PROVIDER RESOURCE MANUAL Revised Date:
Transcription
PROVIDER RESOURCE MANUAL Revised Date:
PROVIDER RESOURCE MANUAL A Reference Guide for Network Providers at Group Health Cooperative of South Central Wisconsin. Revised Date: August 4, 2014 Table of Contents SECTION 1 INTRODUCTION TO GHC-SCW 1.1 About GHC-SCW………………………………………………………………………………… 1.2 History of GHC-SCW………………………………………………………………………….. 1.3 How to use the Provider Manual……………………………………………………….. SECTION 2 PROVIDER RESOURCES 2.1 Key Contact Information…………………………………………………………………… 2.2 Provider Resources on GHC-SCW Website (ghcscw.com)………………….. SECTION 3 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 11 11 11 12 12 12 12 12 ELIBIBILITY VERIFICATION 5.1 Understanding the Member ID Card………………………………………………….. SECTION 6 10 10 10 COVERED SERVICES Inpatient Hospital Services………………………………………………………………… Emergency Care………………………………………………………………………………… Skilled Nursing Facility Care………………………………………………………………. Complementary Medicine………………………………………………………………… Mental Health and Substance Use Disorder Services…………………………. End of Life Services…………………………………………………………………………… Dental Services………………………………………………………………………………….. Vision Services…………………………………………………………………………………… SECTION 5 6 8 PRODUCT DESCRIPTIONS 3.1 Health Maintenance Organization (HMO) Plan…………………………………. 3.2 Point-of-Service (POS) Plan………………………………………………………………. 3.3 Preferred Provider Option (PPO) Plan………………………………………………. SECTION 4 4 5 5 13 PRIOR AUTHORIZATION GUIDELINES 6.1 Authorization for Services…………………………………………………………………. 6.2 Second Opinions……………………………………………………………………………….. 1 15 16 SECTION 7 7.1 7.2 7.3 7.4 7.5 7.6 7.7 Filing a Claim…………………………………………………………………………………… Claim Filing Time Frame………………………………………………………………….. Common Claim Denials and Rejects………………………………………………… Billing When a Member Has Other Health Insurance Coverage……….. Reconciling Payments……………………………………………………………………… Member Billing Restrictions……………………………………………………………. Recoupment…………………………………………………………………………………… SECTION 8 8.1 8.2 8.3 8.4 8.5 CLAIMS AND BILLING GUIDELINES PHARMACY AND PRESCRIBER INFORMATION Prescription Drug Formulary Information………………………………………… How the Formulary is Developed……………………………………………………. Pharmacy Prior Authorization…………………………………………………………. Medication Therapy Management Program…………………………………….. GHC-SCW Pharmacy Network………………………………………………………….. SECTION 9 25 25 26 26 26 26 MEMBER SERVICES 11.1 Primary Care Provider Selection…………………………………………………….. 11.2 Primacy Care Provider Changes………………………………………………………. 11.3 New Member Materials………………………………………………………………….. 11.4 Member Rights and Responsibilities……………………………………………….. SECTION 12 24 CREDENTIALING 10.1 Credentialing Process……………………………………………………………………… 10.2 Re-credentialing……………………………………………………………………………… 10.3 Provider Rights………………………………………………………………………………. 10.4 Credentialing Confidentiality Policy………………………………………………… 10.5 Provider Changes…………………………………………………………………………….. 10.6 Evaluation of Clinic Site…………………………………………………………………… SECTION 11 22 22 22 23 23 CARE MANAGEMENT 9.1 Referring Members for Care Management……………………………………….. SECTION 10 17 18 18 18 19 20 20 28 28 28 29 IMPORTANT FUNCTIONS AND SERVICES 12.1 Clinical Health Education…………………………………………………………………. 12.2 Disease Management………………………………………………………………………. 12.3 Health Care Effectiveness Data and Information Set (HEDIS®)………….. 12.4 Wellness and Preventive Services……………………………………………………. 2 31 31 32 33 SECTION 13 PRIMARY CARE PROVIDER RESPONSIBILITIES 13.1 Clinical Practice Guidelines……………………………………………………………… 13.2 Access Standards…………………………………………………………………………….. 13.3 Encounter Data Submission…………………………………………………………….. 13.4 Cultural Competency………………………………………………………………………. 13.5 Interpreter Services………………………………………………………………………… 13.6 Fraud or Abuse - Investigating and Reporting…………………………………. SECTION 14 PROVIDER APPEALS PROCESS 14.1 Appeal /Request for Hearing………………………………………………………….. 14.2 Waiver by Failure to Request a Hearing………………………………………….. 14.3 Notice of Time and Place for Hearing……………………………………………… 14.4 Appointment of Hearing Panel………………………………………………………… 14.5 Attendance/Representation……………………………………………………………. 14.6 Rights of Parties………………………………………………………………………………. 14.7 Postponement………………………………………………………………………………… 14.8 Hearing Panel Report………………………………………………………………………. 14.9 Notification of Authorities……………………………………………………………….. SECTION 15 35 36 38 39 39 40 41 41 41 41 42 42 42 42 42 CONFIDENTIALITY 15.1 Privacy within GHC-SCW…………………………………………………………………… 43 15.2 How GHC-SCW Will Use and Disclose Patient’s Protected Health Information……44 15.3 When GHC-SCW is Required to Obtain Patient Authorization Prior to Use or Disclosure of PHI 15.4 Safeguarding PHI……………………………………………………………………………… 45 15.5 Statement of Patient’s Health Information Rights…………………………….. 46 15.6 Internal Protection of Oral, Written, and Electronic PHI Across the Organization..47 15.7 GHC-SCW Website Privacy Protections……………………………………………... 47 15.8 Personal Information vs. Non-Personal Information………………………….. 47 15.9 Sharing Personal Information…………………………………………………………….. 48 APPENDIX – A POLICIES AND PROCEDURES…………………….. 3 49 SECTION 1 INTRODUCTION TO GHC-SCW Welcome to Group Health Cooperative of South Central Wisconsin (GHC-SCW). We are pleased to have you in our network of providers and look forward to a long, partnership with you. This manual is intended to be used as a communication tool and reference guide for the network providers of GHC-SCW. It contains information on our policies and procedures, and our quality initiatives, as well as how to refer members to specific services. This manual in a way that emphasizes: • Essential information that providers need to know • Steps that providers need to take for any prior authorizations for specialty care • How to obtain more information The information contained in the manual is as current as the date published. We update individual subsections of the manual from time to time. In the event of a conflict or inconsistency between the federal or state regulatory requirements and this manual, the provisions of the regulatory requirements will prevail. 1.1 About GHC-SCW Group Health Cooperative of South Central Wisconsin (GHC-SCW) is a non-profit cooperative health maintenance organization (HMO) representing 75,000 cooperative members. GHC-SCW, as a consumer sponsored health plan, provides or arranges for the delivery of both primary and specialty health care and health insurance products to members living or working in South Central Wisconsin. GHC-SCW clinic services focus on primary care and select specialty care services. One of our Common Values is to provide for the health and wellness to those in our communities. Community involvement is core to our non-profit status and Common Values. Mission: The mission of Group Health Cooperative of South Central Wisconsin (GHC-SCW) is to provide accessible, comprehensive, high quality health care and outstanding service in an efficient and personalized manner. Vision: Group Health Cooperative of South Central Wisconsin (GHC-SCW) will be a leader among health plans in providing high quality medical care, impeccable service, and competitive benefit levels and premium rates. GHC-SCW will maintain consistent membership growth and a sound financial return each year. Our Common Values: What drives the success of GHC-SCW is our unwavering belief in five Common Values which shape the way we behave each day in order to deliver the best possible member experience. These values guide our work: • • • We are innovative: we create a culture of openness, honesty and the freedom to generate and express new ideas which provide solutions and enhance services to members. We are quality- driven: we foster personalized excellence in primary care for members. We are patient-centered: we encourage member involvement in their care and we devote ourselves to the health of our members. 4 • • We are community involved: we work to cultivate partnerships with our community by performing good deeds, and contributing to and aiding community organizations. We are a not-for-profit cooperative: we empower our members to set service standards and to have “a voice” in their health care while recognizing the unique nature and opportunities of our non-profit, cooperative governance structure. Better Together: because we believe in these Common Values, we are able to act according to our brand promise, “Better Together.” This is a promise we make each day to ourselves and to our key stakeholders—our members, our group leaders, our agents, our community and each other. The essence of “Better Together” is the belief that we are stronger together than alone. This belief has been the guide for our organization since we saw our first patient in 1976 and it will continue to guide us in the future. 1.2 History of GHC-SCW GHC-SCW began with the vision of its early founding members who had a novel idea that consumers of health care should own and govern the way health care is organized and delivered. From that vision, GHC-SCW was incorporated on March 6, 1972. Almost four years later, on March 1, 1976, GHC-SCW saw its first patient. GHC-SCW owns and operates six clinics (Hatchery Hill, Sauk Trails, Capitol, Madison College, East and DeForest) in Dane County. The vision of the founding members has been validated as GHC-SCW continues to be recognized as one of the highest quality HMOs in the country. The organization has been recognized by the National Committee for Quality Assurance (NCQA) as they rated GHC-SCW the top health plan in for eight years in a row. 1.3 How to use the Provider Manual This manual was drafted in a way so that it is easily searchable and accessible through our website ghcscw.com. Providers can easily search for particular topics by reviewing the manual’s table of contents, or by using the Adobe word search feature. The contents of this manual are organized to highlight important topics, including: • Covered services • Eligibility verification • Prior authorization guidelines • Claims and billing guidelines • Pharmacy and prescriber information We encourage providers to become familiar with contents of the provider manual and to refer to it frequently. If you have questions or concerns after reading the manual, please discuss them with us. We welcome and appreciate your ideas for improving our services. Please call the GHC-SCW Provider Resources Line at (608) 662-4193. 5 SECTION 2 2.1 PROVIDER RESOURCES Key Contact Information GHC-SCW Administrative Offices 1265 John Q Hammons Drive Madison, WI 53717 (608) 251-4156 TTY: (608) 257-7391 ghcscw.com Department Care Management Address GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 Phone Number (608) 257-5294 (800) 605-4327, ext. 4514 Compliance GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 662-4899 (800) 605-4327 Claims GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 251-4526 Fax: (608) 828-4856 Clinical Health Education (608) 662-4924 6 Services Provided - Referral request/status/extension/reason for denial - Home care nursing assistance/Continuing Care - All Inpatient Admissions - All Outpatient services/procedures - Audit questions or requests - Privacy or Security Breaches • Julie Coleman, ext:4237 - Federal or State regulatory inquiries • David Berry, ext:4873 - Provider inquiries on claims status - Claims fax number and address requests - Register for Disease Management and Prenatal/Child Classes -Answer questions about class offerings Enrollment GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 260-3170 Fax: (608) 662-4837 Eye Care Center GHC-SCW 3051 Cahill Main Fitchburg, WI 53711 GHC-SCW 8202 Excelsior Dr. Madison, WI 53717 (608) 257-7328 Laboratory Services (608) 250-2005 Fax: (608) 831-9081* Hours: 7:30 a.m. – 10 p.m. daily seven days a week (608) 251-4138 Medical Billing GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 Medical Imaging GHC-SCW 3051 Cahill Main Fitchburg, WI 53711 (608) 661-7248 Medical Records GHC-SCW 5249 E. Terrace Dr. Madison, WI 53718 (608) 222-9777, ext: 3222 Fax: (608) 441-3499 7 - Primary Care Provider (PCP) changes - Address/demographic changes - Eligibility status for new or existing members - Cobra questions - Member ID card requests - Adding or dropping dependents to a policy - Adding newborns to a policy - Employer group requests for additions/terminations to a group policy - Request for Certificate of Creditable Coverage * Fax outside orders for your patients to have their lab draw at any GHC-SCW lab - Fee For Service (Member wants to be seen but is not a GHC Member) - Copies of payments made for copays and Rx - Medicare and other insurance - Workers Comp/Motor Vehicle Accident Questions - Billing Statement questions or payments - X-ray - CT Scan - Ultrasounds - Mammography - Bone Mineral Density - Flourscopy - Questions about how to obtain copies of GHC-SCW Medical Records - Questions about immunizations given at GHC-SCW (also available via GHCMyChart) Member Services GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 828-4853, press 0 and ask for Member Services or toll-free at (800) 605-4327 Mental Health GHC-SCW 700 Regent St., Ste 302 Madison, WI 53703 (608) 441-3290 Prior Authorization GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 257-5294 (800) 605-4327, ext: 4514 Pharmacy Administration GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 828-4811 (800) 605-4327 Quality Management GHC-SCW 1265 John Q Hammons Dr. Madison, WI 53717 (608) 257-9705 2.2 - Benefit questions/interpretations - Claims questions from a member - Compliments/Complaints - Appeals - Dental Benefits - Member eligibility questions from a provider - MyChart Password reset - Questions about mental health benefits - Assistance with scheduling an appointment for the GHC-SCW mental health department - Request/status/extension/reason for denial - Questions about pharmacy benefits or drug information - Pharmacies with questions about submitting a prescription claim - Disease management and preventive outreach • Chronic conditions • Letters • TeleVox calls - Worksite Wellness calls - Employee Trust Fund/State Wellness initiative - NCQA related issues/questions Provider Resources on GHC-SCW Website The provider resource page on ghcscw.com is intended to serve as a one-stop hub for providers. The provider page offers easy access to information on specific services, guidance on completing certain functions, everyday reference materials (e.g., formulary information, procedures requiring authorization), and other resources. EpicLink is a secure, online tool that can be used by all GHC-SCW providers and network provider to perform administrative tasks, including reviewing: • Verify insurance coverage • Review member demographics • Creating and viewing authorizations • Summary of Benefits & Coverage 8 Click on the EpicLink button in the right side navigation bar to get started. If you do not have access but would like access to EpicLink, please contact your Provider Network Coordinator. You will be asked to sign a Confidentiality Agreement prior to gaining access. If you need assistance, on-site training can be provided. After you have returned the required Confidentiality Agreement, your Provider Network Coordinator will contact you to determine who the administrator account person will be. This person will be provided access to: • View Eligibility, Claims, and Benefits • If needed, Prior Authorization and Remittance Additionally, you can add users within your facility to allow access to: • View Eligibility, Claims, and Benefits • Prior Authorization and Remittance Forgotten Password/Username: If you have forgotten your password for EpicLink, simply click on the EpicLink login at ghcscw.com and enter your username and select Forgot your password. You will be prompted to enter your username again choose the Email Password. A new password will be emailed to you immediately. 9 SECTION 3 PRODUCT DESCRIPTIONS GHC-SCW offers several managed health care products for members: 3.1 Health Maintenance Organization (HMO) Plan GHC-SCW provides a variety of HMO plans, including co-payment, deductible, and co-insurance plans. Members with an HMO plan must select a PCP and obtain all non-emergent health care services through a defined network of providers, hospitals, and other medical professionals. 3.2 Point-of-Service (POS) Plan GHC-SCW’s POS plan pays benefits at two different levels – In-Plan or Out-of-Plan, depending on the “point” at which the care is accessed. 3.3 Preferred Provider Option (PPO) Plan GHC-SCW contracts with ChoiceCare and Wisconsin Health Plan as our preferred provider organizations that make up a national network for our PPO Plan. 10 SECTION 4 COVERED SERVICES GHC-SCW provides members with coverage for a wide-range of health care services. The covered services may be subject to cost-sharing (copayments, deductibles, coinsurance, and maximum out-ofpockets) and exceptions/limitations in coverage. For more information about specific benefits, please consult the GHC-SCW Member Certificate, Benefits Summary, and Summary of Benefits and Coverage (SBC). The covered services provided by GHC-SCW include, but are not limited to, the following: 4.1 Inpatient Hospital Services GHC-SCW provides coverage for medically necessary services and supplies furnished to members by a hospital. Inpatient hospital services covered by GHC-SCW include the hospital room, meals, lab tests, physical therapy, oxygen, and additional services. Inpatient special duty nursing is available when medically necessary. GHC-SCW provides coverage for maternity-related hospital or surgical services, including prenatal and postnatal care. GHC-SCW covers hospital maternity stays that are 48 hours in duration for vaginal delivery and 96 hours in duration for Cesarean section. GHC-SCW also provides coverage for obstetrical services, including lactation services. 4.2 Emergency Care GHC-SCW provides coverage for services obtained at a hospital emergency room or an emergency room located at an outpatient facility when the services are necessary to treat an emergency medical condition. GHC-SCW provides ER coverage for patients both in-network and out-of-network. If a member is experiencing an emergency medical condition, GHC-SCW instructs them to go to the nearest emergency room to seek care. Emergency care also provides coverage for ambulance services when a member is experiencing an emergency medical condition. This includes both air and ground ambulance services. Air ambulance services will only be covered when ground transportation would further endanger the member’s health, or other emergency transportation is not available at that location. 4.3 Skilled Nursing Facility Care GHC-SCW provides coverage for services that require a qualified nurse or therapist in certain convalescent/chronic disease facilities. This does not include custodial care or domiciliary services for chronic conditions. Skilled nursing facility care is typically limited to a certain amount of days in a plan/benefit year. Information about limits on skilled nursing facility care can be found in the GHC-SCW Member Certificate, Benefits Summary, and Summary of Benefits and Coverage (SBC). 11 4.4 Complementary Medicine GHC-SCW provides coverage for complementary medicine services. Complementary medicine services/treatment include: acupuncture, homeopathy, naturopathy, biofeedback, various types of manual therapy, various types of massage therapy and energy work, various types of stress reduction and mind/body medicine, various types of mindfulness therapy, various types of eastern practices, yoga, movement therapy, wellness classes, and lifestyle change classes. GHC-SCW is proud to be a leader in the area of complementary medicine. For HMO members, complementary medicine services must be received from the GHC-SCW Complementary Medicine Department (located at the GHC-SCW Clinics). 4.5 Mental Health and Substance Use Disorder Services GHC-SCW provides coverage for mental health (MH) and substance use disorder (SUD) services received on an inpatient, outpatient, and transitional treatment basis. This includes treatment for eating disorders and other psychiatric conditions. Inpatient MH/SUD services are covered when received at a GHC-SCW contracted hospital as a bed patient in that hospital. Outpatient MH/SUD are services provided at a non-residential facility. Transitional treatment MH/SUD services are typically provided at day treatment programs for adults, children, and adolescents. All MH/SUD services must be medically necessary and appropriate, as determined by the GHC-SCW Chief Medical Officer. 4.6 End of Life Services GHC-SCW provides coverage for supportive and palliative care for terminally ill members whose lifeexpectancy is six months or less. Covered services include nursing care, psychological counseling, dietary counseling, physical/occupational therapy, medical supplies, prescription medications, and additional services. This benefit includes an expanded complementary medicine benefit. 4.7 Dental Services GHC-SCW provides certain dental services under our medical policies. Additionally, GHC-SCW offers a stand-alone dental policy to employer groups, which offers a more diverse set of dental benefits. Dental services are provided through our In-Network provider, Dental Health Associates of Madison (DHA). GHC-SCW medical policies include coverage for accidental injury to teeth, treatment of the temporomandibular joint (TMJ), and oral surgical procedures. Also, some plans offer preventive dental (cleanings and fluoride treatment) for children, up to a certain age (typically 12, 15, or 19). 4.8 Vision Services Some GHC-SCW plans cover vision examinations. Additionally, some plans have an increased vision benefit that covers eyeglasses for children up to age 19. For HMO members, vision services must be received from the GHC-SCW Optometry Department (located at the GHC-SCW Hatchery Hill Clinic). 12 SECTION 5 ELIGIBILITY VERIFICATION Except for emergency services, providers rendering covered services to any GHC-SCW member should first verify eligibility prior to rendering the service. GHC-SCW does not require a provider to verify a member’s eligibility prior to rendering emergency services. Verifying the member’s eligibility is critical to determine whether a member’s enrollment status has changed and to help ensure payment. A member identification card does not guarantee eligibility. 5.1 Understanding the Member ID Card All Group Health Cooperative of South Central Wisconsin (GHC-SCW) subscribers or policyholders receive two individualized member identification cards upon enrollment. The member identification card (ID card) it is not a proof of member eligibility. It includes the following enrollment related information: 1. Your Network - The ID card will indicate which network to use to search for providers in Find A Provider. 2. Plan ID - This is a code for the benefit coverage for the group. You can refer to this information when calling GHC-SCW Member Services for a more detailed explanation of the member’s benefit plan coverage. 3. Group Number - The group number identifies the subscriber’s employer group and is usually the same for all employees and their dependents within that employer group. 4. Prescription (Rx) Information - This information will provide the pharmacy with detailed information about the plans prescription drug coverage. Within this information there are contact numbers for prescription drug coverage help and/or questions. 5. Effective Date – This is the date the coverages was effective. 6. Member Name - Each member/dependent is listed under “member name,” along with each individual member’s PCP name or clinic name and telephone number. 7. Member ID Number - Each member/dependent is identified by a member number. You can refer to the member number when calling the GHC-SCW. 8. PCP Location - The clinic in which the Primary Care Physician (PCP) selected by each member is listed along with the clinic phone number. Each member listed on a card may have a different PCP and/or location. Please Note: This information will not be listed for PPO and POS members. 13 1 2 3 5 8 7 6 4 The back of the ID card includes information for both members and providers. It describes how to obtain urgent and emergency care. It includes hours and phone numbers for GHC-SCW Member Services. Please contact GHC-SCW Member Services with questions regarding member benefits. 14 SECTION 6 PRIOR AUTHOIRZATION GUIDELINES Prior Authorization (PA) is a process which identifies specific procedures or services which require a medical necessity and/or medical appropriateness review prior to services being rendered for either inpatient and/or outpatient services. 6.1 Authorization for Services GHC-SCW maintains a prior authorization list at ghcscw.com. This list has specific CPT procedure codes and HCPCs DME/specialty drug codes which require prior authorization. To view the PA list, please see click here. GHC-SCW uses the Milliman Care Guidelines® to ensure consistency in utilization practices. The guidelines span the continuum of patient care and describe best practices for treating common conditions. The Milliman Care Guidelines® are updated regularly as each new version is published. A copy of individual guidelines pertaining to a specific case is available for review upon request. To support prior authorization, concurrent review, and retrospective review decisions, GHC-SCW uses nationally recognized evidence-based criteria with input from health care providers in active clinical practice. These criteria are applied on the basis of medical necessity and appropriateness of the requested service, the individual member’s circumstances, and applicable contract language concerning the benefits and exclusions. The criteria will not be the sole basis for the decision. Criteria sets are reviewed annually for appropriateness to GHC-SCW’s needs and changed as applicable in order to reflect current medical standards. The annual review process involves appropriate providers in developing, adopting, or reviewing criteria. Providers may obtain a copy of the utilization criteria upon request. Prior authorization, concurrent review, and retrospective review requests are presented to the Physician Reviewer or Chief Medical Officer for review when the request does not clearly meet criteria applied as defined above. Before making a determination of medical necessity, the reviewing physician may contact the requester to discuss the case. The prescribing or treating provider may request a peer review to discuss a medical necessity denial with a chief medical officer reviewer. Health care services and items must be medically necessary and provided in an appropriate, effective, timely, and cost efficient manner. Providers will need to submit by fax or complete the appropriate authorization online via EpicLink. The following information is required for prior authorization: • Current, applicable codes (e.g., Current Procedural Terminology (CPT)/HCPCs codes) • Member name • Date of birth 15 • • • • • • • • • • • Gender Member ID # Primary care or treating provider Tax ID# Facility name Facility address Facility phone and fax number Signature, if applicable of the referring provider Problem/diagnosis, must include the ICD-9 code Reason for the referral Clinical information such as progress notes, consultation reports, or a letter of medical necessity, reports of laboratory and imaging studies, and treatment dates, as applicable for the request. If DME, indicate rental or purchase Following the NCQA guidelines, the Care Management Department has up to 15 days to make a determination; however, if all the clinical information is submitted with the initial PA requests, a determination is made within 5-7 business days. If additional information is required, the Utilization Management (UM) staff will contact the provider to inform them what clinical information is needed. UM staff will contact the provider twice in one week to submit the additional information. If the information is not received after 5 business days upon receipt of the prior authorization, the PA will be sent to Physician or Chief Medical Officer to review as is. When the Care Management Department approves the referral request, a letter is mailed to the member and the specialist only if provider does not have access to EpicLink. EpicLink will identify PA approval and/or denials for providers to view. When the member receives the letter of approval, the member may schedule the appointment to see the specialist. It is helpful for the member to take the letter of approval to the appointment as it is not always seen by the specialist office in the member’s electronic medical record. If the member makes an appointment without approval from the GHC-SCW Care Management Department, they may be responsible for full payment of the services provided. If the member’s referral request is denied, both the provider and the member will receive a denial letter in the mail explaining member/provider appeal rights. If the appointment has already been scheduled for the same day or next day after the denial decision is made, GHC-SCW Care Management Department will contact the member and the provider of the denial decision. GHC-SCW approves services or supplies based on the information that is available at the time of the approval/denial decision. Approval does not guarantee a member’s eligibility or benefits under his/her health plan. It is the responsibility of the member to know their deductible, Co-payment, or Co-insurance amounts that apply to Specialty Services. 6.2 Second Opinions Second opinions are a covered benefit when provided by another GHC-SCW plan provider. Members should contact their Primary Care Provider for a prior authorization for a second opinion if the request is for an out of plan provider. 16 SECTION 7 7.1 Filing a Claim CLAIMS AND BILLING GUIDELINES The GHC-SCW Claims Department is responsible for the processing of claims for professional, institutional, and ancillary services rendered to GHC-SCW members. GHC-SCW is committed to meeting the standard goal of processing claims within 30 days of receipt. In order to meet that goal we have implemented a workflow system to: • Eliminate the possibility of misdirected claims • Retrieve claims and other documentation electronically • Reduce processing errors through the electronic transfer of claims information GHC-SCW accepts claims in both electronic and hard copy formats. Please follow the guidelines listed below to help ensure the GHC-SCW Claims Department can pay the claim in a timely and accurate manner: • Submit claims electronically using the standard ASC X12 005010 837 format. Please contact our EDI administrator Shannon Westman at swestman@ghcscw.com to establish an EDI submission. • If you are unable to submit claims electronically, please follow the guidelines below for paper claims: o Submit the original claim form individually o Carbon copies, photocopies, facsimiles, and forms created on laser printers are not acceptable for claims submission and processing o Do not staple multiple claims forms together • Use alpha or numeric characters o Please use only alphabetical letters or numbers in data entry fields as appropriate. Symbols such as “$,#, cc, gm” or positive (+) and negative (-) signs may be used when entering information in the Specific Details/Explanation/Remarks • Do not write on the claim form with red ink or dark highlighter o Highlighted areas will appear as a solid black mark, covering the highlighted information • Use prescribed format when enter dates o Enter dates in the six-digit format (MMDDYY) without slashes • Cover corrections o Do not strike over errors o Do not use correction fluid o Do not use correction tape When submitting a claim please make sure it includes the following data: • Member name and GHC-SCW member ID # • Dates of service • National Provider Identifier (NPI) number • Service address where services were rendered • Diagnosis, using current and appropriate ICD-9 codes 17 • • Services provided, using current and appropriate CPT procedure codes Charges for each service, using current and appropriate revenue codes Submit hard copy claims to: GHC-SCW Administrative Offices P.O. BOX 44971 Madison, WI 53744-4971 7.2 Claim Filing Time Frames Providers should file claims within the applicable time frames. • Providers have one year from the date of service to submit a claim for covered services rendered on or after January 1, 2014. Questions regarding the claims submission process should be directed to: GHC-SCW Claims Department (608) 251-4526 GHC-SCW Member Services (608) 828-4853 or (800) 605-4327 7.3 Common Claim Denials and Rejections The GHC-SCW Claims Department is responsible for processing claims for professional, institutional, and ancillary services rendered to GHC-SCW members. This section identifies several common reasons that may cause the GHC-SCW’s Claims Department to deny a claim. When the GHC-SCW Claims Department identifies a claim that may be contested or denied, the GHC-SCW Claims Department will send a request for additional information to the provider. If the provider does not respond within 45 calendar days of the date of the letter requesting the additional information, the claim will be processed based on the available information. Below you will find the most common reasons for denying claims when providers do not furnish any additional information. Description Duplicate Claim No Authorization 7.4 Billing Tips The claim has been denied because an earlier claim was received for the same member, for the same services, and the same date of service. The provider should be sure to check the previous payment record before re-billing the original claim. To inquire on the status of a claim, the provider can contact the GHC-SCW Claims Department at (608) 251-4526, Monday through Friday from 8 a.m. to 5 p.m. The claim has been denied because the service was not authorized. The provider should refer to ghcscw.com/Pages/Plan-Proivders.aspx for authorization requirements. Billing When a Member Has Other Health Insurance Coverage In general, providers should bill the primary health insurance coverage carrier prior to billing GHC-SCW. The primary carrier may reimburse the provider at a higher rate than GHC-SCW. If a provider receives partial payment from the primary carrier, GHC-SCW may be billed for the balance of the benefit/payment consideration. Below is a more detailed explanation of how to bill GHC-SCW when a member has other primary health insurance coverage: 18 • • • • • • • 7.5 Bill the primary health coverage carrier first. Bill GHC-SCW second. Attach the primary coverage carrier’s Explanation of Benefits to the claim and submit to the GHC-SCW Claims Department. GHC-SCW may be billed for the balance remaining from other health coverage, including copayments, coinsurance, and deductibles from the primary coverage. GHC-SCW will pay up to the limitations of member’s specific plan, less the primary coverage payment amount, if any. GHC-SCW will not pay the balance of a provider’s bill when the provider has an agreement with the other health coverage carrier/plan to accept the carrier’s contracted rate as a “payment in full.” An Explanation of Benefits or denial letter from the other health coverage must accompany the GHC-SCW claim. The amount, if any, paid by the other health coverage carrier for all items listed on the claim form must be indicated in the appropriate field on the claim. Providers should not reduce the charge amount or total amount billed because of any other health coverage payment. Reconciling Payments It is important that providers account for each claim, so that the provider can conduct any appropriate follow-up. Providers should also be vigilant in adhering to requirements governing claims submission timelines. Tips for reconciliation issues • Missing Checks If a check is missing, please allow 10 calendar days from the release date before making an inquiry. After 10 days, contact the GHC-SCW Claims Department at (608) 251-4526. Send the notification to: GHC-SCW Claims Department, P.O. BOX 44971, Madison, WI 53744. Please be sure to include a request for the check to be reissued. GHC-SCW will initiate a search for the check. If the search finds that the missing check was canceled, GHC-SCW will send a copy of the front and back of the check to the provider. If a provider believes that a check has been stolen, the provider should call the GHC-SCW Claims Department at (608) 251-4526. Providers should be prepared to furnish the GHC-SCW claims representative with all of the claims details. Providers should then submit written notification that a check was stolen. Send the notification to GHC-SCW Claims Department, P.O. BOX 44971, Madison, WI 53744. GHC-SCW will verify that the check has not been presented for payment and will place a stop payment order, if appropriate. A replacement check may be issued by GHC-SCW. Please note that once a “STOP” is placed on a check, it will not be honored if presented for payment. • Returned Checks A check may be returned to GHC-SCW by a provider or by the U.S. Postal Service as undeliverable. The GHC-SCW Claims Department researches undeliverable checks to locate a correct address. If the check remains undeliverable, the check is re-deposited into a suspense account, and the claim lines on the check are voided. Once a check has been re-deposited and its claim lines have been voided, a provider must re-bill GHC-SCW to receive payment and advise the GHC-SCW Claims Department of his or her correct address. The re-submitted claim must be within the timeliness 19 guidelines. If the claim is no longer within the timeliness guidelines, the provider may file a Provider Dispute Resolution (PDR) form with the appropriate documentation indicating why the claim was submitted late. If the check is returned by a provider because of an incorrect payment, the check will be re-deposited into a suspense account. If there are any correct claims that should be paid to the provider, the provider must re-bill the claim for reprocessing. 7.6 Member Billing Restrictions Providers contracted with GHC-SCW cannot bill GHC-SCW members for covered services, except for applicable co-insurance or co-payment amounts. Furthermore, providers cannot sue a member to collect sums owed by GHC-SCW. The prohibition on billing of the member includes, but is not limited to the following: • Covered services (inclusive of Medicare) • Covered services provided during a period of retroactive eligibility • Covered services once the member meets his or her share of cost requirement • Co-payments, co-insurance, deductible or other cost sharing required under a member’s other health coverage • Pending, contested or disputed claims • Fees for missed, broken, cancelled or same day appointments • Fees for completing paperwork related to the delivery of care (e.g., immunization cards, WIC forms, disability forms, and well-child visit forms) A provider may bill a member only for non-covered services, if: • The member agrees to the fees in writing prior to the actual delivery of non-covered services; and • A copy of the written agreement is provided to the member and placed in his or her medical record. 7.7 Recoupment GHC-SCW’s most common method of claim payment correction is the recoupment process. This means that any amount owed to GHC-SCW will be offset from future payments. All recoupments will be listed individually and at the end of the remittance advice and will be listed as a negative amount. If an amount is due to GHC-SCW and there are no claims payments due to a provider during a weekly payment cycle, an outstanding liability report will print out showing the amount that is still owed to GHC-SCW. Example: A claim was submitted to GHC-SCW and was paid in the amount of $39.43. GHC-SCW then receives notice that the member terminated coverage. In this case, the full amount of the payment will need to be recouped from subsequent remittance advices until the amount is repaid. • The claim is reprocessed and notification that the member was terminated is sent to the provider on the first payment cycle after the date the claim was reprocessed. On this remittance advice, there was no payment due to the provider for any other claims. The amount owed to GHC-SCW on the reprocessed claim will show individually and on the last page of the remittance advice. 20 • On the following payment cycle, the check to the provider contained claims payments totaling $216.00; however, since there is $39.43 listed as an outstanding liability, the check is written for $176.57. This clears the outstanding liability. Detail of each claim payment amount and the negative amount is included on the remittance advice. 21 SECTION 8 PHARMACY AND PRESCRIBER INFORMATION The following information is provided to help you understand the prescription drug benefit, address concerns you may have regarding medication coverage, answer benefit-related questions from members, and work within the GHC-SCW system to ensure the best possible care for our members. 