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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Objectives
Overview of ValueOptions®
Giving Value Back
ProviderConnect® Demonstration
Overview of Operational Areas
Featured Presentation – Fraud Waste & Abuse
Questions and Answers
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions
Founded in 1983
Largest independent behavioral health company
Serving over 32 million members
Contracts with 20 health plans
More than 50 Medicaid contracts in 14 states
Committed to principles of recovery and resiliency
Diverse client base • Commercial Division
Employer Groups
Health Plans
• Federal Division
• Public Sector Division
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions National Presence
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Regional support, EAP staff and corporate support offices
Major service centers
Public Program/ Medicaid Membership
National Innovation and Technology Center
AK
NM
MT
WY
COUT
ID
AZ
NV
WA
CA
OR
TX
OK
KS
NE
SD
ND
IL
MS
AR
LA
MO
IA
MNWI
FL
KY
WV VA
NCTN
SC
AL GA
RI
NJ
DEMD
ME
NY
PA
MI
VTNHMA
CT
OHIN
HI
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
How Does ValueOptions Give Value Back to the Providers?
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Welcome Packet
www.valueoptions.com
Provider BenefitsCEU Opportunities & Training Resources
Electronic Online Administrative ServicesProvider Designation Programs
Single Integrated Connect System
Provider Forums
Visit to Key Facilities
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueSelect Program
A provider designation implemented by ValueOptions
Selected based on:• Accessibility
• Administrative efficiency
• Clinical and quality efficiency
• Number of complaints received from patients
• Engagement in at least one or more of the following: On Track Outcomes Program Electronic submission of at least 75% of non-EAP claims Patient completion of ValueOptions Patient Treatment Survey CEAP credentialing
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Relias and CEQuick
Relias (previously known as Essential Learning):
Free Internet based training and development program for ValueSelectSM providers
Wide variety of online CEU courses Providers take courses at their own pace ValueSelect eligibility reviewed semi-annually; if provider is
eligible, will receive an Relias welcome letter and learner manual
CEQuick Offers all of the benefits of the Relias training platform but is
available to non-ValueSelect providers at a cost.
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
On Track Outcomes
A client-centered outcomes management program
Supports clinicians as they help clients achieve their goals
Utilizes a standardized, client-completed questionnaire
Provider receives rapid feedback
Disclaimer: The ValueOptions On Track Outcomes program does not make recommendations or decisions aboutappropriate clinical care or service. Any questionnaires, reports, guidelines and other material related to thisprogram are intended as an informational aid to network clinicians. They do not substitute for or limit in any waythe use of other resources and the clinician's own professional judgment in the delivery of counseling services.
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
PaySpan® Health
A tool enabling you to:
• Receive payments automatically
• Receive email notifications immediately upon payment
• View your remittance advice online
• Download an 835 file to use for auto-posting purposes
Visit the PaySpan Health website at www.payspanhealth.com
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Electronic Provider Summary Vouchers (PSVs) and Authorization Letters
Electronic Clinical Notifications for Outpatient Outlier Requests forInformation
Online Provider Recredentialing
ValueOptions self-service option, ProviderConnect
Green Program Webinars: http://www.valueoptions.com/providers/Training/Training_Workshops_Archives.htm
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Up to the Minute Communications
Provider PulseSM Messages
Fax and Email Communications
Provider Mailings
Constant Contact Alerts
Monthly Valued Provider eNewsletter
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ProviderConnect – Provider Online Services
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A HIPAA-secure online tool where providers can: Verify member eligibility Access ProviderConnect Message Center
Access and Print Forms Submit EAP Case Activity Forms (CAF)
Request Payment for EAP Services Request and View Authorizations
Download and Print Authorization Letters Submit Claims and View Status
Access PSVs Submit Customer Service Inquiries
Submit Updates to Provider DemographicInformation
Submit Recredentialing Applications
INCREASED CONVENIENCE, DECREASED ADMINISTRATIVE PROCESSESDisclaimer: Please note that ProviderConnect SM may look different and have different functionalities based on individual
contract needs, therefore some functions may not be available or may look different for your specific contract.
