OMHSAS Policy Clarification Regarding BSC

UPDATED ONLY FOR LOGO AND BRANDING
Provider Notice
To:
HealthChoices Network Providers
From:
Sheryl M. Swanson, MBA, VP, Provider Network Operations
Date:
November 30, 2011
Subject:
AD 11 117 OMHSAS Policy Clarification Regarding BSC Education
Requirements and Applicability Across the Network
The Attached policy clarification speaks to the importance of closely investigating the education credentials
of staff hired. While this policy clarification focuses on Behavioral Specialist Consultant, it exposes a
concern regarding education for all clinical staff hired. Education provides the foundation for solid
treatment delivery and as such, providers must be diligent in assuring that each employee received their
education from a valid, recognized entity.
The policy clarification indicates that The United States Department of Education (USDE) and the Council
for Higher Education Accreditation (CHEA) recognize accreditation agencies that ensure their accredited
schools "meet acceptable standards of quality" and "maintain standards requisite for its graduates to gain
admission to other reputable institutions of higher learning or to achieve credentials for professional
practice" (http://www.ed.gov). A CHEA and USDE-recognized accrediting organization is considered a
"reliable authority as to the quality of postsecondary education within the meaning of the U.S. Federal
Higher Education Act of 1965" (http://www.chea.org). A complete list of USDE and CHEA accrediting
agencies as of August 2011 is attached to the policy clarification.
Licensed Provider organizations and supervising clinicians have a responsibility to verify the credentials of
their staff. Prior to credentialing any Agency Provider, PerformCare verifies that there is an acceptable
process in place for Provider staff credentialing. Providers must verify and maintain documentation of the
verification of certain credentialing elements for their staff. Please review the PerformCare Provider
Manual for additional detail about credentialing expectations. Please know that from this point forward,
PerformCare will be monitoring policies and procedures for evidence of proper verification of education,
including that education requirements of staff are met through properly accredited entities.
PerformCare and the counties are committed to supporting our providers and ensuring that they provide
the highest possible quality service delivery in our networks. You are encouraged to contact your Provider
Relations Representative with any questions or concerns.
ATTACHMENT
Office of Mental Health And Substance Abuse Services
Bureau of Policy and Program Development
HealthChoices Behavioral Health Policy
Clarification
Issue Clarification #: 02-11
Date of Receipt: 06-09-2010
Submitted by:
County Authority:
Topic Area:
Applicability: All Zones
Source Documentation: MAB 01-94-01
Pamela Hunter, Bureau of Program Integrity
Butler
Educational requirements for behavioral Specialist Consultant (BSC)
Question:
We are requesting interpretation of MAB# 01-01-05 and # 01-94-01.
Can an individual with a BSC's Master Degree obtained from a non-accredited, online organization be
considered as having met the minimum staff qualifications to provide behavioral health services?
Background: A current referral received by the BPI, involves an individual who obtained a BSC degree
from Ashwood University with an Education major and a Master of Arts Degree.
The BSC's degree is being deemed invalid by a Behavioral Health MCO audit. The Plan has found the
documentation for the Master Degree to be from a non-accredited, online organization and has
considered the documentation to show inadequate education or work experience.
Ashwood University advertises it is a fully recognized University awarded the status of accreditation
from the Board of Online Universities Accreditation (BOUA) and the World Online Education
Accrediting Commission (WOEAC).
However, the BOUA and WOEAC are accrediting bodies that award degrees on the basis of
employment and life-learned experiences.
Both bulletins contain staff qualification language relating to "degree" requirements and staff who
obtain a "level" of achievement. However, there is no information in either bulletin with regard to staff
who has obtained degrees online.
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OMHSAS Answer/Response:
The United States Department of Education (USDE) and the Council for Higher Education Accreditation
(CHEA) recognize accreditation agencies that ensure their accredited schools "meet acceptable standards
of quality" and "maintain standards requisite for its graduates to gain admission to other reputable
institutions of higher learning or to achieve credentials for professional practice" (http://www.ed.gov). A
CHEA and USDE-recognized accrediting organization is considered a "reliable authority as to the quality of
postsecondary education within the meaning of the U.S. federal Higher Education Act of 1965"
(http://www.chea.org). A complete list of USDE and CHEA accrediting agencies as of August 2011 is
attached.
Neither BOUA nor WOEAC are recognized by the US Department of Education or the Council for Higher
Education Accreditation; and as such, they have no authority to provide nationally recognized
accreditation. Therefore, the "degrees" from unaccredited institutions such as Ashwood University are
not acceptable as proof that an individual has satisfied any academic requirements to meet job
qualifications.
In this particular case, the MA degree in Education would not be sufficient to meet the requirements set
forth in Medical Assistance Bulletin 01-94-01 for a BSC, regardless of the granting institution, because an
Education degree does not qualify a graduate as a "master's level mental health clinician."
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