VCU RRTC 9 11 CFM Call... · Web viewYour WIPA material, your staff notes, your BS&A’s, that BPQY that you get, all of that is required to be held in a separate, physically separate

NORTHROP GRUMMAN SYSTEMS CORPORATIONModerator: (Susan O’Mara)

02-09-11/2:00 p.m. ETConfirmation # 43067681

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NORTHROP GRUMAN SYSTEMS CORPORATION

Trainer: Lucy MillerFebruary 9, 2011

2:00 p.m. ET

Lucy Miller: I am utterly convinced that everyone of you just ran out of bed this morning, ran to your office because you just couldn’t wait for 2:00 o’clock to come around eastern time so that you could participate in this training. I know that case file; this stuff is not your favorite topic. Guess what it’s nobody favorite topic but we have to kind of get into it because it is a requirement. So I’m going to try my very best to keep this focused, to keep it real, to give the information that you need to get your record keeping done correctly and with as little time and effort as possible. I have no illusions about how much free time you all have in your hands. I know how busy you are and doing pointless record keeping is nobody’s idea of a good time and I’m certainly not in favor of that. So we’re going to keep this very practical, lots of do’s and don’ts, lots of practical tips I hope and hopefully keep it light and as entertaining as one can possibly make a training on managing records, beneficiary records.

What are we going to go over today? Well first of you should have your slides in front on your, I hope you do, either on your screen or printed out in front of you. I will try to refer to the slides that I’m on, tell you what the title of it is. There are some slides in this presentation that I’m going to skip over particularly if we have a whole lot of questions and I sort of expect us to have a lot of questions. So as (Susan) said I will stop periodically to take questions. I’m not going to wait until the very end. So if you have a question don’t be shy, just jump in, believe me if you have that question other people on this call also have it and everybody is struggling with record keeping. So don’t be



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embarrassed to ask the question. We’ll get everything handled that we possibly can.

Well let’s start with figuring out what are you here for, what’s the objective of all this? Really simple, we want to make sure that you are 100 percent informed about what the requirements are that Social Security has for you. Lots of you guys are having site visits and Social Securities’ reviewing your records and they’re writing your site visit report and kind of giving you a thump on the (inaudible) and saying your records aren’t as good as they need to be. And folks say, “Why I didn’t really understand what the requirements were”. Well guess what, after today you’re going to be complete informed about what those requirements are. We’re going to go over the fastest and easiest ways to meet those requirements and finally we’re going to talk about how important it is that you keep those paper files confidential and what you need to know about how to guard the confidentiality of the people that you serve.

All right, let’s take a look at this, what the record keeping guidelines are. The first thing, I think if everybody understood the purpose of that record that you’re keeping on beneficiaries, it would really help everybody keep better record. The two main purposes are number one, so that you have a paper record, documenting what you have done with the beneficiary that it verifies the services that you provided to this person and that documents the advice that you gave this individual about what will happen to my benefits if I go to work. It’s truly a protection for you, OK, definitely a protection so you can documents that you gave beneficiaries correct information but it’s also a way for you to keep track of what you’ve done. If you don’t’ write it down you’re not going to remember. And it has to be more than just make believe, you’ve got to write things down. They have to be in writing. That’s a really important purpose of these records.

Number two, you know all of us in the WIPA program, myself included, we are funded with federal government money. And in this day and age in particular it’s very important that we prove that the federal government got something in return for the money that they spent. I talked to a lot of (inaudible) and they say, “But Lucy I’m doing good stuff. I’m meeting with



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beneficiaries. They love me, it feels good. People are choosing to go to work.” And I believe that, the problem is, if there’s nothing in that record that clinical file that document that then its just your say so. It’s not enough that it feels good. It needs to be verifiable. You need to be able to say, “Look what I did. See these outcomes. Look at all the service I provided.” And again it can’t just be because you say so; it has to be written down. This is important accountability for you and it’s important for you to get credit for the work that you’re doing. And if there’s no written record, how are you even going to get credit. So we got to get past this, what I’m doing feels good, I know it does but there has to be a way for you to prove that what your doing is actually what you’re supposed to be doing and that you’re giving correct information and helping people move forward towards employment.

Finally remember that clinical record. In any human service is a very important document for handing over services if, heaven forbid, there is staff turn over. You know that’s the way of the world, people leave, they come in to a job, they do services, they move on. If you haven’t kept good records, if you don’t have good staff notes, if there’s not a benefit summary and a now assist in your records that talks about the advise you gave the individual, then I you leave then nobody who follows in your footsteps has any idea what you did. So when you’re working in your case files, when you’re managing those files, always be thinking, am I leaving a clear record for any one else who comes behind me.

You know there have been instances where we’ve had someone get sick or get hurt and have to take an extended leave of absence and let me tell you how appreciative another (inaudible) or a project coordinator, your boss perhaps if that person has to step in and you have kept good client records. Then everything is clear, nobody misses any steps, no balls get dropped but if you’re one of those people that everything feels good but you’re not writing anything down, you’re making it real hard for anybody to be able to cover in case you have an emergency or have to be out. So three really important reasons why we keep record and these are no different, no matter what kind of human services you’re in, no matter what kind of governmental funded program you’re in. There’s nothing unique about WIPA in terms of the reasons why we keep records. We’re going to teach you today what have to



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be in the record. We’re going to teach you how to maintain those items and certainly how to work with those stake holders as well.

Before we move into the next slide, which is we’re going to talk a little bit about confidentiality, I want to make sure that you understand the content of today’s training. It’s really on records for people who got more than information and referral. Information and referral recipients would have really tiny little records. You might have or two staff notes. You might have the INR assessment that you completed in ATO, printed out and put in the file. For some of you there may be an initial call questionnaire. We have one in the manual that you filled out. And that might be absolutely it, two pieces of paper in a little manila folder and that would be an INR file. That is perfectly appropriate, that’s all that’s necessary. You don’t need to have a ton of stuff in those files but those are not the files we are talking about today. We are talking about the files for someone that is a high priority, first of eligible for WIPA services; secondly a high priority and somebody that you’re going to offer and provide some intensive services for possibly even on an ongoing basis. So I want to make sure you’re clear. We are not going to be covering INR files. These are people that you’ve enrolled in with the services and that you are going to be doing some more intensive programming with.

All right, confidentiality. It is so important when you are working with Social Security beneficiaries is that you are guarding the records that you keep. And Social Security, their confidentiality and privacy guidelines are absolutely crystal clear. They are clearly spelled out in your manual, they were spelled out in the 2010 manual and they are reiterated again in the 2011 manual. Remember that if your agency does other services, you could very well have a client who’s getting with the services, who might also be getting say employment services or independent living services.

You may not hold all of the materials in one master file. Your WIPA material, your staff notes, your BS&A’s, that BPQY that you get, all of that is required to be held in a separate, physically separate file and the only people permitted to access those files are individuals who have completed the federal security clearance required by the Social Security administration. Those files should be kept in a separate location, they should be locked at all times and



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the only people who have access to those should be those people with the security clearance required by Social Security.

Generally you should not be including forms or information related to any other service that that beneficiary has like from you agency in that WIPA file. The WIPA file should be completely segregated. It is the benefits, your WIPA services, the social security and other federal benefit, our other transfer program information that you require and that is it. Don’t include anything else that isn’t absolutely necessary.

Let’s take at a look at the next slide here. You may not share anything that’s in that record, that WIPA record without a signed release of information from Social Security. Now I get questions about the whole issue of releases a lot because there’s confusion about when you are asking for someone else to release information to you and then when you have information in your file that you created like a BFNA, that you are wanting to release to someone else and how all that works, its different processes.

When you are requesting information from Social Security which would most usually be a BPQY you have to use Social Securities standard release forms. It has to be the most current version. It has to be an original one of their original forms that you have downloaded either off of our website or off of their, of the (palms) or where you actually have hard copied given to you by Social Security. You’re not allowed to just take their form and make it look pretty like on your letterhead. That’s absolutely not allowed. And there are required information release forms that are clearly identified in the manual for you to use when you are asking Social Security to send you the benefits planning query.

Now let’s say you develop information about a beneficiary that you then want to release to say the (inaudible) councilor. That’s a different story. Each of you agencies should have your own release of information form, an authorization that the beneficiary signed where you are very specific and write down, “I want to release this piece of information to this person.” And the beneficiary would sign that form giving you permission to do that one discreet transaction.