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ProviderConnect Benefits
What are the benefits of ProviderConnect?• Free and secure online application.
• Access routine information 24 hours a day, 7 days a week
• Complete multiple transactions in single sitting
• View and print information
• Reduce calls for routine information
• Smartphone/Mobile Device Friendly
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
How to Access ProviderConnect
Go to www.ValueOptions.com, choose “Providers”
In-network providers can self register for using provider ID number
Multiple logons from same provider ID number available• Fax completed Provider Services Account Request Form to
1-866-698-6032
Contact Information:• ValueOptions EDI Helpdesk • 1-888-247-9311 • [email protected]• Monday to Friday, 8:00 a.m. - 6:00 p.m. ET
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ProviderConnect Message Center (Personalized!)
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Outpatient Outlier Request for Information
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Message Center – Treatment Guideline Notification
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Request for Clinical Information Response Process
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
EAP Case Activity and Billing Form on ProviderConnect
Network providers authorized to perform EAP services can now submit their one-page version of the CAF-1 billing forms via. ProviderConnect
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Role-Based Security: Features
New level of ProviderConnect access to enhance security as required by HIPAA guidelines
Level of ProviderConnect access defined by role
Roles defined by user type and/or VO business rules
Users assigned roles with access to certain functions
i.e. claims
User Types: Super User, Managed User (managed by Super User), Standard User
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
NETWORKCONNECTSM
Robust network management and provider relations
CARECONNECTSM
Superior clinical case management and data collection
SERVICECONNECTSM
Industry-best customer service and issue resolution
MEMBERCONNECTSM
Online self-service and award-winning content for members
TELECONNECTSM
Easy-to-access telephonic self-service for providers and members
PROVIDERCONNECTSM
Secure, online administrative self-service for providers
ValueOptions Connect System
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ProviderConnect Training Webinars
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Scheduled monthly
Topics include: Authorizations, Claim Submission, Role-based security, Re-credentialing, Viewing Patient Info, etc.
Webinar calendar available at http://www.valueoptions.com/providers/Providers.htm• Next webinar scheduled for 10/9/13
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Video Tutorial Library
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The library includes tutorials on how to:• Navigate ValueOptions.com
• Navigate ProviderConnect
• Navigate the Provider Handbook
• Locate the most recent version of the Provider newsletter
Video tutorials are located at the following link:• http://www.valueoptions.com/providers/How-To.htm
Additional video tutorials will be posted throughout 2013!
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions National Network Services
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Provider Relations• Ensures members’ behavioral health care needs are met
through a geographically and clinically robust network of providers
• Ensures maintenance of network composition by engaging in assertive retention strategies;
• Engages in timely and appropriate recruitment
• Engages in professional, consistent, and educative communications with provider community and staff
Provider Credentialing• Completion of Credentialing Application required for
network participation
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions National Network Services
Provider Recredentialing (every 3 years)
Notifications• 4 months prior to due date (telephonic), 1 week later (email/fax), 15
and 30 days prior to due dateFailure to respond to requests will result in disenrollment from the network
Process• Complete online, prepopulated recredentialing application
• Attach updated license, certification and malpractice information
• Electronically sign the application (once signed, it is automatically submitted)
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Provider Contracting
• ValueOptions Provider Agreements
ValueOptions National Network Services
Questions about Contracting and Credentialing?
Call 1-800-397-1630
(8am – 5pm ET)
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions Quality Management
Quality Management Program Oversight provided by Medical Director
Key Quality Indicators include but are not limited to:• Satisfaction Survey measures
• Access/Availability of Services – geographic access, phone statistics, appointment availability, etc.
• Complaints/Grievances - tracking and reporting
• Patient Safety – adverse incidents and quality of care
• Coordination of Care
• Quality Improvement Activities/Projects
• Compliance with URAC and NCQA Standards
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions Quality Management (cont.)
