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Behavioral Health Compliance Solutions, LLC

S. BHC. Behavioral Health Compliance Solutions, LLC. Behavioral Health Medicaid Training 7 AAC 135. S. BHC. Staff Qualifications. Behavioral Health Medicaid Training 7 AAC 135. Staff Qualifications. Program Staff

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Behavioral Health Compliance Solutions, LLC

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  1. S BHC Behavioral Health Compliance Solutions, LLC Behavioral Health Medicaid Training 7 AAC 135

  2. S BHC Staff Qualifications Behavioral Health Medicaid Training 7 AAC 135

  3. Staff Qualifications Program Staff •Program Staff are professionals who render behavioral health services directly to a recipient. •Required staff qualifications depend on the service category. •Service Categories are –Clinic –Rehabilitation –Residential –Detoxification –Day Treatment

  4. Staff Qualifications Staff Types •Substance Use Disorder Counselor •Behavioral Health Clinical Associate -includes Peer Support Specialists •Mental Health Professional Clinician •Directing Clinician

  5. Staff Qualifications Behavioral Health Clinical Associate •May have less than a master’s degree in psychology, social work, counseling, or a related field with specialization or experience in providing rehabilitation services to recipients with severe behavioral health conditions. •Responsibilities may include a provision of psychosocial evaluation, education related to a recipient’s behavioral health condition, encouraging and coaching, counseling, and teaching of needed life skills. •Works within the scope of the their training, experience, and education.

  6. Staff Qualifications Substance Use Disorder Counselor •Subject to the limits of the their education, training, and experience. They may provide behavioral health rehabilitation services with a focus on the treatment of substance use disorders, while working for a community behavioral health services provider.

  7. Staff Qualifications Mental Health Professional Clinician • Working for a community behavioral health services provider; • Performing limited behavioral health services that are within field of expertise; • Not working in a capacity that requires licensure under AS 08; and • Has a master's degree or more advanced degree in psychology, counseling, child guidance, community mental health, marriage and family therapy, social work, or nursing; Note: there are licensure requirements for mental health professional clinicians that are not working for a community behavioral health service provider

  8. Staff Qualifications Directing Clinician •A substance use disorder counselor or mental health professional clinician working within the scope of their education, training, and experience who, with respect to the recipient’s treatment plan: –Develops or oversees the development of the plan –Periodically reviews and revises the plan as needed –Signs the plan each time a change is made to the plan –Monitors and supervises the delivery of all services identified in the plan

  9. Staff Qualifications Directing Clinician • By signing a treatment plan, a directing clinician attests that (in their professional judgment) the services prescribed in the plan are appropriate to the recipient’s needs, delivered at an adequate skill level, and are achieving treatment goals. • Responsible for monitoring recipients’ care across all programs within an agency as identified on a treatment plan. • May bill Medicaid for 1hr per week/per recipient of case management services for the monitoring by direct observation the delivery of services as those services are provided to the recipient

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  15. Staff Qualifications Peer Support Specialists •Peer support staff must be employed by the Provider as a behavioral health associate. •Minimum age is determined by labor laws for employment and agency policy. •Good practice indicates that all employees, and particularly peer support staff should be aware of the prohibition of dual relationships with clients and maintain appropriate boundaries.

  16. S BHC Recipient Eligibility Behavioral Health Medicaid Training 7 AAC 135

  17. Recipient Eligibility There are five categories of recipient eligibility for Medicaid services. Recipients who are eligible to receive behavioral health clinic services include: • A child experiencing an emotional disturbance– a recipient is under the age of 21 who is experiencing on non-persistent mental, emotional, or behavioral health disorder that: • Is identified and diagnosed during a professional behavioral health assessment; and • Is not the result of an intellectual, physical, or sensory deficit • An adult experiencing an emotional disturbance – a recipient is 21 years of age or older who is experiencing on non-persistent mental, emotional, or behavioral disorder that: • Is identified and diagnosed during a professional behavioral health assessment; and • Is not the result of an intellectual, physical, or sensory deficit

  18. Recipient Eligibility Behavioral health clinic services 3) A child or adult experiencing a substance use disorder – a recipient of any age experiencing a disorder that is identified by a diagnostic code found in the American psychiatric Association’s diagnostic and statistical manual of mental disorders that is related to: a) alcohol, amphetamine, or similar acting sympathomimetics; b) cannabis, cocaine, hallucinogens, inhalants, nicotine or opioids c) analogues of phencyclidine (PCP) or similar arylcyclohexylamines;or d) sedatives, hypnotics, or anxiolytics

