Wednesday, May 02, 2007

It's not rocket science, Carmen : your audit couldn't launch a paper airplane : THE EMPRESS HAS NO CLOTHES

This is really beginning to bug me, the way the news services just blathered on and on about how the audit, 'according to Hooker Odom' (hereafter known as: ATHO) revealed that Endorsed Providers had been abusing Community Support.


That's both incredible and very scary

Verla Insko, the co-chair of the Joint Legislative Committe for mental health reform, has informed me that she can get further information about the audit. My questions start with: SHOW ME THE STATISTICIAN WHO DEVELOPED THIS TRASH.

I'll go you one further: THERE WASN'T ONE. Get the EXCEL file copy of what's available:
Brad Deen N.C. Dept. of Health and Human Services Public Affairs Brad Deen

Questions about the audit itself, might include:

1. How many Endorsed Providers are there in NC? (in other words, what is the overall 'n' or number of Endorsed Providers from which the 167 were gathered.

2. Were the 'passpoints' of 50% and 75% as associated with Gps 1,2,3 set:
a. arbitrarily?
b. norm-referenced? (there is no normative data and so that is not possible; in other words, this matter has not been studied before and a set of data carefully created in order to evaluate subsequent behaviors is not in existence)
c. criterion referenced? If so, what were the criteria utilized in order to make the judgments and render the percentages? In other words, how was it that 50% and 75% were chosen? There is no clear reason to do this. It is assumed to be arbitrary. And that does not suffice.

3. What were the target measures associated with rendering the scores, the percentages, the cut-offs? What did the raters look at besides the fact that these were the 167 heaviest billers in NC?
We get a little look at just how these people realized they screwed up when we ask this qustion and refer to this document: Implementation Update #28 'DHHS Rate Review Board Revisits CS Rates', signed by Allen Dobson, MD, and Mike Mosley, head of DMH, the writer assumes this chatty urbane tone.
This is the reason that this filthy little audit was (attempted to be) used:

"We do want to explain what's happened with the CS rate in the past few months. Earlier this year, we noticed a major increase in the use of CS services. By the end of March, CS was the single largest Medicaid service----outpacing payment for hospitals, physicians, and prescription drugs."

Nevermind that the Joint Legislative Committee had seen this also and made a recommendation to DHHS and Hooker Odom, which Endorsed Providers would have understood, namely, that the more highly educated the hands-on CS worker is, the better they need to be paid. In the world of mental health, where a PhD or MSW means independence, and something else means being under the thumb of the PhD or the MSW, WE GET THIS.

(to continue): "When we first noticed this phenomenon, we did a service audit of 167 providers who were billing large amount of CS services per consumer. That audit showed that those providers were using paraprofessional staff to deliver 98 percent of the services ....SO?? ....and why don't you say here ATHO..... something about the cut-offs of 50% and 75% which was used for no obvious reason as According to Hooker Odom, all the 167 providers were at fault (the sound of the press rolling over is overwhelming) "...not the 75% that had been factored into the original rate...."

These people botched it, the whole thing: as per the Service Definition associated with the providing of CS, there is no stipulation that using paraprofessional staff would not be allowed or desirable.....

4. What is the impact of having chosen this skewed population of 'heaviest billing' Endorsed Provider companies? One might assume that Endorsed Providers who heavily bill might make more errors related to volume of paperwork. IN that case, the notes of '4 or more notes missing' would not have much meaning as against the volume of billing that was taking place. They chose this population in order to see what they wanted to see.

5. Who were the raters? . This returns us to the question of what were the target measures? It looks to me like the target behavior associated with this audit were two things and TWO THINGS ONLY: the percentage of paraprofessionals and how many notes did these heavy billing agencies miss of those perused.

6. What was the problem w/ the other 7 providers in Category 3 (as associated with missing data e.g., no information about 'missing notes and/ or what the criterion measures were). It simply looks like the data was missing and therefore we return to the question of 'who were the raters?' and what were the targeted measures to be taken.

DHHS, under Hooker Odom, didn't do their homework re: use of paraprofessionals as the hands-on CS workers. Indeed, their Service Definitions make clear that this is perfectly acceptable. Then they saw the Medicaid funds being utilized and instead of using the expertise of Insko and Nesbitt and other members of the Joint Legislative Committee on mental health reform, told them to 'get lost...we know what we're doing' and so cut CS such that instead of 28 max sessions, we have 12 sessions; instead of $60/ hour we have $51/ hour.

As necessarily willing accomplices, the LME personnel now play the tune of : 'however many hours of CS you use/ client, you have to document the necessity of it.' According to Becki Wolfe, provider relations at Smoky Mountain Center LME, the LME is now charged with 'reviewing' any Community Support Services delivered at more than 12 hours/ week/ client. She stated that the matter is not that the services cannot be delivered at more than 12 hrs/ week/ client. The Rovian conundrum, however is this: this 'reviewing' is problematic to the extent that 'reviewing' holds up any delivered Community Support services----as the Endorsed Provider then needs to know if s/he can be paid----or not. Without authorization or an authorization, services may be delivered----but not paid for. This will quickly break any Endorsed Provider.

YES: of course. We know that. But ATHO we have chaos and confusion such that now (some) Endorsed Providers have caught on to the game here and will be using the same number of hours, which will cause red flags to go up at the LME's, the willing accomplices, leading to an avalanche of Medicaid appeals hoisted onto 'The Department', otherwise known as DHHS-----which will boondoggle the entire system, such that consumers/ clients will not get their services and so EFFECTIVELY the 12 hours of CS is all anyone will get.


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