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Ongoing Quality Improvement Activities (QIAs)• Clinical QIAs
• Ambulatory Follow-up Time in the Comm unity – Depression Management
Risk Tracking – Referral for Urgent and Emergent Treatment
• Service QIAs Average Speed of Answer
Provider Satisfaction with Utilization Management
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Electronic Claims Submission
Advantages: • Better, faster, and cheaper
• Reduced Paper Files
• Reduced Labor and Postage Expenses
• Reduced potential of error or mishandling
• Faster claims processing improves cash flow
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ValueOptions EDI (Electronic Data Interchange)
Accept claims files from any Practice Management System outputting HIPAA formatted 837P or 837I files, and from EDI claims submission vendors
Offer Direct Claims Submission on website to providers who do not have own software or who wish to submit certain claims outside their batch files• These claims are processed immediately, and you are provided the
claim number.
• You may submit batch claims files or Direct Claims interchangeably.
No charge for electronic claims submission
Access to support:• http://www.valueoptions.com/providers/Provider_Connect.htm
• Helpdesk: 1-888-247-9311 between 8am - 6pm ET
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
ICD - 10
ValueOptions is preparing for the 10th modification to International Classification of Diseases (ICD) codes
• Will be compliant with regulation and only accept ICD-10 codes on or after the official compliance date confirmed by CMS to be October 2014
• Will cease to accept ICD-9 codes following the time parameters of the regulation.
• All providers should read the latest ICD-10 Frequently Asked Questions (FAQs) at http://www.valueoptions.com/providers/Files/pdfs/ICD-10_FAQ.pdf
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Customer Service Philosophy
Committed to providing our members and providers with the most accurate and informed benefit, eligibility, claims, and certification information in the most effective, efficient, and compassionate manner
Puts our members’ needs and concerns first and is committed to resolving inquiries promptly without the need to make a re-contact
We value our members’ questions and concerns and place member satisfaction at the heart of our Customer Service philosophy
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.72
Referred by Health Plan Care Manager
Referred From Employer EAP Provider
Key Components of the ValueOptions®
Care Management Paradigm• Authorization and care management recommendations
are Individualized for Diagnoses and Level of Care requests.
• Collaborative approach with treating providers.
• Symptom Complex based review processes.
• Utilization of treatment guidelines, Level of Care criteria and treatment algorithms.
• Intensive Care Management programs for high risk high cost members.
• Intensive Care Management activities to impact:
Acute Inpatient
Residential
Partial Hospital
• Special protocols based on client nuances.
Members Who Seek Care Via the ValueOptions®
Clinical Referral Line
Members Identified By Health Plan Disease
Management Screening
Members Identified By Predictive Modeling
Software – High Risk Physical Potential
Co-morbid Behavior
Members Entering the Behavioral Health System
In Crisis
Members Identified As High Risk (Multiple
Channels)
Members Identified By ValueOptions®
PharmaConnect Application
Care Management Paradigm
Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Referral Assistance
Licensed care management staff is available 24 hours a day/seven days a week for referral and utilization management• Member referral process:
Emergencies are followed until disposition
Urgent referrals are offered appointments within 48 hours and are called to ensure appointment is kept
Providers can contact ValueOptions for referral assistance if needed
Providers should contact ValueOptions 24 hours a day/seven (7) days a week if members require higher level of care or increased visit frequency
Care Management staff will assist with referral to inpatient or specialty programs
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Utilization Management Process
Inpatient• Requests are completed via the web or telephonically by calling the
number on the back of the members Identification card
• Some clients still require pre-authorization for HLOC – notification requirements may also vary
• ValueOptions staff are available 24 hours a day/ seven (7) days a week
Outpatient• Since pass through or registration no longer applies to outpatient
services impacted by federal parity, authorization cannot be required
Not all clients are subject to federal parity
It is important to check benefits and authorization requirements on each member via the web or by calling the number on the member’s identification card.
