CORNERSTONE BEHAVIORAL HEALTH
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- Dennis Murphy
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1 CORNERSTONE BEHAVIORAL HEALTH Policy & Procedure Manual
2 CORNERSTONE Behavioral Health -A Division of Mountain Regional Services, Inc Feather Way, Suite 1 * P.O. Box 6005 Evanston, WY Policy & Procedure Manual Copyright 2000 by Mountain Regional Services, Inc. All Rights are Reserved No part of this manual may be duplicated in any form without prior written consent of Mountain Regional Services, Inc. Written 1994 Revised: 1997 Revised: 2000 Revised: 2003 Revised: 2006 Revised: 2009 Revised:
3 TABLE OF CONTENTS - POLICY AND/OR PROCEDURE: SECTION I: PROGRAM QUALITY Service Delivery Plan Consent for Services 18 Client Refusal to Sign Paperwork 18 Criteria for Admission/Re-Admission Accessibility of Treatment 19 Developing a Waiting List 20 Order of Selection for Admission of Persons Awaiting Services Ineligible for Services 21 Psychological Screening Substance Abuse Evaluations 22 Client Rights Confidentiality Financial Agreement - Fee for Services Sliding Fee Scale Substance Abuse Quality of Life (QOL) Client Orientation to Cornerstone Behavioral Health 29 Coordinating Client Services 29 Filing Grievance Initial and On-Going Assessment Client Duplicate Charts 32 Client Treatment Records Time Frames for Making Entries Into Client Charts and Completing Reports Direct Involvement of the Client in the Decision Making Process 34 Individual Plan for Client Client Follow-Up 37 Transition/Discharge Planning 38 Transition/Discharge Summary Plan Referrals of Needed Client Services Release of Information 43 Obtaining Previous Diagnostic Medical & Other Reports 43 Coordination of Prevention, Treatment and Transition/Discharge Planning Medication Use and Storage of Pharmaceutical Samples 45 Psychiatric Advance Directives Special Needs Use of Special Treatment Intervention 49 Crisis Intervention Quality Assurance Records Review 51 Medicaid Quality Assurance Plan Weapons and Violence 54 Nonviolent Practices 54 Smoking & Smokeless Tobacco Use 55 Abstinence
4 Alcohol and/or Other Drugs and Psychiatric Disabilities 56 Controlled Substances at Cornerstone 56 Child/Adolescent Being Suspended from School While in Treatment 57 Recruitment and Retention Plan for Psychologists Staff Training Supervision of Direct Service Personnel SECTION II: MRSI-NOTICE OF PRIVACY PRACTICES SECTION III: THE INTERNSHIP PROGRAM The Internship Program Goals Expectations for Interns Supervision Didactics Observational Learning/Technology-Assisted Consulting Administration of the Internship Evaluations Additional Educational Opportunities Vacation/Professional Leave What if Problems Arise? Frequently Asked Questions Evanston/Rocky Mountains Cornerstone s Staff Internship - POLICIES AND PROCEDURES Intern Recruitment/Public Disclosure Intern Selection Administrative and Financial Assistance Intern Rights and Responsibilities Intern Performance Evaluations Due Process and Grievance Procedure for Interns and Training Staff Outline of Internship Program Goals, Objectives, Competencies, and Activities Allocation of Intern Hours -4-
5 SECTION I PROGRAM QUALITY -5-
6 195 Feather Way Post Office Box 6005 Evanston, WY Telephone (307) Fax (307) I. NEEDS FOR SERVICE AREA SERVICE DELIVERY PLAN Cornerstone Behavioral Health (hereinafter Cornerstone ) is active in assessing the needs of the community by collecting and analyzing data from available resources. Examples include: Hearing Our Consumer Voice: The 2011 Consumer Survey; The 2010 Wyoming Prevention Needs Assessment: State of Wyoming Profile Report (WYSAC); and Wyoming s 2011 Youth Risk Behavior Survey. Our assessment of community needs is an ongoing process. Cornerstone collaborates with a wide variety of social service agencies by participating in regularly scheduled meetings, which keeps Cornerstone in touch with the needs of the community. In addition to conducting ongoing needs assessment with other agencies and referral sources, we regularly survey our clientele, which provides another way to assess community needs, to which we respond in a constructive fashion. For example, we survey our clientele during treatment, as part of the required attendance of Family Week activities, State mandated surveys, after discharge, in our follow-up surveys, client satisfaction surveys, and a suggestion box located in the lobby. Consequently, our needs assessment, which focuses on both prevention and treatment, is a continual process that spans agencies, including social service agencies and State agencies, referral sources, the legal system, and our clientele. This information is continually analyzed, and the analysis is integrated into the business practices of the organization. The input is used to help determine if the organization is: Meeting the current needs of the persons served and other stakeholders; offering services that are relevant to the persons served and other stakeholders; and identifying potential new opportunities for the growth and development of programs and services. For example, the need for adolescent substance abuse treatment has again been identified by the community. As a result, Cornerstone has implemented a full array of treatment programs specifically designed for adolescents to include the following: Minor in Possession School (MIP) - Early Intervention, ASAM 0.5 Level of Care; Adolescent Outpatient Treatment Program (AOP) - ASAM I Level of Care; Adolescent Intensive Outpatient Treatment (AIOP): Phase I (ASAM II Level of Care) and Phase II (Aftercare; ASAM I Level of Care). The services outlined below reflect the ongoing needs assessment and are updated as the needs of the community change. -6-
7 II. ABOUT CORNERSTONE BEHAVIORAL HEALTH Cornerstone Behavioral Health (hereinafter Cornerstone ) Wyoming's premier provider of nationally accredited outpatient mental health services and substance abuse treatment programs. Established in 1988, Cornerstone provides area residents with comprehensive, professional services in the comfort and privacy of a state of the art clinic located next to Evanston Regional Hospital. The professional staff at Cornerstone consists of a broad range of mental health providers, licensed psychologists, psychological interns, and board certified psychiatrists (via telehealth through Cheyenne Regional Medical Center). Cornerstone s outpatient treatment programs refer to a variety of services in the areas of mental health and substance abuse, which are designed to address the needs of the clients. Cornerstone offers a wide range of mental health services, including: Psychological testing and assessments, family and couples therapy, child and adolescent therapy, computerized testing for attention deficit hyperactivity disorder (ADHD), individual and group therapy, and telehealth psychiatry through Cheyenne Regional Medical Center. In the area of substance abuse services, Cornerstone offers substance abuse treatment programs that allow clients to remain with their families and at their jobs or school while receiving treatment. Substance abuse services include: Substance abuse evaluations, Cornerstone s long-standing and successful Intensive Outpatient Treatment Program (IOP-Phase I, IOP-Phase II), Outpatient Treatment Program (OP), DUI School, individual, couples and family therapy, drug testing, breathalysers, and prevention education; and Cornerstone s more recent Adolescent Programs that include Adolescent Intensive Outpatient Treatment Program (AIOP-Phase I, AIOP-Phase II), Adolescent Outpatient Treatment Program (AOP), and Minor in Possession School (MIP). Cornerstone accepts most insurance plans, including Medicare and Medicaid. All fiscal operations are in accordance with generally accepted accounting principles. As part of the Wyoming Department of Health, Behavioral Health Division Contract, Cornerstone will charge clients, who are served under the contact, according to the sliding fee scale adopted from the Wyoming Department of Health, Behavioral Health Division Sliding Fee Scale Guidance for Treatment Providers as set forth in The sliding fee scale shall be posted in the lobby and made available to persons seeking services provided by the contract. III. GOALS FOR CORNERSTONE BEHAVIORAL HEALTH Cornerstone Behavioral Health is committed to developing and implementing services for each client to meet the following goals: 1. Support the recovery, health and well-being of the persons or families served; 2. Enhance the quality of life of the persons served; 3. Reduce symptoms or needs and build resilience; 4. Restore and/or improve functioning; and, 5. Support the integration of the persons served into the community. -7-
8 IV GENERAL ADMISSION CRITERIA Cornerstone strives to provide the highest quality behavioral health and substance abuse services. The organization uses treatment interventions that are based on accepted practices in the field and incorporate current research and evidence-based practices. Unless otherwise stated, Cornerstone will accept individuals who: Are medically stable enough to be in an ambulatory setting versus an inpatient facility; Are financially able to accept and pay for services as billed with or without the assistance of medical insurance. However, as part of the Wyoming Department of Health, Behavioral Health Division - Block Grant, Cornerstone Behavioral Health will charge clients who are served under the contract, on a sliding fee scale adopted from the Wyoming Department of Health, Behavioral Health Division Sliding Fee Scale Guidance for Treatment Providers as set forth in Cornerstone may not refuse services to clients who are served under the contract due to the client s inability to pay. V SERVICE DELIVERY RANGE OF SERVICES Psychological Screening A psychological screening/assessment is the initial contact/interview with client. Information collected during this interview includes: Demographics, mental health history, medical history, social history, substance abuse history, legal history, occupational history, mental status, etc. The assessment results in the preparation of an interpretive summary that is: Based on the assessment data; used to formulate treatment needs and development of the individual plan; identify any co-occurring disabilities and/or disorders and how they will be addressed in the development of the individual plan; assess whether the individual has other needs that might be better met by alternative treatment or providers. Individual/Family/Couples Therapy Individual/Family/Couples Therapy is for those individuals who demonstrate a need for psychotherapy during the psychological screening. The therapist, with client input, will determine the form of psychotherapy that would best serve the client s needs. The client is seen individually if problems are primarily associated with his/her functioning or if family/significant others are unwilling to attend therapy. If problems are embedded within the couple s dyad or family system, those therapies are provided. Psychological Evaluation When a psychological screening does not provide conclusive information about an individual s problems, psychological testing is recommended to get a more complete understanding of the individual in order to facilitate treatment planning. -8-
9 Substance Abuse Evaluation and Intake Substance abuse services, including appropriate placement of clients and their continued stay, transfer, and discharge recommendations, are determined to the extent reasonably possible, through application of the current American Society of Addiction Medicine Patient Placement Criteria-Second Edition-Revised (ASAM PPC-2R; please see ASAM PPC-2R for additional information on ASAM criteria). A. Substance Abuse Evaluations (clinical interview plus testing, including ASI) are designated for new clients or clients without a current evaluation. A current evaluation may be one that has been completed within the past six months to one year, as long as the evaluation is a valid indicator of the client s current level of functioning. This evaluation is the initial contact/interview with the client. Information collected during this interview includes: Demographics, mental health history, medical history, social history, substance abuse history, legal history, occupational history, mental status, risk assessment, etc. The assessment results in the preparation of an interpretive summary that is: Based on the assessment data; used to formulate treatment needs and development of the individual plan; identify any co-occurring disabilities and/or disorders and how they will be addressed in the development of the individual plan; assess whether the individual has other needs that might be better met by alternative treatment or providers. If an urgent need for treatment is apparent, a client may be admitted to the treatment program until such time as a substance abuse evaluation can be conducted. A clinical interview/brief intake will be conducted to determine the need for detoxification and appropriate medical referral prior to admission. As the schedule permits, a substance abuse evaluation will be conducted with testing, including ASI, with appropriate referrals if needed. The substance abuse evaluations are designed to evaluate if the client has a substance abuse problem and to indicate which treatment modality, if one is needed, best serves his/her needs. In addition to the ASAM placement criteria and the ASI, the following testing instruments and protocols may be used in the evaluation/intake process, as indicated: AUP; SASSI-3; JASAE; PEI; SALCE; CIWA-AR; and, NEEDS Assessment Survey. In the case of the diagnoses of Substance Dependence or Abuse, per DSM-IV, treatment options include: Detoxification, residential/inpatient, intensive outpatient, outpatient or transitional services. When the evaluation indicates a sub-critical substance use problem that would be better served with a preventative treatment focus, modalities such as MIP or DUI School may be recommended. While Cornerstone does not provide services for all levels of care, clients are informed of treatment recommendations and of services available both at our agency and other agencies. -9-
10 B. Substance Abuse Intakes (Clinical Interview) are designed for individuals who have recently completed a treatment program, moved from another geographic area where they were receiving services, or had evaluations completed by another agency within the last six months. VI CORNERSTONE S SUBSTANCE ABUSE PROGRAMS General Information ASAM Criteria. Substance abuse services, including appropriate placement of clients, their continued stay, transfer, and discharge recommendations are determined, to the extent reasonably possible, by applying the American Society of Addiction Medicine Patient Placement Criteria-Second Edition-Revised (ASAM PPC-2R). The ASAM PPC- 2R is a guiding tool for determining placement, continued stay, and discharge of a client, spanning a broad range of intensity of care, from Early Intervention (Level 0.5, least intense level of care) to Medically Monitored/Managed Intensive Inpatient Treatment (Level III.7/IV, most intense level of care). Cornerstone provides adolescent and adult outpatient care that spans ASAM Levels of Care 0.5, I and II, with groups as the primary method and modality of care. Our MIP and DUI schools are Early Intervention, ASAM 0.5 Level of Care; our Outpatient Programs provide services at the ASAM I Level of Care; our Outpatient Aftercare Programs, which are Phase II of our Intensive Outpatient Program, provide ASAM I Level of Care; and, Phase I of our Intensive Outpatient Programs provide ASAM II Level of Care. Special Populations for Substance Abuse Services: Criminal Justice Clients: Cornerstone Behavioral Health will maintain certification from the Wyoming Department of Health, Behavioral Health Division to provide treatment to criminal offenders. For those clients that are involved in the criminal justice system, Cornerstone specifically addresses the person s criminal behavior(s) and thinking. Cornerstone shall comply with all court orders and cooperate with probation and parole agents in sharing information reasonably necessary for both to fulfill their obligations. Drug and alcohol testing will be conducted with offenders in coordination with the legal system overseeing the client. Where possible, Cornerstone shall use restorative justice principles in the individualized treatment plans of offenders. Clients are required to provide written consent in compliance with the 42CFR, Part 2 and 45CFR, Part 160 and 164, for the exchange of information between Cornerstone and the corrections system. This release per 42 CFR, Part 2, does not require an expiration of the release due to criminal justice status. If a client refuses to sign the release, Cornerstone may deny services. -10-
11 The clinical staff providing treatment to criminal justice offenders shall demonstrate training, education, and knowledge in the treatment of the criminal population. If the client fails to attend required treatment without permission as prescribed by the court, Cornerstone must notify the court or its representative within three (3) days of the client not showing. Cornerstone shall develop in collaboration with the court or its representative a case plan that identifies the roles and responsibilities of the client, program and court. In addition, a liaison from Cornerstone shall attend Uinta County Adolescent and/or Adult Drug Court staffing weekly. Cornerstone shall utilize referral sources in the areas of: housing, employment, mental health, education, and other services, as needed. Adolescent Treatment Services: Cornerstone Behavioral Health will maintain certification from the Wyoming Department of Health, Behavioral Health Division to provide treatment to adolescents. Adolescent services are provided for clients age 13 through 17. If the individual started the program prior to turning age 18, they may complete the program after they turn age 18. At a minimum, services shall include: Behavioral health services designed specifically to address the multifaceted needs of this population; in addition to general treatment requirements, Cornerstone shall tailor services to the particular safety, developmental, educational, healthcare, family needs, and preferences of children and adolescents. A discharge/transition plan shall be developed prior to the client being discharged and should include information addressing educational needs of the client and the transition of the client back into school, if applicable. Cornerstone shall comply with the program descriptions set forth in the ASAM Patient Placement Criteria Manual specifically relating to adolescent treatment services. Co-Occurring Treatment Services: Cornerstone Behavioral Health will maintain certification from the Wyoming Department of Health, Behavioral Health Division to provide treatment to co-occurring clients. At a minimum services shall: Address a high level of relapse potential with more intense levels of service; adapt program material and methods of counseling to individuals with mental disorders; provide and utilize skill building groups, as appropriate; provide case management, as necessary; emphasize motivation enhancement, including outreach for -11-
12 clients with active substance abuse disorders and severe mental disorders who are disengaged. SAMHSA TIP (Treatment Improvement Protocol) and Tap (Technical Assistance Publications Series): The manuals in the Treatment Improvement Protocol (TIP) and Technical Assistance Publication (TAP) series are best-practice guidelines for substance abuse treatment. The Division of Services Improvement at SAMHSA s Center for Substance Abuse Treatment (CSAT) draws on the experience and knowledge of clinical, research, and administrative experts to produce the manuals, which are distributed to facilities and individuals across the country. Cornerstone s treatment services are based in part on the SAMHSA s TIP/TAP series (i.e., the treatment services for the criminal justice population are based in part on the Substance Abuse and Mental Health Services Administration (SAMHSA) Treatment Improvement Protocol 44 (TIP) Series publication, Treatment of the Criminal Justice Client ; adolescent treatment services are based in part on the SAMHSA Treatment Protocol 32 (TIP) Series publication, Treatment of Adolescents with Substance Abuse Disorders ; and substance abuse services for individuals with co-occurring disorders are based in part on the SAMSHA Treatment Protocol 42 (TIP) Series publication, Substance Abuse Treatment with Co- Occurring Disorders. Signing Documents, Discharge, Grievance. To participate in treatment, clients must sign all required documentation, including but not limited to: Consent for Services, Financial Agreement, Group Rules, Policy on Abstinence, Group Therapy, Agreement to Attend, Disease (TB, STD, AIDS) Reporting Requirements, etc. Basis for discharge include, but are not limited to: Refusal to sign all required documents, violations that endanger self or others, violations that interfere with treatment, or for lack of progress. Discharge may result in referral to a more structured program. If a client is dissatisfied with one or more aspects of services/treatment received, the client may file a grievance as outlined in the Policy/Procedure Manual (Filing Grievance). Individual Psychotherapy: Treatment/Counseling/Consultation. Individual Psychotherapy Treatment, which is part of the Outpatient and Intensive Outpatient Treatment Programs, is tailored to the unique needs of the client, such as, but not limited to: Co-occurring diagnoses, grief and loss issues, crisis management, lack of satisfactory progress in completing program requirements, etc. The length and frequency of this intervention are determined on a case by case basis. DUI School (Early Intervention, ASAM 0.5 Level of Care) Program Description. Cornerstone s DUI School utilizes Hazelden s Who s Driving DUI Curriculum. In addition, the provider of these services has demonstrated the ability, through education and training, to provide the services required according to Rules and Regulations for Substance Abuse Standards Chapter 4, Section 10. Cornerstone s staff has completed the education curriculum developed by the Division. The DUI School is -12-
13 an eight hour program that Cornerstone offers six (6) times per year. DUI School educates the individual about the seriousness of driving under the influence. The School also provides a basic education of alcohol and drugs, related abuse issues and high risk behaviors connected with acquiring HIV and STD s. To complete the school successfully, clients must satisfy requirements, including but not limited to: Complete a post test with a score of 70% or above as a measure of acquired knowledge; and, develop a satisfactory personal action plan setting forth actions he/she will take to avoid violations in the future. The provider will determine if all requirements have been met. Who We Serve. DUI School is for adults, who are seeking education as a result of a court order and/or as required by the Department of Transportation. If a client has legal charges and/or is court ordered to attend a DUI School, an evaluation/assessment is required. The evaluation/assessment should include documentation of review of the record of blood alcohol level and driving record of the client. If Cornerstone did not complete the evaluation/assessment, a copy of the report including recommendations is required. If the evaluator recommends an educational modality, with the intention of preventing a more serious substance abuse problem, the client may attend the DUI School. If there are no legal charges and/or DUI school is not court ordered, an evaluation is not required to attend the DUI School. Any participant in the DUI School must be able to make use of this process, be motivated, not be a danger to self or others, and not interfere with delivery of the DUI School. MIP School (Early Intervention, ASAM 0.5 Level of Care) Program Description. Cornerstone s MIP School utilizes Prime for Life (PRI), which is a research-based curriculum addressing alcohol and other drugs. Cornerstone s staff has completed the training for the Prime For Life education curriculum. The MIP School is an eight hour program that Cornerstone offers up to six (6) times per year. The curriculum can also be lengthened, depending on the needs of those being served. The MIP School educates the individual about the seriousness of high risk behavior and substance use to help people reduce their risk for alcohol and drug problems throughout their lives. The curriculum's nonjudgmental approach tends to decrease resistance to the life-saving information presented in the program and to increase the students' openness to change. To complete the school successfully, clients must satisfy requirements, including but not limited to: Attendance for the duration of the School, satisfactorily completing a post test as a measure of acquired knowledge, and develop a satisfactory personal action plan setting forth actions he/she will take to avoid violations in the future. The provider will determine if all requirements have been met. Who We Serve. Our MIP School is for individuals who have not reached majority and are seeking education as a result of a court order and/or as required by the Department of -13-
14 Transportation. If a client has legal charges and/or is court ordered to attend a MIP School, an evaluation/assessment may be required as per Wyoming Law , Driving or having control of vehicle while under influence of intoxicating liquor or controlled substances. If an evaluation is required, the evaluation/assessment should include documentation of review of the record of blood alcohol level and driving record of the client. If Cornerstone did not complete the evaluation/assessment, a copy of the report including recommendations is required. If the evaluator recommends an educational modality, with the intention of preventing a more serious substance abuse problem, the client may attend the MIP School. If there are no legal charges and/or MIP school is not court ordered, an evaluation is not required to attend the MIP School. Any participant in the MIP School client must be able to make use of this process, be motivated, not be a danger to self or others, and not interfere with delivery of the MIP School. Outpatient Treatment Program-Adolescent (AOP) and Adult (OP) (ASAM I Level of Care): Program Description. AOP/OP consists of one two-hour group session a week, for a total of twelve (12) sessions, and various treatment program requirements. Group members must arrive 15 minutes before group begins to take care of finances and testing (urinalysis or breathalyzer). Prime Solutions is an evidence-based interactive treatment program that includes standardized treatment measures based on The Transtheoretical Model of Change. The outpatient treatment programs will focus on the Stages of Change, incorporating in-class activities as well as take-away experiential exercises to be completed at home. Who We Serve. AOP/OP is designed for adolescents and adults who meet criteria for ASAM I Level of Care and typically, have a substance abuse diagnosis, with no withdrawal, who are stable and able to make use of the group process, and whose needs are manageable in this program. OP Alumni (Optional): Upon successfully completing the program, clients are considered lifetime alumni and are welcome to participate in AOP/OP sessions, at no charge and as needed, as long as this continues to be the appropriate level of care and the therapist and group members consent. Intensive Outpatient Treatment-Adolescent (AIOP) and Adult (IOP): Phase I (ASAM II Level of Care): Adolescent Intensive Outpatient Treatment (AIOP) and Adult Intensive Outpatient Treatment (IOP). Our Intensive Outpatient Treatment Programs (AIOP/IOP) consists of two phases, Phase I and Phase II, both of which a client must complete successfully to graduate from Cornerstone s Intensive Outpatient Treatment Program (AIOP/IOP). -14-