  19. Recipient Eligibility Behavioral health clinic services 4) A child experiencing a severe emotional disturbance– a recipient is under the age of 21 who: a) has or had a diagnosable mental, emotional, or behavioral health disorder any time in the past year that resulted it in a functional impairment (that is not a result of response to stressful situations) which substantially interferes with the child’s role functioning in family, school, or community activities as indicated by a global assessment of functioning score of 50 or less b) exhibits specific mental, emotional, or behavioral disorders that i) place them at imminent risk for out of home placement ii) place the individual at imminent risk for being placed in the custody of the Division of Juvenile Justice iii) have resulted in the individual being placed in the protective custody of the Office of Children’s Services

  20. Recipient Eligibility Behavioral health clinic services 5) An adult experiencing a serious mental illness– a recipient that is 21 years of age or older who a) has or had a diagnosable mental, emotional, or behavioral health disorder any time in the past year that resulted it in a functional impairment (that is not a result of response to stressful situations) which substantially interferes with or limits one or more life activities including i) basic daily living skills ii) instrumental living skills such as managing money iii) functioning and social, family, or vocational/educational contexts

  21. Recipient Eligibility Three of the five categories of recipient eligibility for Medicaid service are eligible to receive behavioral health rehabilitation services including: • A child or adult experiencing a substance use disorder • A child experiencing a severe emotional disturbance • An adult experiencing a serious mental illness

  22. S BHC Clinical Documentation Requirements Behavioral Health Medicaid Training 7 AAC 135

  23. Clinical Documentation Requirements Community behavioral health services providers (CBHS) “must maintain a clinical record for each recipient in accordance with the standards used for the Medicaid Program” [7 AAC 70.100(a)(6)] 7 AAC 135.130 Clinical Record A CBHS must maintain a clinical record that contains the following: –Screening using AST –Client Status Review –Behavioral Health Assessment –Treatment Plan –Progress Notes (for each service / each day service provided)

  24. Clinical Documentation Requirements •A Medicaid provider must retain a record of service for each recipient according to requirements noted in 7 AAC 105.230 •To document active treatment a Medicaid provider must describe or list active interventions provided to a recipient •All changes to assessments and treatment plans must be noted in the recipient’s clinical record

  25. Clinical Documentation Requirements •A provider shall maintain accurate records necessary to support the services for which the provider requests payment, and ensures that the provider’s staff meet the requirements of this section 7 AAC 105.230 •A provider’s record must identify all the following: –Recipient name –Specific services provided –Extent of each service provided –Date of service –Individual who provided service

  26. Clinical Documentation Requirements • A Provider shall maintain a clinical record for each recipient in accordance with professional standards applicable to the provider that includes: –Recipient’s diagnosis –Medical need for each service –Prescribed Service or Plan of Care –List of prescription drugs –Stop and start times for time-based codes –Progress notes of services provided signed / dated by person who provided service

  27. Clinical Documentation Requirements Behavioral Health Screening Alaska Screening Tool (AST) •A CBHS must complete the AST for each new or returning recipient of behavioral health services before a behavioral health assessment is conducted [7 AAC 135.100(a)] •AST does NOT have to be completed for recipients receiving: –SBIRT –Short-term Crisis Intervention / Crisis Stabilization •AST is a reimbursable Medicaid service [7 AAC 145.580]

  28. Clinical Documentation Requirements Behavioral Health Screening Client Status Review The Department will pay a CBHS for completing a client status review with the client present if: 1. it is used as relevant clinical information concurrent with an initial Behavioral Health Assessment 2. Conducted Every 90-135 Days 3. Conducted at discharge from treatment [7 AAC 135.100(b)] 4. Administered using the Dept. CSR Form

  29. Clinical Documentation Requirements Behavioral Health Screening Client Status Review 6. Documented in the clinical record 7. CSR data reported to Department 8. Used to help determine recipient’s level of functioning 9. Used by Directing Clinician to: a. Measure Treatment Outcomes b. Make Treatment Decisions c. Revise Treatment Plan