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Utilization Management Process
Outpatient
• Outpatient care management will be conducted primarily through front-end claims or claims extracts, and will emphasize 4 areas:
Complex Diagnoses
Outlier cases
Outlier Providers
Intensive Care Management
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Resources for Providers
Clinical information on www.valueoptions.com:
• ValueOptions Medical Necessity criteria
• Changes to Substance Use Medical Necessity Criteria
• Treatment Practice guidelines
• PCP consult line 9 am to 5 pm (Eastern Time)
• Intensive Case Management Services
• PharmaConnect analyzes pharmacy data and uses automated rules engine to screen for:
Sub-optimal therapy
Under-use
Early discontinuation
Automatic notification to providers
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Resources for Providers (cont.)
Clinical information: www.valueoptions.com:
• Health Alert
• Federal Mental Health Parity
• On Track
• Achieve Solutions®
• a continuously updated and trusted behavioral health and wellness Web site that you can share with your patients. Designed with an intuitive, user-friendly interface, the site provides more than 6,000 articles on over 200 topics
• Outpatient Detoxification/Buprenorphine (Suboxone® or Subutex® ) Maintenance Program
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Medical Necessity Criteria Changes
On January 1, 2013, ValueOptions revised the structure for Substance Use Medical Necessity Criteria and will no longer follow the American Society for Addiction Medicine (ASAM) Patient Placement Criteria for the Treatment of Substance – Related Disorders
Providers can access the revised Substance Use Medical Necessity Criteria via the Provider Handbook page
• http://www.valueoptions.com/providers/Handbook/clinical_criteria.htm
Reference the Network Specific Site to see whether a Network Specific Contract requires the use of ASAM Criteria
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
DSM-5
In May, the American Psychiatric Association (APA) released the new DSM-5.
The APA is recommending all insurance companies have DSM-5 implemented by January 1, 2014.
ValueOptions will be adopting the DSM-5 coding for clinical purposes and will be working towards the APA deadline.
Additional details around the migration to DSM-5 will be released on our website as it becomes available.
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Stamp Out Stigma (S.O.S.) Campaign
S.O.S. encourages individuals to talk to friends and loved ones about mental illness to show commitment to stamping out stigma of mental illness.
The campaign is now being introduced to our provider community to further support our valued providers when communicating with patients about mental illness.
A provider toolkit is available online for our providers to access S.O.S. materials.
Visit our provide page to learn more about S.O.S.
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Provider Contacts
Provider Relations, Credentialing and Contracting Questions:
• 1-800-397-1630 (8 am - 5 pm ET Monday - Friday)
Electronic Claims & ProviderConnect Technical Questions (EDI Help Desk):
• 1-888-247-9311 (8 am - 6 pm ET Monday - Friday)
For PaySpan Registration Provider Support contact:
• 1-877-331-7154
Provider Support is available from 8am to 8pm Eastern time, Monday through Friday
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Copyright © 2013 ValueOptions, Inc. All Rights Reserved.
Featured Presentation: Fraud Waste & Abuse
2013
Topics for Today’s Presentation
• Development of Program Integrity, Laws & Requirements
• Current Audit Activities
• Preparing for an Audit
• Basic Documentation Requirements
2
Key Terms
Fraud – Intentional deception or misrepresentation
made by a person with the knowledge that the
deception could result in some unauthorized benefit.
• Many payment errors are billing mistakes and are not the result of
someone such as a physician, provider, or pharmacy trying to take
advantage of the Medicaid Program.
• Fraud occurs when someone intentionally falsifies information or
deceives the Medicaid Program.
3
Key Terms (cont.)
• Waste – Thoughtless or careless expenditure, consumption, mismanagement, use or squandering of healthcare resources,
including incurring costs because of inefficient or ineffective
practices, systems or controls.