8.1 Prescription Drug Formulary Information A formulary is a list of medications identifying their level of coverage. It is an important tool to help GHC-SCW meet its goal of providing coverage for safe and effective medications in an affordable manner. The Standard GHC-SCW Drug Formulary includes three categories of drugs: Tier 1, Tier 2, and Specialty drugs. Specialty Tier drugs require prior authorization for coverage and are distributed through only through selected pharmacies. Some drugs are excluded, including cosmetic treatments, weight modification medications, medical food, nutritional supplements, most infertility medications, sexual dysfunction medications, and most over-the-counter medication. The current Formulary is always posted at https://ghcscw.com/get-care/pharmacy. Questions about drug benefits or medications listed on the formulary can be directed to GHC-SCW Pharmacy Administration at (608) 828-4811, or toll free at (800) 605-4327, 8 a.m. – 5 p.m., Monday- Friday. 8.2 How the Drug Formulary is developed The GHC-SCW Formulary Committee is responsible for creating and maintaining the prescription drug formulary. This committee is made up of physicians and pharmacists who consider a variety of factors, such as safety, side effects, drug interactions, how well the drug works, dosing schedule and dose form, appropriate uses, and cost-effectiveness. The committee obtains the information from a variety of sources: published clinical trials, data submitted to the FDA for drug approval, recommendations from local or national treatment guidelines, and input from local experts. GHC-SCW Drug Formulary is subject to change at any time. 8.3 Pharmacy Prior Authorization In cases when the GHC-SCW Drug Formulary does not include a specific medication that a physician believes is medically necessary, the physician may request that GHC-SCW prior authorize that drug for a specific patient. Requests may be submitted two ways: 1. Complete a PA Request form and fax it to (608) 828-4810. You can find the form on our web site at ghcscw.com/getcare/pharmacy or by clicking the link below: https://ghcscw.com/SiteCollectionDocuments/Formulary_Exception_Request.pdf 2. Request a PA by phone; GHC-SCW Pharmacy Administration staff is available at (608) 828-4811, 8 a.m. -5 p.m., Monday through Friday. Please be sure to include documentation of appropriate clinical information that supports the medical necessity of the requested item. Please document other drugs tried previously, along with the resulting clinical outcome. The reviewer may request additional supporting documentation. 22 The GHC-SCW Pharmacy Department is responsible for notifying the member and requesting provider of the decision. Generally, PA Requests will be decided within 3 business days (1 day if urgent). If there is a denial, members will be notified in writing. Denials will include the reason for denial and an explanation of the plan’s formal appeals process. A copy of the denial letter will be faxed to the provider who submitted the PA. 8.4 Medication Therapy Management Program GHC-SCW’s prescription claims processing interface with local pharmacies includes drug utilization software that can signal a warning to the pharmacist when certain situations are found, such as potential duplicate therapy, drug interactions, excessive dose, and more. 8.5 GHC-SCW Pharmacy Network GHC-SCW uses the national Navitus Pharmacy Network, which includes nearly every pharmacy in Wisconsin. A list of participating major pharmacy chains is available at https://ghcscw.com/getcare/pharmacy. Providers can also search for pharmacies by zip code or city at https://prescribers.navitus.com . 23 SECTION 9 CARE MANAGEMENT Care management is the coordination of care and services for members who have experienced a critical event or chronic diagnosis, or may be a high-risk member. Typically, these members require extensive use of resources and need help navigating the health care system to facilitate the appropriate delivery of care and services. GHC-SCW is committed to providing case management services for our members. We perform a comprehensive assessment of the member’s condition, determine the available benefits and resources, develop and implement a case management nursing care plan, establish goals with the member as they are engaged with the case management program, and continue with monitoring/follow-up contacts with the member. The following are guidelines: • Active chronic diagnoses with two or more co-morbidities • Two or more hospitalizations in the past three months • Two or more emergency room visits in the past three months • Experiences a transition in care or change in health status • Readmissions within 30 days 9.1 How to Refer a Member for Case Management Services If a provider identifies a member who would benefit from case management services, the provider should immediately contact GHC-SCW Care Management Department at (608) 257-5294. Providers and/or members may self-refer for case management services by completing the CM Self-Referral form. Please click here for form. 24 SECTION 10 CREDENTIALING Credentialing is an important process GHC-SCW uses to ensure that we offer quality care to our members. GHC-SCW’s credentialing and re-credentialing processes follow National Committee for Quality Assurance (NCQA) guidelines for the acceptance, discipline, and termination of providers based on the provider’s education and history. 10.1 Credentialing Process Credentialing is an important process GHC-SCW uses to ensure that we offer quality care to our members and that all providers meet minimum standards relative to licensure, education, malpractice coverage, etc. The Credentialing Committee reviews all providers who are in GHC-SCW’s network and make all credentialing and re-credentialing decisions based solely on the verified information provided on the provider’s applications. GHC-SCW does not discriminate against an applicant or make credentialing decisions based on an applicant’s race, ethnic/national identity, gender, age, sexual orientation, or patient (e.g., Medicaid) in which the provider specializes. The committee reserves the right to determine which health care providers are eligible to participate in GHC-SCW’s Network. Providers are required to complete the credentialing process and be approved by the committee prior to treating GHC-SCW members. When a new provider joins your facility, please contact your Provider Coordinator to request a credentialing packet. GHC-SCW’s Medical Staff Administrator will send a packet to the provider within 7 days. If your facility prefers to have the credentialing packet sent to a staff member, please indicate this to the Provider Coordinator. Typically, the credentialing process will take less than 90 days, but it can take up to 180 days. When the Medical Staff Administrator has completed the verification process, the credentials file is presented to the Credentialing Committee which meets on a monthly basis. The Credentialing Committee reviews the completed file and either: (a) accepts, (b) accepts with restrictions or conditions, or (c) denies the application. Within 60 calendar days of the Credentialing Committee’s decision, an appropriate notification letter is sent to the individual provider or their designee. The Provider Coordinator will also notify the facility that the provider has been approved and able to see GHC-SCW members. 10.2 Re-credentialing Re-credentialing takes place every three years. Providers who are due for re-credentialing will receive their re-credentialing packet from the GHC-SCW’s Medical Staff Administrator approximately two to three months in advance. This enables GHC-SCW to complete the process within the required time frames and will prevent termination of Network participation. The same process that is used for credentialing is followed for the re-credentialing process. 25 10.3 Provider Rights Providers have the right to review the information submitted in support of their credentialing application with the exception of references, recommendations or other peer-review protected information. GHC-SCW’s credentialing staff will notify the provider of any information obtained during the credentialing process that varies substantially from the information provided to GHC-SCW by the provider. The practitioner has the right to correct erroneous information and has 30 days to submit written corrections. The provider also has the right to request application status during the credentialing or re-credentialing process. 10.4 Credentialing Confidentiality Policy Information obtained during the credentialing process is confidential. Access to credentialing information is carefully monitored and the information will not be released to outside parties without permission of the provider involved, or as permitted by law, including the Health Care Quality Improvement Act of 1986. Provider credentialing files are accessible only to the Credentialing Committee, credentialing staff, and GHC-SCW’s Chief Medical Officer An individual provider may request to review the information contained in his/her file with the exception of references, recommendations or other peer-review protected information. To request a review, the provider should contact the Medical Staff Administrator who will schedule an appointment. 10.5 Provider Changes GHC-SCW requests timely notification of significant changes within your organization so that we can ensure accurate claims processing, notification to providers and members and continuity of care processes. Please notify GHC-SCW Medical Staff Administrator as soon as possible of any changes, such as: • New practitioner within your facility • New facility location • Terminated practitioner • Terminated location • Changes in relation to: o Tax Identification Number o National Provider Identifier (NPI) o Phone or Fax number o Street or Billing address 10.6 Evaluation of Clinic Site GHC-SCW sets standards for and monitors offices of all practitioners in its network where care is delivered. GHC-SCW has standards for the quality and safety of office sites, including but not limited to physical accessibility, physical appearance, adequacy of waiting and examining room space, and adequacy of medical treatment record-keeping practices. Member Services reports all complaints about clinic offices to the Medical Staff Administrator. The Medical Staff Administrator and Clinic Facilities Supervisor will investigate all complaints related to clinic offices and determine what follow-up is required. 26 If two complaints about the same issue for the same office are received within a one-year period, the Medical Staff Coordinator and/or Clinic Facilities Supervisor conducts a site visit within 60 days of the second complaint. If a corrective action plan is established for the office site, the Medical Staff Coordinator and/or Clinic Facilities Supervisor will conduct follow-up site visits until the office site is compliant with GHC-SCW standards. GHC-SCW will make every effort to assist the facility to achieve compliance. However, if compliance cannot be obtained, the Credentialing Committee may take action, up to and including a recommendation that GHC-SCW terminate its contract with the facility. An audit may be triggered by member complaints. If a member complaint is made regarding clinic physical accessibility, appearance or adequacy of waiting room or exam rooms, the Credentialing Specialist will conduct an on-site audit, using a tool approved by NCQA. If the clinic is found to be deficient in any area, a corrective action plan will be required. The clinic will have the opportunity to make corrections and become compliant. The final audit results will be presented to GHC-SCW’s Credentialing Committee. 27 SECTION 11 MEMBER SERVICES The GHC-SCW Member Services Department responds to the questions and needs of members, as well as answers questions from providers about their members. Member Services helps members: • Choose or change a primary care provider (PCP) • Know how to access care within the managed-care system • Understand their benefits and how to access care • Recognize their rights and responsibilities as members • And more Contact Member Services, at (608) 828-4853 or toll free at (800) 605-4327, Monday through Friday, from 8 a.m. to 5 p.m. 11.1 Primary Care Provider Selection GHC-SCW is committed to ensuring that its members have ample opportunity to select a primary care provider (PCP) when they join GHC-SCW. The following outlines the major elements of PCP selection process. Choice upon Initial Enrollment into GHC-SCW: • New members have the opportunity to select a GHC-SCW Network. Based on the network chosen, a PCP is then chosen upon enrollment. • New members receive a Provider Directory during the GHC-SCW enrollment process, which lists GHC-SCW’s providers, network clinics, and hospitals. • New members complete an enrollment form and choose a PCP during the enrollment process. • If a member does not select a PCP, GHC-SCW will assign the member to a PCP based on the member’s geographical location. GHC-SCW will notify the member of the assignment, along with instructions about how to change the PCP. 11.2 Primary Care Provider Changes Members may choose any of the providers listed in the GHC-SCW Provider Directory as their PCP. If the PCP is not open to new members, we will ask the member to choose another PCP. Members may change their PCP and/or network at any time by calling the Member Services Department at (608) 828-4853 or toll free at (800) 605-4327. 11.3 New Member Materials Upon enrolling in GHC-SCW, members receive a New Member Welcome Packet. This is sent to members prior to their effective date of coverage. The packet contains information to help members access GHC-SCW’s programs and services as well as their GHC-SCW Member ID Card. 28 Members also receive an e-newsletter four times a year called HouseCall. The newsletter includes articles on health education, service and benefit reminders, and information about how to use the health plan. 11.4 Member Rights and Responsibilities GHC-SCW stands behind our commitment to provide high-quality, comprehensive and accessible health care to members in an efficient and personalized manner. To further demonstrate this commitment, we have established the following patient rights and responsibilities: Member Rights: • Receive information about GHC-SCW, its services and its providers, including the right to receive a copy of the GHC-SCW Patient Rights and Responsibilities. • Be treated with dignity and respect in a confidential manner • Participate with your providers in making decisions about your health care • Participate in a candid discussion of appropriate or medically necessary treatment options for your conditions, regardless of cost or benefit coverage • Voice complaints about the service and care you receive without penalty or disenrollment • Receive notification and a rationale when case management services are changed or no longer needed • Receive a certificate outlining the coverage to which you and/or your family members are entitled, and to whom the benefits are paid • Ask questions regarding your medical plan coverage, the preauthorization process or claims payment • Submit complaints about appeals about GHC-SCW or the care we provide. • Select a primary care provider and to request a new provider without indicating a reason • Receive a full explanation of any charges billed to you as a result of care • Participate in the governance of GHC-SCW. Each member must be at least 18 years of age to be a voting member of the Cooperative and is encouraged to actively participate in its operation. • Make recommendations regarding the organization’s member rights and responsibilities • Receive informed consent, as required by law, prior to procedures or treatments. To the extent permitted by law, it is your right to refuse the recommended treatment and be informed of the consequences of this decision • Receive confidential treatment of all communications and records concerning your care, except as otherwise provided by law. • View and receive a copy of your health records and x-rays upon receipt of written authorization. • Receive a copy of the GHC-SCW Notice of Privacy Practices Member Responsibilities: • Be considerate of others. • Observe safety and smoking regulations in all GHC-SCW facilities • Treat GHC-SCW employees with consideration and respect • Provide accurate and complete health care information • Use facilities and equipment properly • Read and understand your coverage • Be on time for appointments and inform the clinic in advance when appointments cannot be kept 29 • • • • • • Follow plans and instructions for care as agreed to with your provider Understand your health problems and participate in developing mutually-agreed-upon treatment goals Pay your financial obligations under the benefit plan Know and confirm your benefits before receiving treatment Obtain preauthorization for services indicated in your certificate Notify GHC-SCW of changes in your address, phone number or family status For more information about member rights and responsibilities, please contact Member Services at (608) 828-4853 or toll free at (800) 605-4327 and ask for Member Services, Monday through Friday 8 a.m. to 5 p.m. TTD/TTY users can contact us at (608) 257-7391. 30 SECTION 12 IMPORTANT FUNCTIONS AND SERVICES 12.1 Clinical Health Education Clinical Health Education (CHE) services are an available benefit for members with no co-payment for many GHC-SCW plans, although co-insurance or deductibles may still apply. GHC-SCW’s Clinical Health Education specialty areas include but are not limited to: • Asthma and COPD • Diabetes Education and Management • Nutrition Counseling • Tobacco Cessation • Genetic Counseling • Pregnancy, Childbirth, and Infant Feeding Prior Authorization is not needed to see a CHE provider, although an order from the primary care provider documenting the need for the visit as part of the member’s plan of care is requested. GHC-SCW members can schedule individual clinic visits with a CHE provider by calling their clinic. To register for a CHE class or for more information about these services, contact our Clinical Health Education Department at (608) 662-4924 or visit ghcscw.com and select “Get Care.” 12.2 Disease Management GHC-SCW has developed Disease Management Programs to measure and improve the health status and quality of life of our members. GHC-SCW identifies and automatically enrolls members who are diagnosed with the following conditions: • Asthma • Diabetes • Cardiovascular Disease GHC-SCW’s Disease Management Programs are confidential; available to members at no additional cost, and participation in the programs is voluntary. Each program provides a variety of services for at-risk members with chronic conditions. The goal is to promote member self-management, assist the primary care provider in managing the condition and improving the health, well-being, and quality of life for members. Member resources and services include: • An informational brochure about the condition, along with a list of national and local organizations to contact for additional information • Condition-specific newsletters • Reminders about necessary screenings and exams, recommended frequency of practitioner visits 31 • • • • Annual influenza vaccine reminder Ongoing educational mailings regarding important health information Information about the connection between chronic conditions and other co-morbid indications and when to seek medical assistance Telephonic follow-up following a visit to the ED or hospital to offer health coaching or potential referral to case management Provider resources and services include: • GHC-SCW's Clinical Practice Guidelines (CPG). Each CPG is developed by an interdisciplinary group of recognized local leaders and is based on a nationally recognized evidence based recommended guideline. • Provider-specific notification on members recently seen in the ED or hospitalized with a condition-specific diagnosis. Prior Authorization is not needed to see a health educator. GHC-SCW members can schedule individual clinic visits with health educators who are certified in diabetes, asthma, and cardiac education. For more information about the Disease Management Programs, contact our Quality Management Department at (608) 257-9705. 12.3 Health Care Effectiveness Data and Information Set (HEDIS®) HEDIS® is a set of standardized measures designed by the National Committee for Quality Assurance (NCQA) to evaluate performance of health plans and their providers. It allows for assessment based on quality and performance. Data that is obtained from HEDIS helps GHC-SCW direct its quality improvement activities, evaluate performance, and identify further opportunities for improvement. It also helps employers understand the value a health plan offers and how to hold a health plan accountable for its performance. An increasing number of employers request HEDIS reports for evaluating cost and quality and for making comparisons among health plans. Currently, the State of Wisconsin mandates HEDIS reporting for managed care organizations that provide coverage to State employees. Members and practitioners periodically receive reminders about missing labs or tests. Collecting data for HEDIS reports can be challenging. Claims and other pertinent data are collected by the managed care organization. Such data is not always adequate for complete and accurate reporting, especially for clinical measurements. Often a review of the medical record is needed to provide accurate reporting of performance levels. As a result of measuring health care services, GHC-SCW develops initiatives to improve the health of members based upon their health care needs. Quality programs serve to increase member awareness and understanding of preventive health care, health care screenings and appropriate care for specific conditions. Throughout the HEDIS data collection process, GHC-SCW maintain every member’s confidentiality at the highest level. No individual results are reported. 32 The seven major areas of performance measured in HEDIS are: • Effectiveness of Care • Access and Availability of Care • Satisfaction with the Experience of Care • Health Plan Stability • Use of Services • Cost of Care • Health Plan Descriptive Information If you have questions about the HEDIS measurement process or GHC-SCW’s individual results, please contact the GHC-SCW Quality Management Department at (608) 257-9705. To review GHC-SCW’s Quality Improvement Plan please click on link below: https://ghcscw.com/SiteCollectionDocuments/Quality_Report.pdf 12.4 Wellness and Preventive Services GHC-SCW provides reminders to members on a variety of preventive health services. Reminders are sent to members who qualify based on gender, age, claims, laboratory results, and/or pharmacy indicators. The services for which regular reminders are sent are: SERVICE OR MEASURE Childhood Well Check Visits Health Milestones – reminders of age and gender appropriate services Pap and Mammography Influenza Diabetes Lab and Screening PROTOCOL Annually, to those ages 3 – 21 Female: age 18, 40 and 50 Males: age 50 Females past due Annually to those considered high risk Annually (monthly between calls and letters) Educational topics are available on a variety of topics at ghcscw.com/be well/wellness resources. Members may participate in a variety of wellness reimbursement options. You may learn more at ghcscw.com/be well/wellness-reimbursement. To enroll a member in any of these services, or to learn more, call (608) 828-4853. 33 SECTION 13 PRIMARY CARE PROVIDER RESPONSIBILITIES The primary care provider (PCP) is the main provider of health care services for GHC-SCW members and is responsible for the delivery of health care to his or her assigned members. GHC-SCW’s model of care is built around the PCP, with the PCP at the center of a multidisciplinary team coordinating services furnished by other physicians or providers to meet the needs of the member. PCP responsibilities include, but are not limited to, the following: 1. Furnish appropriate care for the health care problems presented by a member, including preventive, acute and chronic health care, and provide referrals to other practitioners for services. 2. Provide risk assessment, treatment planning, coordination of medically necessary services, referral, follow-up, and monitoring of appropriate services and resources required to meet a member’s health care needs. Coordinate medically necessary services that are available to GHC-SCW members as part of their dual eligibility. 3. Provide basic medical case management to assigned members: • Ensure continuity of care for the member and an interactive relationship between the PCP and the member. • Initiate and maintain in the medical record an individualize care plan (ICP) that addresses areas identified through the comprehensive assessment. • Communicate the ICP with providers involved in the member’s care at the point of notification of a planned or unplanned transition of care. • Increase member satisfaction. • Facilitate access to appropriate health services. • Ensure appropriate use of specialty and hospital services. • Ensure the appropriate use of the pharmacy and drug benefit including medication reconciliation. • Screen health status, monitor, and provide preventive health services. • Identify and provide appropriate health education to improve a member’s understanding of the importance of a healthy lifestyle and disease-specific interventions. 4. Assure the provision of the required scope of services to the assigned members. 5. Verify eligibility of the member at the time services are provided. 6. Assure access to care 24 hour per day, seven days per week, including accommodations for urgent care, performance of procedures, and arrangements for emergency and back-up coverage in the PCP’s absence. 7. Keep office waiting times to a maximum of 45 minutes. 8. Coordinate and direct appropriate care for members, including scheduling an appointment for high risk members within 30 calendar days. 9. Provide second opinions as necessary. 10. Consult with a referral specialists (including providing necessary history and clinical data to assist the specialists in his or her examination of the member). 11. Provide follow-up care to assess results of the primary care treatment regimen and specialist recommendations 12. Provide special treatment within the framework of integrated, continuous care. 34 13. Coordinate the authorization of specialist and non-emergency hospital services for a member, and ensure that services generated from referrals are initiated within 30 calendar days after the visit at which the referral was made. 14. Assure the provision of basic clinical services including primary evaluation and treatment of acute and chronic medical and surgical problems in all systems. 15. Record the following information in the medical record and make records available for review upon request by GHC-SCW, and applicable federal and state oversight agencies • Member office visits, emergency visits and hospital admissions) • A problem list that includes allergies, medications, immunizations, surgeries, procedures and visits • Efforts to contact a member • Treatment, referral, consultation and inpatient stay reports • Laboratory and radiology results ordered by the PCP • Individualized Care Plan (ICP) 16. Adhere to the following to ensure that the member’s medical record documentation is accurate: • The documentation of each encounter includes: reason for encounter and relevant history, physical examination findings, and prior diagnostic test results, assessment, clinical impression, or diagnosis, medical plan of care, date and legible identity of the rendering provider • The current procedural terminology (CPT) and current International Classification of Diseases (ICD) codes reported on the health insurance claim form or billing statement supported by the documentation in the medical record 17. Facilitate and ensure quality of care by establishing procedures to contact a member when the member misses an appointment that requires rescheduling for additional visits, and following up on referrals to a specialist for care. 18. Assist the member with the GHC-SCW Grievance and Appeals process. 19. Coordinate the transfer of the member and his or her medical records to another provider upon notification of a planned or unplanned transition of care episode, or upon request by the member. 20. Make all reasonable attempts to communicate with a member in the member’s preferred language, using interpretation or translation services available through a member’s physician medical group. 21. Preserve the dignity of the member. 13.1 Clinical Practice Guidelines GHC-SCW encourages its providers to practice evidence-based medicine. GHC-SCW has links to clinical practice guidelines available to address conditions frequently seen in patients at your practice. All clinical practice guidelines included have been reviewed and approved by GHC-SCW’s Clinical and Service Quality Committee (CSQC) and are based on guidelines from national organizations or on a review of the medical literature. GHC-SCW participates in a stated wide collaborative that meets period ally to review, develop and approve CPGS. This initiative is led by the University of Wisconsin Center for Clinical Knowledge and HealthCare. All guidelines are connected to links that are simple to access and include algorithms for quick reference. A detailed document accompanies each algorithm. GHC-SCW is confident you will find these clinical practice guidelines valuable to your daily practice. 35 GHC-SCW’s Quality Management Department reviews the Clinical Practice Guidelines annually and updates as appropriate to include additional guidelines once approved by the Clinical and Service Quality Committee. Notifications regarding updates/changes to the Quality Management provider manual and clinical practice guidelines are emailed to providers annually. If you would prefer a paper copy of the clinical practice guidelines or any other part of the provider manual, please contact the GHC-SCW Quality Management Department at (608) 828-4820. To view GHC-SCW’s Clinical Practice Guidelines click web site link below: https://ghcscw.com/Pages/Provider-Resources/Clinical-Practice-Guidelines.aspx 13.2 Access Standards GHC-SCW is required to adhere to patient care access and availability standards. GHC-SCW has implemented these standards to ensure that members can get an appointment for care on a timely basis, can reach the provider over the phone, and can access interpreter services, if necessary. All GHC-SCW providers and contracted providers are expected to comply with these appointment, telephone access, practitioner availability and linguistic service standards. GHC-SCW monitors its providers for compliance with these standards. GHC-SCW will develop a corrective action plan for providers and health networks that do not meet these standards. Below is a brief description of the access standards for GHC-SCW members: Access to Medical Care: Type of Care Wait Time Emergency Services Immediately Urgent Care Within 24 hours after request Non-urgent acute care Within three calendar days after date of request Primary care Within 1 business days after the date of request Routine physical exams and wellness visits Within 7 calendar days after the date of request Specialty care Within 15 business days of request for appointment Ancillary services for diagnosis or treatment Within fifteen 15 business days of request for appointment Comprehensive Health Assessments Within 30 calendar days after enrollment; follow-up at 30 and 60 calendar days if not returned In office wait time for appointments Not to exceed 45 minutes after time of appointment Emergency care that is life-threatening Immediately 36 Emergency care that is not life-threatening Within six hours after receipt of request Telephone Access Wait Times Telephone wait time during business hours A non-recorded voice within 30 seconds and an abandonment rate of not greater than five percent Non-emergency and non-urgent messages during business hours Practitioner returns the call within 24 hours after the time of message Urgent message during business hours Practitioner returns the call within 30 minutes after the time of message Emergency message during business hours Practitioner returns the call within five minutes after the time of message Telephone access after business hours If recorded message: "If you feel that this is an emergency, hang up and dial 911 or go to the nearest emergency room." If live after-hours attendant and call is an emergency: • Connect member to the on-call physician; or • Physician returns the call within five minutes after the call Cultural and Linguistic Services Availability Verbal interpretation Verbal interpretation shall be available through an interpreter in person upon a member's request or by telephone 24 hours a day and seven days a week. Written translation All written materials to members shall be available in threshold languages as determined by GHC-SCW. Cultural sensitivity Practitioners and staff shall encourage members to express their spiritual beliefs and cultural practices, be familiar with and respectful of various traditional healing systems and beliefs and, where appropriate, integrate these beliefs into treatment plans. 37 Provider Access Availability After- hours access A PCP or designee shall be available 24 hours a day, seven days a week to respond to afterhours member calls or to a hospital emergency room practitioner. Telephone Triage Telephone triage shall be available 24 hours a day, seven days a week. PCP access 90 percent of members shall have a PCP within 10 miles or 30 minutes from the member’s residence. PCP availability Ratio of physician PCPs to members of 1: 2,000 Hospital and ancillary facility access Within 15 miles or 30 minutes from a member’s residence or place of business 13.3 Encounter Data Submission GHC-SCW encourages providers to document patient health information accurately because this information is permanently a part of the member’s medical record. Below are some important reminders about data submission: • Each GHC-SCW provider is responsible for collecting the data and providing it to GHC-SCW. • To help ensure a complete data encounter accurately, report ICD-9-CM diagnosis codes, including secondary diagnoses, to the highest level of specificity. • Maintain accurate and complete medical record documentation (ICD-9 codes submitted should have proper documentation in the medical record) • Alert GHC-SCW of any erroneous data that has been submitted. • Report encounter data within 30 days of the date of service. • Member risk scores are based on acute, chronic and status conditions documented in the members’ medical record. In our view, “if it wasn’t documented, it didn’t happen.” • Every encounter with a patient is an opportunity to assess health and comprehensively document chronic conditions, co-existing acute conditions, active status conditions, and pertinent past conditions. • The most common issues with documentation is that it is not sufficiently thorough. The following conditions are frequently not documented or documented correctly: o Major depression (rather than depression) o Old myocardial infarction o Renal failure o Diabetes with complications o Angina pectoris o Breast, prostate, colorectal cancers coded as “history of’ rather than active o Protein calorie malnutrition o Amputation status o Drug or alcohol dependency o Tracheostomy status or respirator dependence 38 For more information or additional questions about encounter data, please contact the Coordination of Benefits Department at (608) 251-4138. 13.4 Cultural Competency Cultural competency is the ability of individuals, as reflected in personal and organizational responsiveness, to understand the social, linguistic, moral, intellectual, and behavioral characteristics of a community or population, and translate this understanding systematically to enhance the effectiveness of health care delivery to diverse populations. Members are to receive covered services regardless of: race, ethnicity, national origin, religion, gender, age, gender identification, mental or physical disability, sexual orientation, genetic information or medical history, ability to pay, or ability to speak English. GHC-SCW expects providers to treat all members with dignity and respect as required by federal law. Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and national origin in programs and activities receiving federal financial assistance, such as Medicaid. Most importantly, to the extent possible, GHC-SCW strives to meet recipient needs by developing and maintaining a provider network that mirrors the racial, ethnic and linguistic composition of our members. 13.5 Interpreter Services Federal and state regulations require interpreter services to be provided to members with limited English proficiency. Limited English proficient members include those who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English. Documenting Interpreter Services: Regulations require that GHC-SCW, and its health network providers to offer free interpreter services to limited English proficient members, and ensure that the interpreters are professionally trained and are versed in medical terminology and health care benefits. Because of these requirements, it is important that providers document when members use or refuse to use interpreter services. Documenting refusal of interpreter services in the medical record not only protects the provider and the provider’s practice, it also ensures consistency when medical records are monitored through site reviews/audits to ensure adequacy of Language Assistance Programs. Below are some tips on documenting for interpreter services: 1. GHC-SCW recommends using professionally trained interpreters and documenting the use of the interpreter in the member’s medical record. 2. If the member was offered an interpreter and refused the service, it is important to note that refusal in the medical record for that visit. 3. Using a family member or friend to interpret should be discouraged. However, if the member insists on using a family member or friend, it is extremely important to document this in the medical record, especially if the chosen interpreter is a minor. 39 4. Consider offering a telephonic interpreter in addition to the family member/friend to ensure accuracy of interpretation. 5. For all limited English proficient members, it is a best practice to document the member’s preferred language in their electronic medical records. 13.6 Fraud and Abuse – Investigating and Reporting GHC-SCW takes matters of fraud and abuse very seriously. Strict policies and procedures related to health care fraud and abuse are in place to ensure that GHC-SCW staff is vigilant in identifying warning signs and responding appropriately. Examples of health care fraud include: • • • • • A person using someone else’s GHC-SCW Member ID card A member getting a bill for services not covered by GHC-SCW A member getting a bill for unnecessary services A member getting a bill for services not performed A supply or equipment company sending a bill (e.g., for a wheelchair or diabetic supplies) not ordered by the provider or incorrectly delivered to the member. To report suspected or known fraud and abuse, contact the GHC-SCW Compliance Department at (608) 662-4899 or the Compliance Hotline at (608) 662-4930 or toll free at (800) 605-4327. 40 SECTION 14 PROVIDER APPEAL PROCESS GHC-SCW is committed to a fair and thorough process for making medical management decisions. To ensure fair decision-making, GHC-SCW invites providers to discuss such decisions with the chief medical officer if necessary. 14.1 Appeal / Request for Hearing Providers have the right to request a hearing and appeal any decision of the GHC-SCW Peer Review Committee. The providers must request a hearing, in writing, within 30 days from the date the provider receives the Chief Medical Officer’s final decision and action plan. The request should be sent via certified mail to the Chair of the Peer Review Committee, 1265 John Q. Hammons Drive, Madison, WI 53717. 14.2 Waiver by Failure to Request a Hearing A provider who fails to request a hearing within the time and in the manner specified waives his/her right to any hearing or any appellate review to which he/she might otherwise have been entitled. Such waiver shall apply only to the matters that were the basis for the initial review. 14.3 Notice of Time and Place for Hearing Upon receiving a timely and proper request for hearing, the Chief Medical Officer shall then schedule a hearing. Within fifteen (15) business days of receipt of the request for hearing, the Chief Medical Officer shall send the provider, via certified mail, notice of the time, place and date of the hearing. The hearing date shall be within forty-five (45) days of the date the notice of hearing was sent to the provider. The notice of hearing must contain a concise statement of the provider’s alleged acts or omissions, a list of the specific or representative patient records in question, and/or the other reasons or subject matter forming the basis for the adverse action that is the subject of the hearing. 