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We don’t provide standard formats for you on that, your agency probably already has one? If your agency does any kind of human services, this is a very standard kind of form that you would have. But they are different forms and you need to make sure that you’re clear on that. Again the files have to be kept under lock and key.

If you are traveling carrying files which may not be the best idea, you do have to carry them in a locking file cabinet of some sort. If you are one of the (inaudible) who is based out of a home office, you still have to have a locking file cabinet and you need to make sure that you’re not leaving beneficiary file information out in the open all around your house for anybody, your neighbor, your kids, your husband to wander by and to see. Just because your working at home, doesn’t mean that the confidentiality or privacy rules are you know are done away with. You still have to follow them. You just have to kind of do it in a little bit of a different manner.

Remember about the computer files, you know, you want to make sure everything is password protected. You want to make sure if you’re working from home that you’re cutting your computer off, that you’re not leaving a half finished BS&A up on your screen in the middle of your living room for everybody in the world to see. Just remember the basic guidelines and try to be mindful of protecting the privacy of the people that your servicing all the time at all times.

All right lets take a look at what needs to be in these files. And you know I guess I come from a different perspective than some of the (inaudible). My background is mostly in helping people with disabilities to get job and I came out of private rehab, private non-profit rehab agencies that were CARF. I don’t even remember what CARF stands for now. Many of you are probably familiar with CARF. Some of you may be affiliated with healthcare organizations that are JCHHO accredited.

Well these kinds of accreditations involved incredibly burn some record keeping requirements. So I guess I’ve seen how bad it can get. And one of the things I like about WIPA is that Social Security has been very smart in



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how lenient really they have been with you in terms of what they require to keep for paper work. When you consider what a lot of other human services programs require, it really is quite minimal. It may not feel like that to you but in comparison when you can see the broad scheme of things, what’s required of (inaudible) is really very manageable.

The trick is just knowing well what is required exactly and what stuff isn’t required and making sure that you’re not self-imposing a bunch of record keeping requirements because you’re used to being like JCHO accredited or CARF accredited. And you think that because of that you have to self-impose all these rules. You don’t. Your funder is Social Security; you need to follow their rules. And this is a time that Social Security has been extremely reasonable and what they expect to find in those paper files. There’s nothing, you now outside of the ordinary at all and it’s really quite manageable.

Now that next slide file, the case file components and there are nine things listed on there and that’s it, nine things. You can do these, I promise you. We’re going to go through each one of these nine things and clear up questions that people have or misunderstandings that people have about how far you need to go versus when you haven’t gone far enough.

The first thing you need to have is an intake sheet and that isn’t just you know little hand written notes on a blank sheet of paper. It needs to be structured. We will go over each one of these. You need to have case notes, also called staff notes, OK. There need to be releases of information forms if you released any information or if you have any information that you requested from other agencies in your file. If I see a BPQY in your file and there are no standard social security releases of information forms, you’re in trouble, OK?

You have to be able to show that you got permission to ask for those things to get those things. You should have correspondence of something in writing to verify all benefits that the individual received. Now if that’s Social Security, that might be a BPQY, it might be a TPQI under certain circumstance that’s known as a third party query as oppose to a benefits planning query. Although in some circumstances even just correspondence from Social



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Security might be sufficient to meet this requirement. It might be faxed in information from your state Medicaid agency.

We’ll give you some ideas about ways to minimize the work around verification but also give you tips about when, you know what you need to do to meet these requirements because this really is critical that when someone says like at food stamps or (I’m on hood) housing subsidy that you have some verification on file from some authoritative source to indicate what exactly the individual gets. You don’t have that. You’re not going to know for sure and you could make a mistake.

Now number five is one that most people don’t have, it’s interesting when I go have around the country, certainly region four, my region and check records. There’s a widespread misunderstanding or just non-awareness that you really kind of have to have a WIPA project policies and procedure. Sometimes it’s called rights and responsibilities or just sort of operations and where you’re actually explaining to the beneficiary, here’s what you can expect from me and here’s what I need from you. And when you have some kind of verification like a signed piece of paper that says, “I Mr. Beneficiary actually read this and understood it.” And I think of all the things in this list of nine, the number one most missing is probably that number five and we’ll talk about that in a minute. Copies of BS&A’s, that’s benefits, summaries and analysis and work incentive plans or WIP’s and I think gradually we’ve been making progress here. We still have a ways to go but if you’ve developed one of these or more of these documents for a beneficiary, certainly copies of these documents would need to be on the file.

If you’ve gotten copies of correspondence to and from other agencies, we would expect to see that in the file. Not everyone would have this, we tend to see copies of letters from Social Security, probably more than anything else but not always would we see that. Certainly copies of any work incentive information. If you’re working with a beneficiary to develop a past, we would absolutely expect to see a copy of the past and any past amendments. If in the BS&A you indicate that you’re moving forward on a past, in the staff notes it indicates that you’re working on developing the past, then there needs to be a copy of that past.



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Same thing would go for things like a request for an impairment related work expense or letters to Social Security prompting them that a beneficiary is entitled to the student on income inclusion, anything like that. You need to request those things in writing and then a copy would be held on file.

On the cover sheet its really up to you, that’s just kind of a checklist that keeps (inaudible) on, have I got everything in the file that I need to have in here and is there anything missing. It’s a nice little form that you can develop or your boss can develop to help you all stay organized and then to guide internal record reviews when something is supposed to be in there and then it’s not on the cover sheet, it’s clear to everybody that there are items missing.

Now I want you to look at your case files when you go back to you office or you know tomorrow or whenever, are you including things in your case files on a routine basis that are not on this list of nine things? If you are you need to stop that right now because what that means is that you are self-imposing additional paperwork that may not have much value that is not required by your funder and that takes valuable time out of your day so that you’re not now doing the required paperwork you’re supposed to do. And I can’t tell you how often I see this.

When you asked somebody you’ll say, now why are you putting this in the file and they’ll say well all of our programs are supposed to do this. And it’s like, well do you get money for your WIPA from somebody else because if it’s Social Security that’s funding this you need to follow their rules and they don’t say that you have to have this. So check those files with a very unbiased eye. Are there things that your agency is telling you have to be in that file that may not have to be and if you are adding paperwork (inaudible). Stop doing that if you’re not sure that it’s something that should be in the file, talk to your technical assistance liaison

But one of the things we can do right now to make your life easier is to have you stop doing things unnecessary paperwork that you are putting in these files folders that is not required to be there. So go back and take a look. Now where did this list come from? Guess what I didn’t make it up. Social



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Security made this up. This is what needs to be in the file and it’s nothing new. This has been in your manual, wow, years, probably since at least 2006, if not before that, its in module six, it’s been in every addition of the manual since BCU took over working on the manual.

So this isn’t new. It’s always been in there. If you have it (inaudible) well we made it easier for you, I went it to 2011 manual, I cut and pasted everything in there about record keeping and I dropped it into a separate little word document and you should have gotten that with the materials. So if you don’t want to take the time to get into the new 2011 manual online, maybe you haven’t printed off your new manual yet, then just open this document that came with these materials, take those 10 minutes that it takes to read this.

You know if you don’t take that 10 minutes your going to spend hours and hours and hours doing stuff wrong, doing stuff you don’t need to do, that’s why you’re on the call is to learn what it is you need to do and the minimum requirements have been published in the manual for years. So you need to go and do yourself a favor and read what it says in there about what needs to be in that file.

All right, before we start, I’m showing that it’s 2:34, we’re going to start looking at these file components one by one but I want to take questions in general first. So if the operator can ask for people to queue up as they’ve got sort of over arching questions before we start individually going through the file components.

Operator: At this time I’d like to remind everyone in order to ask a question please press star followed by the number one on your telephone key. We’ll pause for a moment to compile the Q&A roster. Your first question comes from (Wayne Hawel); your line is now open.

(Wayne Hawel): Hi Lucy.

Lucy Miller: Hi (Wayne) what’s up.



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(Wyane Hawel): I have a question. Are we to understand that you’re saying that for INR files they’re better kept in separate files even if it’s only two or three pages as opposed to kind of bulking them up into one file and calling it INR file?

Lucy Miller: I mean actually Social Security offers you very little information or guidance on that. As a former project manager, I probably would have like a plain manila file folder with the persons name on it and I would put that somewhere where I could access it again in the future, where I could find that person fairly easily. Because one thing I found, INR people often come back later and turn into WIPA people and I would want to have record of that initial call that was made even if it was five or six years ago. So I just think it, you know what works for you is what works for you but I would probably set it up, I would keep them separate from the WIPA folders because they’re very much smaller. But I would have it so bad; you know that I could find it again, yes.