  30. Clinical Documentation Requirements Professional Behavioral Health Assessments If a behavioral health screening (AST), or a referral by a court or other agency, has identified an individual suspected of having a behavioral health disorder that could require behavioral health services, the Dept. will pay a CBHS for one of the following behavioral health intake assessments [7 AAC 135.110]: 1.Mental Health intake assessment 2.Substance Use intake assessment 3.Integrated MH and Substance Use intake assessment 4.Psychiatric Assessment (used as Intake Assessment)

  31. Clinical Documentation Requirements Professional Behavioral Health Assessments Mental Health Intake Assessment • Are conducted by a Mental Health Professional Clinician for the purpose of determining: –Recipient’s Mental Status, Social & Medical Histories –Nature & Severity of Mental Health Disorder(s) –Complete DSM Multi-axial Diagnosis

  32. Clinical Documentation Requirements Professional Behavioral Health Assessments Elements of ALL Behavioral Health Assessments: • Finalizes in a written report • Documents that results of AST and CSR were reviewed and considered • Documents information on functional impairment • Documents treatment recommendations that form basis of a treatment plan • Identifies the need for Recipient Support Services (if appropriate) that includes Hxof violence/need for vigilance & location/frequency of RSS • Is updated as new information becomes available

  33. Clinical Documentation Requirements Professional Behavioral Health Assessments Substance Use Intake Assessment •Conducted by a Substance Use Disorder Counselor, Social Worker, or other Qualified Staff Member working within the scope of their authority, training, and job description •Conducted to Determine: –If recipient has substance use disorder –Nature & severity of disorder –Correct diagnosis

  34. Clinical Documentation Requirements Professional Behavioral Health Assessments Integrated Mental Health and Substance Use Intake Assessment •Conducted by a Mental Health Professional Clinician (able to diagnose BOTH Mental Health & Substance Use Disorders) •Documents –All Requirements for Mental Health Intake Assessment –All Requirements for Substance Use Intake Assessment

  35. Clinical Documentation Requirements Professional Behavioral Health Assessments Psychiatric Assessments • The department will pay a community behavioral health services provider for a psychiatric assessment that is to serve as the professional behavioral health assessment if the recipient's condition indicates the need for a more intensive assessment, including an assessment to evaluate the need for medication. [7 AAC 135.110(f)] • A psychiatric assessment must be conducted by a licensed practitioner working within the scope of their education, training, and experience, if the provider has prescriptive authority, and if the provider is enrolled under 7 AAC 120.100(c) as a dispensing provider: •Physician •Physician Assistant •Advanced Nurse Practitioner

  36. Clinical Documentation Requirements Professional Behavioral Health Assessments Psychiatric Assessments •2 Types of Psychiatric Assessments: 1.Psychiatric Assessment Interview 2.Interactive Psychiatric Assessment (uses equipment and devices) •Both Types must include: – Review of medical & psychiatric history or problem; – Relevant recipient history; – Mental Status Examination; –Complete Multi-axial DSM diagnosis –Listing of identified psychiatric problems

  37. Clinical Documentation Requirements Professional Behavioral Health Assessments Psychological Testing and Evaluation The Dept. will pay a CBHS, or psychologist for psychological testing and evaluation to assist in the diagnosis and treatment of mental and emotional disorders [7 AAC 135.110(g)] •Psychological testing and evaluation must be conducted by a Mental Health Professional Clinician working within the scope of their education, training, and experience. •Psychological Testing and Evaluation includes: –assessment of functional capabilities –administration of standardized psychological tests –interpretation of findings

  38. Clinical Documentation Requirements Behavioral Health Treatment Plan • Based on Behavioral Health Assessment recommendations • Developed with recipient or –Recipient’s representative if recipient 18 & older –Treatment team if recipient is under 18 • Supervised by Directing Clinician • Remains current based on Client Status Review conducted every 90-135 days

  39. Clinical Documentation Requirements Behavioral Health Treatment Plan Documentation Requirements [7 AAC 135.130(a)(7)]: •Recipient’s identifying information •Date that plan will be implemented •Treatment goals related to assessment findings •Services & interventions employed to address goals •Frequency and duration of services & interventions •Name, signature & credentials of Directing Clinician •Signature of recipient or recipient’s representative