14.4 Appointment of Hearing Panel When a hearing has been requested in the manner specified above, the Chief Medical Officer shall appoint a hearing panel composed of the Chief of Staff, who shall Chair the panel, and no less than three (3) additional members whose practice is relevant to the issue addressed. This may necessitate the use of non-employed providers. The hearing panel shall be composed of members of the medical staff who have not participated actively in consideration of the matter involved at any previous level. Knowledge of the reasons or subject matter forming the basis for the adverse action or recommendation, which gave rise to the request for a hearing, shall not preclude a member of the medical staff or other person from serving as a member of the hearing panel. 41 14.5 Attendance/Representation The provider may attend the hearing in person or may submit written materials in lieu of their presence. The practitioner may be accompanied and represented at the hearing by an attorney or by another person of his/her choice. The provider shall inform the Chief Medical Officer in writing of the name of that person at least ten days prior to the hearing date. GHC-SCW shall appoint an individual to represent them. Such individual may be an attorney or any other person designated by the Chief Medical Officer. 14.6 Rights of Parties During the hearing, each party shall have the following rights: a) call and examine witnesses; b) introduce exhibits; c) cross-examine any witness on any matter relevant to the issues; d) rebut any evidence e) to have a record made of the proceedings, copies of which may be obtained by the appellant upon payment of reasonable charges for the preparation thereof; 14.7 Postponement Requests for postponement or continuance of a hearing may be granted by the Chief Medical Officer only upon a timely showing of good cause. 14.8 Hearing Panel Report Within twenty (20) days after adjournment of the hearing, the hearing panel shall make a written report of its findings and recommendations. The report shall contain a summary of the basis of the decision. The hearing panel shall forward the report along with the record and other documentation to the Chief Medical Officer. The provider shall also be given a copy of the report. 14.9 Notification of Authorities As required by the Health Care Quality Improvement Act of 1986, as amended and 45 Code of Federal Regulations Part 60, the Chief Medical Officer or his/her designee shall report to the State Medical Examining Board and/or the National Practitioner Data Bank (NPDB) in accordance with the respective state and federal regulations. Incidents requiring reporting include, but are not limited to: contract suspension/termination due to quality reasons; involuntary reduction of current clinical privileges; suspension of clinical privileges; termination of all clinical privileges. All submissions will be reviewed by corporate council prior to notification to authorities. 42 SECTION 15 CONFIDENTIALITY The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal regulation that requires GHC-SCW and its providers to protect the privacy and security of its members’ Protected Health Information (PHI). This includes, but is not limited to, ensuring that their right to file a complaint, amend or restrict the use or disclosure of their PHI is honored in a timely manner. Because patient information is critical to carrying out treatment, payment, and health care operations, GHC-SCW supports and encourages the efforts of providers and other staff to work collaboratively to comply with HIPAA requirements. GHC-SCW Network Providers are encouraged to visit the Office of Civil Rights website at http://www.hhs.gov/ocr/privacy/index.html to determine whether its privacy practices align with federal regulations as well as the expectations of GHC-SCW. Protected health information (PHI) is any individually identifiable health information including but not limited to a member’s name, address, phone number, social security number, date of birth, medical, financial, and insurance information. Privacy protections at GHC-SCW are divided into two distinct components. The first describes the protections afforded to protected health information (PHI) collected, used, maintained, and disclosed internally within the organization. The second component addresses privacy protections in place for the GHC-SCW website, ghcscw.com. 15.1 Privacy within GHC-SCW Care provided at GHC-SCW is documented and stored in an electronic health record (EHR). This record contains identification and financial information as well as symptoms, diagnoses, test results, a description of the patient’s physical examination and a treatment plan. This information is used: • to plan for care and treatment • for communication among healthcare providers • as a legal document describing the care received • as a way for the insurance company to verify the services provided • to help GHC-SCW review and improve health care and outcomes • for other similar activities that allow GHC-SCW to conduct business efficiently and provide the patient with high quality health care The GHC-SCW Notice of Privacy Practices (“Notice”) provides the patient with the following important information: • • • How we use and disclose protected health information (PHI) Patient privacy rights with regard to protected health information (PHI) GHC-SCW’s obligations to our patient’s concerning the use and disclosure of PHI The terms of the Notice apply to all designated GHC-SCW records containing PHI that are created and maintained by the organization. The Notice is posted at the entrance to each clinic and is readily available to our patients in the form of a brochure within our clinical locations and also available by contacting the GHC-SCW Privacy Officer at (608) 662-4899 or toll free at (800) 605-4327. 43 At any time, the patient may request a copy of the Notice. It is the expectation of GHC-SCW that our affiliated health care partners maintain, provide and post a copy of their Notice of Privacy Practices in accordance with the provisions of the HIPAA Privacy Rule. GHC-SCW provides care and administers health insurance benefits to our patients in partnership with physicians and other health care professionals and organizations. Our privacy practices are observed by: • • • Any of our health care professionals who care for patients at any one of our locations (e.g. nurses, lab technicians, billing staff) All locations and departments that are part of our organization; and All members of GHC-SCW’s workforce including employees, students, contractors, interpreters and interns GHC-SCW participates in a regional arrangement of health care organizations, who have agreed to work with each other to facilitate access to health information that may be relevant to their care. As a result of this sharing, other health care organizations may directly access the PHI of GHC-SCW for the provision of care and treatment. 15.2 How GHC-SCW Will Use and Disclose Patient’s Protected Health Information In accordance with the requirements of the HIPAA Privacy Rule, we may use and disclose PHI without authorization for the following purposes: • • • • • • • • • • • • • • 15.3 Treatment, payment and health care operations Information Provided to the Patient for the Patient Appointment Reminders Disclosures Required by Law Correctional Institutions, law enforcement and victims of abuse, neglect or violence Public health, public safety and research Health oversight activities Judicial and administrative proceedings Coroners or Medical Examiners and Organ and Tissue Donation National security Worker’s compensation Plan sponsor disclosures (for enrollment and disenrollment purposes only) Health information marketing functions and disclosure of PHI after death To those involved with care or payment When GHC-SCW is required to Obtain Patient Authorization Prior to Use or Disclosure of PHI Except as described within the Notice of Privacy Practices, GHC-SCW will not use or disclose PHI without the patient’s written authorization. For example, uses and disclosures made for the purpose of psychotherapy, marketing, disclosures to plan sponsors and sale of PHI require patient authorization. If authorization is granted, it may be revoked at any time by contacting the GHC-SCW Privacy Officer at (608) 662-4899 or toll free at (800) 605-4327. 44 15.4 Safeguarding PHI PHI in Paper Form In the Office PHI located in work areas such as provider’s office, nurse’s stations and reception desks should be turned upside down at attended desks and in a locked drawer or file cabinet when unattended. Paper PHI should never be left in an unattended exam room or patient care area. Verify fax numbers prior to sending the fax. Fax Outgoing faxes must include a fax cover sheet, which contains a confidentiality disclaimer. Incoming faxes should not be left unattended on fax machines or common work areas during non-business hours and retrieved promptly during business hours. Verify the accuracy of contents to envelope information prior to sending. Mail Envelopes or packages must be securely sealed prior to sending. Envelopes for mailings that contain PHI must contain the name of the GHC-SCW sender in the return address area. Paper PHI utilized in remote (e.g. home or travel) locations must be afforded heightened privacy protections. If unattended, PHI must be properly secured. Handling PHI Offsite or a Remote Location If paper PHI is lost or stolen, it must be reported immediately to the proper person in authority at that facility. Loss or theft of paper containing PHI must be evaluated in accordance with the HIPAA Breach Notification Rule. Disposal Documents containing PHI must be properly shredded or destroyed. 45 PHI in Electronic Form Internal Email: Internal e-mail within the GHC-SCW Network should be used only for business purposes unrelated to patient care. The electronic health record (EHR) should be used for such reasons to ensure proper documentation guidelines are achieved. If use of e-mail within the GHC-SCW Networks is essential, its content must be limited to the minimum necessary amount of information required to accomplish the intended task and should not include PHI in the subject line. Email External Email: E-mail sent to external entities may include PHI only if the sender’s computer has been equipped with a secure encryption function. The sender’s e-mail must contain a disclaimer to ensure that mis-directed e-mails are managed appropriately. Patients may not use e-mail as a means of communicating with their provider(s). The appropriate tool for patient-provider communication is either GHCMyChart or telephone. Portable electronic devices containing PHI, such as laptops, tablets, or cell phones, must be encrypted and password-protected. Portable Electronic Devices If such devices are lost or stolen, it must be reported immediately to the proper person in authority at that facility. Loss or theft of portable devices containing PHI must be evaluated in accordance with the HIPAA Breach Notification Rule. Disposal 15.5 PHI in an electronic format must be destroyed or disposed of in a secure manner in accordance with the requirements of the HIPAA Security Rule. Statement of Patient’s Health Information Rights Patients have the right to: • • • • • • • • Inspect and copy health information Request restrictions Request confidential communications Request record amendment Request an accounting of disclosures Receive notification of a breach of protected health information Receive a copy of the Notice of Privacy Practices File a privacy complaint 46 To exercise any of these rights, the patient may contact the GHC-SCW Privacy Officer directly by: • • • • • 15.6 Telephone at: (800) 605-4327 or (608) 662-4899 E-mail to: jcoleman@ghcscw.com Fax to: (608) 662-4965 Mail to: GHC-SCW Privacy Officer at 1265 John Q. Hammons Drive, Madison, WI 53717 Web: ghcscw.com Internal Protection of Oral, Written and Electronic PHI across the Organization GHC-SCW will maintain adequate management controls to ensure appropriate access to PHI regardless of format or location. Oral, or verbal, access is protected through an ongoing process of education such as encouraging staff to be aware of their physical surroundings and the use of a moderate voice tone and volume when in work environments where such discussion may be overheard by those with no need to know. Protection of written PHI is assured by providing ongoing education and training to staff and periodic site audits to evaluate compliance with laws and regulations governing such environments. To ensure protection of electronic PHI, the organization utilizes role-based access. This process limits employee access to that PHI specifically required to carry out his/her work functions. For example, a physician may need access to problem lists and medications while an insurance representative may need only referral and claims information. Electronic audit trails collect specific information about each keystroke made into the EHR permitting retrospective review of employee access to confirm appropriateness. Employees must complete annual HIPAA Privacy Training, including re-signing of the Confidentiality Agreement. Other activities and publications designed to emphasize expectations for privacy protections occur throughout the year. 15.7 GHC-SCW Website Privacy Protections The Website Privacy Statement and the Website Terms and Conditions statements provide detailed information about GHC-SCW’s efforts to maintain the privacy of information collected, maintained, used, stored and disclosed on the site. The nature of this information is different than that referenced in the “privacy within GHC-SCW” portion of this document. 15.8 Personal Information vs. Non-Personal Information “Personal Information” means information that specifically identifies a user as an individual, such as full name, telephone number, e-mail address, postal address, or certain account numbers. The website may include web pages that give the user the opportunity to provide this personal information. A user does not, however, have to provide the information if they do not wish to do so. GHC-SCW may use personal information for the following purposes: • To respond to an e-mail or particular request about the user • To personalize the website • To process an application requested by the user • To administer surveys and promotions • To provide information that may be useful to the user, such as information about health care products or services provided by GHC-SCW or other businesses • To perform analytics and to improve our products, website and advertising 47 • • • • • To comply with applicable laws and regulations To protect someone’s health, safety or welfare To protect our rights, the rights of affiliates or third parties, or take appropriate legal action, such as to enforce our Terms and Conditions To keep a record of our transactions and communications As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law “Non-Personal Information” means information that does NOT permit us to specifically identify our patients by name or similar unique identifying information such as a social security number, member number, address or telephone number. Non-personal information may be used, unless restricted by law or by this statement, for the following purposes: • Customizing the user experience on the website including managing and recording preferences • Marketing, product development and research purposes • Tracking resources and data accessed on the website • Developing reports regarding site usage, activity and statistics • Assisting users experiencing website problems • Enabling certain functions and tools on the website • Tracking paths of visitors to the site and within the site 15.9 Sharing Personal Information GHC-SCW will only share personal information as outlined in the GHC-SCW Terms and Conditions or this statement. We do not sell or rent personal information about visitors to this site or customers who use this site. We may share information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors. If information is submitted to a chat room, bulletin board, or similar “chat-related” portions of this website, the information you submit, along with your screen name, will be visible to other visitors, and such visitors may share with others. We may share personal information with other companies that we hire to perform services on our behalf or collaborate with. 48 APPENDIX – A POLICIES AND PROCEDURES A.1 HEALTH PLAN INFORMATION A.2 EPICLINK USER MANUAL A.3 PHARMAUCEUTICAL MANAGEMENT PROGRAM A.4 CREDENTIALING AND RE-CREDENTIALING A.5 PEER REVIEW COMMITTEE A.6 MEMBER RIGHTS AND RESPONSIBILITIES A.7 ULTLIZATION MANAGEMENT PROGRAM DESCRIPTION A.8 COMPLEX CASE MANAGEMENT PROGRAM DESCRIPTION A.9 ASTHMA DISEASE MANAGEMENT PROGRAM A.10 DIABETES DISEASE MANAGEMENT PROGRAM A.11 HEART AND VASCULAR DISEASE MANAGEMENT PROGRAM 49 APPENDIX A.1 . GHC-SCW Departments: Health Education…..……. (608) 662-4924 Care Management……….. (608) 257-5294 or (800) 605-4327, ext. 4514 Quality Management.…… (608) 257-9705 Mental Health……………… (608) 441-3290 Language Assistance: TTY……………………………. (608) 257-7391 Interpreter Services ……… (608) 828-4853 or (800) 605-4327, press 0 and ask for Member Services Gateway Recovery…………………... (608) 278-8200 Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O Group Health Cooperative of South Central Wisconsin MK11-137-2(08/13)O APPENDIX A.3 _________________________________________ APPROVAL as appropriate: Board _________Exec Dir _________ Med Dir _________ Other Dir/Mgr _________ _________________________________________ REVIEWED BY LEGAL COUNSEL Date: x Yes ___No ___ Name: x __________________________________________ POLICY STATUS: _x__ Approved ___Pending Policy and Procedure Title: Author: Volume: Pharmaceutical Management Program P. Baum Div/Dept/Serv Area: Pharmacy V Number: CL.PH.BEN.008 Date of Issue: 5/00 Page 1 of 4 Formerly B2b.050 (4/08), PH,033 PURPOSE: The purpose of this policy is to articulate the Pharmaceutical Management Program of Group Health Cooperative of South Central Wisconsin (GHC-SCW). POLICY: The GHC-SCW Pharmacy promotes and supports rational and cost-effective use of pharmaceuticals in compliance with NCQA guidelines for pharmaceutical management. PROCEDURE: 1. Adoption of Policies and Procedures a. Criteria used to adopt pharmaceutical management procedures. 1) The pharmaceuticals covered will include multiple options for most drug classes that are not excluded by the insurance contract. 2) The Formulary Committee will evaluate which pharmaceuticals within drug classes will be covered, taking into account the relative safety, effectiveness, and value of the pharmaceuticals. Other factors that may be considered in the evaluation include FDA approval: anticipated demand; addressing a medical need; quality of published studies. The Formulary Committee will also determine criteria for prior authorization for pharmaceuticals that require it. 3) When coverage limits exist for specific pharmaceuticals, they will be noted within the Formulary document. 4) An exceptions process for obtaining non-covered pharmaceuticals will conform to NCQA standards. b. Evaluations will use clinical evidence from appropriate external organizations. 1) Information from external organizations is obtained prior to changes in the drug formulary. 2) Information obtained is presented to the Formulary Committee for evaluation. 3) External organizations used include medical and pharmacy literature, University of Wisconsin Center for Drug Policy, U. S. Food and Drug Administration and its advisory panels, pharmaceutical industry news, and consultant-specialist recommendations. Review Date Revision Date 6/04 9/01 7/13 9/05 9/01 12/13 9/07 9/03 9/09 6/04 9/06 10/08 10/10 7/11 7/12 Policy and Procedure Title: Pharmaceutical Management Program Policy Number: CL.PH.BEN.008 Page 2 of 4 c. Procedures will be developed and approved by the Formulary Committee, Medical Director, and appropriate oversight committees. 1) The Formulary Committee is composed of practitioners and pharmacists. Membership is by appointment of the Medical Director. The Medical Director retains the right of final approval of Committee actions. The Pharmacy Services Manager serves as chair of the Committee. 2) Specialist recommendations are sought and made available to Committee members for all new drug evaluations and for other relevant topics. The Committee Chair may invite a specialist to actively participate in a given meeting. d. Availability of pharmaceutical management procedures. 1) The Formulary Committee will review and approve changes to Pharmaceutical Management Procedures annually, and additionally as needed. The most current Procedures will be posted on the health plan website. 2) New drugs may be added to the drug formulary subsequent to each Formulary Committee meeting. The most current Procedures will be posted on the health plan website. 3) Members’ financial responsibility will be identified on Formulary documents by Tier category. Members’ plan Benefits Summary information will specify the actual copayment or coinsurance for each Tier. 2. GHC-SCW maintains a list of pharmaceuticals covered under the drug benefit, which includes restrictions, and makes this information available to members and practitioners. a. The current drug Formulary will be available on the web, and changes will periodically be published in member communications. b. The Formulary will include information on how to use it. c. The Formulary will include information on restrictions or limits that may apply. 1) Pharmaceuticals on the Formulary are not restricted (beyond the terms of the certificate of insurance) unless noted within the Formulary. An example would be a quantity limit on a specific drug, as approved by the Formulary Committee. 2) Drugs listed on the formulary do not require prior authorization unless specifically noted and are subject to the cost sharing and quantity limits as described in their plan’s certificate of coverage. 3) Exceptions to the quantity limits may be established by the Medical Director and/or the Pharmacy Services Manager. 4) The GHC-SCW Board of Directors has authority to make changes to the certificate of coverage. d. Practitioners must provide information to support an exceptions request, establishing that: 1) A reasonable number of similar drugs that are on the formulary have been tried; 2) The formulary drugs were tried with an adequate dose and duration of therapy; Policy and Procedure Title: Pharmaceutical Management Program Policy Number: CL.PH.BEN.008 Page 3 of 4 3) The formulary drugs were not tolerated or were not effective; and 4) The requested drug therapy is evidence-based and generally accepted medical practice. e. Related processes: generic substitution, therapeutic interchange, and step therapy. 1) Generic substitution is addressed in the Outpatient Prescription Drug Rider, which may provide for a cost penalty for choosing a brand when an approved generic is available, or identify a copayment tier for branded versions of generic pharmaceuticals. 2) Therapeutic interchange is not part of the GHC-SCW pharmaceutical management program. 3) Pharmaceuticals on Formulary subject to step-therapy will be identified on Formulary documents. 3. Clinical and Patient Safety Programs a. GHC-SCW will utilize a prescription claims system that identifies and classifies potential drug interactions. It will utilize a generally recognized reference source (e.g., Medispan) to identify and classify interactions and utilize prescriptions in the Claims database, i.e., written by any prescriber and dispensed by any practitioner the plan is aware of due to on-line prescription claim submissions. b. GHC-SCW will notify the dispensing practitioner at the point of dispensing of potential interactions by using a prescription claims system that responds in real-time when a prescription claim is submitted on-line. c. GHC-SCW will identify patients and prescribers affected by a Class II recall or a voluntary withdrawal from the market for safety reasons, by query of the central prescriptions claims database. Prescribers will be supplied the identity of the patients affected by this before communication goes to the patients. This process will be completed within thirty (30) calendar days of the FDA notification. This procedure does not apply if the recall is issued at the wholesale-level only. d. GHC-SCW will identify members and prescribers affected by a Class I drug recall by query of the central prescription dataset. Notification will be sent to patients and prescribers as quickly as possible, but no later than seven (7) calendar days of FDA notification 4. Review and Updating pharmaceutical management procedures. a. The Formulary Committee will review and approve changes to pharmaceutical management procedures annually and additionally as needed to respond to practitioner, member, or pharmacist requests, or to address new drug approvals or information. b. The Formulary Committee will review and revise the list of covered pharmaceuticals at scheduled meetings. Revisions to the list may occur subsequent to each meeting. 5. Exceptions Process a. Requests for formulary exceptions may be made by the practitioner or the member by contacting GHC-SCW Pharmacy Services by telephone or fax. Practitioners who use GHC-SCW’s electronic prescribing system may Policy and Procedure Title: Pharmaceutical Management Program Policy Number: CL.PH.BEN.008 Page 4 of 4 also submit a request by choosing the class of “Prior Auth” when electronically ordering a medication. Members may use the secure GHC-SCW MyChart website “Ask the Pharmacy” function to submit a request. b. Formulary exceptions must be based on medical necessity. Any member-generated request will be forwarded to the member’s practitioner to obtain documentation of medical necessity before evaluation of the request occurs. c. (See also Section 2c: “Practitioner provides information supporting the request”.) When the information submitted to support an exceptions request is insufficient to establish medical necessity, Pharmacy Services will contact the practitioner to obtain additional information. d. The request is initially reviewed by Pharmacy Services. If the drug requested has specific written criteria established and the request includes information supporting that the criteria are met, the request may be approved. If support is unclear (or for any drugs without specific written criteria), the request is referred to a pharmacist for review. The pharmacist may consult as necessary with a specialist, Medical Doctor, or other practitioner as appropriate before making a decision. e. Exception requests will be handled in a timely manner. 1) Urgent (pre-service) requests will be decided and responded to within one (1) business day of receipt. (Urgent request are those that could seriously jeopardize the life or health of the member or the member’s ability to regain maximum function based on a prudent layperson’s judgment, or, in the opinion of a practitioner with knowledge of the member’s medical condition, would subject the member to severe pain that cannot be adequately managed without the care or treatment that is the subject of the request.) 2) Non-urgent (pre-service) requests will be decided and responded to within three (3) business days of receipt. 3) If additional information is requested from the practitioner, the request will be pended for an additional five (5) business days. Lack of response to a request for additional information after the additional period will result in a denial of that request. If and when additional supporting information is provided, it will be treated as a new exception request. f. Pharmacy Services is responsible for notifying the member and requesting practitioner of the decision. Denials will further include the reason for denial and an explanation of the plan’s formal appeals process. Approval notification may be made verbally, electronically, or in writing. Denials to members will be made in writing. Practitioners will be notified electronically, via fax, or in writing. APPENDIX A.4 _________________________________________ APPROVAL as appropriate: Board _________Exec Dir _________ Med Dir _________ Other Dir/Mgr _________ _________________________________________ REVIEWED BY LEGAL COUNSEL Date: x Yes ___No ___ Name: x __________________________________________ POLICY STATUS: _x__ Approved ___Pending Policy and Procedure Title: Author: Volume: Credentialing and Re-credentialing/HEDIS Process M. Ostrov, MD Div/Dept/Serv Area: Medical Division 7/94 Page 1 of 22 VI Number: MED.ADM.025 Date of Issue: Formerly A1a.150 (2/08)/MED.025 (1/12) PURPOSE: The purpose of this policy is to document the Credentialing and Re-credentialing /HEDIS Process for Assessment of Practitioner Board Certification at Group Health Cooperative of South Central Wisconsin (GHC-SCW). POLICY: 1. In order to promote the highest quality of care for Group Health Cooperative of South Central Wisconsin (GHCSCW) members, GHC-SCW ensures that all employed and contracted practitioners and providers meet minimum standards relative to licensure, education, and board certification, if applicable. The licensure, educational, and board certification is verified by the collection of specific credentials on a routine basis. 2. Medical practitioners requiring credentialing are defined as Medical Doctor (MDs), Doctor of Osteopathic Medicine (Dos), Oral Surgeons, Doctor of Podiatric Medicine (DPMs), Doctor of Chiropractic (DCs), Nurse Practitioners (NPs), Physician Assistants (PAs), Optometrist (ODs), Physical Therapists (PTs), Occupational Therapists (OT), Certified Nurse Midwives (CNM) and Speech/Language Therapists. Behavioral Health practitioners requiring credentialing are defined as physicians and psychiatrists (MD or DO); masters or doctorate level psychologist who are state licensed (PhD or PsyD); licensed Advanced Practice Nurse Prescribers (APNP); masters or doctorate level Licensed Clinical Social Workers (LCSW); Licensed Marriage & Family Therapists (LFMT); Licensed Professional Counselors (LPC); and licensed Clinical Substance Abuse Counselors (CSAC) who are certified to practice independently. 3. Providers are defined as Hospitals, including Behavioral Health inpatient services; Home Health agencies; Skilled Nursing facilities; Free Standing Surgical Centers and Behavioral Health Residential and Ambulatory facilities. 4. OVERSIGHT, PRACTITIONER RIGHTS, AND CONFIDENTIALITY a. OVERSIGHT AND ACCOUNTABILITY 1) As part of the GHC-SCW Quality Improvement Program, GHC-SCW has adopted standards for credentialing. These standards are described in Policy Items 5a, 5b, and Procedure Item 3 of this Attachment. 2) The GHC-SCW Board of Directors through the Health Services Committee has delegated the responsibility of practitioner credentialing to the Medical Director. The Medical Director, in turn, delegates the credentialing process to the GHC-SCW Peer Review/Credentialing Committees. GHC-SCW’s Credentialing Committee is the same body as the GHC-SCW Peer Review Committee which reviews all credentialing/re-credentialing applications with or without exceptions (malpractice, sanctions, pending claim, etc) Final approval for credentialing all practitioners is done by the Medical Director after reviewing recommendations from the Credentialing Committee and the information obtained during the credentialing process. Review Date Revision Date 3/95 1/05 1/97 1/07 5/97 2/08 2/98 1/09 3/99 12/09 2/00 2/11 2/01 1/12 7/02 2/13 7/03 1/04 Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 2 of 21 3) The GHC-SCW Medical Director or the Quality Management MD Liaison chairs the Credentialing Committee which approves the credentialing & re-credentialing of the staff model MDs and DCs, all PCPs in the Department of Family Medicine and in the UW Health Clinics, direct contract psychiatrists, and all behavioral health practitioners. 4) GHC-SCW’s Credentialing Committee makes credentialing and re-credentialing decisions based solely on the verified information provided on the practitioner’s applications. GHC-SCW does not discriminate against an applicant based on race, ethnic/national identity, gender, age, sexual orientation, or types of procedures or types of patients (e.g. Medicaid) the practitioner specializes in. 5) GHC-SCW recognizes the need to expedite the approval of clean credential files and may approve clean credential files outside of the regularly scheduled Credentialing meetings. Clean credential files are defined as initial or re-credential files whose primary source verification elements (outlined on the GHC-SCW Initial and Re-Credentialing Checklists) are complete and without questions or concerns and the files meet the necessary requirements eligible to be approved by the GHC-SCW Credentialing Committee. Clean files may be approved by the GHC-SCW Medical Director or the Quality Management MD Liaison or designee outside of the regularly scheduled Credentialing Committee meeting. The Medical Staff Coordinator (MSC) is responsible for completing the GHC-SCW Initial and/or Re-Credentialing Checklist and will present clean files to either the Medical Director or the Quality Management MD Liaison or designee for review and approval. The Medical Director or the Quality Management MD Liaison or designee will sign and date the GHC-SCW Checklist as indication of approval. A list of the files approved outside of the regularly scheduled meeting will be presented at the next Credentialing Committee meeting. 6) GHC-SCW’s Credentialing Committee receives and reviews the credentials of all practitioners, including those who do not meet the organization’s established criteria. GHC-SCW’s Medical Director or Quality Management MD Liaison monitors for nondiscriminatory credentialing and re-credentialing by reviewing every file that is denied in the credentialing process to ensure that there has been no discrimination. The Medical Director or Quality Management MD Liaison performing the review will be the one who did not chair the Credentialing Committee meeting when the application was denied. GHC-SCW’s Medical Director or Quality Management MD Liaison will forward the result of their review to the Credentialing Committee, and the result of his/her review will be documented in the Credentialing Committee minutes. 7) In addition, all applications that are received by the MSC but are not taken to the Credentialing Committee will be reviewed by the Medical Director or Quality Management MD Liaison. The individual conducting the review for potential discrimination will be the one not involved in the processing of the application. 8) Annually, all Credentialing Committee members are required to sign an affirmative statement that they will make decisions in a non-discriminatory manner. 9) GHC-SCW prevents discrimination of credentialing and re-credentialing by maintaining a heterogeneous credentialing committee and requiring those responsible for credentialing decisions to sign a statement affirming that they do not discriminate applicants and re-applicants on the basis of race, ethnicity/national identity, age, gender, sexual orientation, disability status, type of procedures or type of patients. 10) Appropriate documentation for a GHC-SCW credential file must include primary source verification documentation in one of two ways: Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 3 of 21 a) A detailed, signed/initialed and dated checklist where the checklist contains the name of the source used, the date of the verification, the signature or initials of the credentialing professional who performed the primary source verification and the date of the report, if applicable; or b) Copies of credentialing information and a checklist. GHC-SCW may use an electronic signature or unique electronic identifier of staff to document verification if it can demonstrate that the electronic signature or unique identifier can only be entered by the signatory. The system must identify the individual verifying the information, the date of verification, the source and the report date, if applicable. 11) GHC-SCW will maintain credential and re-credential files for all practitioners that are not delegated for not less than a six (6) year period to ensure the current credentialing and previous credentialing cycle are available. 12) The decision making process for initial and re-credentialing of GHC-SCW practitioners and providers is achieved through the use of a standardized and objective set of criteria set forth in Policy Items 5a and 5b and Procedure Item 3 below. b. PRACTITIONER RIGHTS 1) Practitioners have the right to review the information submitted in support of their credentialing applications with the exception of references, recommendations or other peer-review protected information. Should any information obtained during the credentialing and re-credentialing process vary substantially from the information provided by the practitioner, the MSC will notify the practitioners in writing within 10 days of becoming aware of the discrepancy. The practitioner has the right to correct erroneous information and is requested to respond, in writing, with additional information to support a correction. Practitioners have up to 30 days to submit written corrections to the MSC. The MSC will respond by telephone, United States Postal Service or by email to the practitioner within seven (7) calendar days of receiving the corrections. 2) Practitioners have the right, upon request in writing to the MSC, to be informed of the status of their credentialing or re-credentialing applications. The MSC will respond by telephone, United States Postal Service or by e-mail to the practitioner within seven (7) calendar days of the status of their credentialing or recredentialing application. 3) In the event an application and attestation must be updated, only the practitioner may attest to the update, a staff member may not sign on behalf of the practitioner. 4) Practitioners have the right to receive notification of the above rights. GHC-SCW notifies applicants of their Practitioner Rights at the time of initial and re-application in a statement on the initial application form and in the letters that accompanies the initial and re-credentialing application. 5) MSC will notify practitioners in writing of credentialing decisions (decisions include acceptance, denial or if additional information is required to process the application or re-application) within 60 calendar days of the Credentialing Committee decision. c. CONFIDENTIALITY OF INFORMATION 1) The information obtained in the credentialing process is confidential. Access to information obtained throughout the credentialing process will be carefully monitored and will not be released to outside parties Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 4 of 21 without permission of the practitioner involved or by legal responsibility, including the Health Care Quality Improvement Act of 1986. 2) The credentialing files will only be available to GHC-SCW’s Credentialing Committee, Credentialing Staff and GHC-SCW’s Medical Director. Credentialing files and minutes will be maintained in a locked, secure location. The individual practitioner may read information contained in his/her file upon request of a scheduled appointment. The file review will take place in the presence of GHC-SCW MSC. 5. CREDENTIALING OF STAFF (EMPLOYED) PHYSICIANS, DANE COUNTY PCPs, BEHAVIORAL HEALTH PRACTITIONERS, CHIROPRACTORS a. The credentialing verification activities for these practitioners are performed by GHC-SCW. b. INITIAL CREDENTIALING (See Checklist) 1) The following is a listing of the items that must be present and will be verified. The criteria and the source of verification is listed below: 2) GHC-SCW requires that the eligible practitioner holds a valid, current, unrestricted license in the State of Wisconsin. Primary source verification is completed by receipt of written verification directly from the appropriate state licensing agency or verification via the WI State licensing web page at http://online.drl.wi.gov/LicenseLookup/LicenseLookup.aspx is acceptable. 