Maximizing Resources and Ensuring
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1 Maximizing Resources and Ensuring Compliance with State Licensure Statutes when Partnering with an Accreditation Organization Presented by: Calvin Green Barb Sylvester Mary Lou Fleming
2 Accreditation in Texas Calvin Green, Director Policy, Rules and Curriculum Development January 28, 2014
3 History and Statute Texas Health and Safety Code Sec (h) Except for the investigation of complaints, a HCSSA licensed by the department under this chapter is not subject to additional surveys while the agency maintains accreditation for the applicable service from the Joint Commission for Accreditation of Healthcare Organizations, the Community Health Accreditation Program, or other accreditation organizations that meet or exceed the regulations adopted under this chapter. Page 3
4 Challenges to Accreditation Approval Challenges for the Accrediting Body: Nationwide Applicability Balancing Best Practice and Minimum Standards Consistent Application of State Specific Regulatory Requirements Need for Specialized Staff (e.g., Life Safety Code Surveyors) Page 4
5 Challenges to Accreditation Approval Challenges for DADS as the State Regulatory Agency: Limited Statutory Guidance Ensuring Enforcement of Minimum Licensing Standards Ensuring Consistency in Interpretation Maintaining Consistency and Compliance Over Time Page 5
6 Overcoming the Challenges Helpful Initial Information Statistics Standards and Operating Procedures Sample Summary of Findings and Plan of Correction Documents Sample Agreements and Contracts with Providers Page 6
7 Overcoming the Challenges Comparative Analysis and Follow-up Initial Standards Crosswalk Regulatory Review and Gap Analysis Development of Supplemental Materials Strategies for Ensuring Consistency Moving Forward Page 7
8 Overcoming the Challenges Strategies for Ensuring Consistency Moving Forward Accreditation Approval Formalized Via Policy as Opposed to Rule Ongoing Communication and Updates Regulatory Monitoring of Complaint Data Page 8
9 CUSTOMIZING ACHC ACCREDITATION FOR STATE LICENSURE
10 ACHC MISSION Accreditation Commission for Health Care (ACHC) is dedicated to delivering the best possible experience and to partnering with organizations and healthcare professionals that seek accreditation and related services. 10
11 RELATIONSHIP BUILDING ACHC strives to provide the best possible experience to those with whom we partner This includes State Survey Agencies (SAs) and Regional Offices (ROs) We are privileged to be here to provide this presentation and to meet those of you that we correspond with throughout the year An effective collaboration can positively impact utilization of state resources and budgets 11
12 ABOUT ACHC Nationally recognized accreditation organization with over 25 years of experience: CMS Deeming Authority for: Home Health, since 2006 DMEPOS, since 2007 Hospice, since 2009 Recognition by third-party payors Recognition by state licensing agencies 12
13 ACHC PROGRAMS AND SERVICES
14
15 ACHC CORPORATE CUSTOMERS 15
16 EXPERIENCE THE ACHC DIFFERENCE Commitment to exceptional customer service Standards created for providers, by providers All-inclusive pricing Ability to create electronic tools to incorporate state regulations Provision of tools and consultative approach to ensure ongoing compliance 16
17 ACHC QUALITY By making quality a central focus of ACHC, we are able to design programs and services that provide our customers with the ability to deliver consistent, high-quality care We ensure ACHC quality performance through: Quality Management System certified to ISO 9001:2008 Quarterly evaluation of ACHC s performance conducted by the Centers for Medicare & Medicaid Services (CMS): 12 performance measures rated at 100% 3 performance measures rated 93.3% to 99.9% Monthly internal audits to ensure continuous compliance and performance improvement 17
18 ACCREDITATION EXPERTISE Expert Clinical Directors Knowledgeable Clinical Educators Dedicated Clinical Review Specialists Experienced Surveyors Personal Account Advisors Distinguished Board of Commissioners 18
19 EXPERIENCED SURVEYORS Possess direct experience in an administrative or quality leadership role in all programs for which they conduct surveys Participate in ongoing, mandatory training to ensure expertise with regulations and standards Provide explanation of survey findings 19
20 ACCREDITATION UNIVERSITY ACHC places great value on continuing education for agencies to achieve and maintain accreditation. Educational resources include: Hands-on workshops ACHC Accreditation Guide to Success workbooks Ongoing communication including regulatory updates, compliance tips, and valuable improvement strategies Customer Central customized online portal Ongoing compliance checklists
21 IMPORTANCE OF RENEWALS ACHC has a sincere commitment to retaining customers ACHC created a full-time position solely to work with agencies prior to their renewals: Provides written notifications beginning at 12 month pre-expiration Sends an accreditation packet with concise process directions Personally calls all renewing organizations that have not responded Analyzes data to determine reasons for nonrenewal to assist agencies and offers: Flexible payments plans Price negotiation Review facts about the home health sanctions ACHC notifies States 60 days prior to accreditation expiration to provide the state as much time as possible to schedule a state survey (newly implemented) 21
22 ACHC STANDARDS
