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San Francisco Mental Health Plan (SFMHP)
Behavioral Health Services (BHS)
BHS Quality Management
Clinical Documentation Improvement Program (CDIP)
January 2018staff contact: [email protected]
Mental Health Medi-Cal Specialty
Mental Health Services (SMHS):
Private Provider Network (PPN)
Outpatient (Non-Hospital)
Documentation Training
Mins Item Objective
10 Overview: Mental Health Medi-Cal • Logic and frame of MH M-Cal Insurance
10 Medical Necessity • Required elements and clinical pathways
10 Assessment • WHAT is the problem?
10 Treatment Plan of Care (TPOC) • WHY does problem exist?
10 Services & Progress Notes • HOW to address problem
10Case Conceptualization &
Efficiency Strategies• Improve your documentation
2
Agenda/Objectives
MENTAL HEALTH MEDI-CAL
“Medi-Cal Insurance”
Physical Health
Medi-Cal
Mental Health
Medi-Cal
Drug Medi-Cal/
ODS
San
Francisco
Health
Plan
Blue
Cross
Partner.
Plan
BHS
(County
MHP)
BHS
(County
SUD Plan)
• Physical health care
• Mild/Moderate MH care
• Autism Spectrum/BHT
• SMHS
• Moderate
to severe
MH care
• SUD
Treatment
Services
San Francisco Mental Health Plan (January 2018) 3
MENTAL HEALTH MEDI-CAL
San Francisco Mental Health Plan (January 2018)
• Example Algorithm: Health vs. Mental Health Plan Services (for adult client)
List A List B List C
Persistent symptoms & impairments after
2 recent medication trials
Multiple co-morbid health and mental
health conditions
Behavior problems (aggressive/self-
destructive/assaultive/extreme isolation)
Excessive ED visits or 911 calls
Bipolar disorder
Trauma/recent loss/significant life
stressors
Depressive symptoms
Anxiety symptoms
Homelessness/housing instability
resulting from mental health condition
ADHD symptoms
Lack of diagnostic clarity
2 or more psychiatric hospitalizations
within 12
Functionally significant, non-substance
induced paranoia, delusions,
hallucinations, mania,
dissociative symptoms, depression,
personality disorder
Suicidal/Homicidal preoccupation with
plan or behavior in past year
Transitional Age Youth with prodromal
psychotic symptoms
Eating disorder with medical
complications (with medical condition
being treated by Health Plan)
Substance use
disorder not
responding to
SBI (screening
& brief
intervention at
primary care)
MENTAL HEALTH MEDI-CAL
San Francisco Mental Health Plan (January 2018)
• Example Algorithm: Health vs. Mental Health Plan Services for adult client
List A List B List C
Persistent symptoms & impairments after
2 recent medication trials
Multiple co-morbid health and mental
health conditions
Behavior problems (aggressive/self-
destructive/assaultive/extreme isolation)
Excessive ED visits or 911 calls
Bipolar disorder
Trauma/recent loss/significant life
stressors
Depressive symptoms
Anxiety symptoms
Homelessness/housing instability
resulting from mental health condition
ADHD symptoms
Lack of diagnostic clarity
2 or more psychiatric hospitalizations
within 12
Functionally significant, non-substance
induced paranoia, delusions,
hallucinations, mania,
dissociative symptoms, depression,
personality disorder
Suicidal/Homicidal preoccupation with
plan or behavior in past year
Transitional Age Youth with prodromal
psychotic symptoms
Eating disorder with medical
complications (with medical condition
being treated by Health Plan)
Substance use
disorder not
responding to
SBI (screening
& brief
intervention at
primary care)
Specialty Mental Health (County MH Plan)
>4 from list A or >1 from list B
Non-Specialty Mental Health (Health Plan/Beacon):
<3 from list A and 0 from list B
Screening forms (0-4yrs; 5-17yrs; >18yrs) posted to SF Health Plan website
MENTAL HEALTH MEDI-CAL
Area Clinic Model Rehabilitation Model
Definition from
Federal Social
Security Act
§1905(a)(9): “Clinic services [are
those] furnished by or under the
direction of a physician, without
regard to whether the clinic itself is
administered by a physician,
including such services furnished
outside the clinic by clinic personnel
to an eligible individual who does
not reside in a permanent dwelling
or does not have a fixed home or
mailing address”
§1905(a)(13): “Other diagnostic, screening,
preventive, and rehabilitative services,
including any medical or remedial services
(provided in a facility, a home, or other setting)