(Wayne Hawel): OK and one other quick question. In terms of verifying us by food stamps and given all that, now if we’re calling and talking with someone from those agencies, from BFS for example, can we just write in the case notes something that’s been verified or are these something else?

Lucy Miller: In my opinion and other TA liaisons may have a difference of opinion, I don’t think so, I would accept that. Now it needs to be more than, “I called the foot stamp office and they said this is what I got.” You need to tell me the name of the person you talked to, the date and you need to sign it because your signature is you’re swearing, “I verified this and I’m signing my name to that.” But I have no problem with a phone conversation verification.

(Wayne Hawel): OK, thank you.

Lucy Miller: You’re welcome. I tell you what I would do (Wayne), I would in your staff notes maybe circle or highlight that staff note entry with like a magic marker or a highlight marker so that if there ever was question about did you verify this that you can go back and through those staff notes and find that entry very quickly.

(Wayne Hawel): Right, thank you.



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Lucy Miller: You’re welcome. Anybody else?

Operator: Your next question comes from (Valerie Williams); your line is now open.

Lucy Miller: HI (Valerie).

Male: We’re actually on this (inaudible) conference call and I believe the question is from (Randy).

Lucy Miller: OK.

(Randy): So my question with relating to payees and release of information forms. Isn’t that a requirement with regards to moving forward with the work we do with our beneficiaries?

Lucy Miller: It’s an interesting question. When someone has a rep payee that doesn’t mean that the beneficiary no longer has the right to sign for themselves. A rep payee simply helps the beneficiary manage their Social Security benefit. Being a rep payee is not the same thing as being a legal guardian. So re payee’s their signatures are not sufficient on a release of information form unless that beneficiary has been adjudicated as incompetent or is a minor and does not have the ability to sign for him or herself, it is still the beneficiary signature that needs to go one that release of information. Common misconception, people thing that rep payee’s can sign for beneficiaries, they really can’t, they aren’t the legal guardian of that person.

(Randy): (Stops) from our discussion with rep payee’s until we get that ROI signed by the beneficiary.

Lucy Miller: I’m sorry say that again?

(Randy): So we can’t have communication or conversation about the beneficiary with the rep payee until we get that release of information form signed.

Lucy Miller: You probably, I mean technically you should not be, you’re absolutely correct and if the person does have a rep payee and if the beneficiary wants you talking with the rep payee then you should have a signed release on file to verify that you have that permission. No different than you would have a



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signed release to talk to the VR counselor or the job coach or the you know residential case manager, anybody likes that, and the release should be very specific about what things you are authorize to discuss. It’s you know the old center for independent living or advocacies saying nothing about me without me, you know rep payee is not that persons legal guardian. That’s correct.

(Randy): Thank you.

Lucy Miller: Anyone else?

Operator: Your next question comes from (Don Martin); your line is now open.

Lucy Miller: Hi (Don).

(Don): Hi Lucy how are you doing?

Lucy Miller: Good.

(Don): Good. Quick question on the cover sheet, could be as simple as something of these nine bullets and a check off that it’s in there or something more like the WIPA file review?

Lucy Miller: I would do something simple. And it’s just, is it in here? Physically are these things in here? And the main this is already you’re making sure that your staff knows a case file from each one of your employee should look almost identical. You know I shouldn’t open a file from (Mary) and it’s all in one order and then open one from (James) and in all in a completely different order. So what you want to make sure you’re doing is saying section one is where you put this, section two is where you put this, you want to make sure that your (inaudible) are clear. In our file folders these is the order, the place where we want to constantly keep this type of information.

(Don): Got it, thank you.


Operator: Your next question comes from a (Nacio Chavez); your line is now open.



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Lucy Miller: Hi.

(Nacio Chavez): Hi I have a quick question. You mentioned the one of the requirements in the file being the (inaudible), the release. One of the things that’s been happening is when consumers call they bring in their actually their own BPQY.

Lucy Miller: Oh that’s totally fine. That information…

(Nacio Chavez): Should there still be a requirement for the (inaudible) considering?

Lucy Miller: No, if you have requested that, the beneficiary owns that information. It belongs to them. So they have the right to give you anything they want but to protect yourself you should be making a notation about that. If your agency consistently asks beneficiaries to get their own BPQY’s then you need to make a notation on the BPQY saying that this was provided directly to the (inaudible) by the beneficiary or make a staff not entry when you date that, you indicate that and you sign it and then you circle it so that a reviewer can find that when they’re saying, “Hey, where’s your release of information?” And you say, “No problem, this was provided to me directly by the beneficiary.”

(Nacio Chavez): OK and one other quick question, you mentioned the procedures that need to be signed you know kind of the expectation on what’s to be down the road I guess. Is there an existing document for that or is that something that each agency or each entity would make up on their own.

Lucy Miller: Describe it a little bit more; I’m not quite clear on what you’re asking.

(Nacio Chavez): I’m sorry. You mentioned that one of things that should be in the file is a verification that beneficiary understands what the project policies and procedures.

Lucy Miller: Right, right, I understand.

(Nacio Chavez): What’s that?

Lucy Miller: I understand, I get what you’re getting at now, keep going.



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(Nacio Chavez): OK so yes is there a stock form that we should be using or is this kind of up to the projects themselves or?

Lucy Miller: Different projects have different things but they tend to be really similar. They’re very, it’s a lot of human services agencies use things like this because it clarified expectations and I’ve seen it called like policies and procedures, I’ve seen it called rights and responsibilities and they’re all real similar but there’s no standard format and it usually says things like…

(Nacio Chavez): Especially that it should be signed though, correct?

Lucy Miller: Yes, you have some type of a signature sheet somewhere saying you know the beneficiary reviewed this and there signature indicates that they got a copy of it so that you can verify that you went over things. For example, a lot of times beneficiaries think, they end up thinking that it’s your responsibility to report their wages to Social Security. They think that. I’ve heard Social Security employees say things like that to (inaudible); well you’re going to report for him, right? No, no, no but if you can’t assume that beneficiaries understand that. So it’s a protection, it’s protection for you and it’s a protection for the beneficiary to say things like the (inaudible) job is A,B,C, and D. The beneficiary, your job is X, Y, and Z. Well you make it really clear what your job is and what their job is. Rights and responsibilities so that there’s no, go ahead.

(Nacio Chavez): We have something in place for something like that. I’m just curious as to having them sign it, but you feel that that’s a vital part of the process having them sign it?

Lucy Miller: Well if you don’t have them sign it or you don’t at least a staff note with your signature where you’ve indicated that you’ve reviewed it and they get it, then you don’t have any recourse if the beneficiary comes back to you and says, you know well hey my understanding was that (Nacio) was going to report on my wages and he didn’t do it.

(Nacio Chavez): Right. OK now I get it.



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Lucy Miller: Yes, it’s a protection. I do think that there are ways; you don’t always have to have the original client signature. I think that’s the best bet for things like that. I do think that there are times that you can, as a (inaudible) write a staff note saying I gave Mr. Smith a copy of the policies and procedure, we discussed it, he had these questions, I answered his questions and then your signing our name and dating that and that’s an official entry into that record. Where you are at least verifying I did my due diligence, I gave this individual the information they need. I prefer that signature in case there’s a disagreement but I don’t think that’s a 100 percent necessary.

(Nacio Chavez): OK, perfect, thank you very much.

Lucy Miller: Anybody else?

Operator: Your next question comes from (Cindy Hertzone); your line is now open.

Lucy Miller: Hi (Cindy).

(Cindy Hertzone): Hi good afternoon. I am wondering from what point do we need, do we need a back date or a go backwards so far to get other files up to this standard, like the form?

Lucy Miller: Yes, it’s backdating is probably not a good idea. I mean, the record needs to be the read record. So going back and trying to reconstruct feels pretty yucky to me. I wouldn’t recommend that you do that. It’s like that’s a real slippery slope and I don’t know you know people are going too far and misconstrue that. So here’s what I say, you know what no one’s perfect, if you didn’t know what you were supposed to do well that’s just how it is and all you can do is change from today moving forward.

So what you can do, oh gosh I never filled and then take, form a questionnaire today, I will do this intake, I will fill this out, I will date it today, not seven years ago and I will complete it based on whatever you know (inaudible) beneficiary status is today. Staff notes if you weren’t doing staff notes in the past well that’s water under the bridge. It is an ideal but trying to go backwards and reconstruct, that will make you crazy. So start today, change and make those entries starting today moving forward.