3) GHC-SCW requires that the eligible practitioner, if applicable, holds a valid, current DEA in the State of Wisconsin. Primary source verification of DEA is completed by query of the Drug Enforcement Administration (DEA) Registration File from NTIS (CD ROM received quarterly) OR by the MSC viewing a photocopy of the DEA. The DEA must be valid in the state where the practitioner provides care to GHCSCW members. If practitioner type is eligible for a DEA (i.e. MD, DO, DPM, APNP, PA-C or OD) but does not have a DEA, the practitioner must explain why no DEA AND provide explanation of arrangements for his/her patients who need prescriptions requiring DEA certification. If a practitioner’s DEA is pending, a written plan will be documented in the provider’s credential file, which allows a practitioner with a valid DEA certificate to write all prescriptions requiring a DEA number for the prescribing practitioner until the practitioner has a valid DEA. 4) GHC-SCWs requirement for completion of education is based on the practitioner type. Primary verification of highest level of education is outlined by the following provider types: a) MD and DO (1) Board Certification is preferred, but not required by GHC-SCW. If the physician is board certified, primary source verification of board certification satisfies the verification of highest level of education. (2) For MDs, GHC-SCW will verify board certification via the American Board of Medical Specialties (ABMS) thru CeriFACTS on line (password protected). GHC-SCW only recognizes those board associated with the ABMS. For those ABMS Boards who do no provide an expiration date, GHCSCW will verify the board certification within 180 days of the initial or re-credentialing decision date. (3) For DOs, GHC-SCW will verify board certification via the American Osteopathic Association (AOA) Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 5 of 21 Board Certification. GHC-SCW will contact the Board, in writing, online, or by phone for primary source verification. (4) For practitioners who are not board certified, GHC-SCW requires the physician to complete a residency program. Acceptable residency programs include only those residency programs that have been accredited by the Accreditation Council for Graduate Medical Education (ACGME) and the American Osteopathic Association (AOA) in the United States or by the College of Family Physicians of Canada (CFPC) or the Royal College of Physicians and Surgeons of Canada. GHCSCW will contact the residency program in writing or by phone for primary source verification OR verification of licensure from the State of Wisconsin Department of Safety & Professional Services website satisfies the verification of highest level of education. (5) For practitioners who did not complete a residency, primary source verification is completed by contacting the medical school b) DPM (1) Board Certification is preferred, but not required by GHC-SCW. If the physician is board certified, primary verification of board certification satisfies the verification of highest level of education. Verify via the American Board of Podiatric Surgery Board Certification. GHC-SCW MSC will contact the Board, in writing for primary source verification (2) If the physician is not board certified, GHC-SCW requires the physician to complete his/her education from a podiatry college. Primary source verification is completed by contacting the Podiatry school OR verification of licensure from the State of Wisconsin Department of Safety & Professional Services website satisfies the verification of highest level of education. c) DCs (1) GHC-SCW requires physician to complete his/her education from a Chiropractic College. Primary source verification is completed by contacting the Chiropractic College OR verification of licensure from the State of Wisconsin Department of Safety & Professional Services website satisfies the verification of highest level of education. d) NP, PA-C, OD, PT, Speech and Language Therapists and other Credentialed Providers (1) GHC-SCWs requirement for practitioner education is based on practitioner type. (2) Professional School –or(3) Primary Source verification is completed by confirmation from the WI Licensing Department, which performs primary source verification of education for all licensed practitioner types. (4) If the healthcare professional is board certified, primary source verification from the appropriate specialty board is completed. e) Oral Surgeon Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 6 of 21 (1) Board certificated is preferred, but not required by GHC-SCW. If the provider is board certified, primary verification of board certification is obtained from the appropriate specialty board if the board performs primary source verification of graduation from a CODA accredited training program. At least annually, the organization must obtain written confirmation from the specialty board that is performs primary-source verification of graduation from a CODA accredited training program. (2) For providers not board certified, verification of completion of a residency training program in Oral and Maxillofacial Surgery accredited by the Commission on Dental Accreditation (CODA). GHCSCW will contact the residency program in writing or by phone for primary source verification OR verification of licensure from the State of Wisconsin Department of Safety & Professional Services website satisfies the verification of highest level of education. 5) Annually, MSC obtains written confirmation from the WI Licensing agency that it performs primary source verification of education. 6) GHC-SCW requires the applicant to complete an application and attest to its correctness and completeness. The following questions must be addressed: a) Physical and mental health status and reasons for inability to perform essential functions of the position, with or without accommodations b) Chemical dependency or lack of illegal drug use c) History of loss of license and/or felony convictions d) History of loss or limitation of clinical privileges or disciplinary action e) Work history for the last five years in mm/yy to mm/yy format, and any gaps six (6) months or greater must be explained, in writing. f) Malpractice history g) Current coverage for malpractice insurance, including dates and amounts, even if the coverage amount is $0. h) Signature attesting to the correctness and completeness of the application 7) GHC-SCW requires a National Practitioner Data Bank (NPDB) report to be run on all applicants for verification of malpractice history and initial sanction information. The Committee will review all adverse NPDB reports. The MSC will obtain a query of the NPDB at https://www.npdb-hipdb.com/login.html. 8) The MSC will enroll all practitioners in the Proactive Disclosure Service (PDS) for NPDB and HIPDB. All enrolled practitioners are renewed annually. 9) If employment is terminated, the enrollment is canceled 30 days after termination date. 10) Any notifications from the PDS are sent via e-mail to the MSC including malpractice claims, Office of the Inspector General sanctions, and Department of Regulation and Licensing orders Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 7 of 21 11) Review of Medicare/Medicaid sanctions through the NPDB-HIPDB 12) Review of the Disciplinary Actions by the Medical Examining Board through the NPDB-HIPDB for MD, DO, Oral Surgeons, non-physician, and behavioral health care professional. c. For Chiropractors, GHC-SCW requires a query of the disciplinary actions from the National Practitioner Data Bank. The Committee will review all adverse NPDB-HIPDB reports. The MSC will obtain the query. d. For Podiatrists, GHC-SCW requires a query of the disciplinary actions through the State Board of Podiatric Examiners, The Federation of Podiatric Medical Boards, or the National Practitioner Bata Bank. The Committee will review all adverse reports. The MSC will obtain the query. e. Verification and completion of all of the above must be within 180 days prior to the date of the initial credentialing decision. f. The Credentialing Committee reviews the application and credentialing documents and makes recommendations to the Medical Director. A practitioner from the specialty of a practitioner being credentialed participates on the Credentialing Committee. g. Credentialing process is completed prior to a practitioner providing services to GHC-SCW members. h. If GHC-SCW terminates a practitioner and later wishes to reinstate the practitioner, GHC-SCW will credential and re-verify credentialing requirements, if the break in service is 30 days or more. GHC-SCW’s Credentialing Committee will review all credentials and make a final determination prior to the practitioner’s reinstatement. 6. RE-CREDENTIALING (See Checklist) a. GHC-SCW employed physicians; Dane County PCPs, Oral Surgeons, NPs, PA-Cs, ODs, PTs, OTs, Speech and Language Therapists, behavioral health practitioners, DCs and other credentialed providers are re-credentialed every three years. b. The following is a listing of the items that must be present and will be verified. The criteria and the source of verification is listed below: 1) GHC-SCW requires that the eligible practitioner holds a valid, current, unrestricted license in the State of Wisconsin. Primary source verification by receipt of written verification directly from the appropriate state licensing agency or verification via the WI State licensing web page:http://online.drl.wi.gov/LicenseLookup/LicenseLookup.aspx. 2) GHC-SCW requires that the eligible practitioner, if applicable, holds a valid, current DEA in the State of Wisconsin. Primary source verification of DEA is completed by query of the Drug Enforcement Administration (DEA) Registration File from NTIS (CD ROM received quarterly) OR by the MSC viewing a photocopy of the DEA. The DEA must be valid in the state where the practitioner provides care to GHCSCW members. If practitioner type is eligible for a DEA (i.e. MD, DO, DPM, APNP, PA-C or OD) but does not have a DEA, the practitioner must explain why no DEA AND provide explanation of arrangements for his/her patients who need prescriptions requiring DEA certification. If a practitioner’s DEA is pending, a written plan will be documented in the provider’s credential file, which allows a practitioner with a valid DEA certificate to write all prescriptions requiring a DEA number for the prescribing practitioner until the practitioner has a valid DEA. Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 8 of 21 3) GHC-SCW does not require board certification; however if a re-applicant is board certified, GHC-SCW must verify the board certification. Verify via the American Board of Medical Specialties (ABMS) thru CeriFACTS on line (password protected). GHC-SCW only recognizes those board associated with the ABMS or the AOA. For those ABMS Boards who do no provide an expiration date, GHC-SCW will verify the board certification within 180 days of the initial or re-credentialing decision date. 4) GHC-SCW requires continuous monitoring of adverse events through the NPDB/HIPDB and this is maintained through the PDS. 5) The MSC will maintain continuous enrollment of all practitioners in the Proactive Disclosure Service (PDS) for NPDB and HPDB. 6) All enrolled practitioners are renewed annually. 7) If employment is terminated, the enrollment is canceled 30 days after termination date. 8) Any notifications from the PDS are sent via e-mail to the MSC including malpractice claims, Office of the Inspector General sanctions, and Department of Regulation and Licensing orders. 9) Review of Medicare/Medicaid sanctions through the NPDB-HIPDB/PDS 10) Review of the Disciplinary Actions by the Medical Examining Board through the NPDB-HIPDB for MD, DO, Oral Surgeons, non-physician, and behavioral health care professionals 11) At the time of re-credentialing, GHC-SCW requires re-applicants to submit a current, signed attestation by the applicant regarding: a) Physical and mental health status and reasons for inability to perform essential functions of the position, with or without accommodations b) Chemical dependency or lack of illegal drug c) History of loss of licensure since last appointment d) Any felony convictions since last appointment e) History of loss or limitation of clinical privileges or disciplinary activity since last appointment f) Current coverage for malpractice insurance, including dates and amounts, even if the coverage amount is $0. g) Signature attesting to the correctness and completeness of the statement 12) GHC-SCW requires a monthly review of the Disciplinary Actions by the State of Wisconsin Medical Examining Board. The MSC queries the report monthly and presents the report to the Committee. 13) GHC-SCW reviews all Quality of Care and Service complaints for any practitioner being re-credentialed. Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 9 of 21 14) Verification and completion of all of the above must be within 180 days prior to the date of the recredentialing decision. 15) Review of all of the above information by the Credentialing Committee with re-credentialing recommendations to the Medical Director. 16) If GHC-SCW terminates a practitioner and later wishes to reinstate the practitioner, GHC-SCW will credential and re-verify credentialing requirements, if the break in service is 30 days or more. GHC-SCW’s Credentialing Committee will review all credentials and make a final determination prior to the practitioner’s reinstatement. 7. DELEGATED CREDENTIALING OF PHYSICIANS AND OTHER PRACTITIONERS AT HOSPITALS OR OTHER ENTITIES a. GHC-SCW considers delegating to another organization only after performing a pre-delegation audit, which ensures the delegate candidate is compliant with GHC-SCW’s credentialing and re-credentialing policies described in this document. The available elements for delegation are described in Procedure Items 1 and 2 below. It is the Medical Director’s responsibility to determine if the delegated entities meet the standards established by Group Health Cooperative of South Central Wisconsin. The delegation agreement must be in place before delegated activities are performed. b. Upon successful completion of a pre-delegation audit, GHC-SCW prepares a written delegation agreement which includes the following elements: 1) The delegation document is mutually agreed upon 2) The delegation document describes the responsibilities of GHC-SCW and the delegated entity 3) The delegation document describes the delegated activities (as described in Procedure Items 1 and 2 below). 4) The delegation document describes the reporting process, which includes at least semiannual reporting from the delegated entity. GHC-SCW prefers monthly reports, but requires at least semiannual reports. 5) The delegation document describes the process by which GHC-SCW annually performs an evaluation of the delegated entity’s performance 6) The delegation document describes remedies to the organization if the delegated entity does not fulfill it’s obligations, including revocation of the delegation agreement. 7) The delegation agreement includes the use of protected health information (PHI) by the delegated entity and the following PHI provisions: a) A list of the allowed uses of PHI b) A description of delegate safeguards to protect the information from inappropriate use or further disclosure c) A stipulation that the delegate will ensure that sub delegates have similar safeguards Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 10 of 21 d) A stipulation that the delegate will provide individuals with access to their PHI e) A stipulation that the delegate will inform the organization if inappropriate uses of the information occur f) A stipulation that the delegate will ensure that PHI is returned, destroyed or protected if the delegation agreement ends 8) Credentialing activity is delegated to University of Wisconsin Medical Foundation (UWMF) and to Dean Health Plan for practitioners not employed by GHC-SCW who have privileges at area hospitals or are credentialed by Dean Health Plan. 9) GHC-SCW retains the right to approve, suspend and terminate individual practitioners, providers and sites for any delegated practitioner, provider and site. 10) GHC-SCW MSC performs annual reviews of credentialing policies and files at the delegated entities. GHCSCW uses the current NCQA credentialing and re-credentialing Data Collection Tools. GHC-SCW is using NCQA’s 8/30 methodology to review delegate files. 8. INITIAL CREDENTIALING by DELEGATED ENTITY a. ELEMENTS PERFORMED BY DELEGATED ENTITY: 1) Primary source verification of a valid State of Wisconsin license 2) Primary source verification of a current DEA. The DEA must be valid in the state where the practitioner provides care to GHC-SCW members. If practitioner type is eligible for a DEA (i.e. MD, DO, DPM, APNP, PA-C or OD) but does not have a DEA, the practitioner must explain why no DEA AND provide explanation of arrangements for his/her patients who need prescriptions requiring DEA certification. 3) Primary source verification of the highest level of education (board certification satisfies residency or professional school) will be completed. For practitioners who are not board certified, primary source verification is completed by contacting the residency-training program. Acceptable residency programs include only those residency programs that have been accredited by the Accreditation Council for Graduate Medical Education (ACGME) and the American Osteopathic Association (AOA) in the United States or by the College of Family Physicians of Canada (CFPC) or the Royal College of Physicians and Surgeons of Canada. 4) Review of a completed application, including the following: a) Physical and mental health status and reasons for inability to perform essential functions of the position, with or without accommodations b) Alcohol or chemical dependency and lack of current illegal drug use c) History of loss of license d) History of any felony convictions e) History of loss or limitation of clinical privileges or disciplinary action Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 11 of 21 f) Work history for the last five years in mm/yy to mm/yy format, and any gaps six (6) months or greater must be explained in writing g) Malpractice history h) Current coverage for malpractice insurance, including dates and amounts, even if the coverage amount is $0. i) Signature attesting to the correctness and completeness of the application 5) National Practitioner Data Bank (NPDB-HIPDB) inquiry, to include a) Professional liability claims history b) Medicare/Medicaid sanctions c) Disciplinary Actions by the Medical Examining Board 6) Verification and completion of all of the above must be within 180 days prior to the date of the initial credentialing decision. 7) The Credentialing Committee of the delegate reviews the application and credentialing documents, and makes credentialing decisions. A practitioner from the specialty of a practitioner being credentialed participates on the Credentialing Committee. 8) Credentialing process completed prior to practitioner providing services to GHC-SCW members. 9) Delegates provide to GHC-SCW a monthly report, which includes lists of credentialed practitioners, analysis of data, and committee meeting minutes. 10) If a delegate terminates a practitioner and later wishes to reinstate the practitioner, the delegate will credential and re-verify credentialing requirements, if the break in service is 30 days or more. The delegate’s Credentialing Committee will review all credentials and make a final determination prior to the practitioner’s reinstatement. b. ACTIVITIES PERFORMED BY GHC-SCW (in relation to delegated contracts) 1) GHC-SCW performs annual site visit audits at each delegated entity. 2) Review of credentialing policies and practitioner files at each delegated entity, to assure compliance with GHC-SCW credentialing requirements. GHC-SCW uses NCQA’s 8/30 methodology to review delegate files. 3) Evaluation of the file review by the GHC-SCW Medical Director or Quality Management MD Liaison . If any deficiencies are noted, a recommendation for an action plan will be sent. Credentialing Staff send the Audit Report to the delegate and, within 30 days, conduct follow-up with the delegate as indicated in the corrective action plan. Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 12 of 21 4) Credentialing Staff conduct re-evaluations of the delegate’s performance annually or more frequently if indicated in a corrective action plan. 9. RE-CREDENTIALING by DELEGATED ENTITY ELEMENTS PERFORMED BY DELEGATED ENTITY a. Primary source verification of valid State of Wisconsin license b. Primary source verification of a current DEA. The DEA must be valid in the state where the practitioner provides care to GHC-SCW members. If practitioner type is eligible for a DEA (i.e. MD, DO, DPM, APNP, PAC or OD) but does not have a DEA, the practitioner must explain why no DEA AND provide explanation of arrangements for his/her patients who need prescriptions requiring DEA certification. c. Primary source verification of the highest level of education (board certification satisfies residency or professional school) will be completed. For practitioners who are not board certified, primary source verification is completed by contacting the residency-training program. Acceptable residency programs include only those residency programs that have been accredited by the Accreditation Council for Graduate Medical Education (ACGME) and the American Osteopathic Association (AOA) in the United States or by the College of Family Physicians of Canada (CFPC) or the Royal College of Physicians and Surgeons of Canada. d. National Practitioner Data Bank inquiry, to include: 1) Professional liability claim history 2) Review of Medicare/Medicaid sanctions 3) Disciplinary Actions by the Medical Examining Board e. Current, signed attestation by the applicant regarding: 1) Physical and mental health status and reasons for inability to perform essential functions of the position, with or without accommodations 2) Alcohol or Chemical dependency and lack of current illegal drug use 3) History of loss of licensure 4) History of any felony convictions 5) History of loss or limitation of clinical privileges or disciplinary activity 6) Current coverage for malpractice insurance, including dates and amounts, even if coverage amount is $0. 7) Signature attesting to the correctness and completeness of the statement 8) Monthly review of member complaints by GHC-SCW for all practitioners. f. Verification and completion of all of the above must be within 180 days prior to the date of the re-credentialing Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 13 of 21 decision. g. The Credentialing Committee of the delegate reviews the application and credentialing documents, and makes credentialing decisions. A practitioner from the specialty of a practitioner being credentialed participates on the Credentialing Committee. h. Delegates provide to GHC-SCW a monthly report, which includes lists of re-credentialed practitioners, analysis of data, and/or committee meeting minutes. i. If a delegate terminates a practitioner and later wishes to reinstate the practitioner, the delegate will credential and re-verify credentialing requirements, if the break in service is 30 days or more. The delegate’s Credentialing Committee will review all credentials and make a final determination prior to the practitioner’s reinstate activities performed by GHC-SCW. 10. CREDENTIALING OF HEALTH CARE DELIVERY ORGANIZATIONS a. GHC-SCW requires that Health Care and Behavioral Health Care delivery organizations meet requirements of Federal and state regulatory bodies, and that the appropriate accrediting body for the respective organization accredits these organizations. These requirements are verified prior to the initial contract being signed by GHCSCW and every three years thereafter. b. GHC-SCW conducts an on-site visit if the provider organization is not accredited. A non-accredited provider organization MAY substitute a CMS or State Review in lieu of the required site visit. (GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that is passed inspection is acceptable in lieu of the survey report if GHC-SCW reviewed and approved CMS or State criteria as meeting the standard). The CMS or State review may not be greater than three years old at the time of verification. c. GHC-SCW requires specific licensure and accreditation as listed below: 1) Hospitals (includes Behavioral Health inpatient services) a) Medicare certification b) Medicaid certification (optional) c) State licensure d) The Joint Commission (TJC) accreditation e) If not TJC accredited, GHC-SCW will evaluate through the following methods: (1) A copy of the hospital’s malpractice liability insurance declaration (2) Names of the members and by-laws of the governing body or designated person who functions as the governing body (3) A copy of the hospital’s Quality Assurance (QA) plan Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 14 of 21 (4) A copy of the Utilization Review (UR) plan (5) A copy of the hospital’s medical record keeping policies and procedures (6) A site visit by the GHC-SCW Medical Director or his/her designee to review the above or GHCSCW may accept a CMS or state review in lieu of the required site visit. GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that it passed inspection is acceptable in lieu of the survey report if GHC reviewed and approved CMS or state criteria as meeting our standards. The CMS or State review may not be greater than three years old at the time of verification. 2) Home Health Agencies (HHA) a) Medicare certification b) State licensure c) Care Accreditation Commission (CCAC) d) If not CCAC or TJC accredited, GHC-SCW will evaluate through the following methods: (1) A copy of the HHA’s malpractice liability insurance declaration (2) Names of the members and by-laws of the governing body or designated person who functions as the governing body (3) A copy of the HHA’s Quality Assurance (QA) plan (4) A copy of the Utilization Review (UR) plan (5) A copy of the HHA’s medical record keeping policies and procedures (6) A site visit by the GHC-SCW Medical Director or his/her designee to review the above or GHCSCW may accept a CMS or state review in lieu of the required site visit. GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that it passed inspection is acceptable in lieu of the survey report if GHC reviewed and approved CMS or state criteria as meeting our standards. The CMS or State review may not be greater than three years old at the time of verification. 3) Skilled Nursing Facility (SNF) a) Medicare certification (if accepting Medicare patients) b) State licensure c) Medicaid (optional) Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 15 of 21 d) Commission on Accreditation of Rehabilitation Facilities (CARF) e) If not Commission on Accreditation of Rehabilitation Facilities (CARF) accredited or TJC, GHC-SCW will evaluate through the following methods: (1) A copy of the SNF’s malpractice liability insurance declaration (2) Names of the members and by-laws of the governing body or designated person who functions as the governing body (3) A copy of the SNF’s Quality Assurance (QA) plan (4) A copy of the Utilization Review (UR) plan (5) A copy of the SNF’s medical record keeping policies and procedures (6) A site visit by the GHC-SCW Medical Director or his/her designee to review the above or GHCSCW may accept a CMS or state review in lieu of the required site visit. GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that it passed inspection is acceptable in lieu of the survey report if GHC reviewed and approved CMS or state criteria as meeting our standards. The CMS or State review may not be greater than three years old at the time of verification. 4) Free Standing Surgicenter a) Medicare certification b) TJC or AAAHC (Accreditation Association for Ambulatory Health Care) accreditation c) If not AAAHC accredited, GHC-SCW will evaluate through the following methods: (1) A copy of the ASC’’s malpractice liability insurance declaration (2) Names of the members and by-laws of the governing body or designated person who functions as the governing body (3) A copy of the ASC’’s Quality Assurance (QA) plan (4) A copy of the Utilization Review (UR) plan (5) A copy of the ASC’s medical record keeping policies and procedures (6) A site visit by the GHC-SCW Medical Director or his/her designee to review the above or GHCSCW may accept a CMS or state review in lieu of the required site visit. GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that it passed inspection is acceptable in lieu of the survey Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 16 of 21 report if GHC reviewed and approved CMS or state criteria as meeting our standards. The CMS or State review may not be greater than three years old at the time of verification. 5) Behavioral Health Residential and Ambulatory Facilities a) State licensure b) TJC accreditation c) A site visit by the GHC-SCW Medical Director or his/her designee to review the above or GHC-SCW may accept a CMS or state review in lieu of the required site visit. GHC-SCW must obtain the report from the institution to verify that the review has been performed and that the report meets GHC-SCW’s standards; however, a letter from CMS or the applicable state agency which shows that the facility was reviewed and indicates that it passed inspection is acceptable in lieu of the survey report if GHC reviewed and approved CMS or state criteria as meeting our standards. The CMS or State review may not be greater than three years old at the time of verification. 11. INTERNAL NOTIFICATION OF CREDENTIALING DECISION: a. Upon approval by the GHC-SCW Credentials Committee of initial credentialing the MSC sends notification out no later than one week after the Credentialing Committee’s decision to GHC-SCW internal departments of: 1) Facilities 2) Enrollment 3) Claims 4) Marketing 5) Member Services 6) Scheduling Coordinator 7) Epic/Cadence Coordinator 8) Clinic Managers 9) Pharmacy 10) Human Resources 11) Coding Department 12) Health Information 13) Compliance Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 17 of 21 14) Care Management 15) Quality Management 16) Mental Health Manager/Coordinators b. This notification includes the following information for all Staff Model practitioners: 1) Name 2) Credentials 3) Start Date 4) License Number/Expiration Date 5) Board Certification/Expiration Date (if applicable) 6) NPI 7) DEA/Expiration Date (if applicable) c. For Non-Staff Model practitioners 1) Name 2) Credentials 3) Place of practice 12. ONGOING MONITORING OF SANCTIONS AND COMPLAINTS GHC-SCW performs ongoing monitoring of sanctions and complaints continuously. If any incident of poor quality relating to the categories below is identified and requires intervention, the processes outlined in Policy ADM.001 (Attachment 4) govern the intervention process. The information below is reviewed at the Peer Review Committee as standing agenda items. On a monthly basis, before the Peer Review/Credentialing Committee meeting, the MSC compiles the following information: a. Medicare and Medicaid Sanctions 1) Review within 30 days of the release of the quarterly reports from the Office of Inspector General for Medicare and Medicaid Sanctions web page at oig.hhs.gov/exclusions_list.asp. MSC also receives notification of Sanctions from the NPDB Proactive Disclosure Service (PDS) of enrolled practitioners as soon as it is posted. 2) If any GHC-SCW practitioner credentialed by the GHC-SCW Peer Review Committee is listed, the practitioner is required to submit an explanation. The Peer Review Committee reviews this information and the pertinent sanctions at the next meeting. If the Committee determines that corrective action or loss of Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 18 of 21 privileges are necessary, this is recommended to the Medical Director who communicates to the practitioner. The practitioner may appeal this action as outlined in the description of Peer Review Committee actions. 3) If any GHC-SCW practitioner credentialed by a delegate is listed, GHC-SCW will send that information to the delegate in order for the delegate to take appropriate action. b. Wisconsin State Licensing and Examining Board 1) Review of monthly disciplinary reports from the State of Wisconsin Department of Safety & Professional Services web page at online.drl.wi.gov/orders/searchorders.aspx. The MSC also receives notification of sanctions from the NPDB Proactive Disclosure Service (PDS) of enrolled practitioners as soon as they are posted. 2) If any GHC-SCW practitioner credentialed by the GHC-SCW Credentialing Committee is listed, the practitioner is required to submit an explanation. The Peer Review Committee reviews this information and the pertinent sanctions at the next meeting. If the Committee determines that corrective action or loss of privileges are necessary, this is recommended to the Medical Director who communicates to the practitioner. The practitioner may appeal this action as outlined in the description of Peer Review Committee actions. 3) If any GHC-SCW practitioner credentialed by a delegate is listed, GHC-SCW will send that information to the delegate in order for the delegate to take appropriate action. c. Member Complaints 1) GHC-SCW maintains a log of member complaints by practitioner. The log lists whether the complaint is justified after Peer Review Committee and Medical Director review. 2) The GHC-SCW Peer Review Committee reviews the log during their monthly meeting for all GHC-SCW practitioners credentialed by the GHC-SCW Credentialing Committee. If any practitioner has three or more quality of care concerns in the previous 12 months, the Peer Review Committee conducts an additional review of the practitioner. If the Committee determines that corrective action or loss of privileges are necessary, this is recommended to the Medical Director who communicates to the practitioner. The practitioner may appeal this action as outlined in the description of Peer Review Committee actions. 3) Site visits at any participating practitioner office including, but not limited to the offices of primary care physicians and obstetricians/gynecologists for facility review and medical record keeping practices review will be performed when complaints dictate. 4) If any GHC-SCW practitioner credentialed by a delegate is listed on the complaint log, GHC-SCW will send that information to the delegate in order for the delegate to take appropriate action. d. Ongoing Monitoring of Adverse events related to injury (Safety): 1) GHC-SCW collect reports on a monthly basis from Member Services and Care Management Departments on any adverse events related to injuries that happened while receiving health care services from a practitioner. GHC-SCW also maintains a log of Malpractice Cases by practitioner prepared by the GHC-SCW Medical Director. This log lists all active malpractice claims cases. If any GHC-SCW practitioner credentialed by the GHC-SCW Peer Review Committee is reported, the practitioner is required to submit an explanation. The Peer Review Committee reviews this information and the pertinent sanctions at the next meeting. If the Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 19 of 21 Committee determines that corrective action or loss/limitation of privileges are necessary, this is recommended to the Medical Director who communicates to the practitioner. The practitioner may appeal this action as outlined in the description of Peer Review Committee actions. 2) If any GHC-SCW practitioner credentialed by a delegate has any adverse event, GHC-SCW will send that information to the delegate in order for the delegate to take appropriate action. 13. GHC-SCW Directories and Membership Materials: a. The MSC ensures that the information provided in member materials, which include practitioner directories and website listings is consistent with the information contained in the credentialing file. On a monthly basis the MSC sends an e-mail to the Marketing Communication Specialist, Member Services Manager, Enrollment Manager, and Claims Manager, of the newly approved practitioners which includes name, education, training, specialty, license number, board certification status, DEA number and location. The MSC monitors license, DEA, and Board Certification status on a monthly basis and would notify the Marketing Communication Specialist of any changes. b. Before printing the GHC-SCW’s Provider Directory, the Marketing Communication Specialist contacts the MSC to review and verify the correctness of all published information about a practitioner based on credentialing and primary source verification. 14. Initial and Re-credentialing PROCESS for HEDIS: a. GHC-SCW complies with HEDIS Standards for Board Certification and Practitioner Turnover by utilizing the credentialing data obtained in the initial and re-credentialing processes explained above in Procedure Items 1 and 2. b. The MSC maintains a database for all credentialed practitioners. This database is in the MSC’s G:drive. c. Information from those practitioners credentialed in-house and information from delegates is maintained in the database. d. The data in the database can only be modified by the MSC. e. An overview of the credentialing/re-credentialing process is outlined below: 1) For Initial Credentialing: Application Process is outlined as follows: a) Application is sent, allowing two weeks for completion by practitioner b) Two applications and a follow-up phone call will be made in an effort to obtain the initial credentialing application. c) Review of the application for completeness, including signature and date. Fax, digital and photocopied signatures are acceptable. d) Review of the current signed attestation statement regarding physical and mental health status, limitation of privileges and status regarding drug or alcohol use is reviewed. Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 20 of 21 e) Primary source verification of Board Certification status is performed as part of the credentialing/recredentialing process outlined in above Procedure Items 1 and 2. f) Initial applicants are presented to the GHC-SCW Credentialing Committee for approval/denial. 2) For Re-Credentialing: Reapplication Process is outlined as follows: a) Reapplication is sent, allowing two weeks for completion by practitioner. b) Two reapplications and a follow-up phone call will be made in an effort to obtain the re-credentialing application. c) Review of the reapplication for completeness, including signature and date. Fax, digital and photocopied signatures are acceptable. d) Review of the current signed attestation statement regarding physical and mental health status, limitation of privileges and status regarding drug or alcohol use is reviewed. e) Primary source verification of Board Certification status is performed as part of the credentialing/recredentialing process outlined in above Procedure Items 1 and 2. f) Re-applicants are presented to the GHC-SCW Credentialing Committee for approval/suspension/denial. f. Board Certification Calculation for HEDIS: At least annually, the MSC will report the board certification percentage rates of the following practitioners: 1) Primary Care Practitioners (PCP) 2) OB/GYN Practitioners 3) Pediatric Practitioner Specialties 4) Geriatrics 5) All other Practitioner Specialties 6) The MSC manually calculates the board certification status based on information in the credentialing database and in accordance with the most current HEDIS Guidelines. g. Practitioner Turnover Calculation for HEDIS: 1) At least annually, the MSC reports the practitioner turnover rate. 2) Termination dates are entered into the database. 3) The MSC manually calculates the practitioner turnover rate based on the credentialed/termination dates in the credentialing database in accordance with the most current HEDIS Guidelines. Policy and Procedure Title: Credentialing and Recredentialing Policy Number: MED.ADM.025 Page 21 of 21 h. Audit for Accuracy: 1) At least annually, the MSC and Director of Claims provide each other with reports of data in their systems on the practitioners entered into each system for comparison. 2) The reports must contain the following information: a) Name b) Credentials c) Start Date d) License Number e) Board Certification f) NPI g) DEA 3) Any discrepancies are identified, researched and resolved in both systems. APPENDIX A.5 _________________________________________ APPROVAL as appropriate: Board _________Exec Dir _________ Med Dir _________ Other Dir/Mgr _________ _________________________________________ REVIEWED BY LEGAL COUNSEL Date: x Yes ___No ___ Name: x __________________________________________ POLICY STATUS: _x__ Approved ___Pending Committee Charter Title: Peer Review Committee Author: M. Ostrov, MD Div/Dept/Serv Area: Administration/Committees Number: ADM.COM.001 Volume: II Date of Issue: 6/85 Page 1 of 6 Formerly ADM.001 (1/12) PURPOSE: The Peer Review Committee of Group Health Cooperative of South Central Wisconsin (GHC-SCW) investigates patient or practitioner complaints about the quality of clinical care provided by a GHC-SCW practitioner and makes recommendations for corrective actions. The Committee also reviews sentinel conditions identified as having quality concerns by Patient Services (Hospital Concurrent Review Nurses). The Committees discussions and documents are protected by federal and state laws providing confidentiality of health care peer review activities, which are conducted in good faith. In addition, the Peer Review Committee (PRC) is the committee that makes recommendations regarding credentialing decisions for practitioners employed by GHC-SCW, Dane county primary care practitioners, chiropractors, oral surgeons, physician assistants, optometrists, nurse practitioners, physical therapists, and behavioral health practitioners as well as practitioners who do not have privileges at a hospital affiliated with GHC-SCW. GOALS: Peer Review at GHC-SCW is a process designed to improve the quality of health care provided to GHC-SCW members. Peer Review is based on the following assumptions: 1. The provision of health care is a complex process. 