15 AIOP/IOP-Phase I Program Description. Phase I consists of nine (9) hours of intensive group treatment per week for a minimum of 12 weeks for a total of 108 hours); a Family Week experience, and various treatment program requirements, including but not limited to completing the Prime Solutions treatment manual, regularly attending AA, NA or other support groups and regular sponsor contact, all of which must be satisfied to complete Phase I. The program must meet a minimum of three times per week with no more than three days between clinical services, excluding holidays. Upon completion of AIOP/ IOP-Phase I, the client graduates to Phase II, the Aftercare Program. Family Week consists of three nights, three hours per session, with various treatment program requirements. Family Week is for clients in the Intensive Outpatient Treatment Programs and their family members, significant others, and friends. Typically, the client completes Family Week during Phase I of the client s treatment program. Who We Serve. IOP-Phase I is designed for adults and AIOP-Phase I for adolescents who meet criteria for ASAM II.1 Level of Care, who typically have a diagnosis of substance abuse and/or dependence, who are able to make use of the group process, and whose needs are manageable in this program setting, e.g., not a danger to self or others, not a firmly entrenched antisocial personality disorder, not with mental health problems or other problems that would undermine or inhibit group process or the integrity of the treatment program. Intensive Outpatient Treatment-Adolescent (AIOP) and Adult (IOP): Phase II (Aftercare - ASAM I Level of Care): AIOP/IOP-Phase II (Aftercare). Phase II Aftercare for adults (IOP) consists of one twohour group session a week, for a minimum of 52 sessions; Phase II Aftercare for adolescent (AIOP) consists of one two-hour group session a week for a minimum of 26 sessions. In order to satisfactorily graduate from Phase II Aftercare, the client must complete various treatment program requirements, including but not limited to: Regularly attending AA, NA or other support groups and regular sponsor contact, and a required minimum of six months of continuous abstinence. Alumni (Optional) - AIOP/IOP-Phase III: Upon successful completion of AIOP/IOP- Phase II (Aftercare), clients are considered lifetime alumni and are welcome to participate in Aftercare sessions, designated Phase III, at no charge and as needed, as long as this continues to be the appropriate level of care and the therapist and group members consent. Who We Serve. AIOP/IOP-Phase II are for individuals who meet criteria for ASAM I Level of Care, who typically have a diagnosis of substance abuse and/or dependence, who are able to make use of the group process, and whose needs are manageable in this program setting, e.g., not a danger to self or others, not a firmly entrenched antisocial personality disorder or conduct disorder, not with mental health problems or other -15-
16 problems that would undermine or inhibit group process or the integrity of the treatment program. Clients attending the intensive outpatient treatment program Phase I, who successfully completed all the requirements of Phase I, may graduate to Phase II, the Aftercare Program. Furthermore, individuals who have successfully completed either an inpatient treatment program or intensive outpatient therapy for substance dependence or abuse elsewhere, and have maintained an appropriate period of sobriety following treatment may be considered for Phase II. Charges & Readmission for AIOP/IOP-Phase II: As part of the Wyoming Department of Health, Behavioral Health Division - Block Grant, Cornerstone Behavioral Health will charge clients who are served under the contract, on a sliding fee scale adopted from the Wyoming Department of Health, Behavioral Health Services Division Sliding Fee Scale Guidance for Treatment Providers as set forth in The sliding fee scale shall be posted in the lobby and made available to persons seeking substance abuse services. For clients served under this contract, Cornerstone may not refuse to offer or provide services due to the client s inability to pay. A client shall not be denied access to services for nonpayment without it being addressed as part of the treatment plan with a reasonable timeframe for resolution of the issue. However, services may be denied to clients who fail to address financial responsibilities as indicated in the treatment plan and refuse or are unwilling to pay their agreed upon fee. The following policy/procedure applies to only those individuals who completed Cornerstone s Intensive Outpatient Treatment Program-Phase I (AIOP/IOP). If a client relapses during AIOP/IOP-Phase II (Aftercare) and the Treatment Team determines the appropriate level of care is readmission to AIOP/IOP-Phase I, the following criteria are applied regarding cost: A. If the client is in good standing and has not received new legal charges, the client may return to AIOP/IOP-Phase I without new/additional charges for Phase I. When graduating to Phase II Aftercare, charges will resume. B. However, if the client receives new legal charges and is required and/or recommended to return to AIOP/IOP-Phase I, the new financial charges will be determined using a sliding fee scale based on household income and household size A Closer Look: Further Criteria for Admission and Participation in Treatment Programs In addition to criteria for program placement described earlier in this document, the following criteria and guidelines are used for placement, admission and participation in our treatment programs. -16-
17 Outpatient Treatment Program (AOP/OP) and Intensive Outpatient Treatment Program (AIOP/IOP) The client must: a. Be eighteen (18) years or older in the case of IOP or OP; b. Be thirteen (13) through seventeen (17) years of age in the case of AIOP of AOP. If the individual started the program prior to turning age 18, they may complete the program after they turn age 18. All possible admissions outside that age range will be assessed individually for appropriateness to the program; c. Not need detox services. Clients on methadone maintenance must be detoxed from methadone before admission; d. Agree to complete all treatment program requirements and to attend all sessions and appointments. Note: In the case of AIOP/AOP, Parents/Guardians/ Significant others will be asked to commit to being involved in the client s recovery process through Family Week, and possible conjoint therapy/ consultation and/or parenting classes. In the case of IOP, clients will be encouraged to involve their families, significant others and friends in the Family Week Experience; e. Agree to remain free from any mood altering substances, such as alcohol and illicit drugs. Addictive prescription medication will be reviewed; f. Agree, after signing releases, to obtain a letter from his/her physician if the client is on psycho-tropic medication and the therapist requests such a letter. The letter will state the appropriateness of the client for the program; g. Sign all appropriate documentation (described earlier in this document). A client may be deemed inappropriate for admission if a client: a. Failed two previous treatment experiences (inpatient, outpatient, or a combination of both); b. Demonstrates an inability or lack of desire to remain clean and sober; c. Has a current living situation that is considered too dysfunctional for the client to succeed in treatment; d. Is deemed by staff or medical personnel to be in need of ongoing medical attention during the treatment process; or, e. Is deemed inappropriate for group work. -17-
18 Consent for Services Whenever a client comes into Cornerstone, a completed and appropriately signed Consent for Services form will be maintained in the client file. No services will be performed without this Consent for Services form being completed and signed by the appropriate parties. Client Refusal to Sign Paperwork Whenever a client comes into Cornerstone, required documents must completed and appropriately signed (e.g., financial agreement, acknowledgment of privacy practices, consent for services, emergency treatment release, client rights, confidentiality, group rules, TB test agreement, etc.). No services will be performed without these documents being completed and signed by the appropriate parties. These documents will be maintained in the client file. Criteria for Admission/Re-Admission Cornerstone maximizes opportunities for the persons served to gain access to the organization s programs and services. Efforts are made to ensure that individuals who have the potential to benefit from services will be served. Need for behavioral health services will be determined through the screening/evaluation/intake procedure, with admission for treatment based on the client being diagnosed per the requirements of the Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM-IV) at admission with a disorder or with significant behavioral issues which are in need of treatment. The diagnosis will be determined by a clinician legally qualified to do so in accordance with all applicable laws and regulations. Clients who present with behavioral or substance abuse issues that do not fully meet the criteria necessary for a specific diagnosis, but which nevertheless results in significant impairment in functioning, are also considered candidates for treatment. Screenings/evaluations/intakes will be completed in a timely fashion. Information will be obtained from the client, family members/legal guardian (when applicable and permitted); and other appropriate and permitted collateral sources. This collateral information is obtained with the permission (signed release of information form) of the client unless a legal relationship indicated contact without permission. Individual and family services are based on the strengths, needs, abilities, preferences, desired outcomes, expectations, and cultural background of the person or family served. The intake process takes into account the individual s age, development, and education. Substance abuse services including appropriate placement of clients, and their continued stay, transfer, and discharge recommendations are determined to the extent reasonably possible, through application of the current ASAM client placement criteria. The ASAM PPC is a guiding tool for determining placement, continued stay, and discharge of a client. Refer to the ASAM PPC-2R for additional information. -18-
19 Re-admissions are considered on a case by case basis following the admission criteria. If a mental health client returns prior to six months post discharge, a new assessment is not required. Any significant changes in the client, or his/her status, major life issues, accomplishment of significant goals, hospitalizations, etc. will be documented in the re-admission progress note. However, if the absence has been longer than six months, a new screening and supporting documentation will be required. If a substance abuse client returns after being officially discharged, the re-admission will be considered on a case by case basis. However, if new legal charges are present, a new evaluation/assessment is required. Accessibility of Treatment If a person seeking substance abuse services is not able to be seen within 24 hours of the person s initial contact with the program (excluding weekends and holidays) the following options will be discussed with the individual: 1. Waiting list (if applicable). 2. Schedule appointment in first available time slot. 3. Referral to outside agency. 4. Schedule of Twelve (12) Step meetings in the community (if applicable) will be provided. 5. Individuals that are court ordered to receive substance abuse assessments/evaluations are scheduled on a first come/first serve basis. However, individuals who are requesting substance abuse services and are NOT involved with the legal system are scheduled to meet with a substance abuse counselor immediately to determine level of care needed. If an individual is deemed to be appropriate for either Outpatient Group or Intensive Outpatient Treatment, the individual will be admitted into the appropriate program immediately and scheduled for an assessment/evaluation as soon as possible. 6. If the client cannot be seen for an assessment and/or treatment within seventy-two (72) hours of the initial contact, the client will immediately be referred to an outside agency. 7. If an alternative provider is not available, Cornerstone will then engage the client in an appropriate level of care (group and/or individual) and/or will provide information relating to Twelve (12) Step Meetings in the community until such time treatment services are available. -19-
20 Developing a Waiting List Cornerstone s outpatient programs offer a variety of service modalities that are designed to assist individuals from the community to enhance their quality of life. Each clinician has a designated number of individual therapy hours available to provide services. If/when there are no available hours remaining, individuals who call will be informed that a waiting list has been implemented. Individuals are then taken/scheduled from the waiting list on a first come first served basis. For the substance abuse programs, priority is given to pregnant women and IV drug users. However, if the individual does not wish to be placed on the waiting list, the individual is informed of the other agencies in the area that provide like-services. If the individual caller indicates immediate services are needed/required, the individual is directed to call 911, go to the Evanston Regional Hospital Emergency Room, and/or call High Country Behavioral Health (the community mental health center responsible for crisis situations). Once a waiting list is implemented all contacts made to Cornerstone regarding screenings/intakes will be documented on the waiting list. 1. In the event a clinician whose areas of expertise are congruent with the needs of the client is unavailable, the person seeking services will be offered the option of placement on a waiting list. 2. The waiting list will indicate the name of the person seeking services, date o f placement on the list, symptom severity, age, preferences, identified need, or special needs and contact information. The administrative director will maintain the waiting list through ongoing review and updating of the list with regular input from the clinical director. 3. Documentation of any and all contacts with the person on the waiting list is maintained. 4. The waiting list information is obtained, analyzed and used in program planning, performance improvement activities, strategic or community based planning, organizational advocacy efforts, financial planning, and resource planning. 5. Individuals placed on the substance abuse waiting list are encouraged to attend A.A., N.A., etc. and are asked to check in with Cornerstone frequently. Order of Selection for Admission of Persons Awaiting Services Policy: Once a person is placed on a waiting list, services will be provided in a timely manner to persons who have the potential to benefit from the services. Procedure: 1. The waiting list will be reviewed and updated in the weekly Cornerstone staff meeting. -20-
21 2. The list will be rank ordered according to first come first served basis. 3. Staff psychologists will be informed by the administrative director of any appointments scheduled for persons on the waiting list. 4. Upon scheduling of the appointment, the client will be removed from the waiting list. Ineligible for Services Should it be the case that the Clinical Director and the professional staff at the Mental Health or Substance Abuse Staffing meeting find that an individual is ineligible for services at Cornerstone, it will be the presenting clinician s responsibility to inform the individual (and/or referral source, family/support system) of the finding and make an appropriate referral/recommendations for alternative services, if necessary. In the circumstance that an individual is ineligible for services provided by Cornerstone, a list will be initiated and maintained by the Administrative Director to determine trends and patterns of ineligibility as well as to guide planning for future services. Psychological Screening Every individual who wishes to receive mental health services from Cornerstone Behavioral Health, must have a psychological screening. This screening is performed by a qualified clinician and includes an interview (and testing, if applicable) with the person to be served and/or referral source to assess for the appropriateness of available services. Information may also be obtained from family members/legal guardian (when applicable and permitted); and other appropriate and permitted collateral sources. This collateral information is obtained with the permission (signed release of information form) of the client unless a legal relationship indicated contact without permission. The screening takes into account the individual s age, development, culture, and education (i.e., correct form, testing instruments, etc.). The assigned clinician gathers sufficient information during the screening to develop an individualized, person-centered plan with the active participation of the client, and will include, but is not limited to the following information: (1) Individualized goals and needs, if accepted for mental health services; (2) Strengths, abilities, preferences, aptitudes, skills, and interests of the individual; (3) Presenting problems; (4) Suicidal assessment; (5) History of previous behavioral health services, including diagnostic and treatment information, psychiatric/psychological assessments, pharmacotherapy, hospitalizations, alcohol and other drug services, co-occurring disabilities/disorders, and use of community programs; (6) Medical history and status; (7) Diagnosis(es); (8) Mental status; (9) Current emotional and behavioral functioning; (10) Social History, including current and historical life situation; (11) Use of alcohol, tobacco, and/or other drugs; (12) Educational History; (13) Legal History, etc. (refer to screening form). The screening results in the preparation of an interpretive summary that is: Based on the screening data; used to -21-
22 formulate treatment needs and development of the individual plan; identifies any co-occurring disabilities/ and/or disorders and how they will be addressed in the development of the individual plan; as well as to assess whether the individual has other needs that might be better met by alternative providers. The summary must be completed and, if applicable, distributed to appropriate individuals within fifteen (15) working days. Substance Abuse Evaluations Substance Abuse Evaluations (clinical interview plus testing, including ASI, ASAM Placement Criteria for the Treatment of Substance-Related Disorders and/or the Global Appraisal of Individual Needs-GAIN) are designated for new clients or clients who have not had a recent evaluation (six months to one year) that continues to be a valid indicator of the client s current level of functioning. This evaluation is performed by a qualified clinician and includes an interview (and testing, if applicable) with the person to be served and/or referral source to assess for the appropriateness of available services. Information may also be obtained from family members/legal guardian (when applicable and permitted); and other appropriate and permitted collateral sources. This collateral information is obtained with the permission (signed release of information form) of the client unless a legal relationship indicated contact without permission. The evaluation takes into account the individual s age, development, culture, and education (i.e., correct forms, testing instruments, etc.). The assigned clinician gathers sufficient information during the evaluation to develop an individualized, person-centered plan with the active participation of the client, and will include, but is not limited to the following information: (1) Individualized goals and needs; (2) Strengths, abilities, preferences, aptitudes, skills, and interests of the individual; (3) Presenting problems; (4) Suicidal assessment; (5) History of previous behavioral health services, including diagnostic and treatment information, psychiatric/psychological assessments, pharmacotherapy, hospitalizations, alcohol and other drug services, co-occurring disabilities/disorders, and use of community programs; (6) Medical history and status; (7) Diagnosis(es); (8) Mental status; (9) Current emotional and behavioral functioning; (10) Social History, including current and historical life situation; (11) Use of alcohol, tobacco, and/or other drugs; (12) Educational History; (13) Legal History, etc. (refer to evaluation form). The evaluation results in the preparation of an interpretive summary that is: Based on the assessment data; used to formulate treatment needs and development of the individual plan; identifies any co-occurring disabilities and/or disorders and how they will be addressed in the development of the individual plan; as well as to assess whether the individual has other needs that might be better met by alternative providers. The evaluation must be completed and distributed to appropriate individuals within fifteen (15) working days. Client Rights Cornerstone Behavioral Health strives to protect and promote the rights, privacy and confidentiality of all persons served. Cornerstone safeguards the rights of the persons served in a manner that is responsive to each person s age or developmental level, gender, social -22-
23 supports/preferences, cultural orientation/background, psychological characteristics, sexual orientation, physical condition, and spiritual beliefs. Cornerstone ensures that information and education are relevant to the needs of the persons served. Cornerstone communicates and shares the Client Rights in a manner that is clear and understandable to the client prior to the beginning of services and at least annually thereafter. The Client Rights are also posted in the lobby for review. If clarification is needed, the client may speak with their designated clinician. Cornerstone Behavioral Health ensures that the sharing of confidential billing, utilization, clinical, and other administrative and service-related information is done so according to confidentiality guidelines that recognize applicable regulatory requirements such as the federal rules for addiction treatment programs (42CFR) and HIPAA. The organization also ensures that the persons served are protected from abuse (physical, sexual, psychological, and fiduciary abuse); retaliation; harassment and physical punishment; and humiliating, threatening, or exploitive actions. Prior to the first meeting with one of Cornerstone s staff members, each client is given an outline of the policies relating to client rights which states, As a client of this center, you have the following rights: 1) To receive treatment regardless of sex, race, creed, ethnic origin, age, sexual preference, religion, socioeconomic status, handicaps, mental health/substance abuse disorder, or sources of financial support... The client also receives a client handbook that contains information such as client rights and responsibilities; grievance policy/procedure; Notice of Privacy Practices, hours of operation, confidentiality, follow-up policy/ procedure, financial information, after hours emergency contacts, familiarization with the premises; program policies and procedure regarding smoking, illicit or licit drugs brought into the program, policy on controlled substances at Cornerstone, etc. A client may request to examine and/or review the contents of their treatment records with their primary clinician unless clinically contraindicated. If a client s rights under this section are limited or denied because of clinical contradictions, such limitations of denial shall be fully documented in the client record. All client treatment records are the property of MRSI/Cornerstone and may not be removed from the premises. Each client receiving services will be informed of their rights which are as follows: 1. To receive treatment regardless of sex, race, creed, ethnic origin, age, sexual preference, religion, socioeconomic status, handicaps, mental health/substance abuse disorder, or sources of financial support; 2. To participate in the development of their treatment plan and goals that are reviewed and updated periodically, and to include significant others in treatment; -23-
24 3. Upon request, to examine and/or review their charts with their primary clinician unless clinically contraindicated; 4. The right to initiate a grievance and mechanism for requesting review of grievance; 5. Each client (or where appropriate, the client s legal guardian) shall be informed of his/her rights in a language the client understands. The information shall be presented to the client, both orally and in writing; 6. If a client s rights under this section are limited or denied because of clinical contradictions, such limitations or denial shall be fully documented in the client record; 7. Each client s confidentiality, personal dignity, and privacy shall be recognized and respected in provision of care and treatment, except where otherwise prohibited by law (see confidentiality). Confidentiality Each client receiving services at Cornerstone Behavioral Health will be informed of the policy regarding confidentiality. The confidentiality of client records maintained by this program is protected by Federal Law and Regulations. Cornerstone Behavioral Health ensures compliance with 42 CFR Part 2, 45 CFR Part 160 and 164, and other legal restrictions affecting confidentiality of alcohol, drug abuse, and other medical records. Generally, the program may not say to a person outside the program, that a client attends the program or disclose any information identifying behavioral health clients unless: 1. The client consents in writing, OR; 2. The disclosure is allowed by a court order after application showing good cause, OR; 3. The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation, OR; 4. The client commits a crime either at the program or against any person who works for the program, OR; 5. Citation of the Federal Law, OR; -24-
25 6. In the event of imminent life-threatening physical danger to the client or others. Violation of Federal Law and Regulations by a program is a crime. Suspected violations may be reported to the United States Attorney in the district where the violation occurs. Federal Laws and Regulations do not protect any information about a suspected child/adult abuse or neglect from being reported under State Law to appropriate State or local authorities. (See U.S.C ee-3 and 42 U.S.C. 290ff-3 for Federal Laws and 42CFR Part2 for Federal Regulations.) If the client is a moderate to heavy client of alcoholic beverages, or if they have ever used any type of IV drugs in the past, they are at a higher risk for contraction of tuberculosis and/or HIV/AIDS. The staff recommend such clients contact their personal physician or the local County Public Health unit for tuberculosis and/or HIV identification test. The local health unit is Uinta County Public Health 350 City View Drive, Suite 101 Evanston WY (307) Financial Agreement - Fee for Services Mountain Regional Services, Inc., d.b.a. Cornerstone Behavioral Health, is a non-profit organization, established to help people with mental health and substance abuse problems and to provide consultation and education to community organizations. All fiscal operations are in accordance with generally accepted accounting principles. Individuals receiving services at Cornerstone are expected to pay all insurance co-payments and deductibles at the time services are rendered. Clients who have no insurance are required to pay 100% for services rendered at each visit unless prior arrangements are made. Those individuals that have insurance that pays the insured directly (i.e., Blue Cross Blue Shield) are responsible for the entire fee at the time services are rendered. The client s insurance policy is a contract between them and their insurance company. Cornerstone is not a party to that contract. As a courtesy, this office will submit bills to insurance carriers. In order to facilitate claims processing, the client must provide all insurance policy information and changes to our office. If, as often is the case, the insurance company pays less than 100%, the client will be charged for the remainder. If payment is not received from the insurance company within 60 days, the client will be expected to pay the fee. It will then be their responsibility to pursue reimbursement from their insurance company. The fees charged at Cornerstone reflect the usual and customary rates in the area. The clients are responsible for payment regardless of any insurance company s arbitrary determination of usual and customary rates for services. The client s bill is their responsibility whether their insurance company pays or not. Medicaid/Equality Care recipients are responsible for a $2.45 co-pay for each visit; this copay does not apply to recipients under 21 years of age or pregnant women. After 60 days, there will be a finance charge of 1.5% per month (annual rate of 18%) charged to the client s account. -25-