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If you never got verification of benefits, you can certainly do that today, don’t back date it, be honest today is the day that I actually verified it, yes I should have done it a year ago, I didn’t, didn’t know I was supposed to, there’s not much else that you can do. I thing trying to go backwards in time is going to get you in trouble and I wouldn’t go there.

(Cindy Hertzone): Well I mostly talking about like bullet number five and you know their rights and responsibilities. We don’t have things like that. The other thing I’m wondering about when we enter case (nets), we enter case (nets) into the ETO and you’re showing that we should have signed case notes. I print my case notes from the ETO off and put them in the case file, is that acceptable.

Lucy Miller: Perfect, perfect. Make sure there’s a date on it and make sure they’re signed.

(Cindy Hertzone): Oh I can sign them, the dates all in there but the signature, OK that’s what I’m wondering. Thank you.

Lucy Miller: I’m a huge fan of not doing anything more than once. If you’re entering your staff notes in the ETO awesome, print them off, sign your name, put them in the file, your done.

(Cindy Hertzone): OK, very good. Thank you.

Operator: Your next question comes from (Edwana Mitchell); your line is now open.

Lucy Miller: Hi (Edwana).

(Edwana Mitchell): Hi Lucy. How are you doing?

Lucy Miller: Good.

(Edwana Mitchell): I just forgot this would really be a good time to mention the WIPA privacy statement. When project office do state visits, we are looking for a note indicating that the beneficiary received that privacy statement, just a note from the (inaudible), just a signed case note and that’s fine. I just thought this would be a good opportunity to mention that.



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Lucy Miller: That’s awesome. I think if you roll that WIPA privacy statement into your larger policies and procedures, I think that would be acceptable. Just make sure that you do have that designation in your file. I reviewed these policies and procedure with this individual or you have their original signature saying this person got a copy of this, I reviewed it and they understood it.

(Edwana Mitchell): OK, the WIPA, I just also want to mention the WIPA privacy statement is also in a Social Security letterhead and has to be left the way they receive it from Social Security, just wanted to mention that.


Operator: Your next question comes from (Joel Roberts); your line is now open.

Lucy Miller: Hi (Joe).

(Joel Roberts): Hello, can you hear me?

Lucy Miller: Yes.

(Joel Roberts): OK, good I have some questions about compute (screen). Given the fact that every computer eventually goes out to door, either your typing it at home to work on it, it’s a laptop it could get stolen, it’s a flash drive, it could get lost or its an agency computer that’s somebody that’s going to be obsolete and thrown out. When you delete something from a hard drive the (inaudible) the data remains there until the computer happens to overwrite it. Now I’m wondering if we should be doing like storing data into TrueCrypt of some other such free ware and or the leading files with File Shredder which overwrites everything when it deletes it.

Lucy Miller: (Joel) you have now reached the absolute limit of my knowledge, I mean you’re beyond my knowledge of computer security. I think that it’s a question that you’re going to have to ask your project officer in writing. I would send your project officer an e-mail to that effect. My guess is the project officer will need to get that before (Carol) and you’ll have to get a formal determination on that which would then be communicated to our projects.



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(Joel Roberts): I haven’t been doing this but I would certainly think that it would be something that you might want to recommend at least as a best practice.

Lucy Miller: I think you need direction from Social Security directly on that. I don’t think I’m competent to comment. Anyone else?

(Joel Roberts): OK, thank you.

Lucy Miller: You’re welcome.

Operator: Your next question comes from (Jeff Vira); your line is not open.

(Jeff Vira): Hi, actually the gentleman that just spoke, I just wanted to give him one little helpful hand with my laptop, I have both Bios password and hard drive password on it so that gives at least some little bit of security if you’re carrying your laptop and it ends up getting lost. And I for one feel that his suggestion to worthwhile. In reference to my question, one is the intake sheet, is it OK to use the demographic section of the ETO data base and print that and put it in the file as intake information.

Lucy Miller: I don’t have a problem with that as long as Social Security does not have a problem with you printing out that type of information from ETO and having that retained in your hard files. I would caution you to cross reference that with what is in your manual. What (Mathemathica) wants to know for data collection purpose isn’t always the same as what a (inaudible) would need to know for the purposes of providing really good quality counseling?

So I would say check with your project officer to make sure that that printing that off out of ETO and putting that in your file is OK and with regard with their security issues but alone I think you better cross reference what’s on there with what we would recommend that you gather in the manual. And actually the intake, we call in an information gathering form now, that is based on the minimum data requirements that Social Security put in the original request for applications that you agency responded to and that you were funded based on and those data requirements are clearly delineated in your manual. Again module six unit two and right before the little section in there on case files. So I don’t have problems with that. I like not doing things



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twice. I really don’t like rework. As long as everything you need to know about the individual to provide high quality counseling has been collected.

(Jeff Vira): And my second question was regard to bullet five in the policies and procedures document that you suggest beneficiaries sign. Some of the things that I heard mentioned, for example the beneficiary being responsible for reporting wages ends up being at the end in those things to remember section in the BS&A in which they sign. So is that something that would be considered covering that bullet point?

Lucy Miller: Yes but I would say that not everyone who would have a paper file would have a BS&A. So I think you just have to make sure that you’re covering your basis. And I’m not sure that everything that you would want to communicate to a beneficiary is included in that addendum in the BS&A format. You want to make sure that beneficiaries understand what you’re role is, absolutely clearly. And what services you’re going to provide them and what services you’re not going to provide them. So I think you could handle it to some extent that way but not every beneficiary in with the services would have a BS&A, so just be careful that you’re not missing some people.

(Jeff Vira): Thank you.

Lucy Miller: In the interest of time, I know there’s probably more people in the queue but I’m showing we have used almost an hour. So stay in the queue, don’t go anywhere, I’ll answer your questions again but let’s cover some of these file components so that we can move further into the content.

Let’s start with the intake sheet and actually I absolutely hate that name, intake sheet because it leads to believe that that’s like one side of one piece of paper. And if you are truly fulfilling the information gathering responsibilities that you would need to fulfill in order to provide individualized benefit counseling, it’s more than one side of one page.

Again check what is in your manual. And this is something I get a little frustrated with it, we do update the manual on a yearly basis and we improve these forms in the manual every single year. So you need to go and look in the manual. What’s the most current version of that information gathering



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tool? You know you’re not required to use what’s in the manual but why would you want to invent your own if somebody else has written it for you.

Again if you just want to just use the WIPA assessment as long as Social Security is OK with you printing out material like that from the ETO and retaining that in those WIPA hard files, I don’t have a problem with that. Just make sure that you are cross referencing and not forgetting to gather information that you need in order to provide good quality benefits counseling. There is a minimum set of data that’s very clearly delineated in your manual.

Again the form that we provide for you is not required but you certainly would want to cover whatever is on that form and you know printing out what you put into ETO directly is you know we don’t have a problem with that as long as Social Security is OK with that. That is the intake quote sheet which, now I don’t like that name.

All right case notes, I’m going to hit this quickly. This power point presentation goes on a bit (inaudible) at the end about writing case notes. And If you’ve ever been in human services before, many of you may have already I hope have receive training on writing case notes. Certainly if you’ve ever worked in a certified CARF or JCHO certified facility you should have received very specific instruction about how to write staff notes or case notes and they’re really no different.

What’s the whole purpose of case notes, what are you writing down. You are describing the services rendered. It’s not rocker science. You are telling the reader what you did with this person, for this person, to this person, around this person, about this person. What was the service that was rendered, what issues were discussed, what advise did you give, what actions were taken, and what are you planning to do next? If you can’t describe this clearly then you can’t justify how that federal money was spent and that is a critically important purpose of these notes.

The notes also should tell a chronological story. I should be able to read those staff notes in order and no exactly what has gone on with this person. What



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steps have you taken, what problems have you solved, what areas of problems have you identified, what solutions have you offered and what course of action are you pursuing. There should be absolutely no question in the readers mind what it is you are doing with people.

They need to be dated and they need to be signed. If you prefer to go into ETO and type them like I probably would because my handwriting in appalling, that is what you should do, do not type staff notes into ETO and then go handwrite them into your case file. Nothing could be huger waste of time than duplicating that level of effort. Do one or the other. And you know if you want to put those case notes into ETO, you’re more than welcome to do that.