2. Every practitioner has areas in which her/his knowledge is not exhaustive. 3. Every practitioner will make some clinical decisions, which are not optimal. 4. Practitioners may not be aware of their knowledge deficiencies and less than optimal clinical decisions. 5. A managed health care system can provide a framework for allowing practitioners to improve clinical deficiencies in a supportive environment. 6. Peer Review is an organized system in which practitioners provide educational feedback to each other based on review of actual clinical care. Review Date Revision Date 10/12 10/85 8/91 9/98 11/98 7/09 1/12 Committee Charter Title: Peer Review Committee Policy Number: ADM.COM.001 Page 2 of 6 ROSTER Quality Management MD Liaison (Chair) Family Physicians (2-3) Internists (1-2) Pediatricians (1) Physician Assistant (1) Other specialists as needed for case review or credentialing decisions (Dentist, Chiropractor, Psychiatrist) Concurrent review Nurse Medical Staff Coordinator The Medical Director makes appointments to the Committee MEETING FORMAT AND FREQUENCY 1. The minutes of the previous Committee meeting are reviewed. Cases are prepared outside the committee by an initial reviewer who presents the case for further review and discussion at the meeting. Corrective actions, if any, are recommended. Policies concerning confidentiality are followed. 2. Every three years, re-credentialing information for current GHC-SCW staff and certain contracted practitioners is reviewed prior to re-appointment. Credentials of new staff are presented to the Committee when an employment contract is being offered. 3. The Committee meets at least quarterly. CONFIDENTIALITY OF INFORMATION 1. The Peer Review Committee (PRC) is a distinct and separate Committee within GHC-SCW’s Quality Improvement Program. 2. Peer Review is organized and operated to help improve the quality of health care. Accordingly, no person acting in good faith who participates in the review or evaluation of services of health care practitioners as part of the GHCSCW Peer Review Committee is liable for any civil damages as a result of any act or omission by such person in the course of such review or evaluation. This civil immunity, pursuant to law, applies to acts and omissions including, but not limited to, censuring, reprimanding or taking any other disciplinary action against a health care practitioner. 3. No person who participates in the review or evaluation of the services of health care practitioners as part of the GHCSCW Peer Review Program may disclose any information acquired in connection with such review or evaluation, nor may any record of the investigation, inquiries, proceedings and conclusions of the Peer Review Committee be released to any person under Section 804.10(4), Wis. Stats, or otherwise, except as permitted by the exceptions set forth in Section 146.38(3), Wis. Stats. Any person who testifies during, or participates in the review or evaluation may testify in any civil action as to matters within his or her knowledge, but may not testify as to information obtained through her or his participation in the review or evaluation, nor as to any conclusion of such review or evaluation, as provided in Section 146.38(2), Wis. Stats. 4. Consistent with its goals of helping to improve the quality of health care, the PRC reports its findings to the Medical Director who in turn, reports general activities of the PRC to the Health Services Committee of the Board of Directors of GHC-SCW and, ultimately, the full Board of Directors of GHC-SCW. Committee Charter Title: Peer Review Committee Policy Number: ADM.COM.001 Page 3 of 6 COMMITTEE AUTHORITY The Board of Directors is ultimately responsible for the quality of health care provided to GHC-SCW members. The Board delegates the responsibility of ensuring a high level of quality of care to the Medical Director who, in turn, charges the PRC to review all quality concerns referred to it, provide educational feedback to the involved practitioners, to report findings to the Medical Director, and when appropriate, makes recommendations to the Medical Director for credentialing, re-credentialing, and reduction, suspension or termination of individual practitioner privileges. The Medical Director acts in a manner providing for maximum protection for documentation from legal discovery and protection of the identity of individual practitioners. SOURCES OF QUALITY OF CARE CONCERNS FOR COMMITTEE REVIEW Quality of care concerns can be brought to the PRC from several sources, including but not limited to the following: 1. Practitioners 2. Medical Director 3. Members through Member Services complaints or other member generated communications. 4. Utilization Management Department from concurrent hospitalization review and case management activities 5. Other QA/QI committees or teams 6. Medicare / Medicaid Sanctions 7. Licensure Sanctions or Limitations PROCEDURE: 1. Committee Function a. The PRC will carefully review the medical care in all situations in which a quality concern has been raised. The involved GHC-SCW practitioner will be notified of a possible quality concern. The involved practitioner is notified in writing and asked to present additional verbal or written information for the primary reviewer prior to the date of the PRC meeting. The Committee will take these practitioner comments into consideration when reviewing the case. b. The Committee will evaluate the quality concern related to the medical care and make a determination as to whether there is sufficient evidence that the involved practitioner failed to provide care within generally accepted standards. c. The Committee will communicate a written evaluation of the quality concern to the involved practitioner with a copy sent to the Medical Director. The practitioner may respond in writing to the Committee or may appear at a subsequent Committee meeting. If the practitioner’s response prompts a change in the Committee’s findings, this will be documented in the minutes with the revised opinion forwarded to the practitioner and to the Medical Director. Committee Charter Title: Peer Review Committee Policy Number: ADM.COM.001 Page 4 of 6 2. Range of Actions a. The Committee may make a recommendation for an educational activity for the involved practitioner such as reviewing a text or an article. This is consistent with the overall educational purpose of the Peer Review. b. If the Committee observes a pattern of quality concerns regarding a single practitioner, a more structured educational activity may be recommended. The Committee may suggest reduction, limitation, or suspension of privileges, or contract termination. The Committee will make these preliminary recommendations to the Medical Director and will so inform the practitioner. The involved practitioner may respond in writing to the Committee or may appear in person at a Committee meeting. The final Committee recommendation will occur after the response is received from the practitioner or at the following Committee meeting, if there is no response from the practitioner. 3. Appeal Process and process for notifying practitioners: a. The Medical Director will create an action plan after receiving the Committee’s recommendations. The reason for the action and a summary of the appeal rights will be communicated, in writing, to the involved practitioner according to the contract with the practitioner or according to GHC-SCW Personnel Policy, whichever applies. b. The practitioner is informed at that time of his right to appeal this decision. The practitioner may respond in writing to the Committee or may appear in person at a Committee meeting. c. After such appeal, the Medical Director will make a decision and carry out the action plan. d. The practitioner can then appeal the Medical Director’s decision according to the appropriate contract or Personnel Policy. e. The Medical Director will make a final decision after hearing this appeal. 4. Appeal Process a. First level appeal is the first step available to the practitioner: 1) First level appeal provides an opportunity for the practitioner to present additional or amended information to GHC-SCW’s Peer Review Committee. The practitioner must request the first level appeal in writing within 30 days of receiving notification of the Committee’s initial decision. Failure to do so, or to appear without good cause at a scheduled first level appeal, will result in the forfeiture of the right to both the first level and any subsequent appeal rights. 2) The practitioner has the right to review the information upon which the original decision was based and to correct erroneous information in his/her application file. Peer review minutes and information obtained from the NPDB may not be given directly to the practitioner. The practitioner may obtain a self-review thru the NPDB. The practitioner will be provided with a copy of GHC-SCW’s Credentialing & Re-credentialing Policy, the format for the first level proceeding, and the date of the hearing. Notice of the first level appeal date must be supplied to the practitioner within 15 business days of GHC-SCW’s receipt of the request for such appeal and the date of the first appeal. 3) The practitioner will be notified of the result of the first level appeal decision within ten business days from the date of the first level appeal. If the Committee’s decision is to uphold its original decision, or the decision Committee Charter Title: Peer Review Committee Policy Number: ADM.COM.001 Page 5 of 6 is modified but the decision still affects the practitioner’s ability to care for GHC-SCW members, the practitioner may then request a second level appeal. b. Second level Appeal of Peer Review Committee Actions: 1) Practitioners have the right to appeal any decision of the GHC-SCW Peer Review Committee, which affects their ability to care for GHC-SCW members and which has been upheld by the Peer Review Committee after the first level informal review. Appeals will be heard by the Peer Review Committee. If the applicant appeals the decision, a copy of the decision and relevant information will be forwarded to the Peer Review Committee. 2) The practitioner must request a hearing in writing and the request must be received by GHC-SCW’s Peer Review Committee [1265 John Q. Hammons Dr. Madison, WI 53717] within 30 days from the date the applicant receives the Peer Review Committee’s written decision. c. Notice of Hearing: 1) The Notice of Hearing will be sent to the appellant by certified mail within 15 business days of the receipt of the request for hearing. The Notice of Hearing will include the date, time and location of the appeal hearing and a list of witnesses (if any) expected to testify on behalf of the Peer Review Committee. 2) The appeal will be heard within 30 days of the date of the notice of hearing, unless changed by mutual consent of GHC-SCW and the practitioner. Committee Charter Title: Peer Review Committee Policy Number: ADM.COM.001 Page 6 of 6 d. Conduct of Hearing: 1) The hearing will be held before the Appeals Committee as defined above. The right to a hearing shall be forfeited, and the original decision of the committee shall become final, if the appellant fails to request such an appeal hearing within 30 days of the date of receiving notice of the decision based on the informal review or fails, without good cause, to appear. 2) Appellant’s Rights in the Hearing: a) To representation by an attorney or other person of their choosing; b) To have a record made of the proceedings, copies of which may be obtained by the appellant upon payment of reasonable charges for the preparation thereof; c) To call, examine or cross-examine witnesses; d) To present relevant information, regardless of its admissibility in court; e) To submit a written statement at the end of the hearing; and upon completion of the hearing, to receive the written decision of the Appeals Committee, including a statement of the basis for the decision. 5. Process for notifying the appropriate authorities As required by the Health Care Quality Improvement Act of 1986, as amended, and 45 Code of Federal Regulations Part 60, the Medical Director of his/her designee shall report to the State Medical Examining Board and/or the National Practitioner Data Bank (NPDB) in accordance with the respective state and federal regulations. The submission(s) will be reviewed by corporate council prior to submission. APPENDIX A.6 _________________________________________ APPROVAL as appropriate: Board _________Exec Dir _________ Med Dir _________ Other Dir/Mgr _________ _________________________________________ REVIEWED BY LEGAL COUNSEL Date: x Yes ___No ___ Name: x __________________________________________ POLICY STATUS: _x__ Approved ___Pending Policy and Procedure Title: Author: Volume: Member Rights and Responsibilities L. Baird Div/Dept/Serv Area: Marketing/Member Services III Number: MS.027 Date of Issue: 6/82 Page 1 of 3 Formerly A2f.005 (7/08) PURPOSE: The purpose of this policy is to document the rights and responsibilities of the members of Group Health Cooperative of South Central Wisconsin (GHC-SCW). POLICY: 1. GHC-SCW is committed to treating members in a manner that respects their rights as well as the expectations of members’ responsibilities. 2. Members of GHC-SCW are entitled to the following rights: a. Members have the right to receive information about GHC-SCW, its services and , its practitioners., and its practitioners. Further, members have the right to receive information regarding member’s rights and responsibilities. b. Members have the right to be treated with respect and recognition of their dignity and right to privacy. c. Members have a right to participate with practitioners in making decisions regarding their health care. d. Members have a right to a candid discussion of appropriate or medically necessary treatment options for their conditions, regardless of cost or benefit coverage. e. Members have a right to voice complaints or appeals about GHC-SCW or the care provided. Members have a right to appeal decisions made by GHC-SCW. f. Selection of a personal practitioner. Members have the right to change practitioners at any time without having to state a reason. g. Members have the right to a full explanation of any charges that may be billed to member as a result of care. h. Given informed consent, as required by law, prior to procedures or treatments. To the extent permitted by law, member has the right to refuse the recommended treatment and to be informed of the consequences of that decision. i. Participation in the governance of the organization. Each member who is at least 18 years of age is a voting member of the Cooperative and is encouraged to be an active participant in its operation. j. Members have the right to make recommendations regarding the organization’s members’ rights and responsibilities policies. Review Date Revision Date 12/02 8/90 2/04 8/91 1/09 11/91 11/09 8/97 9/02 12/02 Policy and Procedure Title: Member Rights and Responsibilities Policy Number: MS.027 Page 2 of 3 k. Members have the right to receive confidential treatment of all communications and records concerning the member’s care, except as otherwise provided by law. Upon submitting proper authorization for the disclosure of information, a member has the right, except as otherwise limited by law, to: 1) View those health care records generated by GHC-SCW pertaining to the member at any time during regular business hours, upon reasonable notice; and 2) Receive a copy of the member’s health care records, upon payments of GHC-SCW’s costs and upon reasonable notice; and 3) Receive a copy of GHC-SCW’s x-ray reports pertaining to the member or have the x-rays referred to another health care practitioner upon payment of GHC-SCW’s costs and upon reasonable notice. 3. Members have the following responsibilities: a. Each consumer at GHC-SCW has the responsibility to be considerate of others, to observe safety and smoking regulations in all GHC-SCW facilities, to treat GHC-SCW personnel with consideration and respect, and to supply accurate and complete medical history information. b. Members have the responsibility to provide, to the extent possible, information that GHC-SCW and their practitioners and practitioners need in order to care for them. c. Members have the responsibility to use facilities and equipment appropriately and to fulfill any financial obligation they may incur. d. Members are responsible for being on time for appointments and informing the clinic when an appointment cannot be kept so someone else may be seen. e. Members are responsible for reading and understanding their coverage. f. Members have a responsibility to follow the plan’s instructions for care agreed upon with their practitioners. g. Members are responsible for understanding their health problems and participating in the development of mutually agreed upon treatment goals to the degree possible. Policy and Procedure Title: Member Rights and Responsibilities Policy Number: MS.027 Page 3 of 3 PROCEDURE: 1. GHC-SCW apprises the members of the above rights and responsibilities via the GHC-SCW Member Handbook. The Member Handbook explains the member’s rights, the member’s responsibilities, and information about the practitioners available to GHC-SCW members. 2. The new member packet is distributed to all members enrolling with GHC-SCW. 3. The new member packet contains the following items: a. Member Handbook b. GHC-SCW Identification Card c. Primary Clinic Information 4. Practitioners receive this information via the Provideractitioner Handbook. APPENDIX A.7 GROUP HEALTH COOPERATIVE of South Central Wisconsin 2013 Utilization Management (UM) Program Description Purpose: The purposes of the Group Health Cooperative of South Central Wisconsin (GHC-SCW) Utilization Management (UM) Program are to conduct a series of coordinated and integrated activities that assist in: 1) maintaining and improving high quality medical and behavioral health care and services to our members across the full continuum of care, 2) meeting fiduciary responsibilities, and 3) complying with accreditation and regulatory requirements. Goals: The goals of the UM program are to: 1) objectively, consistently, impartially, and fairly promote, monitor, and evaluate the delivery of high quality, cost effective medical and behavioral health, Substance Use Disorder (SUD) care services for all members, 2) make UM decisions based on medical necessity, appropriateness, and availability of resources and benefits, 3) ensure confidentiality of personal health information, 4) monitor and improve practitioner and member satisfaction, and 5) provide case management services for members with complex medical conditions. Objectives: A. To participate in the review of consistency of UM decision making, B. To ensure that medical and behavioral health care and SUD services are medically necessary, appropriate, and provided in the most cost-effective setting, C. To facilitate communication and collaboration among members, practitioners/providers and the organization in an effort to support cooperation and appropriate utilization of health care benefits, D. To provide information to practitioners regarding utilization management activities, E. To identify high utilization of resources and implement appropriate case management activities, F. To render timely determinations and issue timely notifications, G. To initiate process improvement activities to enhance department functions, H. To assist with discharge planning and transition of care issues. Organizational Structure and Accountability (UM 1) The GHC-SCW Board of Directors grants UM authority to the senior management team with the Medical Director having direct responsibility for UM activities. The Medical Director delegates the responsibilities of the daily UM operations to the Manager of the Care Management Department (CM). The Medical Director also delegates behavioral health and substance use disorders UM activities to the Associate Medical Director for Mental Health , the Clinical and Developmental Psychologist, and the Behavioral Health Services Manager, pharmacy UM activities to the Manager of Pharmacy Services, and chiropractic UM activities to the Chiropractor Chief of Staff. The Medical Director grants authority to the following persons for making specific denials that are outlined later in this document: 1) Associate Medical Director for Mental Health, 2) the Clinical and Developmental Psychologist 3) Manager of Pharmacy Services, 4) Chiropractor Chief of Staff, and 5) Manager of Care Management. An annual review is conducted to evaluate the effectiveness of the UM Program and UM Policies. The outcome of an effective UM Program demonstrates appropriate utilization of medical resources to maximize the effectiveness of care and services provided to the members. The UM Program Description is presented by the Medical Director and Manager of the Care Management Department to the Clinical and Services Quality Committee, at least annually, for review and approval. 1 UM Responsibilities The following persons are actively involved in implementing specific aspects of the UM Program, and delegate daily operational activities as needed: 1) Medical Director, 2) Associate Medical Director for Mental Health 3) Clinical and Developmental Psychologist 4) Behavioral Health Services Manager 5) Manager of Pharmacy Services, 6) Chiropractor Chief of Staff, 7) Manager of Care Management, and 8) Manager of Member Services. A. Medical Director responsibilities include, but are not limited to: 1. General Care Management (CM) Department oversight. 2. Acts as the liaison between the organization’s primary care practitioners and external specialists and providers. 3. Assists in the analysis of utilization data for problem identification and prioritization, development and implementation of action plans along with evaluation of correction activities. 4. Reviews and makes determinations regarding: a. All Medical Necessity denial determinations, b. All potentially cosmetic/experimental procedures, c. Benefit exceptions, d. Out-of-network practitioners, and e. When individual needs and assessment of the local delivery system indicate that the UM criteria are not appropriate for the member. 5. Assists in the selection of UM criteria, reviews medical policies. 6. Chairs Technology Assessment Committee and participates in reviews. 7. Collaborates with vendors, employer groups, and providers regarding UM issues, and serves as a clinical resource for the CM Department. 8. Acts as the primary physician reviewer to the Care Management Department. 9. Delegates UM decisions to other physician reviewers as needed. Other physician reviewers include: Chief of Staff Primary Care Site Chiefs Associate Medical Director for Mental Health Chiropractor Chief of Staff Quality Management Liaison, MD B. Associate Medical Director for Mental Health responsibilities include, but are not limited to: 1. Assists with the development, revisions, and/or implementation of Mental Health UM activities, policies, procedures, and reviewing cases. 2. Same activities as described above under Medical Director, MD 3. Reviews and makes determinations for SUD transitional and inpatient UM. 4. Makes determinations for non-staff model behavioral health services, based on medical necessity regarding the level of care and the appropriate setting. 5. Decisions are based on criteria included in Milliman Care Guidelines, GHC-SCW Technology Assessment Policies, American Society of Addiction Medicine (ASAM), CM.MED.115 Referrals to External Mental Health Practitioners, and CM.MED.121 Autism Spectrum Disorder Services: Diagnosis, Intensive, and Non-Intensive Services, 6. Acts as a liaison between the organization’s staff model behavioral health providers and external specialists and providers, 7. Delegates reviews and determinations regarding medical necessity denial determinations for autism spectrum disorders treatment to the Clinical and Development Psychologist, C. Clinical and Developmental Psychologist responsibilities include, but are not limited to: 1. Assists with the development, revisions, and/or implementation of Mental Health UM activities, policies, procedures, and reviewing cases. 2. Reviews and makes determinations for non-staff model behavioral health services, based on medical necessity and the criteria listed in 5.B above regarding the level of care and the 2 appropriate setting, with a particular emphasis on services for autsim spectrum disorders and outpatient psychotherapy. 3. Acts as a liaison between the organization’s staff model behavioral health providers and external specialists and providers, D. Behavioral Health Services Manager responsibilities include, but are not limited to: 1. Manages the overall functioning of the Mental Health department including operational, program and staff-related aspects. 2. Delegates clinical decision making to State of Wisconsin licensed and credentialed staff model practitioners (Psychiatrists, Advanced Practice Nurse Prescribers, Psychologists, Licensed Clinical Social Workers, Licensed Professional Counselors, Licensed Marriage and Family Therapists, Clinical Substance Abuse Counselors regarding outpatient services including initial assessments, prioritization of patients for behavioral health treatment, treatment planning and discharge. These staff participate in initiating referrals for external specialty and provider services, provide clinical information for review, and do not make decisions about medical necessity. 3. Supports the use of a licensed doctoral level clinical psychologist to oversee outpatient prioritization of patients and referral activities, and 4. Supports the use of a licensed board certified psychiatrist for oversight of inpatient utilization. 5. Assists with the development, revisions, and/or implementation of Mental Health UM activities, policies, procedures, and reviewing cases, 6. Provides input and clinical opinion to reviewers making determinations regarding referrals for non-staff model behavioral health services, 7. Acts as a liaison between the organization’s staff model behavioral health providers and external specialists and providers E. Chiropractor Chief of Staff 1. Reviews and makes determinations regarding Acute Chiropractic Care F. The Manager of the Care Management Department responsibilities include, but are not limited to: 1. Directs and manages the UM/CM Processes and the Care Management Department, 2. Collaborates with the Medical Director, on the annual review of the effectiveness of the UM Program, 3. Ensures that the department is in compliance with NCQA Standards and regulatory requirements, 4. Develops, revises, and/or implements CM policies, 5. Coordinates Inter-rater reliability activities and UM Rounds, both medical and mental health (behavioral health and SUD), 6. Collaborates with internal practitioners, external vendors, employer groups, and providers regarding UM issues, 7. Supervises staff responsible for making administrative denials, 8. Participates in multi-departmental committees related to appeals, benefits, finance, operations, and technologies. 9. Assists the Medical Director with technology assessment. 10. Presents UM and CM program descriptions annually to CSQC for approval. G. Case Managers (RN/SW), Utilization RNs, and Utilization Coordinators (LPNs), major responsibilities for medical and behavioral health include, but are not limited to: 1. Perform pre-service, concurrent, and post-service reviews, 2. CM’s and Utilization RNs can approve UM benefit and medical coverage if medical and or benefit criteria is met. If medical criteria is not met all decisions must be taken to medical rounds for the coverage decision to be made by the Medical Director. 3. Utilization Coordinators may approve and deny benefit coverage only. 4. Assure timely referral authorizations and administrative denials, 5. Coordinate transition of care and continuity of services, 3 6. Collaborate with internal practitioners, external vendors, employer groups, and providers regarding UM issues, 7. Actively participate with inter-disciplinary committees related to Disease Management, 8. Collaborate with patient, providers and employer groups to assess, plan, implement, coordinate, monitor and evaluate options and services, 9. Assist in the management of patient care to ensure optimum outcomes, and 10. Provide education and assistance with available resources to promote quality, and cost effective outcomes. H. Worker’s Compensation Assistant responsibilities include, but are not limited to: A. Performs Worker’s Compensation coordination, B. Acts as liaison with patient, providers and employer groups to document Worker’s Compensation information, I. Care Management Associate (CMA )responsibilities include, but are not limited to: 1. Perform timely data entry of referrals, 2. Care Management Associates can make benefit approvals which procedures and tests that are listed in on the CMA approval list. This list is reviewed annually. 3. Provide assistance to the Case Managers to ensure timeliness of referral activities, 4. Direct practitioners to appropriate referral resources, 5. Authorize routine referral services; 6. Non-routine, potentially cosmetic/investigational, out of plan/area, and services for chronic disease requests are referred to the CM staff, 7. Conduct 2nd claims review, and 8. Ensure timely printing of pre-certification, authorization and denial letters. J. Manager of Pharmacy Services responsibilities include, but are not limited to: 1. Make pharmaceutical determinations based on medical necessity and the use of a recommended prerequisite drug of a step-therapy protocol, and 2. Authorizes administrative pharmacists to make UM approvals and denials. K. Manager of Member Services responsibilities include, but are not limited to: 1. Processing appeals of UM denials. Scope The scope of UM activities include Behavioral Health, but are not limited to (Care Management Review Criteria CM.MED.002): 1. Benefit clarification, 2. Referral Management, 3. Pre-service, concurrent, and post-service review and timely determinations, 4. Review of emergency services and out-of-area/plan services, 5. Complex Care Management, including discharge planning and transition of care, 6. Second review of claims, 7. Technology assessment, 8. Inter-rater reliability, 9. Monitoring adverse effects and sentinel events, 10. Integration with QM Department, Pharmacy, Mental Health Department, Marketing, Gateway, Finance, and Insurance Operations, 11. Interdisciplinary communications, 12. Over and underutilization, 13. Review, discussion, and adaptation of UM criteria to NCQA language. 14. Develop policies to clarify benefits, and 15. Denial and appeal notifications. UM Review Criteria (UM 2, Elements A&B) CM staff makes medical necessity and appropriateness determinations for inpatient and outpatient care, including behavioral health and SUD, using clearly written, published criteria which are based on sound medical evidence, to evaluate the necessity of medical services. These criteria 4 sets are intended to be used as guidelines, and are not intended to replace appropriate clinical judgment. Adaptation of these guidelines may be necessary based on individual needs and assessment of the local delivery system. The Manager of Care Management annually reviews the criteria and compares the approved GHC-SCW Clinical Practice Guidelines to the approved UM Criteria to identify any inconsistencies between the documents. Criteria used is the most current edition of Milliman Care Guidelines released in February of each calendar year, ASAM, and Technology Assessment Policies. (Care Management Review Criteria CM.MED.002) Actively practicing practitioners and specialists are part of the Technology Assessment committee that meets 5 times a year to review and develop new technology and coverage for GHC-SCW procedures. They are involved in the development, adoption and review of Milliman Criteria Revisions and nationally developed standards. Criteria used to make UM determinations are available to practitioners on the GHC-SCW Intranet and upon request. Practitioners are also informed of the availability of criteria via the GHC-SCW Provider’s Update newsletter. At least annually, the Clinical Services Quality Committee (CSQC) reviews and approves the criteria utilized: 1. Milliman Care Guidelines: for Inpatient and Surgical Care 2. Milliman Care Guidelines: Ambulatory Care 3. Milliman Care Guidelines: General Recover Guidelines 4. Milliman Care Guidelines: Behavior Health Guidelines, 5. Milliman Care Guidelines: Recovery Facility Care Guidelines, 6. Milliman Care Guidelines: Home Care Guidelines, 7. Milliman Care Guidelines: Inter-rater Reliability 8. The American Society for Addiction Medicine (ASAM) Criteria for AODA Treatment. Interrater Reliability (UM 2, Element C) GHC-SCW reviews twice a year and assesses the consistency of personnel involved in making utilization review determinations using UM criteria. This process includes physicians, nonphysicians, and pharmacists making medical and behavioral health/SUD determinations. Cases are reviewed at identified intervals as part of a group educational process; these include but are not limited to at least weekly UM Medical and Mental Health Rounds to evaluate determinations and problem cases. When areas of improvement are identified, processes and /or interventions are developed or revised, and implemented after staff education is provided. Monitoring of these improvements occurs during weekly Rounds. (Scheduling Behavioral Health Appointments CL.REC.SCH.021) The goals of inter-rater reliability include, but are not limited to: A Minimizing variation in the application of clinical guidelines, B Evaluating staff’s ability to identify potentially avoidable utilization, C Evaluating staff’s ability to identify quality-of-care issues, D Targeting specific areas most in need of improvement, E Targeting staff needing additional training, and F Avoiding litigation due to inconsistently applied guidelines. In addition, the CM department has adopted the use of Milliman Care Guidelines: Inter-rater Reliability Tool which provides, quarterly on-line testing, where the CM staff work through case scenarios and are scored on their use of the criteria against their peers. The Manager of the Care Management Department conducts randomized audits of denials and daily work of Care Management Department staff. When there are issues or concerns, a process improvement plan will be determined based on the findings. Areas of improvement which are identified as part of the audit are then discussed with individuals and/or at departmental staff meetings and appropriate changes are made within the department’s processes. 5 Communication Services (UM 3) Care Management (CM) staff are accessible to members and practitioners/providers to discuss UM issues. (Communication Services CM.MED.021) A. CM staff is available electronically or by phone between the hours of 8:00 am and 5:00 pm, Central Standard Time, Monday through Friday, excluding holidays (working hours). There are both local and toll-free phone numbers for the CM Dept. B. After normal business hours the CM Department has confidential electronic and phone voice mailboxes where message can be reviewed within 24 business hours. During weekends, holidays, and non-working hours, the CM Department has confidential electronic and phone voice mailboxes which are responded to within 24 business hours from receipt of the message. C. CM staff identifies themselves by name, title, and organization/department name when initiating or returning phone calls. D. There are both local and toll-free phone numbers for the CM Department to accept collect calls regarding UM issues. E. Staff are accessible to callers who have questions about the UM process. The CM Department has a dedicated fax machine located within the department which is available 24 hours per day, 7 days per week. F. GHC-SCW Member Services screen incoming phone calls regarding specific UM issues and transfers the callers to the appropriate nurse, administrative staff, or to the Manager of the Care Management Department. G. GHC-SCW offers TDD/TTY services for deaf, hard of hearing or speech-impaired members H. GHC-SCW offers free of charge language assistance for members to discuss UM issues. Appropriate Professional (UM 4, Elements A&F) Utilization Management (UM) determinations are made by qualified healthcare professionals; appropriately licensed professionals supervise all medical necessity decisions. Physicians, chiropractors, dentists, physical/occupational therapists or pharmacists, as appropriate, review non-behavioral health denials of care based on medical necessity. Physicians, appropriate behavioral health practitioners, or pharmacists, as appropriate, review any behavioral health denials of care based on medical necessary. Board-certified physician specialists are utilized to assist in making medical necessity determinations, when necessary. (Appropriate Professionals CM.MED.017) A. Physician reviewers are available for making medical necessity determinations and denials; the Medical Director, the Chief of Staff, the four Primary Care Site Chiefs, the Chief of Quality and Care Innovation, the Associate Medical Director for Mental Health, the Clinical and Developmental Psychologist, and the Chiropractor Chief of Staff. In addition, physician reviewers make determinations related to potentially cosmetic/experimental procedures, benefit exceptions, for out-of-network care and services, and when individual needs and assessment of the local delivery system indicate that the UM criteria utilized are not appropriate for the member. UM denials are not made based on pre-existing conditions. B. The Care Management (CM) Department is supervised by a Registered Nurse Manager with a master’s degree. The Manager, registered nurses, licensed social workers, licensed practical nurses and care management associates approve services for medical necessity based on criteria, and make administrative denials based on the members’ certificate of benefits. Administrative staff makes approvals of services per the direction of the Manager of Care Management. C. The Pharmacy Department is supervised by a Registered Pharmacist. The Manager and the other administrative registered pharmacists, make appropriate medical necessity approvals and denials based on the member’s use of a recommended prerequisite drug or a step-therapy protocol. D. The Mental Health Department is supervised by a Master’s level Licensed Clinical Social Worker and the Associate Medical Director for Mental Health (psychiatrist). The Manager, Associate Medical Director, staff psychologists and other clinicians assist the CM RN/SW’s in 6 making appropriate medical necessity approvals based on criteria, and make recommendations regarding administrative denials based on the members’ benefits. E. The Associate Medical Director for Mental Health oversees referrals for all levels of non-staff model care including inpatient, transitional, and outpatient services. Staff model out-patient service prioritization is overseen by a team that includes a licensed doctoral level clinical psychologist licensed clinical social workers, and a registered nurse. F. A licensed Chiropractor oversees the appropriate use of Chiropractic services for acute chiropractic interventions. G The Manager of the GHC-SCW Physical Therapy Department does not make UM decisions but is consulted for clinical expertise when appropriate. H The physician reviewers and other department managers utilize appropriate board-certified physician specialists from the University of Wisconsin (UW) Hospital and Clinics and UW Medical Foundation as consultants, when necessary, to assist in making determinations of medical necessity when clinical situations occur where the clinical judgment is sufficiently specialized such that primary care physicians are unable to adequately address the issues in question. The GHC-SCW Credentialing Coordinator maintains the list of such specialists and makes it available to the physician reviewers and above mentioned department managers on an as needed basis. I UM decision making is based only on appropriateness of care and service and existence of coverage. The GHC-SCW does not specifically reward practitioners or other individuals for issuing denials of coverage. Financial incentive for UM decision makers do not encourage decisions that result in underutilization. J New employees are presented the Affirmative Statement Regarding Incentives policy (Affirmative Statement Regarding Incentives CM.MED.020) during their employee orientation. The Affirmative Statement is signed annually thereafter. This policy is also located "Under One Roof" on GHC-SCW Internet, in HC and Practitioner's newsletters. Timeliness and Notification of UM Decisions (UM 5) CM staff, other GHC-SCW staff, and physician reviewers make timely and consistent determinations for all UM activities requiring review to assess the medical necessity and/or appropriateness of care or services. These determinations apply to both urgent and non-urgent, requests, and extensions of time may be requested if a determination cannot be made timely due to the lack of necessary information. In whole or in part, decisions and notifications are communicated to appropriate members, practitioners, and providers in a timely manner to accommodate the clinical urgency of the situation to minimize any disruption in the provision of health care. (Policies CM.MED.003, CM.MED.004, CM.MED.007, CM.MED.008, CM.MED.009) 1. Timeliness of Decision Making for Non-Behavioral Health and Behavioral Health UM Decision: 1. For non-urgent pre-service decisions, GHC-SCW makes decisions within 15 calendar days of receipt of the request. GHC-SCW counts the time of receipt as the next business day 2. For urgent pre-service decisions, GHC-SCW makes decisions within 72 hours of receipt of the request. 