26 The standard fee is charged for missed appointments, unless they are canceled at least 24 hours before the scheduled appointment, or if an emergency or extenuating circumstances prevent the client from making their appointment. Cancelled or missed appointments by Medicaid/Equality Care clients cannot be billed to Medicaid/Equality Care, therefore, the client (and/or parent/guardian) will be charged and responsible for missed appointment fees. The administrative director (or designee) will be responsible for communicating regularly with insurance companies to ensure coverage and obtain benefit information; maintaining preauthorization information and working with the clinician to provide necessary information for continued coverage; and keeping track of the clients account information to include copays, insurance payments, amounts due, etc. If the client fails to make the payments as required, the administrative director (or designee) will inform the clinician of the situation. The clinician will then speak with the client to determine what action(s) should be taken (i.e. payment plan, referrals to Department of Family Services, Department of Vocational Rehabilitation, etc.) to address funding issues. If it becomes necessary to discharge a client for non-payment, the client will be referred to the community mental health center which provides mental health services on a sliding fee scale based on household income. Delinquent accounts may be turned over to a professional collection agency or attorney for appropriate action. The client (and/or parent/guardian) will assume responsibility for all collection charges incurred, including but not limited to: Legal fees and court costs. In the event that working with an outside party/parties for collection becomes necessary, the client authorizes release of information necessary to obtain full payment of their account by signing the financial agreement. Sliding Fee Scale As part of the Wyoming Department of Health, Behavioral Health Division - Block Grant, Cornerstone Behavioral Health will charge clients who are served under the contract, on a sliding fee scale adopted from the Wyoming Department of Health, Behavioral Health Services Division Sliding Fee Scale Guidance for Treatment Providers as set forth in The sliding fee scale shall be posted in the lobby and made available to persons seeking substance abuse services. The sliding fee scale rates will not be applied to agencies, organizations or third party payors. For clients served under this contract, Cornerstone may not refuse to offer or provide services due to the client s inability to pay. A client shall not be denied access to services for nonpayment without it being addressed as part of the treatment plan with a reasonable time-frame for resolution of the issue. However, services may be denied to clients who fail to address financial responsibilities as indicated in the treatment plan and refuse or are unwilling to pay their agreed upon fee. -26-
27 At the time of admission clients served under the contract will sign a financial agreement outlining the policies/procedures with regard to the sliding fee scale. The financial agreement will indicate the discount (if applicable) based on the household income (client, spouse, significant other, etc.). Proof of income is required prior to signing the financial agreement. Failure to provide proof of income may result in the implementation of the maximum rate per program until such proof is provided and at which time a new financial agreement will be completed/signed. Once the client submits the proper documentation (i.e., check stubs for family members [self/spouse], previous tax returns, etc.), the sliding fee will be put into effect from that date forward. Financial agreements will not be backdated. If a client (and/or spouse, if applicable) are unemployed, they may both be required to sign an unemployment verification. The client (and/or spouse, if applicable) may be required to submit an unemployment verification each week to maintain the specified discount. If a client (and/or spouse, if applicable) fails to submit an unemployment verification during any week of treatment, the original financial agreement may be void and the client will not be eligible for the sliding fee scale discount. If the client s (and/or spouse, if applicable) employment circumstances change and/or they obtain medical insurance at anytime during treatment, they are required to notify Cornerstone promptly, at which time a new financial agreement will be signed and sliding fee scale discount adjusted according to the client s (and/or spouse, if applicable) current income. They are required to provide proof of income as indicated above. If the client does not follow through with their responsibility of notifying Cornerstone promptly of changes in employment or insurance, Cornerstone reserves the right to balance bill for back charges beginning the first date of their employment/insurance. If the child is a minor, the parents/guardians will be responsible for signing and providing proper documentation. In the event of a positive U/A test, the client and/or parent/guardian will be required to pay a fee to cover the cost of the laboratory testing. This fee is required at the time the service is provided. If the laboratory test results do not confirm the positive urinalysis results, the fee will be refunded. A fee is charged and payment required prior to beginning treatment for books and program materials. As part of the financial agreement, the client will be informed of the minimum weekly payment as determined by the sliding fee scale. Clients will also be informed that the discount will not be applied until insurance payments (if applicable) are received as the sliding fee scale rates are not applied to agencies, organizations, or third party payors as required by the State contract. In addition, if a client has insurance and medicaid, it is the client s (or parent/guardian, if applicable) responsibility to ensure that Cornerstone Behavioral Health receives the explanation of benefits (EOB) from the insurance company so that Medicaid be billed. If the client does not submit the appropriate EOB s in a timely manner, the client will be financially responsible for those dates not billed/paid by Medicaid. At the time of admission, clients served under the contract are informed that a minimum weekly payment is due EVERY WEEK, and they are instructed to call Cornerstone Behavioral Health and speak with the administrative director (or designee) if there are extenuating circumstances -27-
28 that prevents them from making their payment as agreed upon. Clients will be informed that payments made by their insurance company do not go towards their minimum weekly payment. Cornerstone Behavioral Health will not deny and/or refuse services to clients served under the contract due to inability to pay. A client shall not be denied access to services for non-payment without it being addressed as part of the treatment plan with a reasonable time frame for resolution of the issue. However, services may be denied to clients who refuse to pay their agreed upon fee and/or communicate extenuating circumstances as outlined above. Substance Abuse Quality of Life (QOL) Quality of Life (QOL) funds have been contracted to Cornerstone Behavioral Health for the purpose of supporting the basic clinical care provided to targeted and non-targeted substance abuse clients and for whom Cornerstone Behavioral Health has primary responsibility for the basic clinical care. Quality of life funds may be used for other populations if need can be demonstrated. The use of QOL funds by Cornerstone will be specific to each individual client whose needs, as identified in that client s treatment plan, require non-clinical supports and services in order to achieve the clinical outcomes of the client s treatment plan. QOL funds may not be used to pay for staff time unless the staff is a contracted provider for therapeutic foster care or respite care and is providing respite care for a client. Quality of life funds may be used for the following needs: a. Emergency Subsistence: (e.g. crisis shelter, food, clothing, essential personal supplies). b. Prescription Medication: (e.g. prescriptions for psycho-tropic and other medications). c. Health and Medical Supports: (e.g. lab, injections, medical supplies, health assessments, health and dental care, dentures, eyeglasses, and other health and dental devices). d. Housing: (e.g. acquisition, retention, safety). e. Transportation: (e.g. access to clinical services, medical, resources, development of recreation/socialization interests). f. Recreation/Socialization: (e.g. development of interests consistent with current income and long-term lifestyle). g. Respite Care: (Brief non-relative care from a trained provider for clients unable to care for themselves; provided because of the absence or need for relief of those persons -28-
29 normally providing care, in the client s home or place of residence, providers residence, or foster home). h. Other: (These will be itemized on the form, after case-by case approval has been obtained from the Administrator of the Mental Health and Substance Abuse Services Division). Client Orientation to Cornerstone Behavioral Health As soon as a client has been accepted for services at Cornerstone Behavioral Health, it will be the responsibility of the individual clinician to provide an orientation that is appropriate to the needs and type of services provided. The orientation which may include, but is not limited to: Ways in which input is given regarding the quality of care, achievement of outcomes and satisfaction of the client; services and activities; expectations; how individual plans are developed and the client s participation in it; etc. The client will also receive a client handbook that contains information such as Client Rights; Grievance Policy/Procedure; Notice of Privacy Practices, hours of operation, confidentiality, follow-up policy/procedure, financial information, after hours emergency contacts, familiarization with the premises; program policies and procedure regarding smoking, illicit or licit drugs brought into the program, policy on controlled substances at Cornerstone, etc. All orientation information should be presented by the designated clinician in a manner which is clear and understandable to the client. Coordinating Client Services In all cases, the clinician who conducted the psychological screening or substance abuse intake/evaluation, will be responsible for coordinating client services. The primary clinician will ensure that the services provided are coordinated and integrated and address goals that reflect the person s served informed choice; address emergent and ongoing issues; continuity of services; and decisions concerning the client. The individual who coordinates the services should: (1) Assume responsibility for developing and implementing the individual plan(s) and ensure the exchange of information regarding the plan; (2) Assist the person to become oriented to his/her services to include process for after hours contact/emergencies; (3) Enable the person s individual plan to proceed in an orderly, purposeful, and goal oriented manner; (4) Promote the program s responsiveness to the strengths, abilities, needs, preferences and expectations of the client; (5) Promote the participation of the client in an ongoing basis in discussions of his/her plans, goals, and status involving family members, when applicable and permitted; (6) Identify and address gaps in services and provide information relating to community resources relevant to client s needs; (7) Coordinate services provided outside of the organization, if applicable; (8) Participate and advocate consistently in team conferences concerning the client; (9) Facilitate the exit/discharge process and arrangements for follow-up and appropriate supportive services; (10) Communicate information regarding client s progress to appropriate persons including family, legal guardian, or primary care physician, when applicable and permitted. -29-
30 Filing Grievance Policy: On occasion, a client, may become dissatisfied with one or more aspects of services/treatment received. In most cases, a candid discussion with the client/client and the staff member involved may resolve the situation in a responsible and reasonable fashion. However, in some instances, additional action may be required. A document outlining the Grievance Procedure will be presented to each client upon admission to all programs offered at Cornerstone Behavioral Health. The client should read and sign the document which will be retained in the clients individual file. Questions regarding the grievance procedure may be discussed with the clinician during the orientation to Cornerstone Behavioral Health. A review of formal complaints is conducted annually to determine trends, areas needing performance improvement, and actions to be taken. Procedure: The following document will be read and signed by all clients admitted to Cornerstone. If you feel there is some impediment to your participation or that you have a legitimate grievance with the staff or other clients, a grievance procedure is available to you. The following grievance procedure is an upward process intended to promote and foster healthy conflict resolution and problem solving. The action of filing a grievance will not result in retaliation or barriers to services. At any point during the grievance proceeding(s), you may utilize counsel or other representation. An administrative record of all grievances is maintained for review by federal and state licensing and accreditation agencies. INFORMAL Step 1: In most cases, a candid discussion between the client and the staff member(s) involved may resolve the situation in a responsible and reasonable fashion. If the complaint is not resolved to your mutual satisfaction, you may proceed to Step 2. Step 2: You submit your complaint in writing to the next level of authority (staff member s supervisor). This should be done within ten working days after the completion of Step 1. Within five working days after receipt of the written complaint/problem, the next level of authority (staff member s supervisor) will review the complaint/problem, meet with the individuals involved to gather information and assist the parties in resolving the complaint/problem. If the complaint/problem is not resolved to your satisfaction at Step 2, you may consider accessing the Formal Grievance Procedure. FORMAL Step 1: Within ten working days of the informal procedure, you must submit your grievance to -30-
31 the clinical director (or designate) in writing, with copies to the person with whom you have a grievance. Within five working days, the clinical director (or designate) will review the grievance and interview individuals involved in the grievance. A resolution to the complaint/problem will then be issued in writing. If the complaint/problem is not resolved by Step 1, you may proceed to Step 2. Step 2: If the grievance is not resolved by Step 1, you may submit your grievance in writing to the president of Mountain Regional Services, Inc., d.b.a. Cornerstone Behavioral Health within five working days. Within five working days after receipt of the grievance, the president will review the information and call a meeting of all concerned to resolve the grievance. Other outside parties may be called upon in certain situations to appropriately represent members of minority or other advocacy groups. Within five working days, the president will notify all concerned in writing as to his decision/resolution. The decision/resolution of the president will be final. For clients participating in the substance abuse programs, if the client is not satisfied with the results of this process, the client may make a formal complaint in writing to the Division by writing to: Wyoming Department of Health Behavioral Health Division 6101 Yellowstone Road, Suite 220 Cheyenne, WY Initial and On-Going Assessment In the process of participating in any program(s) at Cornerstone, all clients are informed about the agency s commitment to non-discriminatory treatment of our clients (see Client Rights). The assessment (intake/evaluation/screening) is performed by a qualified clinician and includes an interview (and testing, if applicable) with the person to be served and/or referral source to assess for the appropriateness of available services. Information may also be obtained from family members/legal guardian (when applicable and permitted); and other appropriate and permitted collateral sources. This collateral information is obtained with the permission (signed release of information form) of the client unless a legal relationship indicated contact without permission. The assessments (screening/intake/evaluation) take into account the individual s age, development, culture, and education (i.e., correct form, testing instruments, etc.). The clinician identifies strengths, abilities, needs and preferences of the client as well as co-occurring disabilities and/or disorders, and how they will be addressed in the development of the individual treatment plan. In addition, the clinician addresses the client s desired outcomes and expectations and provides for the use of assistive technology or resources as needed. If the assessment identifies a potential risk for dangerous behaviors, a personal safety plan should be developed with the client as soon as possible after admission or identification of the potential risk. The safety plan should include the following: Triggers, current coping skills, warning signs, preferred interventions necessary for personal and public safety, and advance directives, when -31-
32 available. The treatment plan is developed with the active participation of the client and is updated as needed to meet the changing needs of the client. Cornerstone ensures that information and education are relevant to the needs of the persons served. All of these issues are addressed in an ongoing fashion and are documented in progress notes after each session with the client. The initial and ongoing assessment process focuses on the person s specific needs; identifies the goals and expectations of the client; is responsive to the changing needs of the client; and includes provisions for communicating the results of the assessments to: The client/legal guardian; applicable personnel; and others as appropriate; and provides the basis for legally required notification when applicable. Cornerstone staff need to update information gathered in the psychological screening and substance abuse intake/evaluation as necessary. Reassessments are necessary to ensure information, treatment strategies, and plans remain current. A reassessment may be indicated following significant change in the client, major life issues, accomplishment of significant goals, hospitalization, incarceration, referral to a court system or other legal issues, etc. If/when a reassessment is necessary the clinician will update the treatment plan as necessary and document in the client s file. It is the policy of Cornerstone Behavioral Health to review client records at least quarterly and modify treatment plan/services accordingly. Substance abuse services including appropriate placement of clients, and their continued stay, transfer, and discharge recommendations are determined to the extent reasonably possible, through application of the current ASAM client placement criteria. The ASAM PPC is a guiding tool for determining placement, continued stay, and discharge of a client. Refer to the ASAM PPC-2R for additional information. Client Duplicate Charts When the client at Cornerstone is also a developmentally disabled client of Mountain Regional Services, Inc., receiving Medicaid Waiver Funding, the primary client file will be maintained by Mountain Regional Services, Inc. If a file is maintained at Cornerstone on a client fitting this description, it will be classed as a secondary file and cannot be substituted for the main record. These files will be maintained in such a manner as to protect confidentiality. All original progress notes and other original documents must be kept in the primary file at Mountain Regional Services, Inc. A client of Cornerstone may have a mental health file as well as a substance abuse file which are maintained in their respective areas in locked filing cabinets and are maintained in such a manner as to protect confidentiality. Client Treatment Records Cornerstone maintains confidential treatment records for each client. These records include all intake information, releases, emergency treatment release, progress notes, etc. The company -32-
33 strives to protect the confidentiality of these records by storing them in a safe and secure place. Only authorized individuals will be permitted to view confidential records. Authorized individuals include the treatment provider(s)/team and administrative personnel. All documents generated by the organization that require signatures include original (or electronic) signatures. A client may request to examine and/or review the contents of their treatment records with their primary clinician unless clinically contraindicated. If a client s rights under this section are limited or denied because of clinical contradictions, such limitations or denial shall be fully documented in the client record. All client treatment records are the property of MRSI/Cornerstone and may not be removed from the premises. RETENTION AND DESTRUCTION: Mountain Regional Services has specific policies/ procedures relating to business records retention which comply with state and federal laws. It is the policy of Cornerstone to maintain client case records for a period of seven (7) years from the date of termination of treatment or services, except for minors whose records must be maintained until such time as the minor attains the age seven years beyond the age of majority. Clients participating in the substance abuse programs shall be asked to sign a statement at the time of intake acknowledging they have been informed of this policy. At the beginning of each year, those client treatment records that have exceeded the seven (7) year criteria will be destroyed by the administrative director (or designee). In the event a legal process is initiated against the organization, the destruction of records will be halted until such time as the legal process has been resolved. Time Frames for Making Entries Into Client Charts and Completing Reports If a Substance Abuse Evaluation or Psychological Evaluation is administered, the Cornerstone professional staff doing the evaluation has fifteen (15) working days to complete the report from the day the evaluation was initially conducted. Each designated clinician at Cornerstone Behavioral Health must document in the client s chart, the communication between themselves and the client (as well as collateral contacts) regarding the persons served treatment plan and discharge planning. Individual and/or group entries into a client chart will be completed in a timely fashion, and should be put into the record immediately after the session (progress notes should be signed and dated), but in no case later than 24 hours following the session. Individualized client plans are to be developed within the first two sessions following the initial Cornerstone assessment. Discharge planning should be initiated with the client at the earliest possible point in the individual planning and service delivery process; and take place no less than one month prior to -33-
34 the actual discharge, if possible. Discharge planning for persons with Coexisting/Co-Occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities should be part of the planning from the beginning to explore other available options/resources. Direct Involvement of the Client in the Decision Making Process The clinician should empower the client to openly/actively participate in therapy/ treatment and should provide information to the client in sufficient time to facilitate his/her decision making. The client should have significant involvement in the development of the treatment plan, periodic review and/or update of identified goals, and discharge planning. Evidence of the direct involvement of the client in the decision making process should be documented. In addition to the persons served signature on their individual plan, notation in the designated clinician case notes is also required. Attendance rosters of meetings as well as correspondence would also be a way to indicate the persons served involvement. In addition to the active participation of the client, the following individuals may contribute to the decision making process with the permission (signed release of information form) of the client unless a legal relationship indicated contact without permission: Family members, legally authorized representatives, referral source(s), and other community services when appropriate. This information will also be documented in the persons served record. Individual Plan for Client An individual plan should be developed in collaboration and active participation with each client and should involve the family/legal guardian of the client when applicable. The individual plan should be written and/or communicated in a manner that is clear and understandable to the client and to the individuals who are responsible for implementing the plan and be signed by the primary clinician, the client, and where appropriate, members of the persons served family or supportive persons. The individual plan should be developed by the designated clinician using the information collected in the initial screening/intake/evaluation and interpretive summary and specify the services to be provided by the program(s). The individual plan should include the following components and should ensure that information and education are relevant to the needs of the persons served. 1. Goals that are expressed in the words of the client; reflective of the informed choice of the client or parent/guardian; appropriate to the person s age and cultural and ethnicity variations, reflect the desired outcomes, expectations, strengths, abilities, needs, desires, and preferences. Where possible, the use of restorative justice principles shall be used in the individualized treatment plan of offenders. -34-
35 2. As all goals at this agency are fitted to the particular client, the time frame for a goal s applicability is determined on an individual basis and documented in the treatment plan of the client. 3. The measurable/achievable/time specific service or treatment objectives should reflect the results of the assessment and expectations of the client and treatment team; should be appropriate to the treatment setting, the person s age and development, education, and cooccurring disability/disorder/concerns; be reflective of the person s culture and ethnicity; and should reflect pro-social thinking, values and behavior. 4. Treatment team members should include an educational specialist, when applicable. 5. The plan should include specific treatment interventions, their frequency, and services to be provided by the program. The individual plan should also identify any needs beyond the scope of the program and appropriate referrals made and when applicable, information on or conditions for transition to other community services. The primary clinician shall provide for coordination and ongoing communication between internal and external service providers. 6. Each client plan should be developed within the first two sessions after admission to Cornerstone. When possible, a copy of the treatment plan should be provided to the client. 7. Each client plan will have measures to be used to assess the outcomes of the objectives. 8. The individual responsible for implementing the individualized plan will be the primary clinician, unless otherwise noted in the plan. 9. Each plan should be based on the needs and desires of the client and focus on the integration and inclusion of the client into the community, family when appropriate, natural support systems, or other needed services. 10. Clients who participate in the substance abuse programs shall not be denied access to services for non-payment without it being addressed as part of the treatment plan with a reasonable time-frame for resolution of the issue. However, services may be denied to clients who fail to address financial responsibilities as indicated in the treatment plan and refuse or are unwilling to pay their agreed upon fee. 11. For those clients receiving substance abuse services, Quality of Life (QOL) funds may be available if the need can be demonstrated by the individual. The primary clinician will meet with the client to discuss the needs, and if found to be appropriate, will include financial goals and objectives in the treatment plan. The use of QOL funds by Cornerstone will be specific to each individual client whose needs, as identified in that client s treatment plan, require non-clinical supports and services in order to achieve the clinical outcomes of the client s treatment plan. -35-