So figure out what works for you, your agency should be doing this together as a group, I shouldn’t be reading, you know handwritten staff notes on blank sheets of paper in (Mary’s) file, it’s (Sarah) is doing the ETO, I’m typing in there and printing it out. You may even simply type them in a standard word format that your agency has set-up where everybody does their staff notes in the similar format. However you want to do them is fine but everybody needs to be using the same format and the staff notes need to give quality information.

I see a lot of staff notes that are very random, very sort of stream of consciousness, I don’t know how else to describe them when there are just sort of random ideas or facts about the person, there might be doodles in the middle, question marks, circling. If I can’t heads or tails of the staff note, why did you bother because that did not meet any purpose for what a staff note is.

Staff note documents for your (funder), what you did for this person, it tells the story if the service delivery thread that you are following and it would helps a new staff person or a supervisor come in and follow in your steps in case something happens and you are able to do things.

All right, let’s talk about release forms. You have to use the Social Securities real release form if you are requesting the BPQY. And remember there are two of them and there’s versions in your manual and everybody should have



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gotten an announcement over the national WIPA list of today with the most current form, or linked to most current form.

Other releases of information should come from your agency when you specifically need to either get something about a person from the food stamp office, from the public health and authority, from the energy assistance place, from wherever; you take a release of information form from your agency. You tell the beneficiary exactly what it is you want to get and from whom and they don’t sign that form until you have enumerated what piece of information you are going to seek.

Now let me tell you something as a record reviewer from most of my professional life something I have seen in WIPA programs, in supported employment programs, and (inaudible) programs, that just sets my hair on fire. If you are getting blank release forms signed by beneficiaries with a notion that you might need them at some point in the future and this is just faster and easier for you, what you’re doing is illegal. It is also unethical; it is also breeching the privacy and confidentiality of that beneficiary. Do not do that.

When you need a piece of information, you clearly write down what it is you need and from whom and then the beneficiary signs it. But just getting beneficiaries to sign two or three bland releases of information to save you time, when you decide there’s something you want to get is absolutely unacceptable period end of discussion. And if you have any of those in file folders that you are responsible for, the minute you hang up from this call you go to those files and you tear them up. And don’t you ever do that again. And I’m sorry to be so strict about it but it sets my hair on fire when I see that in file folders. If Social Security sees that when they come and do a site visit, you will be spoken to about it, it’s absolutely improper. So just make sure you’re being clear with the beneficiary before you’re asking them to sign what it is exactly that you are going to be getting.

Similarly, when you work through a CARF certification of JCHO certification, human services certifications, one of the things that you are taught is that if you are going to release information to another party, lets say



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you want to release the BS&A to the VR counselor of the residential case manager, totally fine if you have permission from the beneficiary. Again use your agency standard release form, make sure you tell the beneficiary exactly what piece of information you plan to disseminate and to whom and they sign that piece of paper giving their permission for you to do that.

JCHO and CARF are very clear that you are not to be releasing things from your files that you did not create, OK. So if you have a BPQY that you got from Social Security, you should not be then releasing that to VR, that’s not permitted in all the certification programs I’ve been involved in. Now you’re welcome to give the beneficiary and you should give the beneficiary a copy of the BPQY and they may do with it as they please.

But you should not be releasing information you didn’t create to a third party. The information that we would create would be things like WIPS, BS&A’s, staff notes on occasion, things like that. But you don’t want to release correspondence from Social Security to the beneficiary, the BPQY, anything that you didn’t create. Again if the beneficiary wants that information disseminated you may give that beneficiaries copies of everything and you should give them copies of everything, they can do with it as they please.

Similar they can give anything they please to you. If you’re beneficiaries have a copy of their VR plan and you want one, if the beneficiary directly says, “Here’s (Suzy Sewick), here’s my plan for employment, you can copy this.” Awesome, make a staff not to make sure your best covered, that you didn’t just get this without authorization, that you got it directly from the (inaudible), either write it on the form or make a staff note entry and you can move on. But we’ve got to be a lot more careful about making sure we are getting permission to release and to receive things. And if you’ve got questions, will cover those in a minute.

Oh a question I get asked all the time, beneficiary asked if he or she can sit down and review his WIPA record. Yes, absolutely, the WIPA file is not yours to keep secret. Nothing about me, without me, that record is about the beneficiary. They have the right to see anything in that file at anytime which also says something to you about maybe you need to be careful about what



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you write on the staff notes. But there is no problems with letting a beneficiary review their file or copy their file, that’s their information. Don’t mix information from other people, other beneficiaries, everything should be separate but there’s no problem with allowing a beneficiary access to their record.

OK, copies of benefits planning queries. OK, BPQY, does have to be BPQY’s, it can be TPQY, third party queries. We tell you that you know not everyone needs a BPQY and if that just about, if that’s the first time you’ve ever heard that and you’re about to pass out, go back and read your manual. Go to the 2011 manual, we also talked about this at least in 2010, not every single person who calls you up needs to be BPQY. Why would you bother for certain people? Read your manual about who needs one and who doesn’t. If you are doing intensive counseling with someone particularly a title two beneficiary with past work history, a BPQY would be considered required and there’s lots of reasons for that because you want to make sure you know what Social Security knows about what this person has done in the past regarding work.

You have to verify in some way all public benefits, food stamps, housing subsidies, PANA, veterans benefits, unemployment insurance, workers comp, anything that could be in the mix, that could be affected by work in anyway or that could affect other benefits. You would need to get a release of information on file for each item. You can get things in writing or have verbal conversations with employees that you then document in writing and sign.

My advice is use the least intrusive, fastest appropriate method to verify benefits. There is no point in jumping through a lot of ridiculous hoops, getting stuff that you don’t need but you do need to verify by some way shape or form all of those benefits that a beneficiary has indicated here she receives. And there’s lost of ways to skin that cat, not just one way.

Number five, this is the verification that the beneficiary has read and understands your policies. Again as (inaudible) indicated that does include the Social Security policy on privacy. It would also include things like the scope of services to be provided including limitations. You know in every TA



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liaison, a lot of our TA liaisons are listening to this call. I can tell you we get questions from you guys on a daily basis about so and so asked me a tax question and I need an answer. You know this persons case manager needs me to tell him how setting up a you know special needs trust. Hey you are not to know everything. You can’t know everything. There are limits on your service. There’s limits to what you can delve into and it’s OK to tell people no. But maybe it would be a good idea to tell people what you can help them with and what things are beyond the scope of your work.

I am a huge believer in managing the expectations of your customers. Your customers include beneficiaries but they also include parents, they include rep payees, they include community partners, stakeholders, everybody needs to be clear about what it is you do and what it is you don’t do and unless you put this in writing how are they suppose to know. What are the beneficiary’s responsibilities? Hey if it’s your policy that the beneficiary to the greatest extent possible needs to get their own BPQY, I think that needs to be in writing. We need to talk about that.

We need to make sure people know who and who is not eligible, what you know the privacy and confidentiality policy there is and a grievance policy. What is the beneficiary to do if they disagree with the (inaudible)? If they’re not happy with the (inaudible), if they don’t like the services that they’ve delivered, this all needs to be in writing and certainly any other beneficiary rights and disclaimers certainly the standard BS&A form in your most current versions of the manual describe some of these disclaimers and you could certainly roll them in or at your own. We have seen lots of examples of these policies and procedure but there is no standard policies and procedures manual that we have to share with you.

If you want to see examples, I would recommend that you contact your technical assistance liaison directly, see if that person has some examples other projects within your region. Trust me if they don’t have examples, they’ll e-mail all of us. I mean we’re on e-mail together all day everyday. So they’ll put out the call for help and any of us that have examples will forward them on. So you know ask your TA liaison.



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Let’s see what else have we got, copies of BS&A, working set of plans and summaries of any other advisement. Now if you’re going to write a BS&A for somebody and their an FSI recipient, the person needs to have a career goals of some sort. They need to know well I want to work part-time or full-time and I’m kind of sort of thinking about this or they need to have a job offer. If they’ve indicated to you the kind of work they are interested in doing, then you should do an FSI calculation sheet that is individualized and I do not want to see generic examples of FSI calc sheets. That is not acceptable.

If you are writing an individual life BS&A and that’s the whole purpose of a BS&A is to give individualized advisement to someone and that persons on FSI then you owe them that calculation sheet and you need to have explained that in person. It would include trial work periods last EPE tracking charts. If a person has past work history you don’t just say, “Well gee wiz, you’ve worked since entitlement, you may have used TWP months.” Unacceptable. Our job is to develop that past work history. We have to work very closely with the beneficiary, with Social Security, gathering that data on that past work to whatever extent we can figuring out when did those TWT months occur if any.