3. For urgent concurrent review, GHC-SCW makes decisions within 24 hours of receipt of the request. 4. For post-service decision, GHC-SCW makes decisions within 30 calendar days of receipt of the request. B. Notification of Non-Behavioral Health and Behavioral Health Decisions: For all determinations, GHC-SCW gives oral, electronic or written notification of the decision to practitioners and members within the above designated time frames as per NCQA guidelines. 7 C. Notification of urgent care requests decisions, GHC-SCW may notify the practitioner only of the decision since NCQA considers the treating or attending practitioner is acting as the member’s representative. D. If the denial decision is either concurrent or post-service (retrospective) and the member is not at financial risk, GHC-SCW is not required to notify the member. GHC-SCW must notify the member in all other cases. E. For urgent care requests, GHC-SCW may notify practitioners only of the decision. If the decision is either concurrent or post-service (retrospective) and the member is not at financial risk, GHC-SCW is not required to notify the member. GHC-SCW must notify the member in all other cases F. If requests for health care services comes from a practitioner, GHC-SCW may send the request for additional information to the practitioner; but must notify the member if it denies the services. UM Reviews and Timely Determinations (UM 5) CM staff, other GHC-SCW staff, and physician reviewers make timely and consistent determinations for all UM activities requiring review to assess the medical necessity and/or appropriateness of care or services. These determinations apply to both urgent and non-urgent requests. In whole or in part decisions and notifications are communicated to appropriate members, practitioners, and providers in a timely manner to accommodate the clinical urgency of the situation to minimize any disruption in the provision of health care. Preservice Decisions Urgent Preservice Decisions Urgent Concurrent Decisions Postservice Decisions Timeline for Decisions Within 15 days of receipt of request Within 72 hour of receipt of request Within 24 hour of receipt of request Within 30 days of receipt of request Care Management accepts non-urgent referral requests via fax. Fax requests are accepted and processed the next business day. On weekends and holidays, fax requests are entered the next business day. Medical Necessity/Medically Necessary means a service or supply which is determined by the Medical Director to be required for the treatment or evaluation of a medical condition, is consistent with the diagnosis, and which could not have been omitted under generally accepted medical standards, or provided in a less intensive setting. A. Pre-Service Review Determinations 1. Pre-service/urgent determinations are defined as any request for medical care or services whereby application of non-urgent time periods could seriously jeopardize the life or health of the member or the member’s ability to regain maximum function, based on a prudent layperson’s judgment, or in the opinion of a practitioner with knowledge of the member’s medical condition, would subject the member to severe pain that cannot be adequately managed without the care or treatment that is the subject of the request. 2. Pre-service/non-urgent determinations are defined as those required for a request presented prior to the member receiving medical care or services. B. Concurrent Review Determinations 1. Concurrent review determinations are any review for the extension of a previously approved ongoing course of treatment over a period of time or number of treatments. These reviews are typically associated with inpatient admissions or ongoing ambulatory care. 2. Concurrent urgent determinations are defined as any request for medical care or services whereby application of non-urgent time periods could seriously jeopardize the life or health of the member or the member’s ability to regain maximum function, based on a 8 prudent layperson’s judgment, or in the opinion of a practitioner with knowledge of the member’s medical condition, would subject the member to severe pain that cannot be adequately managed without the care or treatment that is the subject of the request. 3. Concurrent non-urgent determinations are defined as those requests that do not meet the above definition for urgent care and may be handled as a new request and decided within the time frame appropriate to the type of decision (i.e., pre-service or post-service). C. Post-Service Review Determinations Care Management (CM) staff, other staff, and physician reviewers make timely and consistent determinations for all UM activities requiring review to assess the medical necessity and/or appropriateness of care or services requested that have already been provided to the member. Extensions of time may be requested if a determination cannot be made timely due to lack of necessary information. Decisions and notifications are communicated to appropriate members, practitioners, and providers in a timely manner. Clinical Information (UM 6) Relevant clinical information, that is pertinent to an identified episode of care, is collected from the treating physician and other appropriate practitioners and documented to support accurate and appropriate UM determinations of coverage based on medical necessity for medical and behavioral health services (MH and SUD). (Documentation Of Clinical Information CM.MED.013) A. Sources of patient specific clinical information include, but are not limited to: History of presenting problem & physical exam findings Patient characteristics and information Consultations and evaluations from healthcare practitioners, providers, and consultants, Hospital and office medical records, Diagnostic testing results, Treatment plans and progress notes, Operative and pathological reports, Information regarding the local delivery systems B. Levels of care include, but are not limited to: Inpatient, and ambulatory care, Medical, and surgical care, Home health care, hospice, SNF, and Behavioral health/ (MH and SUD), including transitional care. C. Formats for UM documentation include, but are not limited to: Hardcopy and computerized case notes, GHC-SCW Request for External Mental Health Services (behavioral health and SUD) Form, Computer generated formatted letters and hard copy letters, Emails, MyChart Messages Epic data files Customer Related Message (CRM) in Tapestry. D. Transition to Other Care If the member’s benefit is exhausted, documentation by the CM and/or Mental/SUD Health staff will document attempts to assist with a member’s transition to other care, if continuing services are needed. This is done in collaboration with the GHC-SCW Community Services Coordinator and other Community Services Department Staff. Behavioral Health GHC-SCW does not have a centralized triage and referral process. GHC-SCW members have direct access to behavioral health care without prior authorization or referral at four different GHC-SCW clinics and at UW Health Gateway Recovery. 9 GHC-SCW members can directly call or walk in to a clinic to obtain behavioral healthcare. After hours, GHC-SCW members calling the 24-hour crisis line with behavioral healthcare inquiries are routed to an on-call behavioral healthcare practitioner. GHC-SCW Member Services staff provides members with information about network behavioral healthcare practitioners and how to access care, but do not make judgments about the needed level of care or type of practitioner that the member should see. Denial Notices (UM 7) CM and other GHC-SCW staff clearly document and communicate the reasons for each denial, provide members and their treating practitioners with the opportunity to discuss a denial with an appropriate reviewer. A copy of the benefit language or criteria on which the denial determination was made is sent to the provider, member and practitioner upon request. This applies to all UM denials: medical, pharmaceutical, and mental health (behavioral health and SUD). Members are directed to the GHC-SCW Member Services Department for appeal submission and resolution. A. CM and other GHC-SCW staff provide written denial notifications for all medical necessity and benefit denials that include the following: 1. The specific reasons(s) for the denial, in easily understandable language 2. A reference to a UM criteria or benefit provision on which the denial is based 3. An easy to understand summary of that reference 4. Directions on how to obtain an actual copy of the reference mentioned above. 5. Insufficient information and or lack of clinical information can be an appropriated cause for a medical necessity denial. In such cases the denial notice must contain all the required components of a medical necessity denial which include a reference to the clinical criteria that have not been met because of lack of information. B. Staff members attach written appeal information in all denial notifications which includes: 1. Description of appeal rights, including the right to submit written comments, documents, or other information relevant to the appeal, and 2. Explanation of the appeal process, including the right to member representation, and time frames for deciding appeals, and 3. If a denial is an urgent pre-service or urgent concurrent denial, a description of the expedited appeal process is included. (Policy SM.MS.001) 4. An expedited external review can occur concurrently with the internal appeal process for urgent care and ongoing treatment. C. For medical necessity denials, CM staff notifies practitioners of the availability of an appropriate reviewer for discussion of the denial and how to contact that reviewer either via written directions in the denial letter, staff messages in the Epic system, or a phone call to the practitioner’s office. Staff documents the time and date of both the denial notification, the offer of reviewer availability, as well as, conversations with the practitioner regarding the specific case while the denial decision was pending. 1. The Medical Director and CM staff is available for discussion of medical denials. 2. The Chief of Chiropractic Services is available for discussion of chiropractic care denials. 3. The Mental Health Medical Director, Manager of Mental Health Services, CM staff and appropriately qualified clinical mental health staff are available for discussion of behavioral/SUD health denials. 4. The Manager of Pharmacy Services and administrative pharmacists are available for discussion of pharmaceutical denials. 5. GHC-SCW Practitioners are informed of the denial and appeal process during their initial orientation and throughout the year in the “Provider Update”. 6. For lack of information denials, reference to the clinical criteria that has not been met must be included. If we are unable to provide a specific policy, we describe the information needed to render a decision. 7. Appeals/grievances will be accepted by Member Services without time limitation 10 D. The External IRO appeal process is administered by the Federal Government Office of Personnel Management (OPM) The member or representative has the right to request an independent review. (An insured may authorize another individual to request an independent review in any written form that is signed by the insured). 1. A written request must be submitted within 4 months of notice of the adverse benefit determination or final internal adverse benefit determination. 2. The request for an external review must be submitted in writing or electronically to: DisputedClaim@opm.gov; by faxing it to 202 606-0036; or by mailing it to P O Box 791, Washington DC 20044 3. If there are any questions during the external review process the member or representative may call toll-free 877 549-8152 4. If additional written comments are submitted to the external reviewer at the mailing address above, it will be shared with GHC-SCW in order to give GHC-SCW the opportunity to reconsider the denial. The IRO’s decision is legally binding on both the complainant and the insurer. Appropriate Handling of Appeals (UM 9) GHC-SCW has a full and fair process for resolving member disputes and responding to member’s requests to reconsider a decision they find unacceptable regarding care and service. The documentation, investigation and appropriate response to an appeal are coordinated through the Member Services Appeals Representative. Appeals are resolved within 30 calendar days of receipt for pre and post-service appeals. Expedited appeals are resolved as expeditiously as the medical condition requires but no later than one bed day, not to exceed 24 hour of the receipt of the appeal. GHC-SCW provides nonsubordiante reviewers who are not associated with the initial determination and the same or similar specialist. Members are notified in writing with the rational for upholding the denial in an easy and understandable language. Denial letters are printed in the member’s primary language. Included in the denial letters are the medical or benefit criteria was used in the decision making process. Member are entitled to reasonable access to and copies of all documents upon request. (Policy SM.MS.001) Technology Assessment (UM 10) The technology assessment process is utilized to evaluate new technologies and new applications of existing technologies. Medical technology assessment is the determination of value or significance of scientific methods and materials to effectively achieve a medical objective. This process is intended to render scientific analysis and opinions that advance the understanding of complex technology issues. This information allows GHC-SCW to make decisions about treatments which best improve members’ health outcomes, help GHC-SCW efficiently manage utilization of health care resources, and make changes in benefit coverage to keep pace with technology changes and to ensure that members have equitable access to safe and effective care. (Technology Assessment Committee CM.MED.010) The Technology Assessment Committee (TAC) is scheduled to meet at least 5 times annually, to conduct technology assessments. Members of the TAC include the Medical Director, assigned GHC-SCW physicians, the Manager of Pharmacy Services, and the Manager of Care Management. The GHC-SCW Mental Health (MH) Medical Director and MH clinicians, University of Wisconsin (UW) physician specialists, and Care Management (CM) staff attend meetings upon request of the committee to provide input as relevant specialists and professionals who have expertise in the technology currently under review. (Policy CM.MED.010) The Formulary Committee (FC) is the first level committee to evaluate new pharmaceuticals or new uses of existing pharmaceuticals. Recommendations from the FC are forwarded to the TAC for final review and approval. 11 1. Technology Categories: technologies encompass medical procedures, behavioral health procedures, pharmaceuticals, and devices. 2. Review Categories: a. Proactive reviews are usually initiated when a new technology is identified from published scientific evidence or an appropriate government regulatory body. b. Reactive or urgent reviews are triggered by a provider’s request for the use of a new technology, a new application of an existing technology, or a special review case. c. Retrospective reviews are conducted when the request was received after the service was provided. d. Scheduled review of established GHC-SCW technology assessments. 3. Technology Evaluation Sources may include but are not limited to: a. Hayes Incorporated is a major vendor of technology assessments. b. The Food and Drug Administration (FDA) information as contained in the Hayes & TEC reports c. Technology Evaluation Center (TEC) sponsored by the Blue Cross/Blue Shield Association and Kaiser Permanente. d. Reports from governmental agencies and medical associations, i.e. Center for Disease Control (CDC), American College of Obstetricians & Gynecologists or recognized sites like Medline may be utilized. e. Medical literature published in peer reviewed journals or by other health plans i.e. Aetna, Cigna, United Healthcare, CMS, Medline, etc. f. Local medical expert opinion or specialty physician consultants. 4. Review Criteria for Determinations: technology assessment decisions are based upon the following criteria; a. The technology must have received final approval from the appropriate government regulatory bodies, if applicable, e.g. FDA, AMA, CMS (formerly known as HCFA). b. The scientific evidence must permit conclusion concerning the effect of the technology on health concerns. c. The technology must be as beneficial as any established alternative. d. The technology must improve the net health outcome of the patient. e. The technology must be attainable outside the investigational setting. Satisfaction with the UM Process (UM 11) GHC-SCW annually evaluates both member and practitioner satisfaction with the UM Process. Identifiable sources of dissatisfaction are addressed through process improvement activities to meet UM goals and objectives, and to meet member and practitioner expectations. Procedure for Monitoring Member Satisfaction A. The GHC-SCW Quality Management Department conducts an annual CAHPS Member Satisfaction Survey; questions related to satisfaction with UM processes are included in that survey. Results are shared with the Clinical Quality Service Committee, members and practitioners, and Care Management (CM) staff. (2012 Member Satisfaction with UM Sept 19 CSQC.pptx) 1. CM staff participates in the analysis of data for the identification of improvement opportunities. 2. GHC-SCW member complaint and appeal process is monitored 3. Evaluation provides opportunities for member education and/or benefit changes. B. Procedure for Monitoring Practitioner Satisfaction 1. The CM Department conducts an annual Practitioner Satisfaction Survey of all staff model and network primary care practitioners, the office managers and referral coordinators of their respective primary care clinics. (CSQC Practitioner Satisfaction with UM June 2012.pptx) 12 2. CM staff participates with the Manager of Care Management in the evaluation of the survey responses. Results are presented to the Medical Director, the Clinical Service Quality Committee (CSQC), the Board of Directors, and the practitioners. 3. Trends and issues are identified for process improvements; action plans are developed by the Medical Director, Manager of Care Management, CM staff, and other appropriate practitioner committees and then presented to the Clinical Service Quality Committee (CSQC). 4. The results of improvement activities are continuously monitored through practitioner feedback and evaluation of the GHC-SCW complaint and appeal processes; annual resurveys also provide feedback. 5. Evaluation provides opportunities for practitioners’ education and/or benefit changes. Emergency Services (UM12) A. GHC-SCW covers all emergency services necessary to screen and stabilize a member without prior authorization in cases where a prudent layperson, acting reasonably, would have believed that an emergency medical condition existed; OR when members have been advised by a GHC-SCW representative to receive such care. B. The Wisconsin State Statutes 2011, Wisconsin Act 632.85 is utilized as a reference in the decision-making. C. NCQA defines a prudent layperson as a person who is without medical training and who draws on his or her practical experience when making a decision regarding the need to seek emergency medical treatment. A prudent layperson will be considered to have acted “reasonably” if other similarly situated laypersons would have believed, on the basis of observation of the medical symptoms at hand, emergency medical care was necessary. D. A physician reviewer retrospectively reviews emergency records to determine if the presenting symptoms and discharge diagnosis meet the prudent layperson definition; all denials related to medical necessity are determined by a physician reviewer. (Policy CM.MED.006) Pharmaceutical Management (UM13) The complete description of the Pharmaceutical Management Program (CL.PH.BEN.008) can be found at: https://ghcscw.com/media/2011_ph_Pharmaceutical_Management_Program_PH033.PDF Triage and Referral for Behavioral Health (UM 14) This standard and all three elements are not applicable to Group Health Cooperative of South Central Wisconsin (GHC-SCW) because the organization does not have a centralized triage and referral process. GHC-SCW members have direct access to behavioral health care without prior authorization or referral at four different GHC-SCW clinics and at UW Health Gateway Recovery. GHC-SCW members can directly call or walk in to a clinic to obtain behavioral healthcare. After hours, GHC-SCW members calling the 24-hour crisis line with behavioral healthcare inquiries are routed to an on-call behavioral healthcare practitioner. GHC-SCW Member Services staff provide members with information about network behavioral healthcare practitioners and how to access care, but do not make judgments about the needed level of care or type of practitioner that the member should see. Quality of Care Issues Care Management (CM) staff monitor, identify, document, and report potential quality of care issues to the Medical Director and the Quality Management (QM) Department. These issues are referred to as Adverse Events and include issues related to medical and behavioral health care and services provided to members. A. An Adverse Event is an untoward event with a less-than-optimal outcome. B. CM staff report the following adverse events for potential evaluation by the Medical Director and/or Medical Peer Review Committee (CM policy and procedure CM.018): 13 (1) Unplanned hospital readmission within 10 days of a hospital medical discharge and within 30 days of a hospital mental health discharge; (2) Unplanned return to the operating room within 48 hours during the same hospital admission; (3) Unanticipated in-hospital deaths; (4) Severe post-surgical infections; (5) Unplanned admission to the hospital after outpatient test or procedure; (6) Prematurity; (7) Trauma or injury suffered while in a health care facility/practitioner office/HMO site i.e. surgery on wrong body part, loss of function not related to illness or condition, rape or suicide in a 24-hour care facility. Complex Care Management (QI-7) Complex Care Management is a collaborative process in which a care manager assesses plans, facilitates and advocates for options and services to meet an individual member’s health needs. Communication and allocation of resources is part of day to day care management. Members for complex case management are identified by claim or encounter data, hospital discharge data, pharmacy data, and data collected through UM management. Criteria utilized to identify potential cases are 1) complex medical cases e.g severe multiple trauma, 2) members with a chronic disease diagnosis and multiple co-morbidities, 3) frequent ER visits and/or 4) frequent hospitalizations. Oversight of Complex Care Management is performed by the Medical Director, Mental Health Medical Director, Manager of Care Management and Manager of Mental Health. Communication is ongoing with the primary care physician to share information and coordinate the individual’s health care needs The complete GHC-SCW Complex Care Management Program is found: https://ghcscw.com/media/2011_ph_CCM_Prog_Man.pdf 14 APPENDIX A.8 COMPLEX CASE MANAGEMENT Table of Contents Complex Case Management Purpose & Objectives Complex Case Management Criteria o Complex Case Manager Description o Meetings o Complex Case management Purpose and Definition Population Assessment Identifying Members for Complex Case Management Access to Complex Case Management EPIC Case Management Information System Complex Care Management Process Measuring Satisfaction with Complex Case Management Measuring Effectiveness with Complex Case Management Action and Re-measurement Communication and Confidentiality Interface with Disease Management Complex Case Management Description Member Identification and Selection Process Member Assessment Care Plan Development and Update Process Care Plan Implementation Process Care Plan Monitoring & Evaluation Process Cost Savings Calculations and Rates Complex Case Management Discharge Process A. B. C. D. E. F. G. H. I. J. 3 4 4 4 4 5 5 7 7 8 10 11 11 11 12 12 12 14 16 16 17 18 19 Appendix Complex Case Management 8 processes Initial Calling Script Complex Case Management Referral Form Patient Activation Measure Quality Management – Key Quality of Care Indicators Complex Case Management Process Case Management Program Patient Satisfaction Survey Practitioner Satisfaction survey Complex Case Management Policy CM.MED.03 CCM Introductory Letter 2012 Complex Case Management Program Description Revision Date: 06/01/2012 14 23 24 25 28 29 30 32 36 41 2 Group Health Cooperative of South Central Wisconsin Complex Case Management Program Description PURPOSE/DEFINITION Complex Case Management is the coordination of care and services provided to members who have experienced a critical event or diagnosis that requires an extensive use of resources and who need help navigating the health system to facilitate appropriate delivery of care and services. POLICY STATEMENT The Complex Case Management program at Group Health Cooperative of South Central WI (GHC-SCW) provides proactive, medically appropriate, cost effective, coordinated care to members with complex medical conditions, or for whom a critical event has precipitated a need for rehabilitation or additional health care support. GHC-SCW members inquiring about or accessing health care services are screened and evaluated to determine their potential need for Complex Case Management services. The goal of the program is to assist members with multiple or complex conditions and comorbidities in obtaining access to quality care and appropriate services through coordination of their health care needs and to help them navigate the health care system. The Complex Case Management Program description is approved annually by the Clinical and Service Quality Committee (CSQC). OBJECTIVES To proactively identify members who have multiple or complex medical and/or psychosocial needs or who are at risk of developing complex needs during an acute episode of illness. To provide early intervention for members appropriate for complex care management. To support the clinical staff focus on the delivery of medical care that maximizes quality of life and ensures that the care is provided in the most appropriate and supportive setting. To facilitate communication among the member, their families, health care providers, the community and the health plan in an effort to enhance cooperation while planning for and meeting the health care needs of the member. To serve as a liaison to community resources regarding options and services not covered by the benefit plan. To allocate resources and maximize the available benefits. To track and report episodes of illness at the member and aggregate level for the purpose of identifying trends, and measuring medical outcomes and financial impact. To increase member and provider satisfaction through the coordination and management of health care resources. To increase member’s satisfaction of GHC-SCW’s Healthcare team. To assist in the development and communication of the member’s selfmanagement plan. To function as an educator of members, the healthcare team and the community regarding the case management process and specific health care issues. 2012 Complex Case Management Program Description Revision Date: 06/01/2012 3 To serve as an advocate for the member and family. To partner with the member and family in assisting the member to reach maximum achievable medical potential and maximum independence. Complex Case Management Criteria Complex Case Manager Description The Complex Case Manager, Registered Nurse/ Social Worker (SW), assesses, plans, implements, monitors, and evaluates the options and services required to meet an individual’s health needs, using communication and available resources to promote quality, and cost-effective outcomes. The Case Management Team Coordinator is responsible for coordinating, leading and participating in case management programs and projects for the Care Management Department. The Team Coordinator provides training to Care Management department staff and monitors compliance with Group Health Cooperative of South Central Wisconsin (GHC-SCW) and the National Committee for Quality Assurance (NCQA) procedures and policies. Meetings The Medical Director meets monthly with case managers to discuss and review cases that have questions or concerns. The complex care management staff meets monthly for educational updates and case review. File audit results are presented at this time. Complex case managers meet biweekly to review the cases opened and to review audit results and identify areas for improvement. PURPOSE To identify GHC-SCW members who have complex care needs that would benefit from additional support and help with coordination of their medical care. To ensure communication with members and practitioners regarding the referrals and participation in GHC-SCWs Complex Case Management Process. DEFINITION Member identification is the initial process of Complex Case Management. Referral sources use established selection criteria to recognize a potential complex care management opportunity. The Complex Case Management Selection Criteria consist of targeted diagnoses and situational criteria which indicate a potential, chronic, catastrophic or complex case which may benefit from complex care management intervention. Potential members may also be identified through member self-referral or referral from other sources. A. To be considered for Medical Complex Case Management all members must meet the following criteria: 1. Valid GHC-SCW Healthcare coverage for their medical services, and 2. Chronic disease diagnosis with 2-3 co-morbidities with multiple hospital admissions and/or multiple Emergency Room visits in six (6) months 2012 Complex Case Management Program Description Revision Date: 06/01/2012 4 B. To be considered for Complex Case Management for mental health and or AODA, all members must meet the following criteria: 1. Valid GHC-SCW Healthcare coverage for their mental health services, and 2. Have an acute diagnosis of substance abuse or dependence, major depressive disorder, personality disorder, psychosis, schizophrenia or autism, AND 3. Readmission for inpatient mental health within 30 days, OR 4. All of the following criteria must be met: i. Two or more ER visits in six months with mental health related diagnosis, AND ii. Two or more hospitalizations in 12 months with mental health related diagnosis, AND iii. Diagnosis impacts ability to perform Activities of Daily Living (ADL) C. Members with prolonged hospital stays are high dollar cases or are at risk for severe complications and repeat hospitalizations may be selected for complex case management. Element A: Population Assessment GHC-SCW annually assesses the characteristics of its member population and relevant subpopulations to identify members for complex case management. GHCSCW reviews and annually updates it complex case management processes and resources to address member needs if necessary. The annual Ethnicity/Race/Age Report for GHC-SCW is reviewed as part of the population assessment process. The initial step in identifying populations with complex case management needs is to identify specific populations which are at high risk for complex conditions and comorbidities. It was identified that a small percentage of the GHC-SCW population, 2.4%, identified themselves with an ethnic background through this Assessment. The ethnic population identified is not significant enough to warrant a change in staff resources or processes. 1. Ethnicity/Race/Age Report ENR0003060 Element B: Identifying Members for Complex Case Management (CCM) Member identification is the initial process of Complex Case Management. The goal is to assist members with multiple or complex conditions and comorbidities in obtaining access to quality care and appropriate services through coordination of their health care needs and to assist them with navigating the health care system. ( Policy CM.MED.03) During this identification process, referral sources use established selection criteria to recognize a potential Complex Case Management opportunity. The evaluation of pharmacy, claims, hospital ER and Inpatient data, health risk assessments and the electronic medical records three additional disease processes were identified for complex case management in 2012. It was through the critical assessment of the listed data that three additional complex disease processes were identified for complex case management. Cancer continues to be complex case managed. Additional Care Management staff was added in 2012 to address the increase in complex case management cases and complexity. The care management selection criteria consist of targeted diagnoses and situational criteria which indicate a potential chronic, catastrophic or complex member which may benefit from care management intervention. The review and evaluation of reports 2012 Complex Case Management Program Description Revision Date: 06/01/2012 5 weekly, monthly or annually assisted with the identification of members for complex care management services. The reports reviewed included but were not limited to: 1. Claims or encounter data identifies chronic conditions with complex co-morbidities and high cost. 1. Claim encounters for Diabetes: crms select etg claims for care management 0027.pdf 2. Claim encounters for CHF: crms select etg claims for care management 0268 3. Claim encounters for COPD: crms select etg claims for care management 0267.pdf 2. Hospital admit/discharge data identifies chronic conditions with complex co-morbidities requiring frequent inpatient stays affecting cost ratio. 1. MUM0002010--Hospital Census -- Current Inpatients.pdf 2. MUM0003020--Hospital Census--9 Days or More 3. Daily UW Health census of GHC patients discharged 3. Pharmacy data identifies complex chronic conditions with costs associated with the treatment of the condition. 1. Top-50 fills detail.xls 4. Data collected through the utilization management process identifies chronic conditions with complex co-morbidities requiring frequent inpatient stays affecting cost ratio. 1. Prior Authorization 2. Concurrent review, a. MUM0026050--High Frequency Emergency Room Patients All HMO Hospital Readmission data3. MUM0011050--Facility Readmissions within 30 Days of Mental Health Discharge a. MUM0007010--All Pended Referrals b. MUM0025050-Facility Readmission within 30 days of Medical Discharge 5. Data collected by purchasers – NA 6. Data supplied by member or caregiver 1. Health Risk Assessment 7. Data supplied by practitioners (EPIC-Electronic Medical Records) allow CCM to evaluate complex conditions of members Three primary chronic conditions, CHF, COPD and Diabetes have been identified for the primary focus for complex case management in 2012. Cancer continues to be a condition that is complex cased managed. The diagnoses have been identified through claims encounters, pharmacy data and emergency room (ER) visits as primary, reoccurring, diagnoses with frequent ER visits. Additional Care Management staff was added in 2012 to address the increase in complex case management cases and complexity. Determining whether a member is appropriate for Complex Case Management services is achieved by gathering and critically assessing relevant, comprehensive information and data, so that members are selected according to case management potential to influence positive outcomes and meet GHC-SCW’s complex care 2012 Complex Case Management Program Description Revision Date: 06/01/2012 6 management criteria as outlined in Steps 1 & 2 – Identification and Access to Complex Case Management. In addition, this determination involves comprehensive assessment of the member’s condition; determination of available benefits and resources; and development and implementation of a case management plan with performance goals, monitoring and follow-up. GHC-SCW has the option for the member to opt out of complex case management. This is presented with the initial phone call (Appendix B) and in the Introductory Letter. (Appendix J) Element C: Access to Complex Case Management Members who experience a critical event or diagnosis should receive timely case management services. To minimize the time between when a member’s need is identified and when the member receives services, GHC-SCW has multiple avenues for members to be considered for case management services including, but not limited to: 1. GHC-SCWs nurses review information from members who contact GHCSCW via the electronic and phone HealthLine to identify members who might benefit from CCM. Such members are referred to the CCM Department for consideration for inclusion in the CCM. 2. Referral from GHC-SCWs Disease Management and Health Registries program. Monthly communication between Disease Management, Health Educators and Care Management allows members to be identified for CCM. a. 2012 Transition of Care Cases b. Health Registries i. Asthma - QMI0017060 ii. Cardiovascular Disease - QMI0008050 iii. Diabetes - QMI0001020 iv. Hypertension - QMI0010050 3. Referral from hospital discharge planners contact CCM’s to identify members who have complex conditions requiring immediate CCM and needs. a. CCM Cases Opened & Assessments Completed Weekly 2012.xlsx 4. Data gathered from UM activities assist with the identification of members who may benefit from CCM. The data includes but not limited to ambulatory care sensitive conditions, diagnoses and readmission rates. a. MUM0026050--High Frequency Emergency Room Patients All HMO Hospital Readmission datab. MUM0011050--Facility Readmissions within 30 Days of Mental Health Discharge c. MUM0007010--All Pended Referrals d. MUM0025050-Facility Readmission within 30 days of Medical Discharge 5. Referral from members or caregivers (Appendix C) a. Health Risk Assessment b. CCM Cases Opened & Assessments Completed Weekly 2012.xlsx 6. Referral from internal practitioners including Mental Health Practitioners. (Appendix C) a. CCM Cases Opened & Assessments Completed Weekly 2012.xlsx 2012 Complex Case Management Program Description Revision Date: 06/01/2012 7 Information regarding referral and participation in GHC-SCWs Complex Case Management Program is communicated to both members and practitioners in a variety of ways, including but not limited to: GHC-SCWs website GHC-SCW MyChart Member, practitioner, and staff electronic communications and postal mailings Informational brochure House Calls Element D: EPIC Case Management Information Systems GHC-SCW facilitates Complex Case Management by providing the necessary tools and information to help case managers do their jobs effectively. 1. Using evidence-based clinical guidelines or algorithms to conduct assessment and management. The EPIC electronic case management system uses algorithmic logic such as scripts and other prompts to guide the case managers through assessment and ongoing management of enrolled members. The clinical basis of these prompts and scripts are developed by using evidencebased clinical guidelines or algorithms from Milliman Care Guidelines, published nursing care plans and other resources, which assist the case managers in conducting initial assessments and ongoing complex care management. 2. Automatic documentation of the member identification and the date and time when the organization acted on the case record or interacted with the member. The EPIC electronic case management information system includes automated features that provide accurate documentation for each entry; recording actions or interactions with members, practitioners or providers; and include automatic date, time and user stamps. 