• Abuse – Provider practices that are inconsistent with sound
fiscal, business or medical practices, and result in an
unnecessary cost to health programs, or in reimbursement for
services that are not medically necessary or fail to meet
professionally recognized standards.
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Key Terms (cont.)
• Compliance Program – Systematic procedures instituted to ensure that contractual and regulatory requirements are being met.
• Compliance Risk Assessment – Process of assessing a company’s risk related to its compliance with contractual and regulatory requirements.
• Compliance Work Plan – Prioritization of activities and resources based on the Compliance Risk Assessment findings.
• Program Integrity – Steps & activities included in the compliance program & plan specific to fraud, waste & abuse.
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History of Program Integrity
• Balanced Budget Act (BBA)
– Amended Social Security Act (SSA) re: Healthcare Crimes
– Must exclude from Medicare & state healthcare programs those convicted of healthcare offenses
– Can impose civil monetary penalties for anyone who arranges or contracts with excluded parties
• Federal False Claims Act (FCA)
– Liable for a civil penalty of not less than $5,000 & no more than $10,000, plus 3x amount of damages for those who submit, or cause another to submit, false claims
• Deficit Reduction Act (DRA)
– Requires communication of policies & procedures to employees re: FCA, whistleblower rights and fraud, waste & abuse prevention, if receiving more than $5M in Medicaid
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History of Program Integrity (cont.)
• 7 Basic Elements of a Compliance Program as Adopted by OIG & CMS (based on Federal Sentencing Guidelines)
– Written policies & procedures
– Compliance Officer & Compliance Committee
– Effective training & education
– Effective lines of communication between the Compliance Officer, Board, Executive Management & staff (incl. an anonymous reporting function)
– Internal monitoring & auditing
– Disciplinary enforcement
– Mechanisms for responding to detected problems
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Regulatory Changes = Heightened
Federal & State Awareness
• Laws & regulations are now formalizing & emphasizing the effectiveness in prevention, detection & resolution of fraud, waste & abuse as well as the recovery of overpayments.
• Fraud Enforcement and Recovery Act of 2009 (FERA)
• Patient Protection and Affordable Care Act (PPACA – Healthcare Reform Act)
• Per Federal regulations, providers excluded from one line of business with ValueOptions, will not be able to participate in
any ValueOptions network or lines of business
• ValueOptions required to check Federal exclusion lists regularly to make sure no excluded providers are in network
•
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New 8th Element of a Compliance
Program
• Compliance Programs Must be Effective
– Must show that compliance plans are more than a piece of paper
– Must be able to show an effective program that signifies a proactive approach to the identification of fraud, waste & abuse
– How much fraud, waste & abuse have you identified?
– How much fraud, waste & abuse have you prevented?
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Types of Audits
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• Compliance Audit Evaluates strength and thoroughness of compliance
preparations.
• Program Integrity Audit Evaluates strength and thoroughness of efforts to prevent,
detect and correct Fraud and Abuse.
Federal Level Activities – Centers for
Medicare & Medicaid Services
(CMS)
• Medicaid Integrity Program (MIP)
• Medicaid Integrity Group (MIG)
• Medicaid Integrity Contractors (MIC)
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MIC Auditors by Region • New York (CMS Regions I & II)
– Island Peer Review Organization (IPRO)
• Atlanta (CMS Regions III & IV)
– Health Integrity, LLC
• Chicago (CMS Regions V & VII)
– Health Integrity, LLC
• Dallas (CMS Regions VI & VIII)
– Health Management Systems (HMS)
• San Francisco (CMS Regions IX & X)
– Health Management Systems (HMS)
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MIC Jurisdictions/Regional Offices
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New York: Regions 1,2
Atlanta: Regions 3,4
Dallas: Regions 6,8
Chicago: Regions 5,7 San Francisco:
Regions 9,10
Also: CNMI, Guam, American
Samoa
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Other Enforcement Entities
• U.S. Department of Health & Human Services, Office of Inspector General (OIG)
• U.S. Department of Justice (DOJ)
• Office of the State Attorney General (AG) – Medicaid Fraud
Control Unit (MFCU)
• Federal Bureau of Investigation (FBI)
• Department of Insurance (DOI)
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How Do We Do This?