Are you in your EPE or not? Do we think you actually engage in STA at some point of not? And all of that has to be in the file. Have you gotten earnings from people? Have they given you pay stuff? That you might want to hang on to. Did you refer the person to VR, supported employment and EN, credit counseling? I want to see written referral forms in that file of staff note entries that clearly say I called this VR counselor and discussed referring this beneficiary. These are things that document the services that you’re delivering and they need to be in the file. And they need to be all coherent so issues that are mentioned in the BS&A should be covered with documentation in the file folders.

If you’re indicating that this person did have impairment related work expenses, then you should be helping to develop those and there should be a written request for an early on file. If you indicated that a person had past work that hadn’t been reported, then our job is to complete a work activity



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report if it’s entitled to beneficiary. That’s part of the service we offer. We would want to see copied of that in the file. All of that stuff that goes together to document the service you deliver.

Now we’ve got some basic things on the next file, not everyone is going to give you copies of correspondence, not everyone is going to have letters from Social Security that you need to see. Some are, some aren’t. Anytime a beneficiary asks you to interpret a letter from Social Security or Medicaid or anyone else, make sure you make a copy, give the beneficiary back the original form, help them learn how to retain documents like that but you would definitely want to keep that and you may need to make a staff note entry regarding what advise you gave the person about the correspondence, what you explained to them and any next step.

And certain item A (inaudible) already talked about, you know if you facilitate a work incentive or if you indicate to someone that they have something that might qualify as a work incentive like they are a candidate for an early, they do appear to be subsidized in employment situation if they are entitled two beneficiary and their wages are over SGA. If they are on (inaudible) and certainly if they are a (inaudible) candidate, its something that I’ve noticed a lot of (inaudible) mentioned in the BS&A about these work incentives but nowhere in the file is there any evidence that the (inaudible) actually did something to develop the work incentive.

OK, you told the person it was a good (pass) candidate, where’s the (bath)? Did he go for the (bath)? If he went for the (bath) why don’t you have a copy of it? You said this person seemed to have (inaudible). Where’s the (inaudible) request letter? Where is the documentation that this person had (inaudible)? It seems like we’re giving people advice but then we’re not going to next step to develop the work incentive. And that is absolutely our value added.

And if you went through the trouble to do that, then copy it, give yourself credit for the work that you’re doing. Are you writing letters to the (past) specialist? Are you writing on behalf of the beneficiary to Social Security or to Medicaid? Keep copies of all that, it’s all part of the story that you’re



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telling about the services that you’re rendering. And you are literally fleshing out, filling in the gaps, telling that reviewer, telling the next staff person who comes after you gone on to greener pastures, what all work has been done. You’re completing that documentation to indicate I said that this person was a good candidate for this work incentive and then I helped facilitate its development, I got it approved and that story is all told in the file. That is absolutely critical information.

And then of course finally the cover sheet, the cover sheet is just, that’s for your purposes. I don’t care if there’s one in the file or not. If I go and review records, I just want to see that everybody is clear in that project about what’s supposed to be in the record and the applicable items are in the record. And if I’m looking at (Mary’s) file and (Jerry’s) file that I can tell you they actually work for the same agency. That there is coherence among those two record keeping systems and there is a variance there.

And I would also like to say that if you are a WIPA who sub contracts your services out to another entity, your are responsible for making sure that that subcontractor or your adheres to these requirements. And you should be telling that subcontractor how their records need to look. If they want money subcontracted through your agency then their records should look like your records. As far as Social Security is concerned its all one project. Maybe it is multiple agencies doing this service but those records should be coherent. I shouldn’t be able to see a difference that one is operated by a subcontractor versus the primary contractor for the WIPA.

OK, some optional components, if you do surveys you might want to keep that, grievance, response forms, miscellaneous fact sheets. Honestly my opinion, I would keep optional components to a minimum. This is where we get into the self-imposing thing and you know agency director or project managers saying oh well all of their other program have this that and the other saying and the next thing you know you’ve got 20 required forms, none of which are actually required by your funder.

So always ask yourself is this really a piece that I need in my record. Is this something that tells a piece of the story, am I going to need to review this later



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or check back on this later? Does this contain information that I might need in the future or that someone who takes my place might need? If the answer to that is yes, go ahead and put it in there. But don’t start developing all kinds of wacky forms that require you to do additional work. Stick with the basics. Do them well. If you do that, your records will come out clean every time you get a review.

All right we’re about to change gears into another subject so I think this is a good time to call for questions. What have we touched on so far that you need clarification on?

Operator: Again if you would like to ask a question, press star one on your telephone key pad. The first question on queue comes from (Gail Hahn) your line is now open.

Lucy Miller: Hi (Gail).

(Gail Hahn): Hi, I actually, my question has to do with something way back at the beginning.

Lucy Miller: That’s OK.

(Gail Hahn): And it was in regard to the, on our BS&A and I’m sure, we use BS&A and at the bottom of them it has like record keeping what’s required of them and things like that.

Lucy Miller: A disclaimer.

(Gail Hahn): A disclaimer, does that go for the part that we have signs for like that they understand the services that we provide. Doesn’t that count; doesn’t that meet the requirement if they sign off on the BS&A?

Lucy Miller: Yes I think it meets that requirement for those individuals who get BS&A’s, more or less.

(Gail Hahn): OK.



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Lucy Miller: Now you still would have to do the additional privacy statement but not everyone who initially is enrolled in WIPA services is going to have a BS&A initially. That’s you know a common misconception that oh my goodness I’ve enrolled this person in WIPA, I absolutely have to do a BS&A. That is not true. So I think you just have to be careful that you’re not relying on the BS&A form to cover that base if other people are not getting that. So you might want to you know find a way to pull that information off or maybe expand that information, whatever and make sure that everyone that you’ve served, that you’ve really given information to has been, has had that information explained to them, the rights and responsibilities thing.

(Gail Hahn): And then one more thing, I just want to clarify it, when we log in to ETO doesn’t that count as a signature, like if we log-in to put in case notes into ETO isn’t that the sign in considered in electronic signature.

Lucy Miller: Well I’m not an attorney but I can tell you that case files are subpoenaed. I personally had case files of my own subpoenaed in the past and I would recommend that put, if you’re going to print those case off and put them in the file, I would sign them. It is a protection for you.

(Gail Hahn): For each of the dates listed?

Lucy Miller: Yes. Actually when I worked for JCHO accreditation if there is more than one entry on a page, you can sign once at the bottom of the page and that is adequate.

(Gail Hahn): OK, all right.

Lucy Miller: I would encourage you to sign everything, just to make sure that you’re covered.

(Gail Hahn): All right, thanks very much.


Operator: Your next question comes from (Lynn Roth); your line is now open.

Lucy Miller: Hi (Lynn)



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(Lynn Roth): Hi there, actually I think my question was answered earlier.

Lucy Miller: OK.

(Lynn Roth): Thanks.

Operator: Your next question comes form (Alejandra Hernandez), your line is now open.

(Alejandra Hernandez): Hi this is (Alejandra’s) boss, (John Klin).

Lucy Miller: OK, (John).

(John Klin): And I’m going to, how are you doing?

Lucy Miller: Good, how are you?

(John Klin): And I’m going to modify our rights and responsibilities form to make it a little different, rights and responsibilities for WIPA consumers. And I was wondering where I would get a list of things to be on that, both the responsibilities of the (inaudible) or the responsibilities of the beneficiaries. Would that be on the 2011 manual?

Lucy Miller: You know you could call them from the manual by reading all of module six but we don’t have a single place that you can go for that. You could certainly get a start by going to the recommended BS&A format and pulling from the waiver or the disclaimer items but it really is a little more than that. we don’t have a standard written, we don’t have a template to show you.

(John Klin): So then I take it that I could call our area residences and we can get examples from other agency.

Lucy Miller: Yes get some examples. You know if you’re an agency that already has done things like this for other programs, there is a lot of (generalizable) information so you want to look at that. You want to make sure the beneficiaries understand what they can expect from you and what the limits are on your services. I think helping beneficiaries understand that is really important.



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And I don’t think we’re doing as good a job as we could when we’re talking with beneficiaries to give them a realistic expectation of what it is we do and what we don’t do and I think that would be helpful. Next question.

Operator: Your next question comes from (Lind Murray); your line is now open.

(Linda Murray): Hi Lucy.

Lucy Miller: Hi (Linda).