recommended by a physician or other
licensed practitioner of the healing arts
[LPHA] within the scope of their practice under
State law, for the maximum reduction of
physical or mental disability and restoration
of an individual to the best possible functional
level”
Treatment
ModelMedical model Recovery model
Focus Stabilization Active treatment and participation
Locations Clinic-based Community-based
Type of StaffLicensed; higher degree
professionals
Professionals, mental health technicians and
peer specialists
Organizational
ModelOrganized clinics
Organizations that provide one or more
covered servicesSan Francisco Mental Health Plan (January 2018) 6
MENTAL HEALTH MEDI-CAL
Provide Treatment
Interventions
MH
Medi-Cal
Conduct assessment Create treatment plan Provide interventionsClinical
Practice
“The Golden Thread” of Clinical Practice & Mental Health Medi-Cal
Establish Diagnosis &
Functional
Impairments
Create Treatment
Plan/Client Plan
“what is the problem?” “why problem exists” “how to address it”
San Francisco Mental Health Plan (January 2018) 7
Medical Necessity for SMHS
• Four Required Elements of Medical Necessity:
1. Included mental health diagnosis
2. Functional impairments (from dx)
3. Treatment interventions (for impairments)
4. Not responsive to physical health care treatment
San Francisco Mental Health Plan (January 2018) 8
Medical Necessity for SMHS
• Four Required Elements of Medical Necessity:
9
Medical Necessity: DIAGNOSIS
• Diagnosis (Element #1):
• Your assessment will describe the symptoms, behaviors and differential diagnosis using DSM.
• Primary MH Dx = Mental Health Medi-Cal
• Primary SUD Dx = Drug Medi-Cal/ODS
• Primary Medical Dx = Physical Health M-Cal
• MH problems 2 to Medical = as above
• Mild/Moderate MH problems = as above
• Tip: SMHS = Special Diagnosis—one that appears on the DHCS list (not just any old dx!)
San Francisco Mental Health Plan (January 2018) 10
Medical Necessity: DIAGNOSIS
• Diagnosis (Element #1):
San Francisco Mental Health Plan (January 2018) 11
Medical Necessity: IMPAIRMENTS
• Functional Impairments (Element #2):
• Functional Impairments as a result of the qualifying diagnosis:
• Symptoms = behavioral expressions/actions associated with the disorder
• Distractibility in client with ADHD diagnosis…
• Impairments = the consequences/outcomes that ensue for the individual as a result of these behaviors
• …can’t pay attention and failing at work
• …can’t stop interrupting and loses friends 12
Medical Necessity: IMPAIRMENTS
• Functional Impairments (Element #2):
• Functional Impairments as a result of the qualifying diagnosis:
• A current significant impairment in an important area of life functioning
• A probability of significant deterioration
• A probability that the child will not progress developmentally as individually appropriate
• If full-scope Medi-Cal, under age of 21 years and has a condition as a result of the mental disorder that SMHS can correct or ameliorate
13
Medical Necessity: IMPAIRMENTS
• Functional Impairments (Element #2):
• Functional Impairments in an Important Area of Life Functioning:
14
Life Functioning Domains to Explore
• Living situation
• Daily activities and functioning
• Family relations
• Social relations
• Finances
• Legal and safety issues
• Work and school
• Health
• Cultural components
• Potential for exploitationSource: BHS Documentation
Manual (2005 Ed & 2012 Eds.)
Medical Necessity: IMPAIRMENTS
• Functional Impairments (Element #2):
15
Medical Necessity: INTERVENTIONS
• Interventions (Element #3):
• The focus of the proposed/actual interventions must address the functional impairment identified as a result of the qualifying mental health diagnosis:
• Focus = functional impairments
• Proposed interventions = creating Client Plan
• Actual interventions = creating Progress Notes
16
Medical Necessity: INTERVENTIONS
• Interventions (Element #3):
• Expectation that proposed/actual interventions must do one of the following:
• Significantly diminish the functional impairment;
• Prevent significant deterioration in functioning
• Allow for a child to progress developmentally as individually appropriate
• Correct/ameliorate the condition for FS-MC, <21 years
17
Medical Necessity: TIP
• Tip: line up your impairments/interventions… these are clinical stories!