36 12. Each individual treatment plan should be reviewed periodically (at least quarterly) with the client and/or the treatment team for continuing relevance to the goal of integration and inclusion, review/maintain court orders, when applicable, and to modify goals, objectives, and interventions when necessary. 13. The review of treatment plans for individuals enrolled in IOP/AIOP occurs at a minimum of once per month. Substance abuse services including appropriate placement of clients, and their continued stay, transfer, and discharge recommendations are determined to the extent reasonably possible, through application of the current ASAM client placement criteria. 14. When modifications are needed, modifications to the plan will be made by the designated clinician, with the person s served input, within two weeks of the change being identified. These changes will be reported and discussed at the next Mental Health or Substance Abuse Staffing. 15. Reassessments should be conducted, when appropriate (i.e., significant change in the client, major life issues, accomplishment of significant goals, incarcerations, or referral to a court system, etc.). 16. Each plan should be coordinated with prior plans or other plans for services received by the individual at Cornerstone Behavioral Health, information on, or conditions for, inclusion/transitions to other services provided outside of the organization, as well as identification of legal requirements/imposed fees. 17. The individual plan should specifically identify individuals having co-occurring disabilities/disorders/concerns and specifically address those issues in an integrated manner. When applicable, medications will be integrated into the overall plan of the client. Services are provided by personnel, either within the organization or by referral, who are qualified to provide services for persons with co-occurring disabilities/disorders/concerns. 18. When applicable, a personal safety plan is completed with the client as soon as possible after admission, that identifies triggers, including assessment of risk for dangerous behaviors; current coping skills; warning signs; preferred interventions for personal and public safety, and psychiatric advance directives when available. 19. Progress toward achievement of service or treatment objectives for the client should be documented and communicated to the client. After each session a progress note shall be completed, signed, and dated. The progress note should document the identified goals and objectives that were achieved or revised during the reporting period, significant events or changes in the life of the client that may impact the course of treatment or services, the delivery and outcome of services and specific interventions that support the individual plan, changes in frequency of services, and movement to other levels of care if applicable. -36-
37 20. It is the policy of Cornerstone Behavioral Health that when changes to a person s served plan is made that the client be actively involved in making those changes, with the full knowledge of the client. These changes will be documented in the person s served file or chart. 21. When clinically indicated, discharge planning should be initiated with the client at the earliest possible point in the individual planning service delivery process. Discharge planning for persons with Coexisting/Co-Occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities should be part of the planning from the beginning to explore other available options/resources. Client Follow-Up Cornerstone Behavioral Health strives to provide individual, confidential and caring treatment for persons and families with behavioral health needs, improving their quality of life. Each client will be asked to participate in ongoing client satisfaction surveys and follow-up surveys as well as state mandated surveys to determine what they find/found helpful about the services they are currently receiving and/or received, what areas need improvement, how Cornerstone might continue to help them, overall quality of care received; achievement of outcomes, and overall satisfaction. They are invited and encouraged to add additional comments on the survey(s) if they would like to comment on any aspect of the services about which the survey(s) did not ask. There is also a suggestion box located in the front lobby. A consent for follow-up will be obtained from each client. After a client is discharged from treatment, the administrative director or his/her designee will immediately prepare and mail a client satisfaction survey. If an unplanned transition or discharge occurs, the primary clinician with the assistance of the administrative director (or designate) will be responsible for follow-up to determine with the client whether further services are needed and to offer or refer to needed services, when possible. If/when a client is discharged or removed from the program for aggressive/assaultive behavior, follow-up occurs (within 72 hours post discharge) to ensure appropriate care is obtained. Approximately three months post discharge a follow-up survey will be sent to determine the status of the client s progress. The administrative director will maintain and monitor information received and provide feedback to the president and/or clinical director for areas that need improvement as well as for program planning, performance improvement, strategic planning, organizational advocacy efforts, financial planning, and resource planning. This information is continually analyzed, and the analysis is integrated into the business practices of the organization. The input is used to help determine if the organization is: Meeting the current needs of the persons served and other stakeholders; offering services that are relevant to the persons served and other stakeholders; and identifying potential new opportunities for the growth and development of programs and services. -37-
38 Transition/Discharge Planning Transition (which may include continuing care [movement to a different level of service or intensity of contact such as from IOP to Aftercare] or placement on inactive status while a client attends an inpatient program) or discharge planning assists the persons served to move from one level of care to another within the organization or to obtain services that are needed but are not available at Cornerstone Behavioral Health based on the needs of the persons served in order to support ongoing recovery, treatment/service gains, or increased community inclusion. Substance abuse services including appropriate placement of clients, and their continued stay, transfer, and discharge recommendations are determined to the extent reasonably possible, through application of the current ASAM client placement criteria. When clinically indicated, transition/discharge planning should be initiated with the client at the earliest possible point in the individual planning service delivery process and no less than one month prior to the actual discharge. However, there may be times when the client leaves abruptly when discharge planning is not possible. For persons served with coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities these issues should be part of the planning from the beginning to explore other available options/resources. Cornerstone professionals will arrange a meeting with the client to develop a plan for posttreatment care. Using the initial diagnostic impression, progress during treatment, and gains achieved during program participation, input will be sought from the client in all aspects of developing a discharge plan. Areas of strengths and challenges will be jointly elicited by the Cornerstone professional and client, then discussed. a. Medical illnesses or physical handicaps will be considered for implications they may have on continued aftercare. b. Emotional, family, marital, relational, legal, environmental, financial, academic, and employment stressors and their impact on continued aftercare will be discussed. The person to be transitioned/discharged will complete assignments prior to a transition/discharge meeting with the Cornerstone professional. A written transition/discharge plan will be jointly developed and discussed in the transition/discharge planning session(s). Transition/Discharge Summary Plan The objective of the transition/discharge summary plan is to provide a systematic and comprehensive approach to assuring continuity of care to persons served being -38-
39 transitioned/discharged from programs at Cornerstone Behavioral Health. This carefully laid ground work will assist the individual to support ongoing recovery and treatment gains. Cornerstone is also attuned to possible concurrent problems the individual may have with emotional difficulties, relationship problems, marital or family distress, employment or academic problems, legal or financial concerns. The transition/discharge summary is a clinical document that includes information about the person s progress in recovery, describes the completion of goals, the efficacy of services provided, continuity of medication use (if applicable), and reasons for transition/discharge. This document is prepared when the person transitions or leaves services for any reason (graduation from program, against medical advice, no show, infringement of program rules, etc.). It is prepared to ensure a seamless transition/discharge to another level of care, another component of care (i.e., aftercare program), or community based support groups (i.e. A.A., N.A., etc.) and to maintain the continuity and coordination of needed services, determine with the client if further/additional services are needed, and offer to refer for needed services when appropriate. A detailed individualized transition/discharge plan will be constructed by the designated clinician and should always involve the client, and when appropriate and permitted, family members, legally authorized representatives, the referral source, educational specialist, and other community services, etc. These supportive services or groups will assist in relapse prevention. A copy of the transition/discharge plan of each client will be placed in the person s record. In addition, individuals who participate in the development of the transition/discharge plan receive copies, when appropriate. The Transition/Discharge plans need to include: 1. The date of admission and date of discharge. 2. The diagnosis or disability/disorder. 3. Description of the desired outcomes and expectations established and achieved. 4. Description of the services provided and the reason for transition/discharge. 5. Short-range goals and how they will be attained will be established for the first month. These will be written into the discharge plan. Longer-range goals for the third, sixth, and twelfth month will also be established and written into the discharge plan, if applicable. 6. Person s served with coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities which need ongoing services such as psychiatry and psychology will have the following arrangements: a. Psychiatry: The discharge plan should include information on the person s medication(s), when applicable. Arrangements will be made with the psychiatrist for continued medication management and/or an evaluation with the first appointment scheduled prior to discharge. b. Psychology: Arrangements will be made with the psychologist for continued individual and group therapy, and the first appointment scheduled prior to discharge. 7. All plans will contain some elements of the following details from the completed assignments. a. A statement of goals/needs to be achieved post discharge (e.g., 90 days
40 meetings); b. A listing of areas of strength, abilities, needs, desires, and preferences elicited from the client (e.g., dependable, trustworthy, sincere); as well as gains achieved during treatment participation. c. A listing of areas of challenges (e.g., don t like commitments); d. Written goals will include listing potential barriers to goal achievement (e.g., no transportation, no baby-sitter); e. Positive reinforcement statements should be included for achieving each goal. These statements will strengthen motivation (e.g., I will have coffee with friends after the meeting each night); f. Potential identified barriers to accomplishing discharge plan objectives will be addressed by writing a short statement about those barriers identified in (d) above, and how each will be dealt with as they come up (e.g., I will ask a friend for a ride; I will exchange an evening of baby-sitting with my neighbor). 8. All plans should contain recommendations to assist the person to maintain and/or improve functioning and increase independence. Linkages to external programs will be discussed with the client and referrals made as necessary. The primary clinician will provide for coordination and ongoing communication between internal and external service providers. These supportive services or groups will assist relapse prevention. They include, but are not limited to the following: Peer support groups, local advocacy groups; self-help groups, agencies/organizations, and classes: * Alcoholics Anonymous (AA) * Narcotics Anonymous (NA) * Alateen * Adult Children of Alcoholics * Alanon * Survivors of Domestic Abuse Programs * Singles with Parents * Family Planning * Vocational Rehabilitation * Parenting Classes * Assertiveness Training * Budgeting Finances * Educational needs; Academic Tutoring Arrangements * Youth Alternative Home Association (YAHA) * Youth Drug and Alcohol Court (YDAC) * Veteran s Services: George E. Wahlen Department of Veterans Affairs Medical Center in Salt Lake City, Utah -40-
41 Referrals of Needed Client Services Policy: Cornerstone Behavioral Health endeavors to make referrals based on the persons served needs. In addition to the services provided by Cornerstone Behavioral Health, the designated clinician will make available to the client a list of contacts/referral sources. A referral list for the region will be developed and maintained at Cornerstone Behavioral Health. When a client s needs cannot be fully addressed via the services provided by Cornerstone, additional referrals will be offered to the client from this list to ensure ongoing recovery and treatment gains. Whenever a client is referred to another agency for additional, concurrent services/ education, or discharge planning, the designated clinician will ensure that the persons served record shows: (1) The place, date and reason for referral. (2) The name of the contact person. (3) A report of the outcome placed in the persons served record. Procedure: 1. If the designated clinician and client determines a need for services outside of the scope of mental health or substance abuse (i.e. inpatient program, discharge planning) services provided by Cornerstone, appropriate referrals will be made. 2. The primary clinician will provide for coordination and ongoing communication between internal and external service providers. These supportive services or groups will assist relapse prevention. 3. The clinician (or designee) will obtain a release of information to a specific agency or individual prior to discussions regarding the client. The release of information will be maintained in the persons served file. 4. The following service providers are examples of possible referral sources. Information is released only to the extent that is pertinent to the situation and agency involved. a. Alcohol & other drug services: Cornerstone Behavioral Health Substance Abuse Program, Southwest Counseling Service, Volunteers of America b. Community housing programs: Evanston Housing Authority c. Vocational rehabilitation: Department of Vocational Rehabilitation d. Crisis intervention services: Evanston Regional Hospital, High County Behavioral Health e. Inpatient services: University of Utah Hospital or Columbia HCA Hospital in Salt Lake City, UT, WYSTAR in Sheridan, Wyoming -41-
42 f. Medical Services: Cathy Depalma, M.D., Ph.D., Ben Barraclough, M.D.; Dental, Dr. Lee Francis; Dr. McKay Francom g. Psycho-social rehabilitation: Columbia HCA Hospital in SLC h. Residential treatment: Wyoming State Hospital, Southwest Counseling, Volunteers of America i. Community supports: Ministerial or pastoral counseling j. Outpatient therapy services: Cornerstone Behavioral Health, Frontier Psychological Associates k. Psychological Services: Cornerstone Behavioral Health, Frontier Psychological Associates, High Country Behavioral Health l. Psychiatric Services: High County Behavioral Health, Cheyenne Regional Medical Center m. Income Maintenance: SSI, SSDI n. Social Protective Services; Medicaid/Medicare eligibilty; food stamps; case management services: Department of Family Services: o. Counseling, Testing and Referral for HIV, Hepatitis B and C and sexually transmitted infections; access to HIV hepatitis B and C, and sexually transmitted infections counseling, testing, referral, and partner notification protocol in cooperation with the Department of Health, etc: Uinta County Public Health: p. Veteran s Services: George E. Wahlen Department of Veterans Affairs Medical Center in Salt Lake City, Utah q. Legal entities for appropriate representation: Local attorneys; Legal Aid of Wyoming r. Legal Status: Wyoming Guardianship Corporation s. Children s Mental Health Waiver t. Self-help support groups; Advocacy support groups. A.A., N.A. -42-
43 Release of Information Whenever information and/or materials are released to, or requested from, other individuals or agencies identifying a client, such releases must be authorized by that person or a legal representative. Only the specific information requested by that individual or agency is to be released. An Authorization to Release and Obtain Information Form must always be completed and signed by the client or their legal representative before any information can be released. Each item checked ( ) to be released and/or obtained, must be accompanied by the initials of the client or their legal representative. Only information that is generated by Cornerstone Behavioral Health may be released, any other materials received from outside sources may not be released and should be sought directly from that source from those requesting such information. (Refer to MRSI s Notice of Privacy Practices) Obtaining Previous Diagnostic, Medical & Other Reports Prior to (or after) the initial screening or substance abuse evaluation, the designated clinician (or designee) will have the client sign An Authorization to Release and/or Obtain Information to obtain previous diagnostic, medical, treatment, and training reports that may affect the development of the individual treatment plan. These may be obtained from current or previous service providers, family members when appropriate, and/or referral sources. Whenever possible, these reports should be integrated into the assessment process. All collateral information obtained will be filed in the client s chart/file in the designated area. Coordination of Prevention, Treatment, and Transition/Discharge Planning Activities Policy: Cornerstone Behavioral Health endeavors to coordinate prevention, treatment, and discharge planning activities with the provision of other appropriate services which best address the needs of the client. Letters of coordination and cooperation and linkage agreements with allied agencies have been secured. Maintaining ongoing communication between internal and external service providers is important for the provision of optimal treatment for the client. Procedure: 1. Although service components utilized will vary depending on the needs of the client, during the course of treatment and transition/discharge planning the designated clinician will maintain regular communication via telephone, written correspondence, or direct contact with ancillary agencies involved in treatment and transition/discharge planning of the client. All communication between service components will be documented in the persons served chart. -43-
44 2. The designated clinician (or designee) will obtain an Authorization to Release and/or Obtain Information prior to specific discussions regarding the client. 3. The designated clinician will participate in regularly scheduled Cornerstone Substance Abuse case staffing meetings, Mental Health staffing meetings, meetings with probation and parole, Adult Drug Court, and the Youth Drug and Alcohol Court (YDAC), Children s Mental Health Waiver and community Multi-Disciplinary Team (MDT) to facilitate exchange of pertinent information. 4. The designated clinician will review weekly progress reports received from the residential treatment facility (YAHA); or if the child/adolescent is living at home, maintain contact with parents/guardians at least weekly. 5. All contacts outlined above will be documented in the treatment records of the client. 6 The following service providers are examples of possible ancillary external components which may be included in the treatment plan and transition/discharge planning, and would therefore, require regular contact by the Cornerstone professional to facilitate exchange of information in efforts to optimize treatment for the client. Information is released only to the extent that is pertinent to the situation and agency involved. a. Formal team meetings: Community MDT meetings b. Case management services: Department of Family Services c. Community housing programs: Evanston Housing Authority d. Educational/vocational programs: Local schools, Department of Vocational Rehabilitation e. Crisis intervention services: Evanston Regional Hospital or High Country Behavioral Health f. Inpatient treatment: University of Utah Hospital or Columbia HCA Hospital in Salt Lake City, UT, Southwest Counseling Services, Volunteers of American g. Partial hospitalization: Volunteers of America or Salt Lake County Youth Services h. Psycho-social rehabilitation: Sheridan House i. Residential treatment: Wyoming State Hospital, Youth Alternative Home Association, High Country Behavioral Health, Southwest Counseling Services, Volunteers of America -44-
45 j. Respite programs: First-Step House k. Community supports: Ministerial or pastoral counseling l. Employers: Employee assistance programs (EAP) m. Hospice: Evanston Regional Hospital n. Counseling, Testing and Referral for HIV, Hepatitis B and C and sexually transmitted infections: Uinta County Public Health o. Veteran s Services: George E. Wahlen Department of Veterans Affairs Medical Center in Salt Lake City, Utah p. Primary Care Physician or other applicable medical personnel q. Laboratory studies, tests, procedures, etc.: Evanston Regional Hospital r. Psychiatric Services: High Country Behavioral Health, Cheyenne Regional Medical Center s. Specialized Funding: Children s Mental Health Waiver Medication Use and Storage of Pharmaceutical Samples Cornerstone Behavioral Health does not provide Medication Use (previously pharmacotherapy) services. Psychiatric Advance Directives Policy Individuals have the right to make decisions concerning their health care, including the right to accept or refuse medical or surgical treatment, and the right to formulate Advance Directives, as permitted under State law. No individual shall be discriminated against, or have care conditioned on whether the individual has executed any Advance Directives. Procedures A. Upon admission, the client and/or guardian will be asked if they have any Advance Directives. If the client indicates that they do have Advanced Directives, a copy will be requested, and noted in the client s file. -45-
46 B. In the event that the client does not have any Advance Directives, but would like additional information; he/she will be provided with appropriate contact information and/or documents. Special Needs Policy: Cornerstone Behavioral Health programs seek to respond to special needs and special subpopulations of the persons served by providing information, education, transition/discharge planning and referral if needed. Whenever special needs arise the designated clinician and administrative staff will accommodate, wherever possible, the needs of the person(s) served. Procedure: The following areas are designated specifically: A) High-Risk Behaviors. Behaviors in this category are those behaviors which present an imminent threat to self or others, e.g., I.V. drug use, unprotected sex, status HIV positive or TB positive. 1. Counseling and education will be provided by Cornerstone professional staff about HIV; the risks of needle sharing; the risks of transmission to sexual partners and infants; and the steps that can be taken to ensure that HIV transmission does not occur. 2. Individuals involved in the substance abuse programs will be required to sign an agreement indicating they agree to be tested for T.B. while in the Cornerstone Treatment Program. If individuals refuse to sign the agreement and/or fail to follow through with the testing and/or treatment, they will be discharged from the program. 3. If indicated, a referral to appropriate agencies or providers will be made by Cornerstone professionals (i.e., Veteran s Services: George E. Wahlen Department of Veterans Affairs Medical Center in Salt Lake City, Utah) B) Obstetric and gynecological needs: 1. Preference will be granted to each pregnant woman who seeks or is referred for and would benefit from services; by moving such persons to the top of the waiting list, if any, for services. 2. Cornerstone professionals will provide education regarding pregnancy and substance use. -46-
47 3. Cornerstone professionals will obtain signed release of information from the client to their doctor. 4. Cornerstone professionals will contact the physician to obtain or provide such information as indicated to facilitate response to the treatment needs of the client. 5. If the pregnant woman does not have a physician, Cornerstone professionals will make an appropriate referral. If the woman should have other gynecological needs, the same procedure would be followed. C) Seniors: A senior citizen will be identified by Cornerstone staff as any person over the age of sixty-five (65). 1. Persons over 65 years of age will be referred for a physical exam prior to entering substance abuse treatment. 2. An Authorization to Release and/or Obtain Information will be obtained from the client for their physician. 3. Educational materials will be designed in order to accommodate visual or auditory limitations of this population. 4. Education will be provided by Cornerstone professionals regarding the potential dangers of substance abuse and prescription drug interactions. D) Adolescents: An adolescent will be defined by Cornerstone staff as any person under the age of eighteen (18). 1. A parent/legal guardian will be required to sign all necessary documentation. 2. In the incidence of medical, behavioral, or monetary need, the adolescents parent/legal guardian will be contacted for resolution of the matter. 3. In the incidence of observed or reported physical, sexual, emotional abuse or neglect, the Cornerstone professional will, as required by law, make a formal report to the Department of Family Services. A second contact to the parent/legal guardian will be made to notify them of the report. 4. Mental health and substance abuse services will be offered after school hours to facilitate attendance. 5. Assessments (screening/intake/evaluation) take into account the individual s age, development, culture, and education (i.e., correct form, -47-
48 testing instruments, etc.). 6. Educational materials used for adolescents will be age appropriate. 7. Based on the needs of the children/adolescents served, Cornerstone includes the development of: Community living skills; social skills; social supports; vocational skills. If the agency is unable to provide such services, an appropriate referral will be made. E) Coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/ conditions and/or intellectual disabilities: 1. Individuals seeking services at Cornerstone who also knowingly (or determined through assessment) have coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities will be encouraged to obtain written approval from their treating physician, psychologist, or psychiatrist, if applicable. 2. Those clients will also need to sign a release of information to their doctor. 3. The treatment plan should address how services will be provided in a manner that ensures the safety of the client. 4. Educational materials will be designed to fit the special needs of individuals with coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities. 5.. If the needs of the client at any time change or become beyond the scope of treatment by the Cornerstone counselors, the client will be referred to the appropriate agency for services (i.e., Veteran s Services: George E. Wahlen Department of Veterans Affairs Medical Center in Salt Lake City, Utah) 6. Transition/discharge planning for individuals with coexisting/co-occurring medical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities should be part of the planning from the beginning to explore other available options/resources. 7. If applicable, the legal guardian will be required to sign all necessary documentation (i.e. consent for services, financial agreement, emergency treatment release, authorization to release/obtain information, etc.). A copy of the legal guardianship documentation will be maintained in the client's file. -48-
