Colleague Q&A

We are happy to provide a forum to answer the many questions that we receive each and every day. We will post our responses along with the discussions in an effort to help you have access to information you need quickly and easily. Please feel free to email Pat Dowse with your questions and to get in on the discussion.

Does your agency use electronic signatures for billing documents?

Agency:
Historically we have not used electronic signatures as part of our process. However, we are moving in that direction for 2012. We are currently working with Therap to implement a documentation system. Where electronic signatures come into play, we will most likely utilize them. We are following guidelines provided by Sheila McBain of OPWDD (OMRDD at the time) back in December of 2009.

Agency:
We use Therap, a web based program, and do use electronic signatures for our MSC notes, ISP's, IPOP's and Hab plans. We will be moving towards electronic processing of incident reports shortly.

Agency:
We do not use electronic signatures for billing.

Agency:
So far only the Psychiatrist in our PROS program is signing docs electronically. I don't know if we will expand because my VP of Behavioral Health said it is difficult (impossible) to correct billing errors once a document is electronically signed

Agency:
We use electronic signatures for billing for waiver services using Therap. The clinic uses Sage for electronic signatures but we will be switching to Acumendic soon.

Agency:
We do not at this time accept electronic signatures...

Agency:
We are not yet using electronic signatures.

NYSRA:
NOTE: Therap is an active Business Partner of NYSRA. http://www.therapservices.net/

Is your agency offering supported employment services that began with Community Based Assessments? Recently, NYSRA has been asked if there are members who have integrated these services and are not only offering assessment as a stand-alone service but have made it part of the full services.

Agency:
Depending on the person, we frequently use some of our hours doing CBAs as part of our assessment of the person, and sometimes is part of our job development.

Agency:
We do CBA as part of our USC from ACCES-VR.

Agency:
We do CBAs as a stand alone service through USC contract. With staff cutbacks, it is not easily arranged anymore. Both our vocational and supported employment department have seen staff positions eliminated. Our evaluator carries a caseload in addition to evaluation duties. Liability issues are factors for some potential sites although we do have arrangements with two employers under USC.

Agency:
We offer Community Based Assessments as part of our ACCES-VR Unified Services Contract. The VR Counselor then decides the next step, i.e., supported employment or training, etc. We also offer a type of Community Based Assessment in the form of Internships for people in our Welfare-to-Work program.

Agency:
It was more of evolution and preservation for our agency, rather than a well thought out, calculated move. There were fewer and fewer referrals for assessments, yet folks were still being referred for job placement and supports. In effect, we wound up doing modified assessments to be able to do job matching, and we were fortunate that our evaluator had enough skills that we can have that position on staff even though his primary job function now are other tasks.

Agency:
Our Supported Employment program is most definitely integrating the community assessment via our G/W stores. The assessment is NOT however the beginning. To assist with the assessment, we are having potential enrollees from both the DD population as well as the MH population meet with the "team" two or three times prior to opening the case.

Is anyone billing for nursing services using APG's that involve administering IM meds (psychotropics, DepoProvera, tetanus, etc.) through their clinics? If so, are they using CPT codes such as 90782 (therapeutic injection) or 90703 (tetanus vaccine)?

Agency:
There are an array of circumstances to be covered by this question. First, the correct therapeutic injection CPT code is 96372, 90782 is an old code and will reject. Then, if nursing is administering i.m. meds, other than depo, the nursing visit must be linked to a medical visit under APGs. Depo on the other hand can be done as a stand alone OA Am visit if performed by a nurse on a date when no medical visit occurs (if there is an order on file) and is billed as an APG claim with a medical visit if performed on the same date as the medical visit.

With all vaccines you have to determine if the vaccine itself was supplied through the vaccines for children program. If yes, then you must follow the VFC Ordered Am claiming protocol, if not then you bill under APGs (except flu & pneumovax which is always ordered am) and link the nurse visit if on a separate date to the medical visit where the vaccine was ordered. The vaccine admin code will bundle into the visit (depending on service date and other CPTs on the claim). By the way, 90703 is the vaccine code, there are companion administration codes for single or multiple vaccines, same day with and without counseling that should be claimed as well.

Are there any agencies out there that are aware of any upcoming MIPS "Train-the-Trainer" sessions scheduled within New York State? Also, if your agency is currently implementing the MIPS curriculum within your own clinics or with medical practitioners in the community, would you be willing to have folks contact you about this?

Agency:
Several of us went to the MIPS training. We then met with our Nursing Coordinator, Residential Director, QA Coordinator, myself and one of our residential nurses who attended the MIPS train the trainer. We then met with our residential nursing staff. After discussing the curriculum we had great concern that this curricula relies on medical professionals knowing what holds can and can not be utilized. We are concerned that these professionals are not trained in their professional education on safe holds and that they may assume our staff should be telling them what to do. We have decided currently, since it is not mandated, not to teach MIPS and our staff are not to assist. There is no proactive approach to MIPS and there is a concern that this will allow a continued level of stress for individuals who have difficulty on medical appointments.

Agency:
There is currently no train the trainer sessions scheduled. Various OPWDD staff has promised that there will be before the end of the year but who knows for sure. The best thing to do is to check the online training catalog on OPWDD's website. I would also recommend emailing the MIPS mail box requesting the training.

Based upon the 10/7/10 Sheila McBain memo limiting providers ability to backfill vacant residential beds that are vacant for extended periods and OPWDD's restrictions on reimbursing providers for vacancy appeals, how or have members altered their residential policies on backfilling vacant beds? 633.12 was and is intended to protect people from inappropriate discharges not prevent providers from filling their vacant beds due to multiple and continuing hospitalizations or rehab admissions that extend for months.

Agency:
We have not changed our policies, but we have changed our practices by being more aggressive with the DDSO staff for information on potential back-fills. We still suffer from higher vacancy rates than we ever experienced -- but still in the low single digits as a percent.

Agency:
We have an internal procedure we follow regarding temporary living arrangements (we only experience this at times due to medical).

Upon the 30th day of individual not at our site -- we request a Physician's certification form to be completed by the physician caring for the person

We then complete a memorandum of Statement of Need to Maintain Home/Living Arrangement and forward to Social Security District Office with the completed Physician Certification Form

If individual is discharged from medical facility by the 90th day of admittance, we then send a memorandum to the Social Security District Office informing them of the date returned home

60 continuous days in other facility -- we start the Facility Initiated Discharge Plan (per the Community Placement Standards dated January 1992). Part of this process, we notify MHLS and keep them in the loop

If individual is not discharged by the 90th day, a notification of change in placement is to be sent to the Social Security District Office informing them of the discharge and MHLS

**Note: Many times MHLS will object and at times we go through that process.