18
Functional Impairment Pathway Treatment Interventions Pathway
#1: Client has current significant
impairments…
…my interventions will significantly diminish
impairments
#2: Client has probability of significant
deterioration…
…my interventions will prevent significant
deterioration in functioning
#3: Child client has probability of child not
progressing developmentally…
…interventions allow the child to progress
developmentally
#4: Child client has Full-scope Medi-Cal +
<21yrs + a condition that SMHS can correct
or ameliorate…
…interventions correct or ameliorate the
condition
Medical Necessity: NOT PHSYICAL
• Not Responsive to Physical Health Care-Based Treatment (Element #4):
• The condition/impairment (that exists as a result of a covered diagnosis) would not be responsive to physical health care based treatment.
• Examples:
• Depression related to a thyroid condition.
• Traumatic brain injury that leads to violent behaviors.
19
Assessment
• Assessment:
• “Assessment” in SMHS: Words Matter!!
• Service: an ACTIVITY to evaluate current mental, emotional, behavioral health (includes MSE, analysis of clinical history, relevant cultural issues, diagnosis);
• Document: a FORM you fill out annually, or when there is a change in the client’s impairments;
• Phase of Treatment: a PERIOD OF TIME when you are determining medical necessity for services.
San Francisco Mental Health Plan (January 2018) 20
Assessment SERVICE
• Assessment Service:
• Only bill assessment if you are doing an assessment!
• a service activity designed to evaluate the current status of a beneficiary’s mental, emotional, or behavioral health. Assessment includes but is not limited to one or more of the following: mental status determination, analysis of the beneficiary’s clinical history; analysis of relevant cultural issues and history; diagnosis; and the use of testing procedures (CCR Title 9, Section 1810.204)
San Francisco Mental Health Plan (January 2018) 21
Assessment FORM
• Assessment Form:
• Fill out completely and SIGN/DATE THE FORM!
San Francisco Mental Health Plan (January 2018) 22
Assessment PHASE
• Assessment Phase:
• Your authorization determines the “phase” of assessment!
• Remember-the purpose of an assessment is to determine medical necessity for Specialty Mental Health Services.
• SIGN AND DATE THE DOCUMENT—IT’S NOT FINAL UNTIL YOU DO!
• Never copy/paste documents!!!San Francisco Mental Health Plan (January 2018) 23
Treatment Plan of Care (TPOC)
• The TPOC/Client Plan is IMPORTANT:
• The Client Plan must address the mental health needs identified in the current assessment (The Golden Thread…assessmentimpairments).
• The Client Plan must have Goals/Objectives that address the functional impairments (The Golden Thread…assessmentimpairments).
• The Client Plan must be updated when there are significant changes in the client’s condition (at a minimum, updated Annually).
San Francisco Mental Health Plan (January 2018) 24
Treatment Plan of Care (TPOC)
• The TPOC/Client Plan is IMPORTANT:
• Document your attempt to get the client’s signature on the Client Plan—get that signature!
• The Client Plan is officially “finalized” when the requiredstaff signature (YOURS) is in place and dated.
• You must finalize the Client Plan before providing treatment services. In other words, you cannot bill “planned services” until the Client Plan is finalized—you will only be able to bill “Plan Development” services.
San Francisco Mental Health Plan (January 2018) 25
Treatment Plan of Care (TPOC)
• The TPOC/Client Plan is IMPORTANT:
San Francisco Mental Health Plan (January 2018) 26
Services: Case Conference (Plan Development)
• Case Conference as Plan Development:
• DHCS has clarified (and BHS/SFMHP has implemented) “case conference” may be billed as plan development, as follows.
• CASE CONFERENCE = discussions between direct service providers and other significant support persons or entities involved in the care of the beneficiary. Could be similar or comparable to a multi-disciplinary team meeting;
• CASE CONFERENCE AS PLAN
DEVELOPMENT = If the case conference concerns the development of a treatment plan for a beneficiary, the conference could be claimed as Plan Development
San Francisco Mental Health Plan (January 2018) 27
Services: THERAPY
• Therapy: definition for Medi-Cal
• “Therapy” means a service activity that is a
therapeutic intervention that focuses primarily on
symptom reduction as a means to improve
functional impairments. Therapy may be delivered
to an individual or group of beneficiaries and may
include family therapy at which the beneficiary is
present.
San Francisco Mental Health Plan (January 2018) 28
Services: THERAPY
• Therapy: example for Medi-Cal
“Conducted individual therapy session to address
Client Plan Objective (‘meet more people so I can find
someone to date’).”
“Implemented behavioral rehearsal intervention with
client. Client was able to introduce himself and ask an
appropriate open-ended question with minimal
prompts from therapist.”