23 ACCREDITATION STANDARDS ACHC has a reputation for providing exceptional customer service and relevant standards that: Are patient-centered and applicable to the type of services and care being provided Have clear, concise language with helpful interpretations for implementing and maintaining compliance Have a crosswalk for customers to transition to ACHC 23
24 OVERVIEW OF ACHC STANDARDS Overview of Standards: Section 1: Organization and Administration Section 2: Program/Service Operations Section 3: Fiscal Management Section 4: Human Resource Management Section 5: Provision of Care and Record Management Section 6: Quality Outcomes/Performance Improvement Section 7: Risk Management: Infection and Safety Control 24
25 PARTNERING WITH THE TEXAS DEPARTMENT OF AGING AND DISABILITY SERVICES (DADS)
26 PARTNERING WITH DADS Established collaborative relationship: Met with DADS to determine their specific needs Held regularly scheduled conference calls to ensure Texas requirements were met and to finalize ACHC processes Provided a detailed crosswalk for ACHC Accreditation Standards to Texas State licensure requirements: Created by ACHC, reviewed by DADS Trained ACHC Surveyors on the Texas survey tool: Created link on ACHC Surveyor Central for Surveyor reference ACHC monitors DADS Listserv and reviews DADS communication for additional Surveyor training or modification to Texas survey tool. 26
27 LICENSURE SURVEYS Currently conduct licensure surveys for: Florida Missouri Texas State licensure process customized to state: Florida and Missouri are two-step processes Texas is a one-step process Customized process for a state with no state licensure: Iowa request survey contains state-specific criteria related to: Criminal background checks Dependent adult abuse background checks Child abuse background checks 27
28 CROSSWALK OF STANDARDS 28
29 CUSTOMIZED DATA COLLECTION TOOL Each standard has required evidence that the Surveyor will review, such as: Observation Home visit Interview Personnel files Patient records Contracts Policies and procedures 29
30 CUSTOMIZED DATA COLLECTION TOOL With all evidence, fulfillments are created Fulfillments are the questions or observations that the Surveyor will ask or observe during the survey: Fulfillments were created specific to Texas licensure requirements Fulfillments reference the Texas rule number (e.g., Agency Organizational Changes): Track top 10 licensure deficiencies specific to Texas 30
31 CUSTOMIZED DATA COLLECTION TOOL FOR TEXAS 31
32 CUSTOMIZED DATA COLLECTION TOOL FOR IOWA Home health agencies in Iowa are not required to obtain a license, but the Iowa Department of Inspections and Appeals (DIA) provides specific criteria on how new initial home health agencies should be processed. ACHC created a process flow for providers to use. This document outlines the steps to follow for the provider, accreditation organization (AO) and DIA. 32
33 CUSTOMIZED DATA COLLECTION TOOL FOR IOWA
34 FLORIDA S MANDATORY ACCREDITATION MODEL Since 2008, Florida has required continuous ongoing mandatory accreditation for home care agencies to maintain licensure. (Agencies licensed prior to 2008 were grandfathered, whereby, no accreditation is required unless they experience a change in ownership). This model provides many advantages: A scheduled triennial survey will be conducted Agencies are not returned to the state at the time of accreditation expiration Complaints are investigated by the AO Agencies instead of states assume the cost After completion of a survey with deficiencies, the AO assumes responsibility for ensuring the agency creates a comprehensive Plan of Correction (POC) and submits evidence that the POC is followed 34
35 THE ACHC PROCESS
36 ACCREDITATION PROCESS 36
37 POST-SURVEY PROCESS All accreditation survey summaries are reviewed by ACHC Review Committee that consists of at least three program specialists. Survey decisions given within 10 business days from the last survey day. 37
38 POST-SURVEY PROCESS
39 POST SURVEY PROCESS POCs are due within 10 calendar days from the date of the decision letter: The POC template that the agency receives is already populated with their deficiencies from their Summary of Findings (SOF) Clinical Review Specialists are available to assist organizations with completing the POC 39
40 40
41 REGULATORY PAPERWORK PROCESS Once the initial decision is made by the ACHC Review Committee the regulatory paperwork process begins: Regulatory packet is created: CMS paperwork is started, including: Summary of Findings
42 REGULATORY PAPERWORK PROCESS Once the POC has been approved, the Clinical Specialist completes all required forms. The Regulatory Coordinator compiles the documents: Updates ASSURE Creates Approval letter The Quality Specialist audits approximately 50% of new regulatory packets: 15 quality indicators are reviewed Last quarter accuracy was 98.6%
43 SUBMISSION OF REGULATORY PACKETS ACHC customizes packets according to the specifications of each: SA RO Central Office Regulatory packets are sent according to the preference of each SA, RO, Central Office via: Certified mail Fax The Regulatory Department is available for any needed assistance. 43
44 CONTACT US ACHC is available to help your organization learn more about services we can provide to meet the needs of your state. Barb Sylvester Director of Regulatory Affairs & Quality Mary Lou Fleming Regulatory and Governmental Affairs Manager 44
45 ACHC WOULD LIKE TO ACKNOWLEDGE Association of Health Facility Survey Agencies Texas Department of Aging and Disability Services Texas & New Mexico Hospice Organization Texas Association for Home Care & Hospice Florida Agency for Health Care Administration Missouri Department of Health & Senior Services 45
46 THANK YOU
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