• Use the 8 Elements of an Effective Compliance Program as a Guide
• Delegate a Knowledgeable Point Person
• Know Your Contractual & Regulatory Requirements re: Fraud, Waste &
Abuse
• Educate Staff on How Daily Activities Prevent, Detect & Address Fraud,
Waste & Abuse.
– https://oig.hhs.gov/compliance/101/index.asp
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Establish an Environment of
Awareness • Provide clinically necessary care through services within the
scope of the practitioners’ licensure
• Routinely monitor treatment records for required standardized
documentation elements
• Monitor & adhere to claims submission standards
• Correct identified errors
• Hold staff accountable for errors
• Cooperate w/ all audits, surveys, inspections, etc.
• Cooperate w/ efforts to recover overpayments
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Establish an Environment of
Awareness (cont.) • Maintain documentation of all P&Ps, activities, audits,
investigations, etc.
• Verify member eligibility
• Ensure staff know how to report fraud, waste & abuse
• Communicate internally & externally
• Set-up a suggestion box for anonymous concerns and suggestions for improvement
• Post fraud, waste & abuse tips
• Send out weekly tips on how to prevent fraud
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Conduct Self-Assessments
• Detail All Program Integrity Requirements &
Contract Requirements
• Assess & Prioritize Gaps in Compliance & Develop
Action Plans to Remedy = Document All Efforts
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Conduct Self-Assessments (cont.)
Ask Yourselves Assessment Questions regarding:
– Identification of employees who lost credentials
– Meeting standards to ensure treatment record documentation
– Accurate billing and documenting for services rendered
– Routine checking of member eligibility
– Training of staff
– Ability to anonymously report internal fraud, waste and/or abuse
concerns?
– Effectiveness of current processes
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Train Staff to Recognize Fraud, Waste
& Abuse • Common Fraud Schemes:
– Billing for “Phantom Patients”
– Billing for Services Not Provided
– Billing for More Hours than In a Day.
– Using False Credentials.
– Double-Billing
– Misrepresenting diagnosis, type/place of service, or who rendered service
– Billing for non-covered services
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– Upcoding
– Failure to collect co-insurance/deductibles
– Inappropriate documentation
– Lack of computer integrity
– Failure to resolve overpayments
– Delays in discharge to run up bill
– Kickbacks
Train Staff to Recognize Fraud, Waste
& Abuse
• Common Member Fraud Schemes:
– Forgery
– Impersonation
– Co-Payment Evasion
– Providing False Information
– Sharing or theft of Medicaid benefits
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Purposes for Documentation
• Provides Evidence Services Were Provided
• Required to Record Pertinent Facts, Findings, & Observations about an Individual’s Medical History, Treatment, and Outcomes
• Facilitates Communication & Continuity of Care Among Counselors & Other Health Care Professionals Involved in the Member’s Care
• Facilitates Accurate & Timely Claims Review & Payment.
• Supports Utilization Review & Quality of Care Evaluations
• Enables Collection of Data Useful for Research & Education
26
ValueOptions’ Approach to Program
Integrity: Prevention
ValueOptions attempts to prevent paying for billing errors through the following ways:
• Being an Industry Partnership
• Training & Education
• Provider Support
• Contractual Provisions
• Provider Profiling & Credentialing
• Ethics Hotline
• Claims Edits
• Prior Authorizations
• Member Handbook
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ValueOptions Provider Handbook
and Contract
• The provider handbook is an extension of the provider contract and includes guidelines on doing business with
ValueOptions, including policies and procedures for individual
providers, affiliates, group practices, programs and facilities.