“Mental status exam: no change in thought content/
processes from initial meeting. No suicidality observed.”29
Services: PROGRESS NOTE P-I-R-P
• P-I-R-P Format:
• Problem = Problem from the treatment plan you are focusing on
• Intervention = Your interventions and activities that address functional impairments (i.e., significantly diminishing impairments/preventing significant decline)
• Response = Client’s response to your interventions (with details about how/why the interventions work, changes that are needed, etc.)
• Plan = You and the client’s next steps to achieve treatment goals
30
Services: PROGRESS NOTE FORM
• P-I-R-P Format
31
Case Conceptualization Method
Most problematic SYMPTOMS of diagnosis…
+
Functioning DOMAINS impacted by symptoms…
+
HYPOTHESIS of “how this works”…
32
#1
#2
#3
Case Conceptualization Method
• Client meets criteria for GAD…
• most problematic symptoms are inability to control worry, difficulty concentrating and irritability
• Client has significant impairment in work domain…
• Due to worry, poor concentration and irritability, the client’s work attendance and work performance have declined significantly
• Client’s impairments can be improved…
• Client is unable to recognize/manage symptoms and becomes overwhelmed—this leads him to miss work excessively (calls out sick 1-2x/week), make mistakes at work (“zones out and gets lost” over worry for 30mins) and is at risk for losing his job (“I’ve had 3 verbal warnings”)
33
#2
#3
#1
Case Conceptualization Method
• Client’s impairments can be improved…
• Client is unable to recognize/manage symptoms and becomes overwhelmed—this leads him to miss work excessively (calls out sick 1-2x/week), make mistakes at work (“zones out and gets lost” over worry for 30mins) and is at risk for losing his job (“I’ve had 3 verbal warnings”).
• DBT interventions can help client make sense of symptoms (psychoeducation), manage symptoms (mindfulness, distress tolerance) and reduce work impairments (implement calming skills and tools in vivo).
• Weekly therapy sessions will initially focus on reducing client’s level of stress and psychoeducation. Teaching and practicing skills will occur in session, at home & at work.
34
#3
IMPLEMENTING Documentation
• Efficiency Tips…
• Stop copying/pasting and start answering the question being asked (read the prompts on the forms and directly address them);
• Don’t leave blanks on the forms (e.g., not yet assessed, insufficient information to rate, etc.);
• Prioritize Assessment items (presenting problem; relevant conditions; risks/strengths; mental status exam; case formulation);
• Easy access to source documents (documentation manual, instructions for forms)
35
PRACTICE!
• Do what the auditors do!
• Assessment & Diagnosis criteria (behaviorally specific; included list; sign the form);
• Impairment criteria (current significant/risk of significant decline);
• Intervention Criteria (reducing the current significant/ preventing risk of significant decline);
• Not Physical Health Care-Based Treatment criteria
36
Treatment Authorization Request!
• Initial Treatment Authorization Request (TAR)
• Required prior to delivery of service!
37
Treatment Authorization Request!
• Initial Treatment Authorization Request (TAR)
• Required prior to delivery of service!
38
Treatment Authorization Request!
• ONGOING TAR—Medical Necessity Attestation for Continued Treatment
39
Treatment Authorization Request!
• ONGOING TAR—Medical Necessity Attestation for Continued Treatment
• Attestation: confirm that all of the elements of medical necessity
• Level of Care Confirmation: the client’s mental health needs may/may not be met at this level—we need to check!
40
Treatment Authorization Request!
• ONGOING TAR—Medical Necessity Attestation for Continued Treatment
41
Treatment Authorization Request!
• ONGOING TAR—Medical Necessity Attestation for Continued Treatment
• Client’s progress: significant impairments are being significantly reduced? Prevention of significant decline in functioning?
• Rationale for Continued Treatment: What is the current status of the client? What are the functional impairments? What are the mental health needs!
42
Wrapping Up
• Questions and Thoughts?
• Resources:
• “Must haves” are 2017 Documentation Manual, Desk Reference & guidance from authorizing body (BHAC, FCMH, FMP, etc.)
• BHS URL: https://www.sfdph.org/dph/comupg/oservices/mentalHlth/CBHS/
• CDIP URL: https://www.sfdph.org/dph/comupg/oservices/mentalHlth/CBHS/CBHSQualityMgmt.asp
• BHS Compliance: [email protected];
• BHS Documentation Improvement: [email protected]