49 F) Specific cultural needs: 1. Individuals with specific cultural needs will be seen/treated at Cornerstone according to their needs. If the needs of the client cannot be met by the Cornerstone staff, an appropriate referral will be made to an agency that can provide said services, e.g., if the client speaks Spanish as their only language, and there is not a Spanish speaking professional, the client will be referred to an agency that can provide that service. All contacts outlined above will be documented in the treatment records of the client. Use of Special Treatment Intervention Cornerstone mental health and substance abuse professionals use interventions that are within the standard of care for their professions, and if used, are individually applied based on the specific needs of the clients and as determined safe and effective. Cornerstone does not place restrictions on the privileges or rights of clients, nor will any event, behavior, or attitude lead to the loss of rights or privileges for the client. Clients are asked to sign an Emergency Treatment Release for medical/psychiatric emergency treatment, should pursuit of such treatment become necessary at any time. The Emergency Treatment Release is signed prior to the initial screening and remains in effect throughout the individual s treatment. The Emergency Treatment Release contains information about the person to contact in the event of an emergency, including the name, address, and telephone number. The Emergency Treatment Release also contains information about the individual s primary care physician, including the name, address, and telephone number, when available. Crisis Intervention Policy: Cornerstone Behavioral Health programs do not provide direct crisis services to the clients served. Its crisis intervention process operates on a referral basis. In working with individuals who have mental health problems and/or alcohol or other drug abuse and dependence, Cornerstone recognizes the potential for self or other injurious behavior, vulnerability to abuse, intoxication, and medical emergencies. It is the goal of Cornerstone to promote the safety and well being of those individuals involved in the treatment program(s). All psychology staff are certified in Nonviolent Crisis Intervention and Applied Physical Training to ensure staff have the skills to safely and effectively respond to anxious, hostile, or violent behavior while balancing the responsibilities of care. Appropriate referrals will be made by the designated clinician for individuals considered a danger to self or others, in abusive situations, and where medically necessary. In some cases, e.g., suicidality, homicidality, or abuse of vulnerable adults or children, reporting is mandated. -49-
50 Procedure: The following situations are considered crisis situations which will be intervened upon and referral or report made: 1. Individuals at risk for suicidality will be referred to the community mental health center s on-call crisis-intervention person for assessment. a. In cases of imminent danger to self, the on-call crisis-intervention person will be summoned to assess the individual. In such cases, Cornerstone staff will stay with the at-risk person at all times until the on-call person arrives. b. In cases where imminence is severe, a 911 telephone call may be necessary and the individual may require hospitalization. In such cases, Cornerstone staff will stay with the imminent risk person at all times for their safety. 2. Individuals at risk for homicidality will be referred to the community mental health center s on-call crisis intervention person and an assessment made of risk factors and imminence of danger. 3. With vulnerable adults in abusive situations, such as the elderly or the developmentally disabled, the Department of Family Services and/or Sexual Assault and Family Violence Task Force for Vulnerable Adults will be contacted and efforts made to remove the individual from the abusive situation and place them in a safe environment. 4. Abusive situations involving children, may be uncovered in a number of scenarios. In all cases every effort will be made to ensure the safety of each child. a. In situations where abuse of a child/children is strongly suspected, the Cornerstone staff will report such suspicions to the Department of Family Services for investigation. b. In situations where abuse of a child is revealed by an adult, the Department of Family Services will be notified. c. In situations where a child discloses that (s)he is the recipient of abuse, the child will be held in a safe environment and the Department of Family Services will be contacted and the child will be placed in a sheltered situation. 5. Battered women or men will be referred to the Department of Family Services, Domestic Abuse Intervention Program, or Sexual Assault and Family Violence- SAFV-House for their safety. 6. Medical emergencies will be assisted through the 911 number. Upon admission to -50-
51 Cornerstone Behavioral Health Programs, an Emergency Treatment Release will be signed by participants. 7. Detoxification is considered a medical emergency and individual s demonstrating such need will be assisted through 911 or referred directly to the hospital emergency room for assessment and treatment. a. If the individual is alert, coherent, and logical in response to questions, they may be referred to the hospital emergency room. b. If the individual is not alert, or is incoherent, illogical, bizarre in thought content expressed, seizing, or unresponsive, the 911 telephone number should be called immediately. 8. Threatening, explosive or assaultive individuals will be turned over for custody to the police department. All contacts outlined above will be documented in the treatment records of the client. Quality Assurance Records Review It is the policy of Cornerstone Behavioral Health to review client case records after the initial assessment and on an ongoing basis to monitor the quality, thoroughness, continuing relevance, appropriateness, and utilization of the services provided. The staff members objectively review and suggest alternative program or service strategies to the team member(s) responsible for establishing and carrying out the clients s individual plan. After the initial review, reviews will be conducted at least quarterly and will address: (1) The quality of service delivery as evidenced by the record of the client; (2) Appropriateness of services; (3) Patterns of service utilization; (4) When applicable, persons served received services that reflect billing. The quarterly reviews are conducted by personnel who are trained and qualified. The mental health case records review committee must be attended by at least two individuals (one of which must be a licensed psychologist) to ensure that a staff member is not the sole reviewer of the services for which he/she is responsible. The substance abuse staffing committee must be attended by at least two individuals to ensure that a staff member is not the sole reviewer of the services for which he/she is responsible. The quarterly reviews will be assigned in a systematic way from a representative sample of current/closed records utilizing a quality records review form and/or Quarterly Multi Disciplinary Staffing and Treatment Plan Review Form which contains the necessary required information to standardize the case records and provide the necessary documentation to best plan for the client s needs. The information collected will be distributed to the applicable personnel and will be used to identify training needs and improve the quality of services provided. Substance abuse services including appropriate placement of clients, and their continued stay, transfer, and discharge recommendations are determined to the extent reasonably possible, through application of the current ASAM client placement criteria. The ASAM PPC is a guiding tool for determining placement, continued stay, and discharge of a client. -51-
52 Medicaid Quality Assurance Plan Peer Utilization/Quality Assurance Review Committee Completeness/Records Review Critical Incident Review I. Peer Utilization/Quality Assurance Review Committee A. Purpose: 1. Peer Utilization/Quality Assurance Review is carried out to accomplish the following goals: a. Review, at a minimum, a sample of 10 percent of all open Medicaid cases at least annually. The cases selected shall represent at least one open Medicaid case of every clinical staff member and shall represent a proportionate share of Medicaid substance abuse cases. b. Determine whether sufficient justification for planned treatment is present, including support for DSM-IV diagnosis. c. Assess whether treatment provided is appropriate to resolve the presenting problem. The review also serves as peer assessment of the clinical assessment, treatment plans, client s progress, and treatment necessity. d. Ensure that each client is receiving no more and no less of the length of service(s) necessary to resolve the presenting problem. e. Document the results of all client record reviews, including the date, committee members present and absent, client numbers of the charts reviewed, a summary of overall findings for that type of review, and recommendation for corrective action by the provider, as well as the signature of the chairperson. The results will be kept in a file separate from the clinical record. f. Ensure that no clinician reviews a client in which that individual is the primary or co-therapist. B. Committee Assignments: 1. The reviews are conducted by personnel who are trained and qualified. The committee must be attended by at least two clinical staff to ensure that a staff member is not the sole reviewer of the services for which he/she is responsible as well as the Administrative Director (or designate). 2. Chairperson: a. The Administrative Director ( or designate) will be the Chairperson. b. The Chairperson s responsibilities include: i. Maintain statistics on number of charts reviewed, number of charts returned, and error patterns. ii. Mediate and review any complaints regarding Peer Utilization/Quality Assurance Review. iii. Generate an annual report with findings and make recommendations to management staff for the improvement of services and corrections of deficiencies with documentation of necessary follow-up. iv. Submit and/or make available the annual Peer Utilization/Quality Assurance -52-
53 II. Review report to the appropriate agencies/individuals. This report should be written to maintain client confidentiality. 3. Schedule: a. Annual Schedule of Peer Utilization/Quality Assurance Reviews i. The annual schedule is developed in December for the next calendar year. 4. Timelines: a. Corrections are to be made and charts returned within seven (7) business days. Completeness Review A. Purpose 1. Ensure that clinical/client records meet the requirements of the Medicaid Manual. 2. Completeness reviews are conducted to ensure all of the required documentation and signatures required for admission are completed and in the chart. B. Procedures 1. Completeness reviews are conducted on every admission during the data entry process. C. Timelines 1. Corrections are to be made and charts returned within two (2) business days. III. Critical Incident Review A. Purpose 1. The professional review of incidents which involve, at a minimum, actual injury to clients or actual injury to staff or others by clients. B. Critical Incidents Requiring Review 1. Client attempted or completed suicide. 2 Client attempted or completed homicide or serious injury 3. Any client death. C. Critical Incident Reporting Procedures 1. Any incident listed on the MRSI/Cornerstone Behavioral Health s Critical Incidents Requiring Review list which occurs and comes to the attention of MRSI/Cornerstone Behavioral Health s staff will be documented on the Incident Report Form. 2. An Incident Report Form must be filled out and submitted to the Clinical Director (or designate) within 24 hours. 3. The Clinical Director (or designate) will notify Wyoming Department of Health- Mental Health and Substance Abuse Services by the close of business the next working day after the Clinical Director (or designate) learns of the event. 4. The Clinical Director (or designate) will submit a written report to the Division of Mental Health and Substance Abuse Services within five working days of the event. 5. The report will include the following information: a. Complete statement of the facts. b. Action taken to address and resolve the matter, if any necessary. c. Copies of any related reports filed with any licensing, certification, or law enforcement agency. 6. The critical incident will be reviewed in the next Cornerstone Meeting to address issues raised by the incident. -53-
54 Weapons and Violence The Company is concerned with providing clients and employees a safe and productive environment. As such, the Company strictly prohibits the possession or use of any and all weapons, including handguns on Company premises by a client, employee, vendor, or other visitor, whether licensed or unlicenced and whether concealed or visible, unless the individual has a valid concealed weapons permit from the proper governmental authority. The Company premises not only include the main facilities, but also entrances and exits, break areas, parking lots, vehicles and pathways. Company employees are further prohibited from the possession or use of any and all weapons while conducting business on behalf of the Company away from company premises. Employees aware of a client or another employee possessing a weapon while on company property or on a company function must immediately report it to their supervisor. If the supervisor has a weapon or is unavailable, the employee should report this to the Human Resource Department or any department director as soon as possible. Clients or employees who are threatened, witness, or overhear a threat of bodily harm must immediately report it to a supervisor. If a supervisor made the threat or is unavailable, the employee should report it to the Human Resource Department or any department director as soon as possible. If a client or employee receives a threat away from company property even though not within the course of company business, such a threat should be reported if you believe it may be carried out on company property or during company business. As determined by the Company, any client or employee possessing a weapon or responsible for threats or violence, is subject to discharge from the program, and/or corrective action, up to and including termination of employment. This policy was adopted from the MRSI/Cornerstone Employee Guidelines. If a client is discharged from the program for violation of this policy, the primary clinician with the assistance of the administrative director (or designate) will be responsible for follow-up to determine with the client whether further services are needed and to offer or refer to needed services, when possible. Nonviolent Practices It is the policy of Cornerstone Behavioral Health that no seclusion, restraints, or intrusive procedures be used at anytime during the course of treatment. In a situation of threatening, aggressive, or assaultive individuals, emergency personnel should be contacted immediately by calling 911. Emergency intervention will then be conducted by emergency personnel/police department. -54-
55 Smoking & Smokeless Tobacco Use MRSI/Cornerstone Behavioral Health is officially a smoke-free/tobacco-free facility. Smoking, chewing, or the sale of tobacco products is strictly prohibited in owned or rented buildings with the exception of designated areas at each location. Failure to adhere to this guideline is a serious offense and may result in discharge from the program. Butts must be deposited in provided receptacles. Abstinence Abstinence is the primary goal of Cornerstone Behavioral Health Substance Abuse programs, unless contraindicated by the assessed special needs of the clients. Clients must agree to remain abstinent from all mood altering drugs/alcohol including prescription medication. In order to assure ongoing abstinence, the clients are tested frequently and at random. Individuals will be randomly selected each week for testing. The individual urinalysis tests are FDA cleared and have a multi-drug screening device with a built-in timer for error-proof testing. The client and/or parent/guardian will not be responsible for the cost of the random urinalysis unless or until follow-up testing is done, at the discretion of the clinician, which typically occurs when the urinalysis test result is positive. In the event of a positive test, the client and/or parent/guardian will be required to pay a fee to cover the cost of the laboratory testing. This fee is required at the time the service is provided. If the laboratory test results do not confirm the positive urinalysis results, the fee will be refunded. If a client is unable to provide an urine sample, they will be tested using the Oral Alert Saliva Tests. The client and/or guardian will be responsible for the cost of the Oral Alert Saliva test as well as any confirmation costs which will be added to their account. The chain of custody for urinalysis tests are as follows: 1. The clinician (or designee) will personally observe clients void into a collection bottle except where the collector and the client are not of the same sex or where it is virtually impossible to collect an observed specimen. (For unobserved specimens, an adulteration panel test may be requested.) 2. The clinician will follow the directions of the urinalysis tests. Testing will be completed in the presence of the client. If the test has a negative result, the specimen will be discarded. 3. For those tests that read positive, the urine sample is sent to Redwood Toxicology for confirmation. The urine sample will be transferred into the specimen bottle supplied by Redwood Toxicology. The specimen bottle will be placed in the specimen bag with appropriate labels, identifying information, and security labels then sent to the lab. If -55-
56 appropriate chain of custody labels are not affixed the test will be determined to be invalid by Redwood Toxicology. Tests are confirmed via GC/MS. 4. When applicable, the supervising/referring agency (Probation & Parole, Drug Court, courts, etc.) are notified when positive tests are confirmed by Redwood Toxicology. Alcohol and/or Other Drugs and Psychiatric Disabilities The use of alcohol and/or other drugs and their interactions with the client s psychiatric disabilities/disorders should be addressed by the designated clinician at the initial screening, in the individual plan, progress reports, and transition/discharge planning. Clients participating in any substance abuse program offered at Cornerstone Behavioral Health must agree to remain abstinent from all mood altering drugs/alcohol to include prescription medications (refer to policy on Abstinence). A client may be discharged from any substance abuse program as a result of taking prescribed medication which is contraindicated in the client s success at remaining abstinent from all mood altering chemicals. Controlled Substances at Cornerstone Cornerstone Behavioral Health seeks to provide a safe, comfortable, drug-free, and effective treatment environment. In the event a client disrupts the treatment setting by bringing a controlled substance into the program area, the following procedures will be followed. 1. Upon intake, each client will sign a contract to abstain from use of and not to be in possession of any illicit drugs. Adolescents (persons under 18 years old) additionally will sign a contract agreeing not to use or bring tobacco onto the treatment premises. 2. Discovery of possession or use of any illicit substance during the course of treatment will: a. Be considered a violation of the core rules of the program. b. Necessitate re-evaluation of appropriateness of the particular treatment program for that individual. 3. The Evanston Police Department will be contacted and requested to come to the scene. a. Upon police arrival, the person in possession will be asked to go to the counselor s office in order to protect the confidentiality of the other group members. b. The police will handle any search or seizure of the substance. The statement given by the counselor will be strictly limited to the minimal facts necessary to explain the discovery of the alleged illicit substance. -56-
57 Child/Adolescent Being Suspended From School While in AIOP or Aftercare Policy: Cornerstone Behavioral Health values continuity of education for child/adolescents. Whenever a client by our programs is suspended, efforts will be made to facilitate reintegration. Procedure: 1. Cornerstone professionals will provide a weekly report on progress of the client via telephone, written communication, or direct contact to agencies involved, e.g., school counselor, court, parents/guardians, DFS, etc. 2. Cornerstone professionals will participate in regularly scheduled meetings of the Youth Drug and Alcohol Court (YDAC), and community Multi-Disciplinary Team (MDT) to facilitate exchange of pertinent information. 3. Cornerstone professionals will review weekly progress reports received from the residential treatment facility; or if the child/adolescent is living at home, maintain contact with parents/guardians at least weekly. 4. All contacts outlined above will be documented in the treatment records of the client. Recruitment and Retention Plan for Psychologists It is our goal and plan at Mountain Regional Services, Inc. to recruit and retain the highest quality psychologists to work in our rural culture with our underserved populations. To achieve this goal when we have positions available, we actively advertise and recruit, thoroughly interview and assess qualifications of applicants, promote the assets of our site, and provide plentiful information about the job details to help applicants make the most informed decision. Once hired, our keys to retention include competitive salaries, opportunities for professional development, small town quality of life, beautiful natural surroundings, and easy access to many area attractions (urban and rural). Recruitment 1. National and regional advertising American Psychological Association Monitor National Health Service Corps Job Opportunities web page Casper Star Tribune University of Wyoming and University of Utah Job Boards Wyoming Workforce Services Local radio advertising -57-
58 2. Recruit directly from our American Psychological Association-accredited predoctoral internship in clinical psychology ( Homegrown Recruitment ). 3. Thorough interview process (less applicable for our homegrown recruits who already went through internship interview and have already been working with us) Review initial application and credentials, licensing verification, letters of recommendation Initial telephone interview Select promising candidates for in-person interview conducted at our expense including airfare, lodging, rental car, food, with the intention of demonstrating professional respect for applicants and to ensure that no one is disqualified on the basis of financial hardship. Interviews include formal interviewing with staff group using standardized questions plus additional less structured interviews with individual staff members; facility and community tours; contact personal and professional references Criminal and professional background checks (including NPDB and HIPDB as applicable) 4. Provide and promote detailed information about our site including: (for homegrown recruitment, this process usually occurs at the internship interview phase) Populations served Collaborative professional teams Typical work days Assets of the job and community Importance of interest and/or experience in a rural setting. Opportunities for professional growth, training, development, and supervision Our beautiful high desert, mountain setting with access to spectacular outdoor scenery and adventures and small town quality of life. Area attractions including Yellowstone, Grand Teton, and Arches National Parks, the Sundance Film Festival, urban amenities in Salt Lake City and Park City, Utah Retention Competitive salary Staff development, training, and supervision Small town quality of life Beautiful rural surroundings Assessment of recruitment and retention plan outcome data as part of our APA accreditation Staff Training One time per week, all Cornerstone Behavioral Health psychology staff, will meet for staff training. Topics for the training will be selected by the Clinical Director or his/her designee. These trainings will serve to assure that clinicians at the agency possess the fundamentals necessary to work as a team with a somewhat uniform knowledge base as well as the attainment -58-
59 of additional skills for clients who have more than one disability or disorder. It is the licensee or certificate holder s responsibility to obtain continuing education credits/units required to maintain license/certification as outlined by each discipline s rules and regulations. The staff should complete competency based training/continuing education related to services provided as well as the population served. Some examples of these trainings may include: Cultural competency; expectations regarding professional conduct; ethics; individual plan development; interviewing skills to help identify special needs; program-related research-based treatment approaches; test administration and interpretation; client rights; person and family centered service; the prevention of workplace violence; contributing factors or causes of threatening behavior, including training on recovery and trauma-informed services and the use of personal safety plans; trauma assessment and management; the ability to recognize precursors that may lead to aggressive behavior; how interpersonal interactions, including how personnel interact with each other and with the persons served, may impact the behaviors of the clients; medical conditions that may contribute to aggressive behavior; the use of a continuum of alternative interventions; the prevention of threatening behaviors; recovery/wellness oriented relationship and practices; how to handle a crisis without restraints, in a supportive and respectful manner; confidentiality requirements; reporting of critical incident and adverse events; basic life support; and emerging trends and best practices. Specialists within Cornerstone in one field may be used to cross train other staff members in that specialty. In addition, all psychology staff will be certified in Nonviolent Crisis Intervention and Applied Physical Training (CPI specialized offerings) to ensure staff have the skills to safely and effectively respond to anxious, hostile, or violent behavior while balancing the responsibilities of care. Supervision of Direct Service Personnel The Clinical Director provides and/or makes arrangements for the provision of ongoing supervision of direct service personnel. Provision of this supervision will be in keeping with the basic publications of the American Psychological Association; the American Psychological Association s National Guidelines for delivery of psychological services as well as the state requirements of the Wyoming Board of Psychologists. In addition, the Clinical Director shall provide oversight and performance evaluation of clinical staff in the core competencies as identified in the most current TAP 21-A-Competencies for Substance Abuse Treatment Clinical Supervisors published by SAMSHA. The Clinical Director also provides and/or makes arrangements for the provision of direct clinical supervision as deemed appropriate and/or necessary by him/her to ensure that all work performed meets acceptable standards of the profession for those engaged in substance abuse counseling or rehabilitation. The ongoing supervision addresses, when applicable, the following: Cultural competency issues; accuracy of assessment and referral skills; appropriateness of the treatment or service intervention selected relative to the specific needs of each client; treatment/service effectiveness as reflected by the client meeting his or her individual goals; the provision of feedback that enhances the skills of direct service staff personnel; issues of professional standards/conduct, ethics, and legal aspects of clinical practice; clinical documentation issues identified through ongoing compliance review. -59-
60 The Clinical Director (or designee) provides feedback and conducts annual performance evaluations for all directly supervised clinical staff as part of an ongoing process of supervision that provides direct and periodic observation and documentation of events involving service delivery. The performance evaluation includes assessment of professional competencies and clinical skills and recommendations for improvement. -60-
