community Living, and Person/Family Directed Support waiver amendments that were effective on November 1, 2023. View the announcement and documents below for instructions and details:

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A new bulletin addressing revisions to the Older Adults Protective Services Act (OAPSA) has been released by the Commonwealth Court. This bulletin specifically focuses on clarifying the legal standing of certain provisions, notably the “lifetime employment ban” for individuals with criminal convictions. Enacted in 1987, OAPSA aimed to protect Pennsylvania’s older population from exploitation, neglect, and abuse, establishing a program for their safeguarding, including those in mental health inpatient and residential facilities. However, subsequent amendments in 1996 introduced a permanent employment ban for individuals convicted of certain crimes. Despite this, a 2015 ruling by the Commonwealth Court found this provision unconstitutional, citing violations of due process guarantees under the PA constitution.

The full bulletin, titled “Bulletin OMHSAS-24-03 Employment Bans in OAPSA,” can be accessed here. Further inquiries regarding OMHSAS-24-03 can be directed to OMHSAS via email. You can also contact RCPA Policy Director and COO, Jim Sharp, with any additional questions.

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The Office of Mental Health and Substance Abuse Services (OMHSAS) has released the OMHSAS-24-01 Restraint Seclusion and Exclusion Bulletin, updating policies on restraint, seclusion, and exclusion in state mental hospitals to reduce these practices. This bulletin supersedes OMHSAS-09-06, necessitating adjustments in local hospital policies. Changes include shifting from “manual hold” to “physical restraint” terminology and clarifications in definitions. It strictly prohibits mechanical and chemical restraints, allowing physical restraint only as a last-resort emergency measure with detailed guidelines on application, documentation, and debriefing protocols. The emphasis is on individualized care, de-escalation techniques, and personnel training to ensure the humane and judicious use of physical restraint.

If you have any questions, please contact RCPA COO and Policy Director Jim Sharp.

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Photo by Markus Winkler on Unsplash

The Medical Assistance Bulletin 08-24-04, issued by the Department of Human Services (DHS) Office of Medical Assistance Programs (OMAP), provides updates to the PROMISe (Provider Reimbursement and Operations Management Information System) Provider Handbook 837, Professional/CMS-1500 Claim Form, specifically focusing on Appendix E – FQHC/RHC (Federally Qualified Health Center/Rural Health Center) Handbook. Released on March 1, 2024, the bulletin outlines revisions to Federal and State requirements for FQHCs and RHCs in Pennsylvania participating in the Medical Assistance (MA) Program.

Notable changes include the addition of pharmacists and licensed dietician-nutritionists as eligible practitioners for billable encounters starting March 1, 2024. The revision addresses group therapy encounters and introduces guidelines for telehealth, telemedicine, and teledentistry in FQHC and RHC services. A new section on alternative payment methodologies is included, along with updates to the MA Cost Reporting and Wraparound Reporting sections. The Centers for Medicare & Medicaid Services’ clarification designates “hospital” as an allowable place of service for FQHC and RHC services. Providers are encouraged to review the revised handbook for detailed information on these changes.

If you have any questions, please contact RCPA Policy Director Jim Sharp.

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The Office of Developmental Programs (ODP) has shared the bulletin Home and Community-Based Waiver Services Provided to Individuals in an Acute Care Hospital along with its accompanying attachment. The purpose of this bulletin is to provide guidance on the delivery of home and community-based waiver services to individuals who are hospitalized in an acute care hospital. Please review the bulletin and attachment for information and details relevant to this topic.

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