(Linda Murray): I remembered hearing some time ago, if we felt the (inaudible) thought that the beneficiary was confident in telling us that yes I did receive such stamps or receive house etcetera that we could take their word without getting it verified.

Lucy Miller: I think that you know, I think that, I’m not going to say that that’s never OK. I would want to ask that beneficiary a lot of questions and if they had any letters from food stamps or the housing authority, to verify that it would be helpful to have that eventually. If it is a case manager telling you that who manages that person’s money and is absolute adamant, no I know exactly what that is; you might be OK with that. I think you can go too far though. So I would say if you are absolutely 100 percent certain that this witness is a reliable witness and its 100 percent accurate in what they’re telling you then you should make a staff note to that effect and say this person was adamant. They know exactly what they were getting; they’ve been the same amount for 17 years. I still would want something in writing eventually and food stamps are you know re-determined on a periodic basis as is your housing subsidy and your welfare payments. So might tell that beneficiary that you would like to see the letter the next time it came. So you know I’m not going to say that it would never be OK, just be careful.

(Linda Murray): OK, thanks.

Operator: Your next question comes from (Lorian Arme); your line is now open.

(Lorian Arme): Yes hi.



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Lucy Miller: Hi.

(Lorian Arme): My question is, I know you had mentioned that all but case files must be uniform. In other words they all should be the same. They all should be in the same format.

Lucy Miller: Yes if you’re from the same agency, the same WIPA contract, there should be consistency across staff.

(Loriam Arme): My question about that is, is there a specific order that we must have the files in the folders?

Lucy Miller: No, that’s your choice.

(Loriam Arme): OK, thank you.

Operator: Your next question comes from (Samar Savari); your line is now open.

(Samar Savari): Hi, can you hear me? Hi for component file, (inaudible) we have not done that for in the past. What can we do?

Lucy Miller: I think it depends. If it’s somebody that you are working with on an ongoing basis, there is nothing the matter with saying you know we have this new policy, we want to make sure we reviewed this information with you. We didn’t use to do this but its something we think is a good idea. I want to send this to you. I want to call you and talk it through, see if you have any questions, get a signature or make that staff note saying that you verbally discussed this with the person, circle it and move on. I think you know water under the bridge is water under the bridge and if it’s a client that you’re no longer really working with on any kind of intensive basis, just let it go.

(Samar Savari): OK, sounds good, thank you.


Operator: There are no further questions queued up at this time.



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Lucy Miller: Awesome, OK. Let’s keep moving forward in the slides. We are not looking at what your files should not include and I’ve already told you my preferences that you know it really shouldn’t include any sort of optional forms that you know are being required by your bosses that really don’t add value. They also really don’t need to include diagnostic, medical or disability verification information. And I know for a lot of us that comes from disability services background, this looks like second nature, oh let them verification of disability, I have to have proof. Not in this program.

You really don’t, that’s not what our job is related to. Now certainly the intake that we recommend that you use, the format that’s in your manual asks the person, do you know what your primary disability is? Do you know what you were awarded disability for and that’s just so that we have some kind basic understanding that we can think about accommodation, if it’s an individual who indicates a visual impairment of some sort that certainly has implications that the person is statutorily blind. But you don’t need diagnostic information and we really, really don’t want you keep things like that in your files.

If you’ve got a bunch of junks in your file folder about I don’t know (inaudible) services the person gets of I don’t know residential programming, something that would really be beyond our mission of promoting employment, then you know lets keep the file folders clean. Let’s not have a lot of stuff in there that’s not necessary. Certainly you know when it comes to writing staff notes, you do need to be very careful about the tone that use that you are using respect for language, people first language that you’re not making judgments or expressing unquantifiable opinions, it really is sticking to the facts, describing what services were rendered, what issues were discussed, what advise was given and what next steps you have. And just keep it simple and keep it factual.

Now here’s something I think is very helpful of I hope is helpful. With the materials that we attach for this call is a form that we technical assistance liaison view when you ask us to review your records. On occasion we have individual (inaudible) or project coordinators that kind of want to get a reality check. They want the technical assistance liaison to review one or two



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records from the staff and judge them for quality and completeness and then the offer recommendations for improvement and all of us tech liaison views the same form when we are doing a record review.

The form has been in your manual for several years, you may never have had a reason to look at it but it is there and has been for some time, we attached it to the materials for this call but I think that form is really important because it tells you what we are looking for and it’s more than one thing. For example the first section on the form is just looking for the presence of things. OK, do you have an intake tool of some sort? Are there any staff notes at all? Do you have a BS&A? Have you verified benefits and what did you verify them with? It’s a yea or nay, present or absent and yes that’s important and that tells us some stuff but beyond that the next thing we’re looking at is to see well what is the quality of the documentation in the folder?

All right you’ve got staff notes but are they random stream of consciousness, weird little jottings and cryptic notes or is it a wonderfully descriptive chronologically oriented you know I’m telling you about the services I’ve delivered, you know, is it good quality or not. So that checklist tells you exactly what we are looking for and it really isn’t rocket science. If you have read module six in your manual and if it’s been a long time since you read it, I want you to read it again for 2011 because we really changed it.

Module six has gone through much iteration and we change it every year because the job is changing, we are learning more about what quality is, about how to do this job right and every time we learn more, we put what we’ve learned in the manual. So by reading what’s in module six, you’re going know what it is we’re looking for. For example, if you did your information gathering and you noticed that an SSI recipient is being assessed in transport and maintenance, so before even going to work their SSI check is reduced. We expect to see that mentioned in the BS&A.

If the person gets food stamps, if it’s in the intake, it needs to be discussed in the BS&A. If this person gets a Medicare saving program like QMB or (inaudible) that needs to be in the BS&A. You see what we’re doing? We’re looking for coherence. You’ve noted all these things in your information



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gathering process. Now were you coherent? Did you look at the intake and then address all of those relevant issues in the BS&A.

Then from there we’re looking to see, OK from reading the benefits summary and analysis is this somebody that we would expect to see a work incentive plan for. And again if you think that everyone who gets a BS&A needs a WIP, that’s wrong, that is not true. Some will, some won’t, it depends on what needs to be done. That WIP is you’re to do list. And that to do list is generated from the advice you gave in the BS&A. It goes as a flowing process. I’ve gathered this information now I’m going to analyze it in the benefit summary and analysis. Based on that analysis there’s stuff that needs to be done and the WIP is the to do list of the plan of how we’re going to get the stuff we talked about in the BS&A done. It should flow.

There should be coherence among all of those things. And that is what we’re looking for. And being someone who does a lot record reviews, not my favorite thing to do in the world but I do a lot of it, that is where I see the best (inaudible) falling down is the paper work isn’t coherent. It doesn’t match. What is addressed in the information gathering tool is then not reflected in the benefit summary and analysis. The benefits summary and analysis, next steps are then not translated into the WIP if there is a WIP.

Again we’re seeing people that are not writing staff notes or case notes that really offer any documentation of what was done and what needs to be done in the future. So what isn’t just, isn’t there. But OK is it quality? Does it tell me anything?

We’re looking to see if your BS&A is technically correct? Did you mix up the work incentive? Did you talk to a title two disability beneficiary about the student earn income inclusion? That wouldn’t be good. Did you talk to an SSI recipient about subsidy, OK, or the Medicare, extended period of Medicare coverage, if they’re getting Medicaid? We’re looking for quality in terms of you know what work incentives go with which benefit and you know how work will affect the various kinds of benefits and you’ve offered a clear and concise description for the beneficiary about what they can expect.



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So all the recommendations in the BS&A appropriate? Does the BS&A flow in a logical manner so that your average person on the street could have some basic understanding or is it all over the place? Do you have the calculation charts included? Did you take an individualized approach? Or do you have absolutely canned BS&A which I will tell you is the number one citation I probably see when I read BS&A’s, that they are completely canned. That there is no original customized advisement contained in those pages at all. And if that’s what you’re doing for everybody then we got a problem and a record review would definitely pull that up as something that required improvement.

Is there missing information? Do you have appropriate updates? Now this is something I see lots and lots of misunderstandings about. I’ve seen some records that some beneficiaries that have been served over a period of many years and that makes me very happy to see that. Where you are demonstrating to me that you have a long term relationship with this individual, that you have helped him through lots of ups and downs, developed lots of different work incentives, maybe held the hands through the past approval and management process. But I only see one BS&A in that file and it’s from the year 2008.