61 SECTION II NOTICE OF PRIVACY PRACTICES -61-
62 Mountain Regional Services Inc. (MRSI) Also dba Cornerstone Behavioral Health NOTICE OF PRIVACY PRACTICES Effective: April 14, 2003 Amended: February 1, 2006 Amended: April 1, 2011 THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION PLEASE REVIEW IT CAREFULLY This notice will tell you how we may use and disclose protected health information about you. Protected health information means any health information about you that identifies you or for which there is a reasonable basis to believe the information can be used to identify you. This notice also will tell you about your rights and our duties with respect to protected health information about you. In addition, it will tell you how to complain to us if you believe we have violated your privacy rights. How We May Use and Disclose Protected Health Information About You. We use and disclose protected health information about you for a number of different purposes. Each of those purposes is described below. For Treatment (45 CFR (b)(1)(ii)(a) We may use protected health information about you to provide, coordinate or manage your health care and related services by both us and other health care providers. We may disclose protected health information about you to doctors, nurses, hospitals and other health facilities who become involved in your care. We may consult with other health care providers concerning you and as part of the consultation share your protected health information with them. Similarly, we may refer you to another health care provider and as part of the referral share protected health information about you with that provider. For example, we may conclude you need to receive services from a physician with a particular specialty. When we refer you to that physician, we also will contact that physician s office and provide protected health information about you to them so they have information they need to provide services for you. For Payment. (45 CFR (b)(1)(ii)(a) We may use and disclose protected health information about you so we can be paid for the services we provide to you. This can include billing you, your insurance company, or a third party payer. For example, we may need to give your insurance company information about the health care services we provide to you so your insurance company will pay us for those services or reimburse you for amounts you have paid. We also may need to provide your insurance company or a government program, such as Medicare or Medicaid, with information about your medical condition and the health care you need to receive to obtain and determine if you are covered by that insurance or program. -62-
63 For Health Care Operations. (45 CFR (b) (1) (ii) (A) We may use and disclose protected health information about you for our own health care operations. These are necessary for us to operate MRSI and to maintain quality health care for our patients. For example, we may use protected health information about you to review the services we provide and the performance of our employees in caring for you. We may disclose protected health information about you to train our staff and students working with MRSI. We may also use the information to study ways to more efficiently manage our organization. How we will contact you. Unless you tell us otherwise in writing, we may contact you by either telephone or by mail at either your home or your office. At either location, we may leave messages for you on the answering machine or voice mail. If you want to request that we communicate to you in a certain way or at a certain location, see A Right to Receive Confidential Communications on page five of this Notice. Appointment Reminders. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you to remind you of an appointment you have with us. Treatment Alternatives. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you about treatment alternatives that may be of interest to you. Health Related Benefits and Services. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you about health related benefits and services that may be of interest to you. Individuals Involved in Your Care. (45 CFR (b) We may disclose to a family member, other relative, a close personal friend, or any other person identified by you, protected health information about you that is directly relevant to that person s involvement with your care or payment related to your care. We also may use or disclose protected health information about you to notify, or assist in notifying, those persons of your location, general condition, or death. If there is a family member, other relative, or close personal friend that you do not want us to disclose protected health information about you, please notify or tell our staff member who is providing care to you. Personal Representatives. (45 CFR (g)(1) In general, MRSI must treat a personal representative as the individual with respect to protected health information under the Privacy Rule unless an exception applies. Personal representatives are those people who, under applicable law, have the authority to act on behalf of an individual in making health care decisions for the individual. Types of Personal Representatives 1. Persons who have broad authority to act on the behalf of a living individual in making -63-
64 health care decisions. The covered entity must treat this type of personal representative as the individual for all purposes under the Privacy Rule, unless an exception applies. Example: A parent with respect to a minor child or a legal guardian of a mentally incompetent adult. 2. Persons who have the authority to act on behalf of a living individual in only limited health care situations. The covered entity should only treat this type of personal representative as the individual under the Privacy Rule with respect to protected health information related to the limited health care situation for which the personal representative has authority to act. Example: A person has an individual s limited health care power of attorney only regarding the individual s use of artificial life support. In this example, the covered entity should only treat the personal representative as the individual, under the Privacy Rule, with respect to protected health information relevant to the use of artificial life support, and not for other health care decisions. 3. Persons who have the authority to act on behalf of a deceased individual or his/her estate, which does not have to include the authority to make decisions related to health care. Example: A person may be the executor of an individual s estate - in such a case, the covered entity must treat this type of personal representative as the individual for all purposes under the Privacy Rule. Exceptions to the General Rule 1. The Privacy Rule specifies three circumstances in which the parent, guardian, or other person acting in loco parentis (parent) is not the personal representative with respect to certain health information about his or her unemancipated minor child. In these situations, the parent does not control the unemancipated minor s health care decisions and, thus, under the Privacy Rule, does not control the protected health information related to that care. The three exceptional circumstances when a parent is not the unemancipated minor s personal representative are: a. When State or other law does not require the consent of a parent or other person before a minor can obtain a particular health care service, and the minor consents to the health care service. Example: A State law provides an adolescent the right to obtain mental health treatment without the consent of his or her parent, and the adolescent has consented to such treatment without the parent s consent. b. When a court determines or other law authorizes someone other than the parent to make treatment decisions for a minor. Example: A court may grant authority to make health care decision(s) for the minor to an adult other than the parent or to the minor, or the court may make the decision(s) itself. c. When a parent agrees to a confidential relationship between the minor and the physician. Example: A physician asks the parent of a 16-year-old if the physician can talk with the child confidentially about a medical condition and the parent agrees. -64-
65 Important Note: Even in these three exceptional circumstances in which the parent is not the personal representative of the minor under the Privacy Rule and is not treated as the individual under the Privacy Rule, the Privacy Rule permits the covered entity to disclose to a parent, or provide the parent access to, an unemancipated minor s protected health information, if there is State of other law that requires or permits such disclosure or access. Likewise, even in these three exceptional circumstances, the Privacy Rule permits the covered entity to refuse to disclose to a parent, or refuse to provide the parent access to, an unemancipated minor s protected health information, if there is State or other law that prohibits such disclosure or access. Further, in these three exceptional circumstances, if State or other law is silent or unclear concerning parental access to the minor s protected health information, the Privacy Rule permits a covered entity to have discretion to provide or deny a parent with access to the unemancipated minor s protected health information, if doing so is consistent with State or other applicable law, and provided the decision is made by a licensed health care professional in the exercise of professional judgment. 2. When a physician or other covered entity reasonably believes that an individual, including an unemancipated minor, has been or may be subjected to domestic violence, abuse or neglect by the personal representative, or that treating a person as an individual s personal representative could endanger the individual, the covered entity may choose not to treat that person as the individual s personal representative, if in the exercise of professional judgment, doing so would not be in the best interests of the individual. Disaster Relief. (45 CFR (b) (4) We may use or disclose protected health information about you to a public or private entity authorized by law or by its charter to assist in disaster relief efforts. This will be done to coordinate with those entities in notifying a family member, other relative, close personal friend, or other person identified by you of your location, general condition or death. Required by Law. (45 CFR (a) We may use or disclose protected health information about you when we are required to do so by law. Public Health Activities. (45 CFR (b) We may disclose protected health information about you for public health activities and purposes. This includes reporting medical information to a public health authority that is authorized by law to collect or receive the information for purposes of preventing or controlling disease. Or, one that is authorized to receive reports of child abuse and neglect. Victims of Abuse, Neglect or Domestic Violence. (45 CFR We may disclose protected health information about you to a government authority authorized by law to receive reports of abuse, neglect, or domestic violence, if we believe you are a victim of abuse, neglect, or domestic violence. This will occur to the extent the disclosure is: (a) required by law; (b) agreed to by you; or,(c) authorized by law and we believe the disclosure is necessary to prevent serious harm to you or to other potential victims, or, if you are incapacitated and certain other conditions are met, a law enforcement or other public official represents that immediate enforcement activity depends on the disclosure. Health Oversight Activities. (45 CFR (d) We may disclose protected health information about you to a health oversight agency for -65-
66 activities authorized by law, including audits, investigations, inspections, licensure or disciplinary actions. These and similar types of activities are necessary for appropriate oversight of the health care system, government benefit programs, and entities subject to various government regulations. Judicial and Administrative Proceedings. (45 CFR (e) We may disclose protected health information about you in the course of any judicial or administrative proceeding in response to an order of the court or administrative tribunal. We also may disclose protected health information about you in response to a subpoena, discovery request, or other legal process but only if efforts have been made to tell you about the request or to obtain an order protecting the information to be disclosed. Disclosures for Law Enforcement Purposes. (45 CFR (f) We may disclose protected health information about you to a law enforcement official for law enforcement purposes: a. As required by law. b. In response to a court, grand jury or administrative order, warrant or subpoena. c. To identify or locate a suspect, fugitive, material witness or missing person. d. About an actual or suspected victim of a crime and that person agrees to the disclosure. If we are unable to obtain that person s agreement, in limited circumstances, the information may still be disclosed. e. To alert law enforcement officials to a death if we suspect the death may have resulted from criminal conduct. f. About crimes that occur at our facility. g. To report a crime in emergency circumstances. Coroners and Medical Examiners. (45 CFR (g) (1) We may disclose protected health information about you to a coroner or medical examiner for purposes such as identifying a deceased person and determining cause of death. Funeral Directors. (45 CFR (g)(2) We may disclose protected health information about you to funeral directors as necessary for them to carry out their duties. Organ, Eye or Tissue Donation. (45 CFR (h) To facilitate organ, eye or tissue donation and transplantation, we may disclose protected health information about you to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue. Research. (45 CFR (I) Under certain circumstances, we may use or disclose protected health information about you for research. Before we disclose protected health information for research, the research will have been approved through an approval process that evaluates the needs of the research project with your needs for privacy of your protected health information. We may, however, disclose protected health information about you to a person who is preparing to conduct research to permit them to prepare for the project, but no protected health information will leave MRSI during that person s review of the information. -66-
67 To Avert Serious Threat to Health or Safety. (45 CFR )(j) We may use or disclose protected health information about you if we believe the use or disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public. We also may release information about you if we believe the disclosure is necessary for law enforcement authorities to identify or apprehend an individual who admitted participation in a violent crime or who is an escapee from a correctional institution or from lawful custody. Military. (45 CFR (k) (1) If you are a member of the Armed Forces, we may use and disclose protected health information about you for activities deemed necessary by the appropriate military command authorities to assure the proper execution of the military mission. We may also release information about foreign military personnel to the appropriate foreign military authority for the same purposes. National Security and Intelligence. (45 CFR (k)(2) We may disclose protected health information about you to authorized federal officials for the conduct of intelligence, counter-intelligence, and other national security activities authorized by law. Protective Services for the President. (45 CFR (k) (3) We may disclose protected health information about you to authorized federal officials so they can provide protection to the President of the United States, certain other federal officials, or foreign heads of state. Inmates; Persons in Custody. (45 CFR (k) (5) We may disclose protected health information about you to a correctional institution or law enforcement official having custody of you. The disclosure will be made if the disclosure is necessary: (a) to provide health care to you; (b) for the health and safety of others; or, (c) the safety, security and good order of the correctional institution. Workers Compensation. (45 CFR (l) We may disclose protected health information about you to the extent necessary to comply with workers compensation and similar laws that provide benefits for work-related injuries or illness without regard to fault. Other Uses and Disclosures. Other uses and disclosures will be made only with your written authorization. You may revoke such an authorization at any time by notifying MRSI, P.O. Box 6005, Evanston, WY 82931, in writing of your desire to revoke it. However, if you revoke such an authorization, it will not have any effect on actions taken by us in reliance on it. Your Rights With Respect to Medical Information About You. You have the following rights with respect to protected health information that we maintain about you. -67-
68 Right to Request Restrictions. (45 CFR (b) (iv) (A); 45 CFR (a) (1) You have the right to request that we restrict the uses or disclosures of protected health information about you to carry out treatment, payment, or health care operations. You also have the right to request that we restrict the uses or disclosures we make to: (a) a family member, other relative, a close personal friend or any other person identified by you; or, (b) for public or private entities for disaster relief efforts. For example, you could ask that we not disclose protected health information about you to your brother or sister. To request a restriction, you may do so at the time you complete your consent form or at any time after that. If you request a restriction after that time, you should do so in writing to MRSI P.O. Box 6005, Evanston, WY 82931, and tell us: (a) what information you want to limit; (b) whether you want to limit use or disclosure or both; and, (c) to whom you want the limits to apply (for example, disclosures to your spouse). We are not required to agree to any requested restriction. However, if we do agree, we will follow that restriction unless the information is needed to provide emergency treatment. Even if we agree to a restriction, either you or we can later terminate the restriction. Right to Receive Confidential Communications. (45 CFR (b) (iv) (B); 45 CFR (b)(1) You have the right to request that we communicate protected health information about you to you in a certain way or at a certain location. For example, you can ask that we only contact you by mail or at work. We will not require you to tell us why you are asking for the confidential communication. If you want to request confidential communication, you must do so in writing to President, MRSI P.O. Box 6005, Evanston, WY Your request must state how or where you can be contacted. We will accommodate your request. However, we may, when appropriate, require information from you concerning how payment will be handled. Right to Inspect and Obtain a Copy. (45 CFR (b) (iv) (C); 45 CFR ) With a few very limited exceptions, such as psychotherapy notes, you have the right to inspect and obtain a copy of protected health information about you. To inspect or obtain a copy of protected health information about you, you must submit your request in writing to President, MRSI, P.O. Box 6005, Evanston, WY Your request should state specifically what protected health information you want to inspect or obtain a copy. If you request a copy of the information, we may charge a fee for the costs of copying and, if you ask that it be mailed to you, the cost of mailing. We will act on your request within thirty (30) calendar days after we receive your request. If we grant your request, in whole or in part, we will inform you of our acceptance of your request and provide access and copying. We may deny your request to inspect and copy protected health information if the protected health information involved is: a. Psychotherapy notes; b. Information compiled in anticipation of, or use in, a civil, criminal or administrative action or proceeding; -68-
69 If we deny your request, we will inform you of the basis for the denial, how you may have our denial reviewed, and how you may complain. If you request a review of our denial, it will be conducted by a licensed health care professional designated by us who was not directly involved in the denial. We will comply with the outcome of that review. Right to Amend. (45 CFR (b) (iv) (D); 45CFR ) You have the right to ask us to amend protected health information about you. You have this right for as long as the protected health information is maintained by us. To request an amendment, you must submit your request in writing to; President, MRSI P.O. Box 6005, Evanston, WY Your request must state the amendment desired and provide a reason in support of that amendment. We will act on your request within sixty (60) calendar days after we receive your request. If we grant your request, in whole or in part, we will inform you of our acceptance of your request and provide access and copying. If we grant the request, in whole or in part, we will seek your identification of and agreement to share the amendment with relevant other persons. We will also make the appropriate amendment to the protected health information by appending or otherwise providing a link to the amendment. We may deny your request to amend protected health information about you. We may deny your request if it is not in writing and does not provide a reason in support of the amendment. In addition, we may deny your request to amend protected health information if we determine that the information: a. Was not created by us, unless the person or entity that created the information is no longer available to act on the requested amendment; b. Is not part of the protected health information maintained by us: c. Would not be available for you to inspect or copy; or, d. Is accurate and complete. If we deny your request, we will inform you of the basis for the denial. You will have the right to submit a statement of disagreement with our denial. Your statement may not exceed 10 pages. We may prepare a rebuttal to that statement. Your request for amendment, our denial of the request, your statement of disagreement, if any, and our rebuttal, if any, will then be appended to the protected health information involved or otherwise linked to it. All of that will then be included with any subsequent disclosure of the information, or, at our election, we may include a summary of any of that information. If you do not submit a statement of disagreement, you may ask that we include your request for amendment and our denial with any future disclosures of the information. We will include your request for amendment and our denial (or a summary of that information) with any subsequent disclosure of the protected health information involved. You also will have the right to complain about our denial of your request. Right to an Accounting of Disclosures. (45 CFR (b)(iv)(e); 45 CFR ) You have the right to receive an accounting of disclosures of protected health information about you. The accounting may be for up to six (6) years to the date on which you request the accounting but not before April 14,
70 Certain types of disclosures are not included in such an accounting: a. Disclosures to carry out treatment, payment and health care operations; b. Disclosures of your protected health information made to you; c. Disclosures for national security or intelligence purposes; d. Disclosures to correctional institutions or law enforcement officials; e. Disclosures made prior to April 14, Under certain circumstances your right to an accounting of disclosures may be suspended for disclosures to a health oversight agency or law enforcement official. To request an accounting of disclosures, you must submit your request in writing to President, MRSI, P.O. Box 6005, Evanston, WY Your request must state a time period for the disclosures. It may not be longer than six (6) years from the date we receive your request and may not include dates before April 14, Usually, we will act on your request within sixty (60) calendar days after we receive your request. Within that time, we will either provide the accounting of disclosures to you or give you a written statement of when we will provide the accounting and why the delay is necessary. There is no charge for the first accounting we provide to you in any twelve (12) month period. For additional accountings, we may charge you for the cost of providing the list. If there will be a charge, we will notify you of the cost involved and give you an opportunity to withdraw or modify your request to avoid or reduce the fee. Right to Copy of this Notice. (45 CFR (b) (iv) (F) You have the right to obtain a paper copy of our Notice of Privacy Practices. You may obtain a paper copy even though you agreed to receive the notice electronically. You may request a copy of our Notice of Privacy Practices at any time. You may obtain a copy of our Notice of Privacy Practices over the Internet at our web site To obtain a paper copy of this notice, contact MRSI, P.O. Box 6005, Evanston, WY 82931, Our Duties Generally. We are required by law to maintain the privacy of protected health information about you and to provide individuals with notice of our legal duties and privacy practices with respect to protected health information. (45 CFR (b) (v)(a) We are required to abide by the terms of our Notice of Privacy Practices in effect at the time. (45CFR (b) (v) (B) Our Right to Change Notice of Privacy Practices. We reserve the right to change this Notice of Privacy Practices. We reserve the right to make the new notice s provisions effective for all protected health information that we maintain, including that created or received by us prior to the effective date of the new notice. (45 CFR (b) (v) (C) Availability of Notice of Privacy Practices. A copy of our current Notice of Privacy Practices will be posted in our Wyoming facilities. A copy of the current notice also will be posted on our web site, In addition, each time you are admitted to services at MRSI, a copy of the current notice will be made available to you. At any time, you may obtain a copy of the current Notice of Privacy Practices by contacting -70-
71 MRSI, P.O. Box 6005, Evanston, WY 82931, Effective Date of Notice. The effective date of the notice will be stated on the first page of the notice. Complaints. You may complain to us and to the United States Secretary of Health and Human Services if you believe your privacy rights have been violated by us. To file a complaint with us, contact the Corporate Compliance Officer, MRSI, P.O. Box 6005, Evanston, WY 82931, All complaints should be submitted in writing. To file a complaint with the United States Secretary of Health and Human Services, send your complaint to him or her in care of: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, D.C You will not be retaliated against for filing a complaint. Questions and Information. If you have any questions or want more information concerning this Notice of Privacy Practices, please contact President, MRSI, P.O. Box 6005, Evanston, WY
72 SECTION III INTERNSHIP PROGRAM -72-
73 PREDOCTORAL INTERNSHIP MANUAL Mountain Regional Services, Inc. is an equal opportunity employer and subscribes to the Wyoming Fair Employment Act. It is the stated policy of MRSI/Cornerstone Behavioral Health that each employee and each applicant for employment, including predoctoral interns, will be accorded equal treatment with regard to recruitment, selection, and employment without discrimination due to race, religion, national origin, disabling condition, sex, age, or sexual orientation. The internship program avoids any actions that would limit access on grounds that would be irrelevant to the success in internship training or a career in professional psychology. The program encourages actions that indicate respect for and understanding of people with varying disabilities, ethnicity, racial background, age, gender, religion, national origin, sexual orientation, socioeconomic background, or any other source of individual or cultural diversity. -73-