  40. Clinical Documentation Requirements Behavioral Health Treatment Plan Treatment Team for Recipient under 18 MUST include: •Recipient •Recipient’s Family Members (including parents, guardians, or others providing general oversight of Recipient) •OCS Staff Member if Recipient in State Custody •DJJ Staff Member if Recipient in DJJ Custody •Directing Clinician •Case Manager, if Recipient is SED

  41. Clinical Documentation Requirements Behavioral Health Treatment Plan Treatment Team for Recipient under 18 MAY include: •Representative(s) from Foster Care, Residential Child Care, or Institutional Care •Representative(s) from Recipient's Educational System

  42. Clinical Documentation Requirements Behavioral Health Treatment Plan ALL treatment team members shall: • Attend team meetings In-person or by telephone • Be involved in team decisions unless the clinical record documents – (1 ) that participation by Recipient or other Individual involved with Recipient care is detrimental to Recipient's well-being (2) family members, school district employees, or government agency employees refuse or unable to participate after provider's responsible efforts to encourage participation or (3) weather, illness, or other circumstances beyond member's control prohibits participation

  43. Clinical Documentation Requirements Behavioral Health Treatment Plan Directing Clinician- Substance Use Disorder Counselor or Mental Health Professional Clinician working within the scope of their education, training, and experience who, with respect to the recipient’s Treatment Plan: 1.Develops or oversees treatment planning process 2.Periodically reviews & revises plan 3.Signs plan each time plan is changed 4.Monitors & directs delivery of services identified in plan • By signing treatment plan, directing clinicians attest (in their professional judgment) that services prescribed are: • Appropriate to recipient’s needs • Delivered at adequate skill level • Achieving treatment goals

  44. Clinical Documentation Requirements Progress Notes Requirements: [7AAC 135.130(a)(8)] •Progress note is written for each service/each day service is provided •Date service was provided •Duration of service expressed in service units or clock time •Description of “active treatment” provided •Treatment goals that service targeted •Description of recipient’s progress toward treatment goals •Name, signature & credentials of individual who rendered service

  45. Clinical Documentation Requirements Short-term Crisis Intervention Provided by a Mental Health Professional Clinician who: 1.Conducts initial assessment to determine: a. Nature of Crisis b. Recipient's Mental, Emotional, & Behavioral Status c. Recipient's overall Functioning related to Crisis 2. Develops Crisis Intervention Plan a. Uses Dept. Form 3.Directs ALL Services (except Pharmacologic Management Services)

  46. Clinical Documentation Requirements Short-term Crisis Intervention Clinician may order & deliver ANY Medically Necessary and Clinically Appropriate Behavioral Health Clinic or Rehabilitation Service or intervention to: • Reduce Symptoms • Prevent Harm • Prevent further Relapse or Deterioration • Stabilize the Recipient

  47. Clinical Documentation Requirements Short-term Crisis Intervention ST Crisis Intervention Plan MUST Contain: •Treatment goals derived from assessment •Description of Medically Necessary and Clinically Appropriate Services •Documentation by individual who delivered service

  48. Clinical Documentation Requirements Short-term Crisis Stabilization Provided by a Substance Use Disorder Counselor or Behavioral Health Clinical Associate who: 1.Conducts initial assessment of recipient's overall functioning in relation to crisis 2.Develops Short-term Crisis Stabilization Plan 3.Orders ANY Medically Necessary and Clinically Appropriate Rehabilitation Service to return recipient to level of functioning before crisis occurred 4.Documents Assessment, Stabilization Plan, and Services on Dept. Form

  49. Clinical Documentation Requirements Short-term Crisis Stabilization ST Crisis Stabilization includes: • Individual or Family Counseling • Individual or Family Training & Education related to Crisis and Preventing Future Crisis • Monitoring Recipient for Safety Purposes • Any other Rehab Service ST Crisis Stabilization May be Provided: • Any Appropriate Outpatient or Community Setting • Premises of CBHS • Crisis Respite Facility • Recipient’s Residence, Workplace or School • Documented by Individual who Provides the Service

  50. Clinical Documentation Requirements Short-term Crisis Stabilization ST Crisis Stabilization includes: • Individual or Family Counseling • Individual or Family Training & Education related to crisis and preventing future crisis • Monitoring recipient for safety purposes • Any other Rehab Service ST Crisis Stabilization may be provided: • Any appropriate outpatient or community setting • On the premises of CBHS • Crisis Respite Facility • Recipient’s residence, workplace or school • Documented by individual who provides the service

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