3. Automated prompts for follow-up, as required by the complex case management plan. To facilitate care planning and management, the EPIC electronic case management information system, includes features to set prompts and reminders for next steps or follow-up contacts. Element E: Complex Care Management Process GHC-SCWs Complex Case Management Process addresses all of the following: Member’s Rights Prior to initiating Complex Case Management services, the case manager will obtain appropriate and informed member consent, including their right to decline participation or dis-enroll from the complex case management process at any time following enrollment. 1. Health Status During initial telephonic (or face to face) assessment, the case manager will evaluate the member’s health status specific to identified health conditions and likely co-morbidities. 2012 Complex Case Management Program Description Revision Date: 06/01/2012 8 2. Clinical History The Complex Case Management process documents the member’s clinical history, including disease onset: key events such as acute phases; and inpatient stays, treatment history (therapies or procedures used to care for a member’s identified health conditions and comorbidities) and current and past medications, including schedules and dosages. 3. Activities of Daily Living As part of the initial assessment, the case manager evaluates the members functional status related to activities of daily living such as eating, bathing and mobility. 4. Mental Health Status During the initial assessment, and ongoing evaluations, the case manager evaluates the member’s mental health status, including psychosocial factors and cognitive functions such as the ability to communicate, understand instructions and process information about their illness. 5. Life Planning The complex care management initial clinical assessment documentation addresses life planning issues such as wills, living wills, advanced directives and health care/financial power of attorney. In situations where a life planning activity is not appropriate, documentation about the situation should be recorded. 6. Cultural and Linguistic Needs, Preferences, or Limitations The case manager’s assessment includes cultural and linguistic needs, preferences or limitations of the member. 7. Visual and Hearing Needs The case manager’s assessment includes visual and hearing aid needs to communicate effectively. 8. Caregiver resources During the initial assessment, the case manager will evaluate caregiver resources such as family involvement in and decision making about the care plan. 9. Available Benefits within the organization and community resources The complex care management plan includes an assessment of the member’s eligibility for health benefits and other pertinent financial information regarding benefits within the organization and from community resources.. 10. Individualized Complex Care Management Plan and Prioritized Goals The care management plan of care identifies, but is not limited to the following: short and long term prioritized goals; time frame for reevaluation; resources to be utilized, including the appropriate level of care; planning for continuity of care, including transition of care and transfers; collaborative 2012 Complex Case Management Program Description Revision Date: 06/01/2012 9 approaches to be used, and family/caregiver needs, level of involvement and preferences. 11. Barriers to Meeting and/or Complying with Plan of Care The complex care management process identifies and addresses barriers to meeting goals or the member’s ability to comply with the plan. These could include the member’s lack of understanding (due to clinical understanding of a condition, language or literacy level), motivation, cultural or spiritual beliefs; visual or hearing, psychological impairment, any financial needs, insurance issues or transportation problems. The health plan documents barriers assessment even if no barriers were identified. 12. Facilitation of member referrals Members may benefit from referrals to available resources as part of their benefit. The organization’s case managers facilitate member referral to other health organizations, when appropriate and when the purchaser provides information about external referral organizations. The organization bases referrals on guidelines developed with the plan sponsor. 13. Follow-up Schedule and Communication to Member The complex care management plan includes a schedule for follow-up communication that includes, but is not limited to counseling, referrals to disease management, education or self-management support. 14. Development and Communication of Self-Management Plan The self-management plan includes the development and communication of the member’s self-management plan, and may include but is not limited to, member’s monitoring of their symptoms, activities, weight, blood pressure and glucose levels and maintaining a prescribing diet. 15. Assessing Progress against case management plans The Complex Case Management plan includes an assessment of member’s progress towards overcoming barriers to care and meeting treatment goals. The complex care management process includes reassessing and adjusting the care plan and its goals, as needed. The case management notes must clearly describe the assessment results for each factor, even if the factor is not applicable to the member. The documentation must include why the factor is not applicable. Element F & G: NCQA reviews a random sample of case management files selected from cases opened for at least 60 days within 12 months prior to the survey. Note: If the CCM is unable to locate or communicate with a member after three or more attempts within a two week period of time and fails to complete the assessment within 30 calendar days, GHC-SCW may exclude the member from complex case management and the file will be excluded from review. The CCM must document its attempts, which may include any form of individualized, 2012 Complex Case Management Program Description Revision Date: 06/01/2012 10 documented contact by telephone, letter, email or fax. If a complex case management stops when a member is admitted to a facility and the stay is longer than 30 calendar days. A new assessment must be performed after discharge if the member is elegible for complex case management. Care Management typically completes monthly audits until there are three consecutive months of 100% on elements E and F (initial assessment and goal planning). When this is achieved the audits are completed every other month. NCQA 8/40 methodology is used for file review. If the member is unable to communicate because of infirmity, assessment may be completed by professionals on the care team, with assistance from the member’s family or caregiver. This information is documented in Epic Tapestry notes. Element H: Measuring Satisfaction with Complex Case Management Program GHC-SCW annually evaluates satisfaction with Complex Case Management program by: Obtaining feedback from members and practitioners through the following surveys: 1. Annual Complex Case Management Member Survey (Appendix G ) 2. Annual Practitioner Satisfaction Survey (Appendix H) 3. Patient Activation Measure (Appendix D) Analyzing member complaints and inquiries. 1. Member Access Report-2012.pptx GHC-SCW uses three patient experience measures to evaluate satisfaction with the Complex Care Management Program. The three measures address satisfaction with Complex Case Management process operations, i.e. satisfaction with the frequency of contact or satisfaction with the assigned case manager. Examples of other measures of patient experience include improved quality of life, pain management and health status. GHC-SCW will analyze complaints and inquiries to identify opportunities to improve satisfaction. Analysis considers quantitative and qualitative data to identify patterns of member comments. Element I: Measuring Effectiveness with Complex Case Management Program GHC-SCW measures the effectiveness of its Complex Case Management by using three measures: Twice a year Patient Activation Measure Survey(PAM 12) (Appendix D) Annual Complex Case Management Member Survey (Appendix G ) Annual Practitioner Satisfaction Survey (Appendix H) For each of the above measures, GHC-SCW will: Identify a relevant process or outcome, Use valid methods that provide quantitative results, Set a performance goal, 2012 Complex Case Management Program Description Revision Date: 06/01/2012 11 Clearly identify measure specifications, Analyze results, Identify opportunities for improvement, when applicable, Develop a plan for intervention and re-measurement. Element J: Action and Re-measurement (Measuring Effectiveness) Based on an analysis of both the satisfaction survey results and effectiveness measures, GHC-SCW will: Implement at least one intervention to improve performance Re-measure results to determine performance. The evaluation of the PAM, Complex Case Management Member and Practitioner Satisfaction Surveys are presented annually to the CSQC committee. Recommended interventions for areas of improvements are discussed and approved. April 2012: 2011 PAM Presentation v3.pptx May 2012 Complex Case ManagementMemberSATIS APRIL3012PDS.ppt June 2012: CSQC Practitioner Satisfaction with UM June 2012.pptx There was a 13% increase in overall statifaction with care managent from 2011 to 2012. This was accomplished with increased case managers in each staff model clinic providing direct interaction with physicians, clinical staff and members. Communication and Confidentiality Effective communication is critical to the success of the Complex Case Management. Various individuals who have an interest in the well-being of the member and the management of the member’s care must be kept informed, and have an opportunity to participate in decisions affecting the member. In order to facilitate effective and efficient communication, guidelines have been established to address the exchange of information during the Complex Case Management process. To ensure confidentiality, no voluntary disclosure of member specific clinical or nonclinical information will be made except to persons authorized to receive such information to conduct case management activities. All information is considered confidential. Interface With Disease Management Key quality indicators and criteria have been established and are incorporated into the Complex Case Management Process. The case manager is responsible for identifying and sharing any potential quality issues with the Quality Management Department who will evaluate and follow up as protocol indicates. The case manager proactively makes referrals to GHC-SCWs Disease Management programs for members who would benefit from such services from information gathered during the following case management processes: Precertification data Concurrent review data Prior authorization data 2012 Complex Case Management Program Description Revision Date: 06/01/2012 12 Hospital admission data Hospital discharge data Complex Care Management Initial Assessment data 2012 Complex Case Management Program Description Revision Date: 06/01/2012 13 Appendix A COMPLEX CASE MANAGEMENT Complex Case Management consists of eight processes: 1. 2. 3. 4. 5. 6. 7. 8. Member Identification Care Selection Care Assessment Plan Development/Update Plan Implementation Plan Monitoring and Evaluation Cost Savings Calculations and Rates Care Discharge Steps 1 thru 8 on the subsequent pages, followed by the process descriptions provide an overview of the Complex Case Management processes. Steps 1 & 2- Member Identification and Selection Process PURPOSE To identify GHC-SCW members who have complex care needs that would benefit from additional support and help with coordination of their medical care. To ensure communication to members and practitioners regarding referral and participation in GHC-SCWs Complex Case Management Process. DEFINITION Member identification is the initial process of Complex Case Management. Referral sources use established selection criteria to recognize a potential complex care management opportunity. The Complex Case Management Selection Criteria consist of targeted diagnoses and situational criteria which indicate a potential, chronic, catastrophic or complex case which may benefit from complex care management intervention. Potential members may also be identified through member self-referral or referral from other sources. A. To be considered for Complex Case Management (Medical, Mental Health, or Alcohol and Other Drug Abuse [AODA]) all members must meet the following criteria: 1. Valid GHC-SCW Healthcare coverage for their medical services, and A. CHF, COPD & Diabetes B. Chronic disease diagnosis with 2-3 co-morbidities with multiple hospital admissions and/or multiple Emergency Room visits in six (6) months B. To be considered for Complex Case Management for mental health and AODA all members must meet the following criteria: 1. Valid GHC-SCW Healthcare coverage for their mental health services and AODA and 2. Have an acute diagnosis of substance abuse or dependence, major depressive disorder, personality disorder, psychosis, schizophrenia or autism, AND 3. Readmission for inpatient mental health within 30 days, OR 2012 Complex Case Management Program Description Revision Date: 06/01/2012 14 4. All of the following criteria must be met: i. Two or more ER visits in six months with mental health related diagnosis, AND ii. Two or more hospitalizations in 12 months with mental health related diagnosis, AND iii. Diagnosis impacts ability to perform ADLs C. Members with prolonged hospital stays are high dollar cases or are at risk for severe complications and repeat hospitalizations may be selected for complex case management. Other criteria which may be met: 1. The member requires many resources, such as home health care services or durable medical equipment, in order to return home or remain at home. 2. The member is at high risk for readmission to the hospital. 3. The member needs extensive interpretation of his health coverage, or the rules for obtaining medical services. 4. The member needs information about alternative funding sources or referrals to community based services. 5. There is a cost effective alternative to the member’s current level of care. Criteria which will not meet enrollment criteria 1. Member is Fee for Service 2. Member is not competent to consent to care management 3. Member is currently enrolled in Hospice Services 4. Member has PPO coverage If the above criteria are met, the case manager will review further resources to: 1. Evaluate diagnosis, clinical condition, complications, or cost to identify potential members suitable for effective complex care management interventions, 2. Consider disease specific risk stratification reports, (i.e., predictive risk, diagnostic cost groups, etc.) 3. Conduct a thorough and systematic evaluation of the member’s current status, including but not limited to, the following components: a. Physical/functional b. Psychosocial c. Behavioral d. Environmental/residential e. Family dynamics and support f. Spiritual g. Cultural h. Financial i. Vocational and/or educational j. Recreation/leisure pursuits k. Primary caregiver(s) capability and availability l. Learning capabilities/self-care m. Health status expectation and goals n. Transitional or discharge plan 2012 Complex Case Management Program Description Revision Date: 06/01/2012 15 5. Assess resource utilization and cost management; the diagnosis, past and present treatment course and services, prognosis, goals, treatment, and provider options. The case manager may determine a need for Complex Case Management for members who do not meet the criteria. This will be at the professional judgment of the case manager. Once the potential member is identified, the case manager will: 1. Initiate a case within the EPIC Case Management information system and place the member in the appropriate disease category roster. 2. Contact the member for potential enrollment in the program using the Initial Calling Script (Appendix A) 3. If the member elects to participate in the program: a. Record member opt in status within EPIC. (Opt In-GHC Prime) b. Send Welcome Letter and business card. c. The case manager coordinates with the member/family/significant other to schedule a telephone or face to face conference to conduct the initial assessment within 2 weeks. 4. If the member elects not to participate in the program at this time: a. Record member opt out status within EPIC b. Close the case. If the CCM is unable to locate or communicate with a member after three or more attempts within a two week period of time and fails to complete the assessment within 30 calendar days, GHC-SCW may exclude the member from complex case management and the file will be excluded from review. The CCM must document its attempts, which may include any form of individualized, documented contact by telephone, letter, email or fax. Step 3 - MEMBER ASSESSMENT PURPOSE To assess the needs of each member, to develop an effective process, to improve health care delivery and management and promote quality, cost-effective outcomes that will maintain or improve a member’s quality of life, and/or more efficiently utilize benefit resources. DEFINITION Through a comprehensive and objective analysis of a member’s clinical, financial and psychosocial status, the case manager assesses the benefits for the member and the health plan for enrollment in GHC-SCWs complex care management process. Information is gathered for the assessment through interviews with the patient, family, significant others, the primary care physician and/or additional healthcare providers. The assessment is used to identify and detail the member’s current “needs list” and to develop an individualized care management plan which will be available to the member and providers involved in their care. PROCEDURE The case manager reviews the member’s chart within EPIC 2012 Complex Case Management Program Description Revision Date: 06/01/2012 16 The case manager reviews other pertinent medical appointments, consultation notes, test results, etc. and notes them in the contact tab. The case manager confirms receipt of baseline questionnaires The case manager conducts the initial assessment using the “Case Management Start of Care Assessment” questionnaire within Epic, noting any pertinent comments. If the baseline questionnaires were not received, obtain responses telephonically and send copy to Quality Management. The case manager contacts additional healthcare providers, as needed. After completing the assessment, the case manager sends communication (Appendix G) to Primary Care Practitioner with pertinent information and queue up any necessary order(s) for signature in Epic Care electronic medical record. Development of Prioritized Care Plan Goals Identify member and caregiver’s needs and preferences The case manager will document the discussion of identified goals and member’s stated priorities. The member identifies the order of priority of goals. Development of Care Plan Interventions Identify healthcare services, treatment options, resources, and funding options. Screen options and select those that best meet the member’s needs and those that will maximize the potential for achieving the goals. Discuss the plan with the member and/or family and the healthcare team to modify as needed and obtain consensus. Serve as an advocate for the member as needed. Consider contingency options in the overall plan to anticipate treatment /service gaps and/or complications. Documentation of Care Plan The (Epic) Case record should contain an easily identifiable Case Management plan that contains the following key elements and should be documented within the EPIC Case Management system: o Member needs/opportunities o Short and Long term goals o Time frame for reevaluation o Resources to be utilized including appropriate level of care interventions/actions o Planning for continuity of care, including transition of care and transfers o Collaborative approaches to be used, including family participation o Self-Management Plan based on activities undertaken by members to help them manage their condition o Barriers to Care o Assessing compliance to Care Plan Correspondence regarding the development of the case management plan should be included in the (Epic) Case record. 2012 Complex Case Management Program Description Revision Date: 06/01/2012 17 Step 4 - CARE PLAN DEVELOPMENT UPDATE PROCESS PURPOSE To determine and document specific goals and a plan of intervention to meet the member’s needs and provide a framework for monitoring and re-evaluating the member’s progress. DEFINITION Individualized care plan development is the process of reviewing information gathered during the assessment and acuity rating phase, developing short and long term goals, and a plan of intervention to achieve those goals. Opportunities for intervention may include, but are not limited to: Over-utilization of services or use of multiple providers/agencies. Under-utilization of services. Premature discharge from appropriate level of care. Use of inappropriate medical treatment or health care center. Use of ineffective treatment. Permanent or temporary alterations in functioning. Medical/psychological/functional complication(s). Lack of education of disease course/process. Lack of self-management Lack of resolution to medical treatment course. Lack of an established treatment plan with specific goals. Member or family/caregiver noncompliance with the clinical treatment plan. CARE PLAN DEVELOPMENT PROCEDURES: Identification and determination of member needs and opportunities for intervention. Development of short and long term goals. Development of plan of intervention including healthcare services, treatment options, resources, and funding options. Documentation of care plan in the EPIC Case Management System. Step 5 - CARE PLAN IMPLEMENTATION PROCESS PURPOSE To coordinate resources and individuals involved in mobilizing the care plan to accomplish immediate goals, as well as short and long term goals. DEFINITION The care plan implementation process is the case manager’s initial step to assist the member to attain the short and long term goals outlined in the care plan. It is essential for the case manager to educate and gain the cooperation and confidence of all the member’s healthcare team, and support system to successfully implement a care plan. CARE PLAN IMPLEMENTATION PROCEDURES The case manager contacts the PCP and reviews the care plan. 2012 Complex Case Management Program Description Revision Date: 06/01/2012 18 The case manager contacts the family/significant others/care givers to explain, review and answer questions about the proposed case management plan. The case manager contacts the appropriate facilities, and/or vendors, agencies, or community organizations to coordinate the required services for the patient. The case manager documents their contacts, care plan, interventions, goals, barriers, and self-care plan within the enrollee’s case record within EPIC. The case manager sends a copy of the care plan to the member, primary care practitioner and primary specialist identified by the member. Step 6 - CARE PLAN MONITORING AND EVALUATION PROCESS PURPOSE The care plan monitoring and evaluation process determines the effectiveness in meeting the goals and achieving the optimal outcome for the member. DEFINITION The care plan monitoring and evaluation process is an on-going process of reviewing and assessing the member’s progress toward achieving the goals established after the assessment phase. The outcome of the evaluation process can result in a modification to the previous short or long term goals; adjustment to the plan to accommodate the member’s current health situation; a change in the treatment setting; and/or implementation of further options in an attempt to obtain optimal level of well-being for the member. The monitoring and evaluation process focuses on the: Quality of care Appropriateness of the setting and services for the member’s current health status, satisfaction of the member, family/significant other and the treatment team regarding the overall plan and care management. Member’s response to the health care services and products. Financial impact from implementing the plan Member’s quality of life. CARE PLAN MONITORING AND EVALUATION PROCEDURES Monitoring the member’s progress The case manager maintains rapport and consistent communication with the member, family, and the healthcare team so that information regarding the member’s care and progress is exchanged in a timely and effective manner. The case manager reviews medical records and other documents as needed to obtain information on the member’s progress. Evaluating the member’s response and the outcome of the care plan The case manager evaluates the member’s response and the outcome of the plan by considering the following factors: o The member’s status and progress toward reaching the goals in the care plan o Medical status at the time of the initial assessment as compared to the current status 2012 Complex Case Management Program Description Revision Date: 06/01/2012 19 o Member and/or family’s satisfaction with the health care services, products, and the complex care management process o Member and/or family’s compliance with the care plan o Financial impact of the plan as compared to the benefits o Quality of life of the member o Quality of care issues as defined in the Quality Management – Key Quality of Care Indicators (Appendix D) Based on the evaluation, the case manager will implement necessary changes to the care plan and modify the goals as needed. The case manager will work with the member to evaluate, modify, and implement self-care plan changes. The case manager will work with the health care team to identify and arrange for additional services vital to the enhancement of the care plan. The case manager will also consider alternative treatments, health care settings and funding options. Records and Documentation The case manager documents any changes in the care plan. The case management record contains the following notes and documents needed for management of the member’s care and for evaluation purposes. All notes and received records should be documented in the EPIC Case Management Information System. o Progress notes and progress reports o Correspondence to and from providers o Notes regarding authorizations for services o Medical records o Site visit reports o Team conferences o Benefit plan and current coverage information o Case management plan financial impact assessments o Provider invoices o Information regarding extra-contractual arrangements Complex Case Management Mock Audits Care Management typically completes monthly audits until there are three consecutive months of 100% on elements E and F (initial assessment and goal planning), when this is achieved then the audits are completed every other month. Step 7 - COST SAVINGS CALCULATIONS AND RATES PURPOSE To identify complex care management savings opportunities and to calculate the savings resulting from actions taken to impact these opportunities. DEFINITION A case management record documents cost savings whenever a savings is achieved due to an action recommended or initiated by a Case Manager, Utilization Coordinator, Care Management Associate, or Medical Director and results in “hard” 2012 Complex Case Management Program Description Revision Date: 06/01/2012 20 savings. Savings should be a reflection of the impact on changing an existing plan of care or negotiating actual discounts for services. 1. Examples of situations where a treatment option or alternatives exist include, but are not limited to: Changing an inpatient level of care to a lesser level, such as acute care to step-down Denying medically unnecessary days Negotiating discounts for inpatient or outpatient services Steering a member from an out-of-network facility to an in-network facility Diverting inpatient admissions to outpatient services Steering members to the most cost effective, in-network facilities for diagnostic services, procedures or therapies 2. Monthly or with scheduled review of the case record, complex care management costs are evaluated and documented for soft savings – this includes but is not limited to: Time saved by PCP or patient care staff. Compliance represented with Decreased Emergency Department visits Compliance represented with decreased In-patient stays. Decreased use of specialty care referrals/visits 3. On an on-going basis, hard and soft case management savings are reported. 4. At completion, total case management savings are accumulated and reported. Case Management Cost Savings Calculations and Rates pre calendar year: Changing an inpatient level of care to a lesser level, such as ICU care to an acute care bed Intensive care rate per day – Inpatient acute per day = $ Savings per day Denying medically unnecessary days (Inpatient acute rate per day x anticipated LOS) – (Inpatient acute rate per day x actual LOS) = $ Savings Negotiating discounts for inpatient or outpatient services Vendor’s price – Negotiated amount = $ Savings Steering a patient from an out-of-network facility to an in-network facility Out-of-network, acute inpatient bed rate/day – In-network, acute inpatient bed rate/day = $ Savings Diverting inpatient admissions to outpatient services Inpatient acute rate/day – Home Health care/skilled nursing rate = $ Savings per day Step 8 - COMPLEX CASE MANAGEMENT DISCHARGE PROCESS PURPOSE To define the point, using established criteria, at which a member is eligible for discharge from GHC-SCWs Complex Case Management process. 2012 Complex Case Management Program Description Revision Date: 06/01/2012 21 DEFINITION The role of the case manager is to coordinate services and to assist a patient and/or family to achieve the short and long term goals outlined on the case management plan. When the case manager, with input from appropriate individuals, feels the patient and/or family has accomplished those goals, has the appropriate skills/knowledge to continue to pursue and achieve those goals, or the patient and/or family has reached their potential, the member will be discharged from GHC-SCWs complex care management program. A member can dis-enroll at any time from the Complex Care Management Program. Complex Care Management Discharge 1. Member has exhausted their insurance benefits (when specific limits apply) 2. The member terminates with the employer and does not opt for COBRA 3. The member/family/significant other elects to no longer participate in GHC-SCWs Case Management Program (opts out). 4. The member reaches maximum medical improvement, or achieves his long and short term goals, and/or is directed to appropriate community resources. 5. The member expires 2012 Complex Case Management Program Description Revision Date: 06/01/2012 22 APPENDIX A.9 The Asthma Disease Management Program Element A: GHC-SCW is committed to helping members, and their practitioners, manage chronic illness by providing tools and resources to empower members to take action to improve their health and chronic conditions. GHC-SCW is committed to helping members self-manage their asthma and stay healthy through a variety of educational opportunities. Through this program, routine asthma evaluations are performed and education is given to help members gain control of their asthma and keep it controlled throughout their life. Element B - Program Content GHC-SCW has designed the Asthma Management Program to educate members about asthma, teach members how to self-manage their disease, emphasize the importance of regular care, and provide support tools and screenings for disease management. The content of the Asthma program includes condition monitoring, patient adherence to treatment plans, consideration of other health conditions, lifestyle issues and ongoing screening for behavioral health concerns. Element B Factor 1 - Condition monitoring GHC monitors the following indicators for all members in the program: • • • • • • • • • • • Assessment of Lung Function (spirometry, peak flow monitoring) Symptom Assessment History of Exacerbations Medication Review Quality of Life/Functional Status (Asthma Control Test) Asthma Action Plan Annual Flu Vaccination Tobacco Use/Exposure Members can access their future appointments, outstanding orders for labs and diagnostics, medication lists, lab results through MyChartSM - an interactive online patient health portal. Members who have MyChartSM accounts have access to disease management information outside of GHC via Healthwise, an interactive shared learning tool. All encounters with health educators are documented in the EMR. Element B2 - Adherence to treatment plans Members work with the Asthma Educator, Registered Nurse Health Educators, Tobacco Cessation Counselor, nursing staff and their primary care practitioner who monitor patient adherence in the following areas: Last updated: November 23, 2012 • • • • • • • • • • Modification of risk factors Medication compliance and appropriateness Tobacco cessation Adherence to an individualized Asthma Action Plan Self-Administration of Inhalants Adherence to the clinical practice guidelines for asthma Adherence to peak flow action plans Adherence to scheduling regular practitioner appointments Physical Activity Level Tobacco Cessation Element B3 - Medical and behavioral health comorbidities and other health conditions The Asthma registry is updated weekly and includes current lab, prescription and risk factor data. GHCSCW identifies members with asthma who also have ASTHMA, hypertension, cardiovascular disease, hyperlipidemia and/or depression. GHC-SCW is committed to a collaborative approach to disease management, especially for those members with multiple co-morbidities. Practitioners are encouraged to refer members to health educators, complementary therapists as well as to outside resources. GHCSCW is the only local practice group and HMO to offer complementary medicine to its members. Referrals are quick and easy using our EMR or internal phone system. Members have several opportunities for a collaborative management approach to asthma care that are included in their insurance coverage. The Asthma Educator and Nurse Health Educators complete initial assessments for all members to assess for learning style preferences, cognitive abilities, socio-economic factors, and physical limitations prior to creating the patient driven treatment plan Clinic staff (includes pharmacy, lab, radiology, CMA’s, LPN’s, RN’s, RT’s, practitioners) have access to the electronic medical record and can see the problem list for each member. GHC-SCW utilizes a care team approach for members which ensure collaboration for those members with multiple co-morbidities requiring more intensive care. Practitioners have the opportunity to refer patients to a variety of other practitioners to support the needs of the patient. Examples of referrals are to Nurse Educators and/or Behavioral Health Specialists. Registered Dietitians also have access to the EMR and document their encounters with members, contributing to the plan of care. A case manager can also be utilized to ensure appropriate care for those with more complex needs. Last updated: November 23, 2012 Element B4 - Health Behaviors Behavior modification is an essential component of an ASTHMA program. The Asthma Educator works with GHC-SCW members who have asthma to provide personalized education, support and to promote healthy lifestyle options. Members may have individual or family counseling sessions as needed. Others within the GHC-SCW system that can support our members include Nurse Educators, Tobacco Cessation Counselor, and Registered Dietitians if needed. Members with asthma who have documented tobacco use also receive outreach mailings providing them with cessation resources. These resources include tobacco cessation classes, individual counseling sessions with a tobacco cessation counselor, and information on community resources such as the Wisconsin Quit Line. In addition, GHC-SCW covers tobacco cessation medications on its formulary at 100% for the majority of its members. For those members who participate in the annual Great American Smoke out campaign, there is no copay for smoking cessation medications and they get free counseling for one year from the Tobacco Cessation Counselor. Members are requested to complete a pre-physical General Medical History Form every time they schedule a physical. They are mailed this before the appointment and are to bring it with them for review during the appointment. In the survey are questions about health behaviors such as alcohol consumption, tobacco use, hobby hazards, wearing seat belts, helmets and preventive self- exams. Based on responses to these questions, practitioners can counsel on at risk behaviors. Element B5 - Psychosocial issues GHC-SCW has incorporated the Anxiety Screening tool GAD-7 into its electronic health record. This is a seven item anxiety questionnaire that has been developed and validated in a primary care setting. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also has access to this screening tool in their member assessments. Element B6 - Depression screening GHC-SCW has incorporated the Depression Screening tool, PHQ-9 into its electronic health record. The Patient Health Questionnaire - Nine is the standard among scales for monitoring symptoms of depression. It has been extensively studied as a screening measure for major depression in primary care settings. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also has access to this screening tool in their member assessments. Last updated: November 23, 2012 Element B7 - Information about the patient’s condition provided to caregivers who have the patients consent Family members and/or caregivers who want or need access to the patient’s medical record are required to have a “Release of Information” consent form signed by the patient, indicating they may have access to their records. Patients may choose to share electronic access to their medical record by sharing password information to their MyChart account with family members and/or caregivers. Family members and/or caregivers who are GHC-SCW members have access to Healthwise, a shared decision making tool and healthcare resource available via MyChart. Each member can also see a Health Educator who can help them create an Action Plan that can be shared with the member’s family, and is available to the member’s health care team. Element B8 - Encouraging patients to communicate with their practitioners about their health conditions and treatment. Members have the ability to utilize MyChartSM which is a patient portal within Epic, the electronic medical record software. They can send messages directly to their practitioner, nursing staff, pharmacy, or member services as well as make appointments, complete the asthma control test, see lab and other diagnostic results. All members are encouraged to sign up for MyChartSM. MyChartSM is now available on both the iPhone and Droid smart phones making it convenient for members who may have these devices. Outreach letters are sent to members in the Asthma Registry to encourage them to contact their practitioner and stress the importance of communication. In addition, if a member completes a Health Risk Assessment (HRA) and based on their results, they are encouraged to follow up with their practitioner and can click on a link that takes them directly to scheduling an appointment Element B9 - Additional resources external to the organization All GHC-SCW members are encouraged to complete a Health Risk Assessment (HRA) that is available free of charge through their employer or via MyChartSM. Members also have access to Healthwise, a shared decision making tool and health resource that is also available via MyChartSM. Practitioners can print information from Healthwise during the visit and give it to members to take home with them. Element C: Identifying Members for DM Programs GHC-SCW uses the following data sources to identify members for the ASTHMA management program: Claims or encounter data Last updated: November 23, 2012 Prescription data Problem list in the electronic medical record (AE updates PL with communication to PCP) Health risk assessment results Data collected through the utilization management or care management process Member referral Practitioner referral Clinical Care Management referral GHC-SCW does not use continuous enrollment criteria for identifying members. The Asthma registry updates weekly. Element D: Frequency of Member Identification The GHC-SCW Asthma disease registry updates weekly. (See Element C) In addition, the disease registry is run monthly to look for members who have outstanding asthma identifiers such as increased use of short acting beta agonist medication, decreased ACT score, or increased emergency department admissions, oral steroids. The asthma educator uses the registry to stratify outreach to our asthma members. Element E: Providing Members with Information How to use services - GHC-SCW sends a letter and a brochure titled “Asthma Zone” to eligible members annually. These highlight the importance of managing asthma and the resources available both internally and externally along with contact information. How members become eligible to participate - Newly diagnosed members are sent a letter and a brochure “Asthma Zone”. The letter informs them that they are now part of the Asthma Management Program and the brochure highlights the importance of managing Asthma and the resources available both internally and externally along with contact information. How to opt in or out - The letter sent to members explains how they can opt out of the outreach associated with being on the Asthma registry. When members contact GHC-SCW QM staff to opt out, they are informed that they will be contacted in one year to follow up to see if they still wish to be excluded from outreach efforts. Element F: Interventions based on Assessment GHC-SCW provides interventions for asthma members based on stratification. Different interventions are provided for members based on severity of illness, participation in completion of testing and examinations as well as the results of those tests. Tier 1: All members with Asthma-targets those with well controlled asthma or intermittent asthma Interventions o Asthma Disease Management Program letter & brochure to be mailed to all asthmatic members annually Last updated: November 23, 2012 o o Annual flu shot reminder Access to Asthma Educator to help develop comprehensive plan of care including, but not limited to: Asthma assessment Spirometry Medication evaluation & education Trigger assessment Asthma education Environmental control plan Action plan development Tier 2: Includes members who have had recent Urgent Care visits, Emergency Room visits, and Hospitalizations for asthma. o Care includes all aspects of Tier 1 care, with the addition of aggressive outreach to ensure clinic follow up with a provider or Asthma Educator is obtained within 14 days of asthma event. Asthma Educator task done weekly. o Ongoing appointments, GHCMyChart, or letter follow up after interventions Type of Report Urgent Care Emergency Room Hospitalizations HEDIS Pharmacy Oral Steroids Member mail out Daily Weekly Monthly Quarterly Semi-Annual x x x x x x Annual x Tier 3: Case Management o Includes members referred to Case Management by providers o Includes those who meet the following criteria: Two or more hospitalizations within a 6 month period Two or more specialists involved in the patient’s care Three or more emergency room visits within a 6 month period Two or more co-morbidities Acute medical issues Complex coordination of care issues One asthma ER visit and one asthma hospitalization within a 6 month period Element G: Eligible Member Active Participation GHC-SCW annually reports the member participation rate to the Clinical and Service Quality Committee (CSQC). Last updated: November 23, 2012 Element H: Informing and Educating Practitioners Instructions on how to use the Asthma Management Program Practitioners are informed of the Asthma Management Program in the following ways: The Practitioner Handbook contains a copy of the Asthma Management Program description Practitioners receive a copy of the Asthma Management Program brochure Newly hired practitioners receive a brief overview from the HE Manager They are notified when outreach is done on members There are updates in organizational newsletters Health Maintenance Modifiers for labs and screening Best Practice Alerts (BPA’s) How the organization works with practitioners’ patients in the program Practitioners have access to see an encounter in Chart Review for all contacts the member has with health educators, care management and case management. They can communicate using electronic messaging and/or in person. Element I: Integrating Member Information GHC-SCW utilizes a common electronic medical record (i.e. EpicCare) which allows for integration of member information for continuity of care. This information is extracted into a variety of reporting tools and reports utilized by GHC-SCW to focus on this member population to ensure focused and relevant interventions. This then allows for comprehensive resources for the following departments: health information line, case management program, utilization management program, quality management outreach program and health education. GHC-SCW utilizes two other EMR resources to integrate member information. Care Link allows staff to see the patients’ medical record if they have been seen at a partnering facility utilizing Epic. In addition, GHC-SCW participates in Care Everywhere, another tool developed by Epic to ensure access to patient information while they are traveling and out of the service area. Element J: Satisfaction with Disease Management All GHC-SCW members in the Asthma registry are surveyed for feedback on their thoughts and experiences of the program. Additionally, those members who utilize care management are surveyed through the PAM and Complex Case Management survey tools. Randomly selected GHC-SCW members who had a visit with their practitioner, health education, complementary medicine, physical and/or Last updated: November 23, 2012 occupational therapy are sent a Press Ganey survey. Random samplings of members are also sent a CAHPS survey as part of GHC-SCW’s accreditation process. All complaints are managed through Member Services per protocol. Element K: Measuring Effectiveness HEDIS results are analyzed monthly to look for trends or changes in compliance. GHC-SCW’s Quality Management Team along with other stakeholders in the organization, actively look for QI projects throughout the year. These projects look at a variety of issues and target areas where a measure is below the 50th percentile as well as ensuring measures stay above the 90th and 95th percentile. The projects will: 1) 2) 3) 4) 5) Address a relevant process or outcome; Produce a quantitative result; Be population based; Have valid data and methodology; Analysis with comparison to benchmarks and goals - use the HEDIS national 90th percentile levels as goals for the Asthma measures. The Quality Management Department reviews and reports the results annually and compares them to these goals and to past performance. Last updated: November 23, 2012 APPENDIX A.10 The Diabetes Management Program Element A: Program Content GHC-SCW is committed to helping members, and their practitioners, manage chronic illness by providing tools and resources to empower members to take action to improve their health and chronic conditions. Diabetes is a major concern for GHC-SCW due to the increase in number of members being diagnosed and the health risks and costs associated with poor control. GHC-SCW currently has approximately 1,800 members with a diagnosis of diabetes. Proactive practitioner intervention and support, in collaboration with health education and clinical outreach, helps members manage their chronic conditions. GHC-SCW has designed the Diabetes Management Program to educate members about diabetes, teach members how to self-manage their disease, emphasize the importance of regular care, and provide support tools and screenings for disease management. GHC-SCW’s patient focused Living Well with Diabetes was developed to help members self-manage their diabetes to reduce diabetic-related complications, morbidities and death. The content of the diabetes program includes condition monitoring, patient adherence to treatment plans, consideration of other health conditions, lifestyle issues and ongoing screening for behavioral health concerns. Element A Factor 1-Condition monitoring GHC monitors the following indicators for all members in the program: Date and result of most recent hemoglobin A1C (hbA1C) -if past due, outreach calls and letters are sent to the member Dates and results of most recent fasting lipid panel (including LDL, HDL, total cholesterol, and triglycerides) -if past due, outreach calls and letters are sent to the member Date of most recent medical attention for diabetic nephropathy (urine microalbumin, etc.) -if past due, outreach calls and letters are sent to the member Date of most recent diabetic retinal eye exam (DRE) -if past due, outreach calls and letters are sent to the member Prescriptions for diabetic medications (date prescribed, date filled) Prescriptions for lipid lowering agents (date prescribed, date filled) Prescriptions for hypertension (date prescribed, date filled) Co-morbidities (asthma, hypertension, cardiovascular disease, hyperlipidemia) Date and result of most recent blood pressure measurement-if past due, outreach calls and letters are sent to the member Members can access their future appointments, outstanding orders for labs and diagnostics, medication lists, lab results and diagnostic results through MyChart-an interactive online patient health portal. Members who have MyChart accounts have access to disease management information outside of GHC via Healthwise, an interactive shared learning tool. 1 Last Edited: Friday, March 29, 2013 Members with diabetes receive blood glucose monitoring devices at no cost to the member. The results can be downloaded during appointments with health educators. All encounters with health educators are documented in the EMR. Element A2-Adherence to treatment plans Members work with Certified Diabetes Educators, Registered Dieticians, nursing staff and their primary care practitioner who monitor patient adherence in the following areas: Modification of risk factors Weight control Blood Pressure control Medication compliance Adherence to Nutritional Guidelines Adherence to scheduling regular practitioner appointments Physical Activity Level Tobacco Cessation Self-Monitoring of Blood Glucose Self-Administration of Insulin Quarterly testing of HBA1C Adherence to the “Essential Diabetes Mellitus Care Guidelines-Wisconsin” (https://ghcscw.com/Pages/Provider-Resources/Clinical-Practice-Guidelines.aspx) Element A3-Medical and behavioral health comorbidities and other health conditions The diabetes registry is updated weekly and includes current lab, prescription and risk factor data. GHCSCW identifies members with diabetes who also have asthma, hypertension, cardiovascular disease, hyperlipidemia and/or depression. GHC-SCW is committed to a collaborative approach to disease management, especially for those members with multiple co-morbidities. Practitioners are encouraged to refer members to health educators, complementary therapists as well as to outside resources. GHCSCW is the only local practice group and HMO to offer complementary medicine to its members. Referrals are quick and easy using our EMR or internal phone system. Members have several opportunities for a collaborative management approach to diabetes care that are included in their insurance coverage. The Certified Diabetes Nurse Educators complete initial assessments for all members to assess for learning style preferences, cognitive abilities, socio-economic factors, and physical limitations prior to creating the patient driven treatment plan Clinic staff (includes pharmacy, lab, radiology, CMA’s, LPN’s, RN’s, practitioners) have access to the electronic medical record and can see the problem list for each member. GHC-SCW utilizes a care team approach for members which ensures collaboration for those members with multiple co-morbidities requiring more intensive care. 2 Last Edited: Friday, March 29, 2013 Practitioners have the opportunity to refer patients to a variety of other practitioners to support the needs of the patient. Examples of referrals are to Nurse Educators and/or Behavioral Health Specialists. Registered Dietitians also have access to the EMR and document their encounters with members, contributing to the plan of care A case manager can also be utilized to ensure appropriate care for those with more complex needs. Element A4-Health Behaviors Behavior modification is an essential component of a diabetes program. Health Educators (i.e. Certified Diabetes Nurse Educators, Tobacco Cessation Counselor, Registered Dietitians) work with GHC-SCW members who have diabetes to provide personalized education, support and to promote healthy lifestyle options. Members may have individual counseling sessions as needed along with an extensive offering of classes. Members with diabetes who have documented tobacco use also receive outreach mailings providing them with cessation resources. These resources include tobacco cessation classes, individual counseling sessions with a tobacco cessation counselor, and information on community resources such as the Wisconsin Quit Line. In addition, GHC-SCW covers tobacco cessation medications on its formulary at 100% for the majority of its members. For those members who participate in the annual Great American Smokeout campaign, there is no copay for smoking cessation medications and they get free counseling for one year from the Tobacco Cessation Counselor. Members are requested to complete a pre-physical General Medical History Form every time they schedule a physical. They are mailed this before the appointment and are to bring it with them for review during the appointment. In the survey are questions about health behaviors such as alcohol consumption, tobacco use, hobby hazards, wearing seat belts, helmets and preventive self- exams. Based on responses to these questions, practitioners can counsel on at risk behaviors. Element A5-Psychosocial issues GHC-SCW has incorporated the Anxiety Screening tool GAD-7 into its electronic health record. This is a seven item anxiety questionnaire that has been developed and validated in a primary care setting. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also have access to this screening tool in their member assessments. Element A6-Depression screening GHC-SCW has incorporated the Depression Screening tool PHQ-9 into its electronic health record. The Patient Health Questionnaire-Nine Item is the standard among scales for monitoring symptoms of depression. It has been extensively studied as a screening measure for major depression in primary care 3 Last Edited: Friday, March 29, 2013 settings. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also have access to this screening tool in their member assessments. All members are mailed a screening tool prior to their physicals. Imbedded in this document are two questions from the PHQ-9 that are used as an initial depression assessment. Based on these results, members can then be directed to complete the entire PHQ-9 for further evaluation and possible followup to a behavioral health specialist if needed. Element A7-Information about the patient’s condition provided to caregivers who have the patients consent Family members and/or caregivers who want or need access to the patient’s medical record are required to have a “Release of Information” consent form signed by the patient, indicating they may have access to their records. Patients may choose to share electronic access to their medical record by sharing password information to their MyChart account with family members and/or caregivers. Family members and/or caregivers who are GHC-SCW members have access to Healthwise, a shared decision making tool and healthcare resource available via MyChart. Members with diabetes are given a brochure called “How Families Can Help”. Each member can also see a Certified Diabetes Educator who can help them create a Diabetes Action Plan that can be shared with the member’s family, and is available to the member’s health care team. Element A8-Encouraging patients to communicate with their practitioners about their health conditions and treatment. Members have the ability to utilize MyChart which is a patient portal within Epic, the electronic medical record software. They can send messages directly to their practitioner, nursing staff, pharmacy, or member services as well as make appointments, sign up for classes, see lab and other diagnostic results. All members are encouraged to sign up for MyChart. MyChart is now available on both the IPhone and Droid smart phones making it convenient for members who may have these devices. Members of the Disease Management Program who are signed up for MyChart will automatically get care reminders via MyChart. Outreach letters that are sent to members in the Diabetes Registry encourages them to contact their practitioner and stresses the importance of communication. In addition, if a member completes an HRA and based on their results, they are encouraged to follow up with their practitioner and can click on a link that takes them directly to scheduling an appointment. Element A9-Additional resources external to the organization All GHC-SCW members are encouraged to complete a Health Risk Assessment (HRA) that is available free of charge through their employer or via MyChart. 4 Last Edited: Friday, March 29, 2013 Members also have access to Healthwise, a shared decision making tool and health resource that is also available via MyChart. Practitioners can print information from Healthwise during the visit and give it to members to take home with them. Element B: Identifying Members for DM Programs GHC-SCW uses the following data sources to identify members for the diabetic management program: Claims or encounter data Prescription data Problem list in the electronic medical record Laboratory results-Diabetic Nurse Educator contacts members with an elevated A1C who do not have Diabetes on their problem list Health risk assessment results Data collected through the utilization management or care management process Member referral Practitioner referral Clinical Care Management referral GHC-SCW does not use continuous enrollment criteria for identifying members. The diabetes registry updates weekly. Element C: Frequency of Member Identification The GHC-SCW diabetes disease registry updates weekly. (see Element C) In addition, the disease registry is run quarterly to identify members who are overdue for a variety of interventions and follow ups. (HgbA1C more than 6 six months ago and/or >9% and/or not done in past 13 months; urine for micro albumin; LDL greater than 6 months ago or >100; Dilated Retinal Exam due; Blood pressure not recorded for 6 months and/or >140/90 mmHg or not recorded in past 13 months) Element D: Providing Members with Information How to use services-GHC-SCW sends a letter and a brochure “Living Well With Diabetes” to eligible members annually. These highlight the importance of managing diabetes and the resources available both internally and externally along with contact information. How members become eligible to participate-Newly diagnosed members are sent a letter and a brochure “Living Well With Diabetes”. The letter informs them that they are now part of the Diabetes Management Program and the brochure highlights the importance of managing diabetes and the resources available both internally and externally along with contact information. 5 Last Edited: Friday, March 29, 2013 How to opt in or out-The brochure “Living Well With Diabetes” explains to members how they can opt out of the outreach associated with being on the diabetes registry. When Members contact GHC-SCW QM staff to opt out, they are informed that they will be contacted in one year to follow up to see if they still wish to be excluded from outreach efforts. Element E: Interventions based on Assessment GHC-SCW provides interventions for diabetic members based on stratification. Different interventions are provided for members based on severity of illness, participation in completion of testing and examinations as well as the results of those tests. Tier 1: All members with diabetes Interventions o Initial letter sent to those with new diagnosis of diabetes describing the program and resources available to them o Diabetes management program letter and brochure mailed to all registry members annually o Access to health educators and/or primary care practitioner o Access to diabetes-related classes o Practitioners are notified of monthly outreach activities Tier 2: Subset of members with diabetes; members are contacted if they meet one or more of the following criteria Had HgbA1C done 6 or more months ago and it was >9% OR have not had a HgbA1c in 13 months or more; Had LDL done 6 or more months ago and result was >100mg/dL OR no LDL done in the last 13 months OR had LDL in last 6-13 months and result was incalculable; Had blood pressure taken 6 or more months ago and it was >_ 140/90 mmHg OR have not had a blood pressure in 13 months or more; Have not had medical assessment for nephropathy in 13 months or more; Have not had a DRE in 13 months or more Interventions: (same as Tier one and include) Contact by mail and phone quarterly for needed tests Offer appointment with health educators and/or primary care Tier 3: Subset of members who utilize the Clinical Nurse Educators 6 Last Edited: Friday, March 29, 2013 Element F: Eligible Member Active Participation GHC-SCW annually reports the member participation rate to the Clinical and Service Quality Committee (CSQC). Element G: Informing and Educating Practitioners Instructions on how to use the Diabetes Management Program Practitioners are informed of the Diabetes Management Program in the following ways: The Practitioner Handbook contains a copy of the Diabetes Management Program description Practitioners receive a copy of the Diabetes Management Program brochure They are notified when outreach is done on members There are updates in organizational newsletters Health Maintenance Modifiers for labs and screening Best Practice Alerts (BPA’s) How the organization works with a practitioners patients in the program Practitioners have access to see an encounter in Chart Review for all contacts the member has with health educators, care management and case management. They can communicate using electronic messaging and/or in person. Element H: Integrating Member Information GHC-SCW utilizes a common electronic medical record (i.e. EpicCare) which allows for integration of member information for continuity of care. This information is extracted into a variety of reporting tools and reports utilized by GHC-SCW to focus on this member population to ensure focused and relevant interventions. This then allows for comprehensive resources for the following departments: health information line, case management program, utilization management program, quality management outreach program and health education. GHC-SCW utilizes two other EMR resources to integrate member information. CareLink allows staff to see the patients’ medical record if they have been seen a partnering facility utilizing Epic. In addition, GHC-SCW participates in Care Everywhere, another tool developed by Epic to ensure access to patient information while they are traveling and out of the service area. 7 Last Edited: Friday, March 29, 2013 Element I: Satisfaction with Disease Management All GHC-SCW members in the diabetes registry are surveyed for feedback on their thoughts and experiences of the program. Additionally, those members who utilize care management are surveyed through the PAM and Complex Case Management survey tools. Randomly selected GHC-SCW members who had a visit with their practitioner, health education, complementary medicine, physical and/or occupational therapy are sent a Press Ganey survey. A random sampling of members are also sent a CAHPS survey as part of GHC-SCW’s accreditation process. All complaints are managed through Member Services per protocol. Element J: Measuring Effectiveness HEDIS results are analyzed monthly to look for trends or changes in compliance. GHC-SCW’s Quality Management Team along with other stakeholders in the organization, actively look for QI projects throughout the year. These projects look at a variety of issues and target areas where a measure is below the 50th percentile as well as ensuring measures stay above the 90th and 95th percentile. The projects will: 1) 2) 3) 4) 5) Address a relevant process or outcome; Produce a quantitative result; Be population based; Have valid data and methodology; Analysis with comparison to benchmarks and goals-use the HEDIS national 90th percentile levels as goals for the diabetes measure. The Quality Management Department reviews and reports the results annually and compares them to these goals and to past performance. 8 Last Edited: Friday, March 29, 2013 APPENDIX A.11 The Heart and Vascular Disease Management Program Element A: Program Content GHC-SCW is committed to helping members, and their practitioners, manage chronic illness by providing tools and resources to empower members to take action to improve their health and chronic conditions. Heart and vascular diseases (HVD) are a major concern for GHC-SCW due to the increase in number of members being diagnosed and the health risks and costs associated with poor control. GHC-SCW currently has approximately 1,500 members with a diagnosis of HVD. Proactive practitioner intervention and support, in collaboration with health education and clinical outreach, helps members manage their chronic conditions. GHC-SCW has designed the HVD Management Program to educate members about HVD, teach members how to self-manage their disease, emphasize the importance of regular care, and provide support tools and screenings for disease management. GHC-SCW’s patient focused Healthy Heart was developed to help members self-manage their HVD to reduce related complications, morbidities and death. The content of the HVD program includes condition monitoring, patient adherence to treatment plans, consideration of other health conditions, lifestyle issues and ongoing screening for behavioral health concerns. Element A Factor 1 - Condition monitoring GHC monitors the following indicators for all members in the program: Dates and results of most recent fasting lipid panel (including LDL, HDL, total cholesterol, and triglycerides) - if past due, outreach calls and letters are sent to the member quarterly Date of last creatinine and result Prescriptions for lipid lowering agents (date prescribed, date filled) Prescriptions for hypertension (date prescribed, date filled) New prescription and dosage change follow up calls and blood monitoring Co-morbidities (asthma, hypertension, cardiovascular disease, hyperlipidemia) Date and result of most recent blood pressure measurement Members can access their future appointments, outstanding orders for labs and diagnostics, medication lists, lab results and diagnostic results through MyChartSM - an interactive online patient health portal. Members who have MyChartSM accounts have access to disease management information outside of GHC via Healthwise, an interactive shared learning tool. All encounters with health educators are documented in the EMR. Element A2 - Adherence to treatment plans Members work with a Cardiovascular Nurse Specialist, Registered Nurse Health Educators, Registered Dieticians, Tobacco Cessation Counselor, nursing staff and their primary care practitioner who monitor patient adherence in the following areas: 1 Last Edited: Friday, March 29, 2013 Modification of risk factors Weight control Blood Pressure control Medication compliance Adherence to Nutritional Guidelines Adherence to scheduling regular practitioner appointments Physical Activity Level Tobacco Cessation Element A3 - Medical and behavioral health comorbidities and other health conditions The HVD registry is updated weekly and includes current lab, prescription and risk factor data. GHC-SCW identifies members with HVD who also have asthma, hypertension, cardiovascular disease, hyperlipidemia and/or depression. GHC-SCW is committed to a collaborative approach to disease management, especially for those members with multiple co-morbidities. Practitioners are encouraged to refer members to health educators, complementary therapists as well as to outside resources. GHCSCW is the only local practice group and HMO to offer complementary medicine to its members. Referrals are quick and easy using our EMR or internal phone system. Members have several opportunities for a collaborative management approach to HVD care that are included in their insurance coverage. The Nurse Health Educators complete initial assessments for all members to assess for learning style preferences, cognitive abilities, socio-economic factors, and physical limitations prior to creating the patient driven treatment plan Clinic staff (includes pharmacy, lab, radiology, CMA’s, LPN’s, RN’s, practitioners) have access to the electronic medical record and can see the problem list for each member. GHC-SCW utilizes a care team approach for members which ensure collaboration for those members with multiple co-morbidities requiring more intensive care. Practitioners have the opportunity to refer patients to a variety of other practitioners to support the needs of the patient. Examples of referrals are to Nurse Educators and/or Behavioral Health Specialists. Registered Dietitians also have access to the EMR and document their encounters with members, contributing to the plan of care. A case manager can also be utilized to ensure appropriate care for those with more complex needs. Element A4 - Health Behaviors Behavior modification is an essential component of a HVD program. Health Educators (i.e. Nurse Educators, Tobacco Cessation Counselor, and Registered Dietitians) work with GHC-SCW members who have HVD to provide personalized education, support and to promote healthy lifestyle options. Members may have individual counseling sessions as needed along with an extensive offering of classes. 2 Last Edited: Friday, March 29, 2013 Members with HVD who have documented tobacco use also receive outreach mailings providing them with cessation resources. These resources include tobacco cessation classes, individual counseling sessions with a tobacco cessation counselor, and information on community resources such as the Wisconsin Quit Line. In addition, GHC-SCW covers tobacco cessation medications on its formulary at 100% for the majority of its members. For those members who participate in the annual Great American Smoke out campaign, there is no copay for smoking cessation medications and they get free counseling for one year from the Tobacco Cessation Counselor. Members are requested to complete a pre-physical General Medical History Form every time they schedule a physical. They are mailed this before the appointment and are to bring it with them for review during the appointment. In the survey are questions about health behaviors such as alcohol consumption, tobacco use, hobby hazards, wearing seat belts, helmets and preventive self- exams. Based on responses to these questions, practitioners can counsel on at risk behaviors. Element A5 - Psychosocial issues GHC-SCW has incorporated the Anxiety Screening tool GAD-7 into its electronic health record. This is a seven item anxiety questionnaire that has been developed and validated in a primary care setting. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also has access to this screening tool in their member assessments. Element A6 - Depression screening GHC-SCW has incorporated the Depression Screening tool, PHQ-9 into its electronic health record. The Patient Health Questionnaire - Nine is the standard among scales for monitoring symptoms of depression. It has been extensively studied as a screening measure for major depression in primary care settings. It is a patient self-assessment tool that can be done in the practitioners’ office jointly with the practitioner or done independently and reviewed at a follow-up appointment. The assessment can be accessed from the members EMR under “Screening Tools”. All Behavioral Health staff also has access to this screening tool in their member assessments. All members are mailed a screening tool prior to their physicals. Imbedded in this document are two questions from the PHQ-9 that are used as an initial depression assessment. Based on these results, members can then be directed to complete the entire PHQ-9 for further evaluation and possible followup to a behavioral health specialist if needed. Element A7 - Information about the patient’s condition provided to caregivers who have the patients consent Family members and/or caregivers who want or need access to the patient’s medical record are required to have a “Release of Information” consent form signed by the patient, indicating they may 3 Last Edited: Friday, March 29, 2013 have access to their records. Patients may choose to share electronic access to their medical record by sharing password information to their MyChart account with family members and/or caregivers. Family members and/or caregivers who are GHC-SCW members have access to Healthwise, a shared decision making tool and healthcare resource available via MyChart. Members with HVD are given a brochure called “Healthy Heart”. Each member can also see a Health Educator who can help them create an Action Plan that can be shared with the member’s family, and is available to the member’s health care team. Element A8 - Encouraging patients to communicate with their practitioners about their health conditions and treatment. Members have the ability to utilize MyChartSM which is a patient portal within Epic, the electronic medical record software. They can send messages directly to their practitioner, nursing staff, pharmacy, or member services as well as make appointments, sign up for classes, see lab and other diagnostic results. All members are encouraged to sign up for MyChartSM. MyChartSM is now available on both the iPhone and Droid smart phones making it convenient for members who may have these devices. Outreach letters are sent to members in the HVD Registry to encourage them to contact their practitioner and stress the importance of communication. In addition, if a member completes a Health Risk Assessment (HRA) and based on their results, they are encouraged to follow up with their practitioner and can click on a link that takes them directly to scheduling an appointment Element A9 - Additional resources external to the organization All GHC-SCW members are encouraged to complete a Health Risk Assessment (HRA) that is available free of charge through their employer or via MyChartSM. Members also have access to Healthwise, a shared decision making tool and health resource that is also available via MyChartSM. Practitioners can print information from Healthwise during the visit and give it to members to take home with them. Element B: Identifying Members for DM Programs GHC-SCW uses the following data sources to identify members for the HVD management program: Claims or encounter data Prescription data Problem list in the electronic medical record Laboratory results - Cardiovascular Nurse Specialist contacts members with an elevated LDL over 100 Health risk assessment results Data collected through the utilization management or care management process Member referral Practitioner referral 4 Last Edited: Friday, March 29, 2013 Clinical Care Management referral GHC-SCW does not use continuous enrollment criteria for identifying members. The HVD registry updates weekly. Element C: Frequency of Member Identification The GHC-SCW HVD disease registry updates weekly. (See Element C) In addition, the disease registry is run quarterly to look for members who have outstanding lab work (no LDL in over 13 months, LDL over 100 in past 6-13 months, and if result cannot be calculated). Element D: Providing Members with Information How to use services - GHC-SCW sends a letter and a brochure “Healthy Heart” to eligible members annually. These highlight the importance of managing HVD and the resources available both internally and externally along with contact information. How members become eligible to participate - Newly diagnosed members are sent a letter and a brochure “Health Heart”. The letter informs them that they are now part of the HVD Management Program and the brochure highlights the importance of managing HVD and the resources available both internally and externally along with contact information. How to opt in or out - The brochure “Health Heart” explains to members how they can opt out of the outreach associated with being on the HVD registry. When members contact GHC-SCW QM staff to opt out, they are informed that they will be contacted in one year to follow up to see if they still wish to be excluded from outreach efforts. Element E: Interventions based on Assessment GHC-SCW provides interventions for heart and vascular disease members based on stratification. Different interventions are provided for members based on severity of illness, participation in completion of testing and examinations as well as the results of those tests. Tier 1: All members with HVD Interventions o Initial letter sent to those with new diagnosis of HVD describing the program and resources available to them o HVD management program letter and brochure mailed to all registry members annually o Access to health educators and/or primary care practitioner o Access to HVD-related classes o Clinical staff are notified of quarterly CVD mailings o 5 Last Edited: Friday, March 29, 2013 Tier 2: Subset of members with HVD; members are contacted if they meet one or more of the following criteria: Had LDL done 6 or more months ago and result was >100mg/dL OR no LDL done in the last 13 months OR had LDL in last 6-13 months and result was incalculable; Interventions: Same as Tier 1 and include: Contact by mail and phone quarterly for needed tests Offer appointment with health educators and/or primary care Tier 3: Subset of members who utilize the Clinical Nurse Educators Element F: Eligible Member Active Participation GHC-SCW annually reports the member participation rate to the Clinical and Service Quality Committee (CSQC). Element G: Informing and Educating Practitioners Instructions on how to use the HVD Management Program Practitioners are informed of the HVD Management Program in the following ways: The Practitioner Handbook contains a copy of the HVD Management Program description Practitioners receive a copy of the HVD Management Program brochure They are notified when outreach is done on members There are updates in organizational newsletters Health Maintenance Modifiers for labs and screening Best Practice Alerts (BPA’s) How the organization works with practitioners’ patients in the program Practitioners have access to see an encounter in Chart Review for all contacts the member has with health educators, care management and case management. They can communicate using electronic messaging and/or in person. Element H: Integrating Member Information GHC-SCW utilizes a common electronic medical record (i.e. EpicCare) which allows for integration of member information for continuity of care. This information is extracted into a variety of reporting tools and reports utilized by GHC-SCW to focus on this member population to ensure focused and relevant 6 Last Edited: Friday, March 29, 2013 interventions. This then allows for comprehensive resources for the following departments: health information line, case management program, utilization management program, quality management outreach program and health education. GHC-SCW utilizes two other EMR resources to integrate member information. CareLink allows staff to see the patients’ medical record if they have been seen a partnering facility utilizing Epic. In addition, GHC-SCW participates in Care Everywhere, another tool developed by Epic to ensure access to patient information while they are traveling and out of the service area. Element I: Satisfaction with Disease Management All GHC-SCW members in the HVD registry are surveyed for feedback on their thoughts and experiences of the program. Additionally, those members who utilize care management are surveyed through the PAM and Complex Case Management survey tools. Randomly selected GHC-SCW members who had a visit with their practitioner, health education, complementary medicine, physical and/or occupational therapy are sent a Press Ganey survey. Random samplings of members are also sent a CAHPS survey as part of GHC-SCW’s accreditation process. All complaints are managed through Member Services per protocol. Element J: Measuring Effectiveness HEDIS results are analyzed monthly to look for trends or changes in compliance. GHC-SCW’s Quality Management Team along with other stakeholders in the organization, actively look for QI projects throughout the year. These projects look at a variety of issues and target areas where a measure is below the 50th percentile as well as ensuring measures stay above the 90th and 95th percentile. The projects will: 1) 2) 3) 4) 5) Address a relevant process or outcome; Produce a quantitative result; Be population based; Have valid data and methodology; Analysis with comparison to benchmarks and goals - use the HEDIS national 90th percentile levels as goals for the HVD measure. The Quality Management Department reviews and reports the results annually and compares them to these goals and to past performance. 7 Last Edited: Friday, March 29, 2013