74 Introduction This manual is designed to introduce new interns to the agencies associated with the internship program and to provide specific information about the internship itself. In addition, we hope to anticipate and answer some of the more frequently asked questions for interns and others involved with the internship program. Description of Organization Mountain Regional Services (MRSI) - MRSI was founded in 1985 to provide residential and dayhabilitation treatment to individuals with developmental disabilities. The agency grew from treating two individuals to its current size, treating over 100 adults and children in two locations. Psychologists Role: Head of a multi-disciplinary treatment team, individual and group psychotherapy, consultation, designing psychodynamically-informed behavioral interventions for front-line staff to follow with clients. Interns Role: Same as psychologists role, but under supervision. Cornerstone Behavioral Health - Cornerstone was originally established as a division of MRSI to provide substance abuse treatment to individuals with developmental disabilities who were not served by other substance abuse treatment providers. Since its inception, Cornerstone has expanded to provide general outpatient mental health services as well as substance abuse treatment to people of Evanston and surrounding communities. As part of this expansion, in 1998, Cornerstone moved to a new, state-of-the-art facility located near Evanston Regional Hospital. Psychologists Role at Cornerstone: Psychotherapy and psychodiagnostic assessment with general mental health clients from Evanston and surrounding rural communities; providing mulit-level substance abuse services including assessment, intensive outpatient (IOP), adolescent intensive outpatient (AIOP), outpatient (OP), Aftercare, DUI School, Under 21 education Interns Role: Evaluation and treatment of adults and adolescents with substance abuse problems; participation in substance abuse treatment programs, individual psychotherapy interventions with substance abuse clients (as needed), some opportunities for general mental health outpatient clients from the general community. Mission Statements MRSI: To assist each person-served in achieving the highest quality of life. Cornerstone: To provide individualized, confidential, and caring treatment for persons and families with behavioral health needs, improving their quality of life. Internship: To develop the skills, competencies, and rigorous scientific attitude necessary for entering the professional practice of psychology, with special sensitivity to the personal and professional growth of the interns while simultaneously improving the quality of life for the persons served. -74-
75 The Internship Program Internship Philosophy and Training Model The Local Clinical Scientist The Cornerstone Behavioral Health internship in clinical psychology recognizes that becoming a professional psychologist is a developmental process. It is a core belief of our program that the path from student to expert is illuminated by developing a working knowledge of a coherent theoretical model of the mind, personality, psychopathology, and therapeutic change that serves as a basis for not only techniques and strategies of practice, but as a unifying way of thinking and clinical judgement. The practicing psychologist is typically faced with unique, complex, multi-determined, and often illdefined, emotionally-charged problems immersed in an intensive interpersonal matrix. At Cornerstone, like many other clinical settings, we are practitioners repeatedly faced with demands to solve problems that are influenced strongly by unique local factors for which there are no clear answers provided by the research literature. As for most practitioners, our clientele are more likely to be those people who would be excluded from research protocols. Yet, as psychologists, we remain faced with the challenge of developing well-reasoned, empirically-based solutions, whether serving as therapist, consultant, or formulating useful recommendations in a well-conceptualized psychodiagnostic report. Under these circumstances, we view ourselves as clinicians who approach problems scientifically, with the same discipline, rigor, logic, critical thinking, and openness to falsification, described by Stricker and Trierweiler (1995) as the essential nature of the local clinical scientist, which serves as our model of training. We approach each person seeking services with a commitment to understanding their individuality and the diversity of human experience and backgrounds. There is no one-size-fits-all approach to treatment. Instead, each clinical situation represents a problem to be solved in the context of the uniqueness of the individual immersed in a therapeutic relationship, using theory-driven hypotheses and a scientific attitude of inquiry as our guides. Our approach to training is to provide the interns with the tools and the theoretical framework for making sense out of the complex and seemingly disparate data of the practitioner s world and coming up with practical solutions that are sound, empirically-minded, and respectful of human diversity. These tools and theories we teach are firmly rooted in empirical demonstrations of the efficacy of psychodynamic/psychoanalytic approaches to treatment, among others, yet applied in the local context. In addition to learning specific techniques and strategies, our interns develop a style of thinking and a structure for clinical judgment an over-arching guide to negotiating and making sense out of the complexities of clinical practice which can be applied in any setting. In accomplishing this, we recognize that the developmental process of becoming a psychologist is best facilitated by a learning environment that contains a number of essential elements. First, the ideal internship environment requires complete immersion of the intern in intensive work that gradually progresses in complexity and responsibility in a way synchronized with each intern s individual development. This intensive environment places demands on the interns abilities, thus stimulating growth, and adds levels of responsibility beyond what was experienced in graduate school. Despite the intensity of the work, it is also essential that the interns have enough time where -75-
76 they are not over-burdened by demands, leaving them the opportunity for contemplation, reading, thinking, and personal time which allow for thorough incorporation of their internship experiences. The internship offers plentiful direct-care clinical experience interwoven with didactic training and in-depth supervision. Didactic seminars continue to deepen the interns knowledge while the clinical work provides opportunities to directly apply new knowledge and broaden the interns view of the diversity of human experience through exposure and empathy. The performance of clinical work occurs under supervision that focuses on development of new skills, application and integration of new learning in the context of direct clinical work with individuals, clear feedback on progress, and overall professional development and support. Other essential ingredients include opportunities for observation of others performing the work of professional psychologists and opportunities to integrate information in written form. We recognize that observing, practicing, listening, reading, writing, contemplating, and verbally articulating thoughts are all ways of knowing. Each is a learning modality, which, when combined in an intensive setting, creates the environment necessary for education at the predoctoral internship level. Internship Goals Goal 1: To produce graduates well-prepared for the practice of professional psychology who have a working knowledge of a core theoretical model of the mind, personality, psychopathology, and therapeutic change that serves as an over-arching guide to clinical practice. Goal 2: To produce graduates capable of assuming multiple professional roles as psychotherapists, psychodiagnostic examiners, consultants, supervisors, and evaluators. Goal 3: To produce graduates who identify with the broader role of the professional psychologist with respect to ethics, diversity, and science. Objectives, competencies and internship activities developed to achieve these goals are found in the Internship Manual Supplements. Primary Experiences The internship program at Cornerstone Behavioral Health was designed to meet a specific set of goals and objectives (see Internship Manual Supplements, Outline of Program Goals). The following are brief descriptions of the activities designed to meet the goals of the internship and to help interns develop the competencies necessary for the professional practice of psychology. The primary experience of the internship is working with individuals who have developmental disabilities, most of whom are dually diagnosed with co-occurring major mental illnesses (at MRSI). Interns assess clients, provide individual and group psychotherapy to these individuals, consult with members of the treatment team, and design psychodynamically-informed behavioral interventions for staff working with the clients. With supervision, the interns operate essentially as the head of the treatment team. Each intern is assigned a primary supervisor for therapy activities and a secondary supervisor for evaluations. -76-
77 Interns also provide services at the Cornerstone office, working with individuals who have substance abuse problems and providing general mental health outpatient services. The substance abuse experience includes performing substance abuse evaluations, providing group treatment, and providing individual or couple s psychotherapy to supplement clients work in substance abuse group treatment and aftercare. A third supervisor oversees interns substance abuse activities. Interns will be expected to carry a small caseload of outpatient clients composed of people referred from the substance abuse program or general mental health outpatients. Didactic experiences include three seminars per week (Psychotherapy/Assessment, Theory Seminar, and Developmental Disabilities Seminar). Additional supervisory experiences include a weekly group supervision with the clinical director, a separate group supervision focused on group psychotherapy, and group supervision of substance abuse experiences and addictions education. Other observational and participatory experiences include working as a co-therapist with doctoral staff in group psychotherapy and substance abuse treatment groups, and attending weekly staffing meetings in which Cornerstone general mental health outpatient clients are presented and peerreviewed. Each of these experiences is described in more detail below and in the Internship Manual Supplements. Expectations for Interns Upon arrival, interns have a four-day general orientation to Mountain Regional Services, Cornerstone, the psychology staff, other multidisciplinary team members, and the expectations for the internship as well as training in crisis intervention techniques used by front line staff. Clinical responsibilities, such as beginning psychotherapy with clients who have developmental disabilities, will begin after the general orientation. The following week, interns begin attending meetings and seminars. After the first month, additional responsibilities (i.e., substance abuse groups, psychodiagnostic assessment, substance abuse assessment, outpatient psychotherapy) are gradually added. It is expected that intern scheduled responsibilities will require at least hours per week. Additional hours vary, typically as a function of time spent reading, preparing for seminars, and writing reports. A specific breakdown of interns allocation of hours can be found at the end of this manual in the supplements section. Interns are expected to be available between 8am-5pm each weekday, with the exceptions of a one-hour lunch break each day and one evening per week, depending on substance abuse group assignments. Some flex time is built into the schedules to account for evening substance abuse group hours. Working a substantial number of additional hours is not preferable, as we hope that interns will have time to read, thoughtfully review their experiences, and consolidate information that is encountered during the various aspects of the internship training. Interns accumulated hours are tracked through the use of a daily time clock. Specific clinical activities and supervision are tracked by daily logs submitted by interns. During work hours, intern performance of responsibilities is expected to be thorough, conscientious, and timely. More specific expectations for intern performance necessary to complete the internship can be found in the program evaluation forms, Policies and Procedures, and the outline of program goals, competencies, and activities (see Internship Manual Supplements). -77-
78 Supervision Interns receive a minimum of six hours of face-to-face supervision every week. The primary supervisor is responsible for providing two hours per week of individual face-to-face supervision for the intern s developmental disabilities therapies and outpatient mental health clients, with additional hours or consultation available as needed. The primary supervisor also works with interns regarding any issues of general professional development. One hour per week, interns meet for group supervision with the Clinical Director/Director of Internship Training. Another hour per week is devoted to group supervision of group psychotherapy. In addition, interns have an assessment supervisor for psychodiagnostic evaluations, with whom they meet individually for one hour per week. Finally, substance abuse treatments and evaluations are supervised separately each week. All supervisors are licensed, doctoral-level psychologists. The psychologists at Cornerstone conceptualize clinical work primarily from a psychodynamic or psychoanalytic perspective. However, among the staff, different schools of psychodynamic theory may be emphasized and additional perspectives may be interwoven into the dynamic treatment umbrella (e.g., family systems, behavioral, cognitive, existential, etc.) through a process of assimilative integration. Didactics Interns attend three one-hour seminars each week in the areas of psychotherapy/assessment, psychoanalytic theory, and developmental disabilities. The seminars are conducted by Cornerstone staff psychologists. Issues of cultural and individual differences will be addressed in each of the seminars with a focus on tailoring psychological services to the needs of the individual (see Internship Manual Supplements for seminar topic lists). Specific topics related to cultural and individual differences include working with LGBT individuals, the role of gender in psychotherapy, and the role of culture in psychotherapy. Other specialized seminars outside of the usual schedule include a psychoanalytic primer, introduction to group psychotherapy, and eight weeks of Rorschach training. Participant/Observer Opportunities Interns get to see and work with psychologists-in-action in a variety of settings. First, interns are assigned four to five group psychotherapy sessions per week, plus one evening substance abuse therapy group, all with a psychologist co-therapist. Second, multidisciplinary team meetings assigned to interns early in the year are attended with their primary supervisor until satisfactory development of comfort and competence indicate the intern is capable of attending such meetings solo. Finally, interns participate in weekly staffing meetings in which outpatient therapy cases are peer reviewed and the psychology staff (including interns) present their cases and receive consultation. Similarly, the weekly psychoanalytic theory seminar attended by all the psychology staff often elicits plentiful and specific case material that is debated, conceptualized, and formulated into treatment ideas, helping to bridge the study of theory with application in the therapy room. -78-
79 Administration of the Internship Training in clinical psychology at Cornerstone is coordinated by the Director of Internship Training. Input by interns regarding the training experience can be offered at the weekly group supervision verbally, and more formally through written evaluations. Feedback from interns is reviewed by the Director of Internship Training, and the entire psychology faculty, as necessary. All of the psychology faculty are engaged in the internship program to varying degrees, and review internship related issues on a weekly basis with the Director of Internship Training. At the end of the year, interns are also invited to an individual exit interview with the Director of Internship Training as an opportunity to provide additional verbal feedback regarding the internship and their experience. Evaluations of Interns, Supervisors, and Internship Experiences Feedback and evaluation of interns is provided continually on an informal basis in supervision and formally via written evaluation forms completed by supervisors mid-year and at the end of the internship. Interns also evaluate their supervisors, seminars, and other training experiences. Midyear and end-of-the year evaluations are available to be sent to the Director of Training at the intern s home university, unless remedial action needs to be taken prior to that time. Copies of evaluation forms are distributed during orientation and kept available on the shared files of the computers at Cornerstone. Vacation/Professional Leave The Cornerstone Predoctoral Internship in clinical psychology is a one-year, full-time, 2000 hour internship. Interns should plan on taking no more than two weeks (10 working days) off during the year for their own personal use. Additional leave time accrued during the year may be used as paid leave for professional activities (conferences, dissertation defense, job interviews, etc.) with advance approval from the Director of Internship Training. Interns may plan on saving leave time for the end of the year, but no leave time will be granted during the last month of the internship. Any additional leave time unused at the end of the year will be paid. What if Problems Arise? If an intern experiences a problem associated with the internship program or work setting, he/she should attempt to solve the problem informally with the individuals involved. If informal channels do not resolve the problem, the intern should follow the grievance procedure found in the internship Policies and Procedures (see Internship Manual Supplements). If interns experience personal problems, the following resources are available. If these resources are not well-suited to the particular problem, the Director of Internship Training or primary supervisor could be consulted for additional referrals: Counseling Services: Pioneer Counseling Service,
80 Frontier Psychological Associates, Financial Services: Family Financial Education Foundation, Legal Services: Uinta County Bar Association, Frequently Asked Questions What is my title and how will people refer to me? Your official title at MRSI/Cornerstone is Psychology Intern. In this pre-doctoral position, your patients and team members will refer to you with the title Mr/Mrs/Ms/Miss and your last name. Please introduce yourself to others in this way. Where can I get basic office supplies? Cornerstone s front-office administrative assistant and the MRSI front desk receptionist. Where can I access professional resources? Cornerstone s library is located in the conference room in the Cornerstone building. Cornerstone psychologists subscribe to several professional journals and have subscriptions to a number of developmental disability newsletters. All psychological testing materials can be found in the library. The library has also has acquired the 24-volume hard cover set of The Complete Psychological Works of Sigmund Freud plus the full-text archive of the top 13 psychoanalytic journals from 1980 to the present and 23 classic psychoanalytic books, all on the Psychoanalytic Electronic Publishing (PEP) CD-ROM, complete with search engines. Materials unavailable from our library can be sought at the IHC Regional Hospital library located adjacent to the Cornerstone building, the University of Utah library or ordered through the University of Wyoming library for a fee. Who do I consult if one of my clients with developmentally disability has questions about financial matters (i.e., Can I get money to go out to dinner on Friday night? )? The clients case managers are responsible for upkeep on client accounts and dispersing funds. If clients wish to get money from their accounts, they fill out check requests and submit them to their case manager. Who do I consult if my client wishes to start a job? First, it is necessary for you as the primary therapist and your supervisor to decide whether the client is indeed ready to begin working in the community. Consult with your supervisor as needed. If the client is ready, the case manager should be contacted so that a pre-employment meeting can be arranged. What do I do if my MRSI client requests a home visit? Clinically, reasons for requesting a home visit should be explored in the therapy session. Then, consultation should be sought with both the case manager and supervisor to obtain historical information that might be useful in making a decision about whether a home visit is clinically indicated. Some clients visit family on a regular basis, but for many, requests for home visits are a form of acting-out or clinically contraindicated due to the dysfunctional or dangerous home environment. Make no promises until you are fully informed. What do I do if an MRSI client does not show for a scheduled psychotherapy appointment? Clinical data from therapy may lead you to make individualized decisions regarding how to -80-
81 proceed with specific clients. However, on occasion there are scheduling errors made by staff and clients. Therefore, in general, if a client is more than five minutes late for an appointment, call the front desk (extension 0) and request assistance in locating the client. How do I know whether a consultation with staff members is necessary and how do I arrange for one of these meetings to be held? If you have attempted to educate staff and resolve questions or problems they may have via responses to Team Communication Reports (TCRs) and meetings with the case manager, and the client continues to have serious difficulties, it is possible that formal consultation with staff members as a team needs to be arranged. Often staff members and case managers will recognize a need and request such a meeting. It is important to talk with your primary supervisor about the clinical issues and how to approach the problem. Sometimes there are other avenues to try before a consultation. If team consultation seems like the best option, the client s case manager can help to coordinate the scheduling of the meeting and gather the appropriate team members. Evanston/Rocky Mountains In addition to developing competencies in clinical psychology and experiencing personal growth as a result of the life-changing aspects of working in the field of psychology, we hope that interns will enjoy the abundant opportunities available in Evanston and the surrounding areas during the training year. Located in the southwest corner of the state and situated along the fabled Oregon, Mormon, and Pony Express Trails, Evanston is in a beautiful high desert region with extraordinary outdoor recreation and access to wilderness. Opportunities abound for backpacking, hiking, skiing, rock climbing, mountain biking, and world renown fishing. Jackson Hole, Grand Teton National Park, and Yellowstone are within a few hours drive to the north, with the spectacular red rock deserts of Moab and Southern Utah to the south. The 2002 Winter Olympic venues are within an hour. If city culture is more appealing, Park City and Salt Lake City, Utah provide easy access to fine cuisine, private art galleries, the Utah Symphony, the Utah Jazz, The Sundance Film Festival and much more. Staff members are knowledgeable about recreational opportunities and eager to share suggestions for weekend road trips or places to find the best powder for a day of excellent skiing! Psychology Staff Mikaela Bernthaler, Psy.D., MS.Ed, M.B.A Staff Psychologist Dr. Bernthaler earned her doctoral degree in clinical psychology from the George Washington University and completed an APA accredited internship at the Albert Einstein College of Medicine - Bronx Psychiatric Center, a state inpatient facility specialized in the psychodynamic treatment of chronically mentally ill and forensic clients. She also completed a one year fellowship at the Baltimore-Washington Institute for Psychoanalysis. Throughout her training, she worked primarily in residential and inpatient settings with chronic, multi-problem, under-served and culturally diverse adults and their families, who presented with a wide array of diagnoses including substance use disorders. In these settings, she provided individual and family psychotherapy, psycho-diagnostic -81-
82 assessments and led groups. Dr. Bernthaler also holds a Masters Degree in Marriage and Family Therapy from the University of Miami and provided couples and family therapy from a systems perspective. Throughout her training, she has also worked with children and adolescents and was a volunteer in the Guardian ad Litem Program at the 11th Judicial Circuit in Florida. She has considerable experience working with the Hispanic community and is able to provide psychotherapy in Spanish. Dr. Bernthaler is a member of the APA Division of Psychoanalysis. Her primary interests are in psychodynamic psychotherapy, trauma, gender, group psychology and culture. Ashleigh Bott, Psy.D. Staff Psychologist Dr. Bott completed her undergraduate studies in psychology at Indiana University. She continued on to earn a doctoral degree in clinical psychology at the Illinois School of Professional Psychology in Chicago, Illinois. Dr. Bott received training in psychodynamic theory and practice, and she enjoys working with individuals across the lifespan. She has focused on serving individuals from underserved populations in an inpatient state hospital and residential treatment facilities. She completed an APA accredited predoctoral internship at Cornerstone Behavioral Health where she remains as a licensed psychologist. Dr. Bott s interests include both brief and long-term psychodynamic psychotherapy, serving individuals with intellectual disabilities, substance abuse and dependency issues, and child and adolescent psychopathology. She also enjoys training future psychologists in psychodynamic theory and technique, psychodiagnostic assessments, and personal and professional development. Cora Courage, Psy. D. Director of Child & Adolescent Services Dr. Courage holds a doctoral degree in clinical psychology from the Minnesota School of Professional Psychology and received training in psychodynamic theory and practice during several field training experiences. She brings twenty years of experience in dual diagnoses to her practice. The APA accredited predoctoral internship at the VA Medical Center of the Black Hills in South Dakota she completed emphasized outreach to rural, under-served, culturally diverse communities, and treatment of minority populations. Her masters degree in counseling psychology from Saint Mary's University integrated the application of psychodynamic orientation with family systems approaches in the treatment of addictions. Her primary interests are in psychodynamic theory and therapy with children and adolescents, trauma and critical incidents, sexuality/gender issues, and the impact of multi-cultural diversity in psychoanalysis. She is a licensed psychologist and a member of the American Psychological Association (Div. 33, 39, 53). Dr. Courage is a Team Leader for the state of Wyoming in the Child Trauma Treatment Network of the Intermountain West, part of the National Child Traumatic Stress Initiative, as well as many local organizations serving the needs of children and adolescents. Dr. Courage is also a commissioned officer in the Medical Service Corps, serving as the psychologist for the 34th Infantry Division of the Minnesota Army National Guard, and a member of the National Health Service Corps. -82-
