Thursday, May 10, 2007

More info on audit fm DHHS ALSO H973, parity bill, moved to TUESDAY, 11am, May 10th: Insurance Committee of NC House

I just talked to Ann, the NC House clerk who was taking notes during the Insurance Committee meeting this morning. There were 2 bills to be discussed this morning, Thursday, May 10th. The one concerned with chiropractic 'took the whole meeting', she stated.

Here is info on the mental health parity bill, H973, which is to be attended to on May 15, 11 a.m., by the Insurance Committee of the NC House:

This gives time to strategize and contact these important representatives who are members of the Insurance Committee of the NC House. Verla Insko has stated that much of mental health bills and associated fuding is impacted (detrimentally) by the powerful insurance lobby in NC. It is critically important that they realize that we know this.

So, this hiatus also gives time for the powerful insurance lobby create problems for the passage of this important bill. One way in which they might do this is purportedly related to pulling the red herring of 'substance abuse treatment would break us.'

First of all, as associated with substance abuse diagnoses, they are secondary to the diagnosis which is 'driving the car' in terms of mood disorders, psychotic disorders, or other mental health diagnoses. This is why there is the term 'dual diagnosis' ,as associated with a DSM diagnosis, and along side it, a DSM substance abuse diagnosis. Substance abuse may look to be the primary problem as pertaining to the havoc of the associated behaviors ----and there is no denying that one has to treat substance abuse in a vigorous manner-----but the other diagnoses have to be addressed also or the client/ consumer will undoubtedly fall prey to the substance abuse again. It is, after all, (under DHHS): DD/MH/SA. There's a reason for that. They sit together, these matters. That is because they impact each other.

Also, as associated with mental health parity laws in 37 plus states, as well as mental health parity at the federal level, substance abuse is not 'extracted', best I know.

Talking points re: parity , might include:
Item 1: Insurance costs have decreased as regards utilization of mental health: (from the American Psychological Association, Russ Newman, JD, PhD:

Item 2: ""This is a public health crisis that in some way impacts every family in America. It's time to break down the barriers to good mental health and addiction treatment."

Item 3: personal and professional antedotal information that 'puts a face' on the importance of mental health parity.

Item 4: Multiple items here to take into consideration:

May 10, 2007
Mr. Jarrard (of DHHS; Dr. Puckett, Clinical Operations Director sent me to you):

Thank you for your quick response. You stated I should speak with Tara Larson and Christina Carter; I assume that their e mail addresses are: and I am sending these questions over to them. Please advise me if their e mail addresses are something else.

This e mail may be perceived as heavy handed but frankly when DHHS attempted to apply faulty methodology on the matter of Community Support and put at risk the livelihoods of Endorsed Provider agencies, you merited a thorough critiquing----rather than the press just rolling over and playing dead----which they did---mentioning the 'bad apples' providers over and over.

Re: this, which you just stated, as associated with my questions:

"....However, I would respond in general to your inquiry by saying that CMS deems all of the items to be equally important and requires the entire record to be considered out of compliance if any of the required items are missing or incorrect. We thought that "all or nothing at all" approach did not accurately represent provider performance since it does not recognize providers who were basically doing well but had some missing or incorrect items. We devised this alternative approach to concentrate on just the most objective, yes or no, items...."

WHOOAAA and wait a minute: the basic question that this audit/ research was to have answered, I had believed, was whether the Endorsed Providers were providing Community Support (CS) in keeping with the Service Definition. That's where all the 'bad apples' talk came from (see earlier Madame Defarge post). (We also realize that the key reason for the audit was in order to staunch the flow of Medicaid dollars...something that had not been anticipated due to the mis-management under Hooker Odom).

The methodology wisely avoided a forced choice format (yes or no: accept or reject). Such would have indeed aroused the ire of many more of the Endorsed Providers in that it would have been an absolute standard; moreover, it would not have been an appropriate standard by any reasonable person's standard.

In my opinion, Mr. Jarrard, neither was it appropriate to utilize an approach which weighted equally the 4 criterion measurements. Those 4 criteria were, as per the 30 plus slides associated with the Powerpoint presentation which Dr. Puckett forwarded to me as associated with your 'OK' that this take place (as per your e mail statement to me):

Valid Service Order: Valid Service Plan; Valid Authorization ; Valid Service Note

As I mentioned on the blogspot, each of these is different in terms of time spent by the Endorsed Provider. Why does this matter? It matters at the level of the work that DHHS and thus the LME's have demanded of the Endorsed Provider companies. We check our boxes in terms of completion. However, not all the boxes are equal in terms of our effort and a dismissal of this matter is disrespectful and what we have come to expect under the DHHS administration of Hooker Odom.