• Together, the provider agreement, addenda, and handbook
outline the requirements and procedures applicable to
participating providers in the ValueOptions network(s)
Except to the extent a given section or provision in the handbook is included to address a regulatory, accreditation or
government program requirement or specific benefit plan requirement, in the event of a conflict between a member’s benefit
plan, the provider agreement and the handbook, such conflict will be resolved by giving precedence in the following order: (1)
the member’s benefit plan, (2) the provider contract and (3) the handbook.
28
Additional Documentation
Standards
• State regulations and/or disciplinary standards may also have an impact on documentation standards
• Be sure to check your state regulations and licensing
standards for any additional requirements
29
Code of Conduct
• The ValueOptions Code of Conduct was created pursuant to State and Federal requirements.
• Providers should read the code of conduct and comply with
the parts that are applicable to their line of business.
30
ValueOptions’ Approach to Program
Integrity: Detection
• Audit & Detection
– Internal/External Referral Process
– Audits
– Post-Processing Review of Claims
– Data Mining & Trend Analysis
– Special Reviews
• Investigation & Resolution
– Investigation & Disciplinary Processes
– Reporting Requirements
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Basic Documentation Needs
• All billable activities must have a start & stop time
• Service codes used in claims for payment must match codes used in charts
• Detailed progress notes for members
• Number of units billed must match number of units in documentation
• Full signatures with credentials & dates on all documentation
• Covered vs. non-Covered services
• Services provided/documented meet service definition for code billed
• Progress notes are legible and amendments clearly marked
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Documentation – Additional Tips
• Activity Logs Should Not be Pre-Signed
• Progress Notes Must be Written After the Group/Individual
Session
• All Entries Should be in Blue or Black Ink for Handwritten Notes,
Not Pencil, No White-Out
• Keep Records Secure and Collected in One Location for Each
Member
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1. Referral received
2. Referral reviewed and charts may be ordered
3. Providers required to supply copies of the charts requested
within specified timeframes
4. Charts will be reviewed by VO staff
5. After completion of the review, results letter will be sent to the provider
VO Provider Audits
Common Errors Found by VO staff
• Not submitting all documentation requested
• Wrong date of service submitted on the claim
• Provider rendering the service was different than
the provider billing the service
• Nothing documented on the weekends for
residential services
35
ValueOptions Contact & Reporting
Info
• ValueOptions Ethics Hotline
– 1-888-293-3027
• Report Concerns to Your Organization’s Compliance Office, ValueOptions directly, or via ValueOptions’ Ethics Hotline
– Remember: you may report anonymously and retaliation is prohibited when you report a concern in good faith
– Reporting all instances of suspected fraud, waste and/or abuse is an expectation and responsibility for everyone
• If Available, Report to Your State’s Medicaid Fraud and Abuse Control Unit (MFCU)
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Laws Regulating Fraud, Waste & Abuse • False Claims Act (FCA), 31 U.S.C. §§ 3729-3733
• Stark Law, Social Security Act, § 1877
• Anti-Kickback Statute, 41 U.S.C
• HIPAA, 45 CFR, Title II, § 201-250
• Deficit Reduction Act (DRA), Public Law No. 109-171, § 6032
• Care Programs, 42 U.S.C. § 1128B, 1320a-7b
• False Claims Whistleblower Employee Protection Act, 31 U.S.C. §
3730(h)
• Administrative Remedies for False Claims and Statements, 31 U.S.C. Chapter 8, § 3801
37
Program Integrity Links • Code of Federal Regulation:
– TITLE 42-Public Health, Chapter IV-CMS, DHHS, SUBCHAPTER C-Medical Assistance Programs, Part 455-Program Integrity: Medicaid.
– www.gpoaccess.gov/cfr/index.html
• Office of Inspector General (OIG):
– www.oig.hhs.gov/fraud.asp
• Center for Medicare and Medicaid Services (CMS):
– www.cms.gov/MedicaidIntegrityProgram/
• National Association of Medicaid Fraud Control Units (NAMFCU):
– www.namfcu.net/
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