83 Adam K. Fuller, Ph.D. Clinical Director Director of Internship Training Dr. Fuller earned his doctoral degree in clinical psychology from the Department of Clinical and Health Psychology at the University of Florida. He completed an APA accredited predoctoral internship at the State University of New York, Health Science Center in Syracuse (SUNY Upstate Medical Center). In both settings he received extensive experience in outpatient and inpatient psychotherapy and psychodiagnostic testing with adults, adolescents, and children. Other inpatient experiences include group psychotherapy, crisis intervention, and psychotherapy with individuals who had severe and persistent mental disorders. Prior to joining Mountain Regional Services, he worked in a group private practice which provided him the practical experience of applying a psychologist s skills within a managed care environment. Dr. Fuller s special interests are related to psychoanalytic theory and therapy, the empirical basis for psychoanalytic principles and treatment, and applications of psychodynamic concepts in brief psychotherapy. He is a member of APA (Divisions 12, 29, and 39) and the Wyoming Psychological Association. Patrick J. Lewis, Psy.D. Staff Psychologist Dr. Lewis completed his undergraduate studies at Washington University in St. Louis before earning his masters and doctoral degrees in Clinical Psychology at The Chicago School of Professional Psychology. Dr. Lewis completed an APA-accredited predoctoral internship at Cornerstone Behavioral Health, where he has remained as a licensed psychologist. He has pursued training in psychodynamic theory and practice and has applied this specific training and knowledge in his work with individuals, groups, adults, children, families, and couples. Dr. Lewis has pursued extensive training in working with underserved populations in both urban and rural settings and is interested in psychodynamic psychotherapy with a relational emphasis. He has also sought extensive training in substance abuse treatment and provides substance abuse group therapy at Cornerstone. He is also interested in the impact of culture and difference in psychotherapy, the experience of depression, the treatment of the disease of addiction, the process of loss and mourning, sexual orientation and gender issues, and supporting clients in their efforts to live more purposeful and satisfying lives. Robert Matzelle, Psy.D. Staff Psychologist Dr. Matzelle completed his undergraduate studies at the University of St. Thomas in Houston, Texas. He continued his education at John Jay College of Criminal Justice earning a Masters degree in Forensic Psychology. Dr. Matzelle completed an APA pre-doctoral internship at Cornerstone Behavioral Health where he has remained as a licensed psycholoigst. Dr. Matzelle received training in psychodynamic theory and practice throughout his graduate studies. He has worked with a wide variety of populations from this perspective, including children, families, couples, and adults. Dr. Matzelle's areas of interest include psychodynamic psychotherapy with an interpersonal emphasis, trauma and posttraumatic stress, couples therapy, sexual orientation and gender issues. Additionally, Dr. Matzelle has focused on working with underserved populations throughout his training and clinical experiences. -83-
84 Suzanne Petren, Ph.D. Staff Psychologist Dr. Petren holds a Ph.D. degree in counseling psychology from the University of Missouri in Kansas City, Missouri. She is also a licensed attorney, having earned her J.D. degree from the University of Missouri School of Law, where she distinguished herself as Administrative Editor of the Law Review as well as speaker and Appellate writer on the National Moot Court Team. She completed her APA accredited internship at Cornerstone Behavioral Health, where she received training in psychoanalytic theory and substance abuse, working with individuals and groups. While at the University of Missouri, she received training in existential phenomenology, biofeedback, and worked extensively with individuals and their supporters through all stages of the cancer experience. Her clinical interests are in psychoanalytic theory and in working with individuals suffering from severe and chronic mental illness as well as substance abuse. She has a long-standing interest in working with groups. Her publications are in the areas of emotion and group treatment methods. She received a National Institute of Health (NIH) Predoctoral Fellowship in the research area of the psychophysiology of emotion. Suzanne Petren was a Fellow of the American Psychoanalytic Association for Outstanding Early Career Psychologist. Brian Schaffer, Psy.D. Staff Psychologist Dr. Brian Schaffer completed his doctoral degree at Nova Southeastern University in Fort Lauderdale, Florida. While at Nova, Dr. Schaffer received training in understanding the complex underlying motivations, emotions, and other factors which can contribute to or impede mental well-being. He has experience working in a variety of settings, including community mental health centers, inpatient and community based treatment centers, and private practice. He has worked with individuals suffering from a wide range of psychological disorders such as depression, substance abuse disorders, bi-polar illness, as well as those who are simply interested in learning more about themselves. Dr. Schaffer has specialized interest in treating individuals with a developmental disability, as well as in unique approaches to managing severe disorders such as schizophrenia. Dr. Schaffer also takes part in training future psychologists as part of an APA accredited internship program, in which he focuses on the application of psychodynamic theory in a pragmatic fashion, as it applies to both clinical work and facilitation of effective treatment team functioning. -84-
85 Internship Manual Supplements I. Intern Recruitment/Public Disclosure: I. Policies and Procedures Cornerstone Behavioral Health Internship in Clinical Psychology Policies and Procedures A. It is the practice of the Cornerstone Behavioral Health Internship program to provide information about the program to prospective interns and other interested parties and to answer questions about the information provided. On occasion, individual prospective candidates will be sent unsolicited information about the program in a recruitment effort (for example, mailing internship information to participants in the APA Minority Fellowship Program). B. Information about the Cornerstone program is updated and published in the APPIC online directory each year. In addition, the revised internship glossy-brochure is mailed to each APAapproved clinical psychology program in early fall of each year. Selected supervisors and program directors are also selected for mailing based on contacts from previous years and a track record of recommending strong candidates in the past. Information about the internship is also available on the World Wide Web at C. Finally, copies of brochures are sent to prospective interns and other interested parties at their request, or inquiries are directed to the website, which contains the same plus more information. Cornerstone staff are available by telephone, as needed, to answer any questions that prospective interns or other interested parties might have. II. Intern Selection (including practicum and academic preparation requirements): A. The application materials listed below must be submitted by the deadline stated in the brochure: 1. Completed APPIC standard application form(aapi). 2. Official uploaded transcripts. 3. Vita. 4. Letter of interest (cover letter) 5. Three letters of reference from psychologists/supervisors familiar with the applicant s clinical work in psychology. 6. Statement of eligibility from the director of training in the intern s graduate program (part of the APPIC application). 7. Applicants selected for interview may be asked to submit additional work samples (two psychodiagnostic testing reports, at least one with projectives) B. A subset of applicants who meet at least the minimum criteria listed below will be invited to interview on site, in person. Telephone interviews are available, but not encouraged. 1. Enrollment in an APA accredited graduate program in clinical or counseling psychology. -85-
86 2. Completion of coursework by the start of the internship with a B average or better (must include coursework in intellectual and personality assessment, psychopathology, and preferably psychodynamic treatment models). 3. Completion of doctoral comprehensive exams by the start of the internship. 4. Two years of practicum experience, including practical experience in both psychological assessment and psychotherapy, preferably from a psychodynamic perspective. 5. Dissertation proposal has been developed and approved by the start of the internship. C. During interviews, the following areas will be assessed: 1. Interest in working with the populations found at Cornerstone. 2. Interest in long-term models of psychotherapy. 3. Basic knowledge of testing theory, psychological tests, and report writing. 4. Basic knowledge of psychodynamic and psychoanalytic theory; interest in immersion in that theoretical setting. 5. Personal/professional maturity, including evidence of having given thought to and ability to articulate ideas about how people change. D. During ranking of acceptable candidates, consideration is given to composing a group of interns with sufficient diversity which includes consideration of individuals of different age, ethnicity, gender, religion, sexual orientation. III. Administrative and financial assistance: A. Administration of the internship program is the duty of the internship director who is responsible for the following: 1. Providing structure for the intern s training activities; 2. Ensuring that the training activities are provided as designated; 3. Dealing with conflicts that arise in the course of training; 4. Ensuring that the training activities meet the requirements of the organizations for which the training program is a member (e.g., APPIC, APA, Wyoming Board of Psychology); 5. Ensuring that training meets minimal standards of quality: a. by providing regular opportunities for interns to evaluate their experiences; b. by providing periodic training to supervisors. 6. Coordinating recruiting efforts. 7. Maintaining contact with interns graduate programs, including providing the training directors with written feedback about interns performance; 8. Serving as a liaison between the internship program and the organization in which the internship program is housed. B. Financial support for interns is provided by MRSI in the following ways: 1. $18,000 stipend for the year-long training 2. Medical, dental, and life insurance after three months of service 3. Malpractice insurance 4. Ability to participate in Cornerstone s 403B deferred compensation plan 5. Ability to participate in Cornerstone s term life and disability insurance programs 6. Six national holidays, one day off in each month without a national holiday, and twelve hours paid leave each month (distributed according to company policy). A portion of leave -86-
87 time is allocated for supporting professional and academic pursuits, such as dissertation meetings and defenses, graduation, job interviews. IV. Intern rights and responsibilities: A. Intern rights: 1. To be provided with quality training experiences consistent with the intern s level of professional development and the schedule provided during the internship orientation. 2. To be treated with respect and dignity in professional interactions. 3. To be free from harassment in the workplace. B. Intern responsibilities: 1. Completion of program requirements in a timely manner and at a level expected for this phase of professional development. 2. Professional and ethical conduct in the workplace and a reasonable amount of consideration to the manner of conducting oneself in a rural community. 3. Personal functioning in the workplace that is not unduly affected by personal intrusions. V. Intern performance evaluation (including feedback, advisement, retention, and termination) A. At the start of the internship, interns will receive copies of all evaluation forms that will be used during the course of the internship and instructions on the use of the forms. The forms reflect what is expected of interns in the performance of their role as an intern. B. Interns will receive informal feedback on their performance on an ongoing basis in supervision. C. Interns will receive formal feedback about performance (i.e., a completed evaluation form) from their primary and assessment supervisors at mid-year and at the end of the internship: 1. The evaluation form includes a statement of whether the intern s performance meets at least minimal requirements; if most ratings are at or approaching 3" (Average expected performance for that point in the year), the intern has successfully met minimal requirements. 2. Training will continue as previously if performance is satisfactory. 3. If performance in any area is below average, the supervisor will make recommendations about what could bring performance into the average range. 4. If performance is deficient, the supervisor must indicate what remedial steps need to be taken to improve performance and the period of time required for such steps. 5. If performance is still deficient after the remediation period, all supervisors of the intern, the internship director, and the clinical director will gather for a formal hearing to review the situation further and to allow the intern to present his/her side of the story or situation as part of the process of deciding whether additional remediation of the problem is possible. 6. If remediation is deemed impossible in the current situation, the intern will be discontinued from the problematic aspect(s) of the program or the entire program if the problems are serious and broad; termination can result from deficits in skills, ethics, or personal functioning: a. Under these circumstances, within 7 days, the intern has the option of submitting a formal, written request for an additional hearing and appeal. The written request should include: description of the situation leading to the remedial steps, efforts taken -87-
88 to remediate the problem area(s), and rationale for re-instituting the discontinued aspects of the program. Once the request for an appeal has been made, the clinical director will re-convene a meeting, within 5 working days, to include supervisors and other members of the training staff as needed, and a third-party official from the personnel department of the organization. The purpose of this meeting will be to reevaluate the circumstances and decisions made in step 6 (above) to determine if the steps taken were appropriate and if any other options are available. The potential outcomes of this meeting would be to uphold decisions made in step 6, or proceed to step 7 (below). 7. If remediation is deemed possible, a new remediation plan will be devised and evaluated by the same team after a designated time period. 8. Termination will result if remediation is not successful, with an option to proceed with step 6a if a previous appeal regarding the problematic area(s) has not already been made. 9. Interns who receive satisfactory evaluations throughout the training will be considered to have successfully completed the internship. IV. Due process and grievance procedures for interns and training staff: A. It is the philosophy of the Cornerstone Behavioral Health Services Internship in Clinical Psychology that grievances of the interns or training staff will be addressed and resolved in a timely manner without coercion, discrimination, or reprisal. B. If occasion arises for dissatisfaction with one or more aspects of intern training at Cornerstone, most cases can be settled with a candid discussion between the individual(s) involved. C. If an informal discussion does not settle the situation, the individual experiencing difficulty in the work situation should consult his/her primary supervisor for assistance in resolving the situation (if the situation involves one s primary supervisor and the informal discussion did not bring satisfactory results, skip this step and consult the internship director). D. If satisfactory resolution of the situation is not achieved following the intern s consultation with their primary supervisor, discussion of the situation with the internship director should occur: 1. The internship director will meet with the individuals involved to gather information and assist in resolving the situation. E. If the situation is not resolved by the internship director, the grievance can be submitted in writing within 10 days to the clinical director. If the internship director or the clinical director are the offending party in the grievance, the written grievance should be submitted to the Director of Human Services or the agency President. The written submission of the grievance should include: The situation leading to submission of the grievance as well as previous steps taken to resolve the grievance. Within five working days, a meeting will be called by the clinical director to discuss and resolve the grievance. Parties to the grievance as well as other members of the training staff as needed will be included in the meeting. Written minutes of the meeting are reviewed and signed by all participants. This step will be the final step in the grievance procedure. -88-
89 II. Outline of Program Goals, Objectives, Competencies, and Activities Goal 1: To produce graduates well-prepared for the practice of professional psychology who have a working knowledge of a core theoretical model of the mind, personality, psychopathology, and therapeutic change that serves as an over-arching guide to clinical practice. Competency 1: Develop a coherent and predictive understanding of a psychological theory. Relevant Activities: 1. Eight-week introductory theory seminar for interns at the start of the year ( Psychoanalytic Primer ) 2. Participate in year-long, weekly psychodynamic/psychoanalytic theory seminar with entire faculty. 3. Participate in individual supervision to elaborate on theoretical issues in a one-to-one setting. 4. Participate in psychotherapy didactic seminars focusing on theory and technique. 5. Ongoing immersion in activities that involve theoretical conceptualizing, including group supervision, weekly Case Conference with the Clinical Director, consultation, staff meetings, assessment supervision. Competency 2: Bridge theoretical knowledge with clinical practice. Relevant Activities: 1. Participate in supervision where theoretical issues are addressed in the context of clinical application with individual clients. 2. Attend weekly group supervision with intern presentations of case material and therapy process notes (Case Conference with Clinical Director). 3. Participate in peer-review staff meetings where faculty use theory to conceptualize clients and plan treatment. 4. Process case illustrations in the context of the theory seminar. 5. Assessment experiences (report writing, integrating test data with theory to form practical understanding of the client and to produce relevant recommendations). Competency 3: Ability to assess outcomes as a means of determining efficacy of practical applications of theoretically-derived interventions, validating the theoretical concept or providing opportunity for flexible adaptation. Relevant Activities 1. Year-long psychotherapy with individuals who have developmental disabilities and co-occurring major mental disorders in a therapeutic milieu, integrating psychodynamic theory and therapy with applied behaviorism. Objective A: Achieve capacity for scientific thinking within a theoretical framework, using theory as a foundation for sound clinical judgement, conceptualizing clients, and clinical decisionmaking. -89-
90 2. Tracking frequency and intensity of maladaptive behavioral and psychological symptoms before and after interventions using a quasi-experimental, single case-study design. 3. Weekly meetings for peer review of treatment plans. II. Goal 2: To produce graduates capable of assuming multiple professional roles as psychotherapists, psychodiagnostic examiners, consultants, supervisors, and evaluators. Objective A: Develop requisite skills necessary for the multiple roles encountered in the applied practice of psychology. Competency 1: Proficiency in providing psychodynamically-oriented individual and group psychotherapy with the capacity for assimilative integration of other techniques as necessary. Relevant Activities: 1. Year-long individual psychotherapy with people who have developmental disabilities and co-occurring mental illness. 2. Year-long group psychotherapy with people who have developmental disabilities and co-occurring mental illness. 3. Group psychotherapy with adults or adolescents in outpatient substance abuse treatment or aftercare, emphasizing Prime Solutions model, motivational interviewing, and 12-step techniques. 4. Provide individual or couples therapy for people concurrently receiving treatment in the outpatient substance abuse program. 5. Provide psychotherapy in a private-practice setting with people from the community-at-large (adults, adolescents, children, individuals, couples, families) 6. Develop behavior modification programs for people with developmental disabilities and co-occurring mental illness. 7. Primary psychotherapy supervision, 2 hour/week minimum (individual faceto-face). 8. Group supervision of psychotherapy, 1 hour/week. 9. Group supervision of group psychotherapy, 1 hr/week. 10. Substance abuse psychotherapy supervision, 2 hour/week. 11. Psychotherapy Seminar, 1 hour/wk. 12. Developmental Disability Seminar, 1 hour/week. 13. Theory Seminar, 1hour/week Competency 2: Proficiency in Psychological Assessment, Diagnostic Formulation, and Report- Writing Relevant Activities: 1. Complete written evaluations of individuals with developmental disabilities and co-occurring mental illness, including assessment of cognitive, emotional, personality, behavioral and adaptive functioning. Approximately one per month (Sept-June). 2. Complete substance abuse evaluations of outpatients, approximately one per month. -90-
91 3. Assessment supervision for evals of people with developmental disabilities and co-occurring mental illness, 1 hr/wk. 4. Assessment supervision for substance abuse evals, 1 hr/wk. 5. Include DSM-IV, five axis diagnostic formulations in all reports. 6. Attend developmental disability assessment seminar. 7. Attend assessment seminars, including diagnostic clinical interviewing, mental status examination, integrated psychodynamic report writing, assessment of intelligence and mental retardation, MMPI-2, Rorschach, TAT, psychodynamic case formulation, and Using the Psychodynamic Diagnostic Manual. Competency 3: Proficiency in Consultation Relevant Activities: 1. Daily formal and informal consultation experiences as head of the treatment team (under supervision) for the clients on their caseload. 2. Participate in semi-annual Individual Plan of Care meetings with multidisciplinary team for clients on their caseload. 3. Lead all-staff consultations on selected clients 4. Attend seminars on consultation (part of the Developmental Disabilities Seminar). 5. Participate in weekly group supervision with Clinical Director, using case presentation format to address therapy issues as well as systems issues and consultation in a multidisciplinary setting. Competency 4: Develop skills and knowledge related to supervision Relevant Activities: 1. Participate in intensive, individual and group supervision 6-7 hours per week. 2. Work with at least 3-5 supervisors throughout the year. 3. Attend didactic seminars on models and issues of individual and group supervision. 4. Work in close consultation with psychologist co-therapists in group psychotherapy. Competency 5: Proficient skills and knowledge related to evaluation of treatment and training. Relevant Activities: 1. Evaluate treatment efficacy using quasi-experimental single case study methods and behavioral data collection (with reversal, where appropriate). 2. Use assessment techniques, where applicable to measure baselines, progress, and outcome 3. Evaluate treatment efficacy using supervision to review clinical work, treatment decisions and outcome. 4. Formal quarterly treatment plan peer reviews for all clients to assess plan and treatment efficacy. 4. Review and implement satisfaction surveys used for all services provided. -91-
92 5. Complete and review evaluation forms for supervision and training program. 6. Receive performance feedback via formal evaluation and as part of ongoing supervision. 7. End of the year exit conference with clinical director to provide additional feedback regarding the program. III. Goal 3: To produce graduates who identify with the broader role of the professional psychologist with attention to ethics, diversity, and science. Objective A: Develop identity as professional psychologist, transitioning out of the student role. Competency 1: Ability to assume professional role in clinical, multidisciplinary setting, including successful negotiation of professional relationships in a complex system. Relevant Activities: 1. Attend seminar titled, Changing roles: From Graduate Student to Intern. 2. Function as head of treatment team for assigned caseload of people with developmental disabilities and co-occurring mental illness, including face-to-face consultation, making treatment recommendations, and generally being seen by others as an authoritative professional. 3. Use supervision to discuss and receive feedback on professional style, development, and future professional directions (including job searching). 4. Ongoing involvement and observational opportunities in staff meetings and as co-therapists with psychology staff in group psychotherapies. 5. Maintain responsibility for paperwork, case notes, evaluations, treatment plans, timely report-writing. 6. Participate in weekly group supervision with Clinical Director, using case presentation format to address therapy issues as well as systems issues and consultation in a multidisciplinary setting and other issues of professional development. Objective B: Develop awareness and skills necessary to think and act in an ethically and professionally appropriate manner. Competency 1: Ability to exercise good judgement and ethical behavior 1. Review APA Ethical Principles of Psychologists and Code of Conduct (provided during orientation) 2. Attend ethics seminar during orientation 3. Address ethical issues in supervision. 4. Ongoing involvement in formal case review with entire psychology staff (1 hr/week). Objective C: Integrate sensitivity to issues of individual and cultural diversity into professional identity. Competency 1: Respect for individual and cultural diversity -92-
93 Relevant Activities: 1. Year-long intensive work with people who have developmental disabilities and co-occurring mental illness. 2. Immersion in rural community. 3. Experience with clients from minority ethnic and religious cultures. 4. Attend year-long seminar on understanding and working with people who have developmental disabilities. 5. Attend seminar on rural psychology and ethics. 6. Attend seminar on Mormon (LDS) culture. 7. Attend seminar on the role of culture in psychotherapy. 8. Attend seminar on the role of gender in psychotherapy 9. Attend seminar on psychotherapy with LGBT populations 9. Use supervision to address diversity issues in individual cases. 10. Participate in recruitment and selection of diverse intern classes in terms of gender, age, ethnicity, sexual orientation, and religion. Objective D: Develop an understanding of the professional psychologist s role as one that integrates science and practice, consistent with the local clinical scientist model of training. Competency 1: Develop skills in accessing, evaluating, and applying existing research. III. Allocation of Intern Hours Relevant Activities: 1. Review applicable articles provided in seminars. 2. Participate in seminars that focus specifically on discussion and evaluation of research (for example, efficacy of brief models of psychotherapy). 3. Participate in seminar on what constitutes empirically supported treatments. 4. Evaluate treatment progress and outcome using data collection and quasiexperimental single case study techniques as part of work with clients who have developmental disabilities. 5. Consult manuals and published research as needed for various clinical tasks. 6. Access libraries of the University of Utah, University of Wyoming; use the Psychoanalytic Electronic Publishing database on CD-ROM; use available internet access via onsite connection. I. Clinical activities and supervision (Approximately 85% of total scheduled hours) Developmental disabilities therapies for full year (51-53%) Individual psychotherapy clients: 11 hrs/wk Psychotherapy groups: 4-5 hrs/wk Supervision for psychotherapy: 2-3 hrs/wk Consultations/Behavior mod plans/team meetings: Variable Substance Abuse therapy rotation (15%) SA therapy group as assigned 3 hrs/wk Supervision: 2 hr/wk Individual Psychotherapy (General mental health outpatient) Variable (2-3 hr. wk avg) 4-7% -93-
94 Evaluations for Sept. through June (15% - includes estimated writing time) II. Didactics/Meetings (Approximately 15%) - Cornerstone conference room unless otherwise indicated Developmental Disabilities (Monday 8am) (1 hr/wk) Variety of topics related to developmentally disabled individuals Theory Seminar (Tuesday 8am) (1 hr/wk) Discussions of seminal papers on psychoanalysis Psychotherapy & Assessment (Wednesday 8am) (1 hr/wk) Individual, Group, Child/Adolescent/Family psychotherapy; Assessment Topics Staffing peer review (Thursday 8am) (1 hr/wk) Peer review of outpatient mental health clients and intakes, monthly DD treatment plan reviews) Substance Abuse Staffing (Wednesday 3pm) (1 hr/wk) Group Supervision (Friday 11am) (1hr/wk) Case presentations and interns administrative forum. -94-
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