NO the BS&A is a living document. As the person moves forward and their benefits changes and they start to claim work incentives then you really do need to revise it. Now you can start from scratch and rewrite it if that’s what you chose to do or you can develop a separate update attachment or format that goes with the BS&A, that’s up to you but if you have five year relationship with the beneficiary which is kudos to you then show me that you are documenting the changing in this person benefits over time and that you’re advising this person about the benefits. Again give yourself credit for the work that you’re doing. And that needs to be in writing and it needs to be shared with the beneficiary. Same thing with the WIP.

You don’t write a WIP that lasts 20 years. A WIP has a very limited shelf life, three to six months. It’s a to do list. You don’t write, you’re personal to do list. You do not write a to do list for yourself on January 1st of every year and not update it until December 31st. It doesn’t happen that way. Most of us



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write to do list on a daily or weekly basis. Stuff gets done, it gets crossed off, new stuff gets added. That’s what a WIP is. It’s not that complicated. You can’t make a WIP last 20 years, if it lasts 20 years it has not meaning.

It’s only going to last about three to six months and then either you’re done and you don’t need to do another WIP because the person issues are all resolved or you’re going to update the WIP, you’re going to change it, new stuff is added, old stuff is taken off, its really I think everybody is over complicating what that WIP is. It really isn’t that big of a deal.

Have about those earning? Have they been reported? Are you clear on what the person is earning right now? Is all the work incentive documentation current? Is the file presented in a manner that a reviewer can make heads or tails out of it? This is a problem sometimes. If I can’t make heads or tails out of your file, if you go to the hospital and your boss has to step in or your colleague believe me that persons not going to be able to get it either.

Things have to be organized. You can’t just have random pages of handwritten stuff thrown into a shoe box and expect that to fly. It’s got to be organized with separations and sections put this that and the other. Things need to be filed chronologically so you can follow the story. Are you documenting contacts with Social Security or other agencies? Is that included in your staff notes? That’s all the stuff that needs to go in.

Social Security is reviewing files and I know most of you know that or you wouldn’t be on this call. You probably have Social Security come and say well the files need a little work and so you know you have to expect that these reviews are going to occur and my guess is that we will see the occur more frequently now. Again your technical assistance liaison is here to help you. This may not be our absolutely most favorite part of our job but we can help you with this, we can look at your files.

We can look at portions of files. We can look at all pieces of the whole file. Now please don’t send us stuff without masking the person identity. We’re not supposed to see that either. So if you’re going to send us a whole paper file, you actually have to make a copy of the whole paper file and by hand go



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through that file with a marker and block out name, birth date, Social Security number, and let me tell you that’s not easy to catch them all but that really is required. We’re not supposed to see that step either.

Let me see what else is going to be reviewed on there. Remember to use your tech liaison. If you’re going to have a review soon, get some advice. If you’re developing new format get it by some new TA liaison. We’re only a phone call or an e-mail away. We’re here to help you. No one wants you to do it wrong and have you get quote citations or get notes in your site review. Everyone wants you to do this right. So we’re here to support you.

This call is being archived or will be subsequently archived and any new staff person can dial in and listen to this at a later date. It probably should be something that you do take care of.

Let’s do a quick review of case notes and take some more calls. We’ve had so many good questions that I think we won’t go over some of these slides that are under case notes but I will tell you that case notes are a critically important component of a record review and quite frankly as a reviewer I like reading the case notes. The case notes give me the flavor, it tells me the story, I know what you’re doing with this person when I read good case notes. So always be thinking as you’re writing.

Is the information I am putting in here useful to A a reviewer or B someone who comes along behind me. Am I telling the story? What did I do with this person, for this person, about this person, what service did I deliver, what results have I seen, what issues are we working on and what are the next steps? And every time you make an entry that is what I want to read. And they need to go on chronological order so that we can start at the beginning of the story and read through so that we understand how this case is progressing. What’s changing for this beneficiary, what impact are you making in this persons life. Give yourself credit for the absolutely marvelous things that you’re doing for people. But if you don’t write it down nobody knows it happened. It may feel good to you but we don’t know what happed unless you write it down, OK.



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It’s about documenting progress. It’s about justifying the expenditure of public money. It’s about providing a historical record to ensure continuity of service. It’s an excellent way for a project manager to see what you’re doing. All the more reason to capture what you’re doing in writing and don’t forget that that case file truly is a legal document. It can be and has been in my experience subpoenaed by a court of law, OK. I’ve had that happen. Not in a WIPA world but in my previous life in supported employment I’ve had record subpoenaed so you need to make sure that you are representing your most professional abilities. That you’re careful what you’re writing in there. That you’re not making the disparaging comments about people that you’re not speaking of the beneficiary in a disrespectful manner. I know none of you would do that but it’s important for you to remember.

The beneficiary can view the record at any time, an attorney can view the record at any time and its just a really, really valuable component to have these case notes that describe what’s being done with the person and where you’re headed and what is working, what needs to be worked on more, what your next steps are and that really describes the advisement too that you’ve been giving people. I think I’ve covered those so its I’m showing that it’s almost 10:10, let’s take some more questions.

Operator: Again if you would like to ask a question please press star one on your telephone key pad. Again to ask a question press star one on your telephone key pad. Your next question comes from (Arneta Ticup); your line is now open.

Lucy Miller: HI (Arneta).

(Arneta Ticup): Hi how are you?

Lucy Miller: Good what’s up?

(Arneta Ticup): Yes I just have one question in regards to case notes, you know as far as individual unlike the past and your attempting you know to communicate, this ongoing, the individual does not want to comply or communicate and ask you not to call them or they don’t want to assist you in any kind of way (inaudible) and what’s going on. As far as the case notes on what I had been doing is you



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know I document any time I try to contact this individual or she sends me e-mails, I kind of like print e-mail and put in her file.

Lucy Miller: That’s fine.

(Arneta Ticup): OK, so that’s OK, even though she’s not, you know there are certain things I need to do with her and make sure everything is, OK what she is saying don’t call me or …

Lucy Miller: And that is her choice (Arneta) and all you can do, you know we can’t stalk people and we can’t make them do things even when the things we’re trying to help them with are in their own best interest. And I totally know what you’re talking about with past candidates who don’t want your help and a lot of times it’s because they’re not doing what they’re suppose to be doing, they may have spent their past funds on things they shouldn’t have, they don’t want you to know that and all you can do is make a couple of contacts, try to get them to respond back but if that person responds back and says I do not want your help, then all you can do is respect that and say I understand, I’m going to make a note to that effect, you put that file folder in an inactive status and make sure the beneficiary knows, you know we don’t terminate people. I mean put that beneficiary in an inactive status, make sure she or he knows you are there. And if something changes, if they need your helps that the door is always open but that you will respect their wishes.

(Arneta Ticup): OK, thank you.


Operator: There are no further questions in queue at this time.

Lucy Miller: You’re kidding me. I’ve got it all done with like five minutes to spare? I can’t believe it. (Susan) do you have any other comments to make before we close out or I don’t know if (Carol Collin) or any of the Social Security people are in the speakers.

(Carol): I’m on its’ (Carol).



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Lucy Miller: Awesome (Carol) do you want to do a close out.

(Carol): I really don’t have much to say just to thank everyone for joining us and we hope this was helpful. As we stated by your extremely confident and enthusiastic speaker, many of you, most of you in fact have participated or been on site when the project officer and team have visited you and perhaps recommended that you participate in this teleconference today. So we’re really delighted you’re here. If you have further questions concerns or anything comes up you know please do not hesitate to contact you BC liaison or your project officer. They’re here to help you 24/7 work with you to assist you make improvements and you manage the WIPA.

And we just really appreciate your participation, hope you found this helpful. If there’s anyone on your staff that was unable to join us today, they certainly can listen to the archive presentation. I don’t have anything else to add, (Susan) do you?

(Susan O’Mara): No I think you all covered it very well.

(Carol): Does anyone on the SSA staff have any comments? I guess not. Ok, well thank you all so much and thank you Lucy.

Lucy Miller: You’re welcome. Good luck to everyone in their record keeping endeavors and don’t forget there’s help out there ready, willing and able to support you and assist. So if you have a question, you some feedback, you know who to call, Tech Liaisons, we’re happy to help. Have a great afternoon everybody.

Operator: This concludes today’s conference call, you may now disconnect.

END

Documents

VCU RRTC 9 11 CFM Call... · Web viewYour WIPA material, your staff notes, your BS&A’s, that BPQY that you get, all of that is required to be held in a separate, physically separate