Valid Service Order: a Valid Service Order is easy to obtain. It is merely a signature from an approved person e.g., psychologist, psychiatrist, psychiatric practitioner (as associated with a relationship arrived at vis a vis the Endorsed Provider. Time expended: less than one hour.

Valid Service Plan: difficult, time consuming (time expended: 10-20 hours) inclusive of interviewing face to face, probably more than once, the consumer (gathering the data); inputting the data; proofreading the data; sending the data off via HIPAA guidelines.

Valid Authorization: This takes about 1 hour of work on the part of the provider. You fill in the form after looking at and/ or digging up the information, you fax it,and then you wait for ValueOptions to send you the paperwork back. The work may also include calls you have to make to Value Options to see what is hanging up the authorization.

Valid Service Note: The Community Support hands-on workers do the notes. For each note, they probably spend 15-30 min/ day, handwriting the note. At the end of the week, this person gives the notes to the supervisor, QP, associated with the Endorsed Provider Organization. That person looks at the notes, consults with the hands-on person if corrections are necessary, in order to come into compliance; there may be necessary corrections made. Per client/ week of notes: 2-3 hours of work combined between the hands on worker and the supervisor.

Why should the 10-20 hours of a valid Service Plan have the same weight as a Service Order?
This is not to mention the problem with the non-direct perusal of the behaviors of the hands-on Community Support person. You used an indirect measure of the work.

If the Person Center Plan (PCP) which sits at the core of this paperwork, is required to be associated with the interviewing of not only the client but of significant others, then I want to know why did not DHHS evaluate the performance of the Endorsed Providers from the stance of the impacted parties, namely, the consumers and in association with that, their improved performance, pertaining to Community Support----or not. If we can do it: you can.

Maybe the problem is ineptitude (the optimistic amongst us might say). However, I speculate that the reason that this audit was done in the manner that it was pertains to Hooker Odom's and DD/MH/SA, 'The Department's' desire to frighten Endorsed Providers and make sure their paperwork is straight----beyond any services that might be rendered to the consumers/ client.

The American Psychological Association has worked for a long long time to create an accurate system which reflects the amount of time that psychologists utilize in order to do things like write a report or organize an assessment. (see: Ratio Value Factor) The end product, for instance, a psychological assessment, was not being accorded the 'relative factor unit' or time necessary in order to create the end product, for instance, the psychological assessment.

Information re: 'relative value factor' or 'relative value unit' is what we are talking about here. Again, why should these 4 criteria be accorded the same value? They do not require the same in terms of input for the Endorsed Providers and so why should DHHS impose (we already know that under Hooker Odom there is no collaboration) this invalid design as associated with our work?

In any case, the matter of evaluating 'ratio value factor' has been used for some time in order to map out just how much work takes place with, for instance, a CPT code. To suit:

"What is the Relative Value Unit of a Code?

The relative value unit (RVU) of a CPT code is one factor that determines what Medicare will pay for the service described by that code. HCFA multiplies the code’s RVU by a monetary conversion factor and the result is essentially the amount Medicare will pay for the service. (There are some adjustments made for geographic differences in resource costs.)"

The creators of this methodology might benefit from taking into account the difference in time as associated with each of these 4 criteria. And they might make measurements based on the outcomes of the interventions, rather than reviewing the paperwork, an indirect assessment of the intervention.

You would have been better off if you had listenedto the Joint Legislative Committee (Nesbitt and Insko) who suggested----as you saw how much money was being spent on community support----to have based the matter on the qualifications of the people doing the hands-on work. The audit seems to have been desperately driven by the need to staunch the flow of Community Support dollars. So, you gigged the providers.

So, we have an invalid piece of research which does not assess what you were (assumably) trying to assess and that was: what is the quality of the work being done by the Endorsed Providers as associated with Community Support......

....and the taxpayers paid for this invalid piece of research. I would like to know how much the tax payers paid.

At the most basic level, this audit has no validity. The gigging of Community Support providers has no validity because the severe reduction in hours and the diminishment of the hourly rate was stated to be based on the audit:

1. DHHS did not even bother to consult with the providers who do the work in terms of the creation of the items (all those 20 Community Support people either sat on their hands or you did not ask them and you already had your instrument in place prior to 'pretending'? to be working with them. )

2. ....which led you to create an invalid tool.

You have skewed the data and your research has no merit. Statistics is black and white with few shades of gray. If you were a dissertation student of mine, you would have been sent back to 'go.'

I would like to hear from Ms. Larson and Ms. Carter, please.


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