Ventura County Grand Jury • 2000-2001

Ventura County Grand Jury Report Mental Health Billing Follow-Up

12 pages
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Findings and Recommendations 15 findings

F1
The Integrity Agreement was intended to correct Medicare Outpatient Mental Health billing problems. The Agreement covers the five-year period which commenced on November 4, 1999.
No recommendations for this finding
F2
The Integrity Agreement consists of two key elements: 1. Compliance Training 2. Production of a Policy and Procedures Manual.
No recommendations for this finding
F3
Ernst and Young, a consulting firm, was hired to conduct the mandated independent review of compliance and to audit billing. They will audit 5% of the charts, which is double the industry standard.
No recommendations for this finding
F4
Compliance Training started November 4, 1999, and trained 2,300 people during the first four months. Those trained included reimbursement person- nel, providers and contractors.
No recommendations for this finding
F5
All contractors and employees are being screened and are removed from consideration if any fraudulent activity is uncovered in their background.
No recommendations for this finding
F6
A Policy and Procedures Manual was developed as a result of the Integrity Agreement and is referred to as the Compliance Program Manual. This manual does not replace Ventura County’s General Administrative Manual, the Human Resources Manual, County and Health Care Agency Policies, applicable labor agreements or any other policies of VCMC that give specific guidance to the daily activities of VCMC and its departments. The Compliance Program Manual sets forth the key elements needed to implement VCMC’s obligations under the Integrity Agreement. The Table of Contents of this manual is shown in Attachment 1.
No recommendations for this finding
F7
A confidential Compliance Hotline that guarantees no retaliation has been established; it documents all complaints and responses and utilizes special- ized health care counseling for complaints.
No recommendations for this finding
F8
A Utilization Review Committee was established to review patient record charts. During the year 2000, 60% of all patient charts were reviewed which is double the industry standard. An example of a utilization review procedure is shown in Attachment 2.
No recommendations for this finding
F9
A summary chart for the outpatient 5% billing chart review is shown in Attachment 3. 6 2000-2001 Ventura County Grand Jury Final Report Attachment 1- VCMC Compliance Program Manual Table of Contents 7 Final Report 2000-2001 Ventura County Grand Jury
No recommendations for this finding
F10
An example of a Master Treatment Plan, which was developed as part of the Policy and Procedures Manual, is shown in Attachment 4.
No recommendations for this finding
F11
The error rate in chart preparation uncovered by the first review has been 40%.
No recommendations for this finding
F12
The Problem Oriented Record computer program used for outpatient billing has been significantly improved to facilitate out-patient billing for Medicare.
No recommendations for this finding
F13
Onsite training is being provided by outside experts from Ernst and Young, a consulting firm.
No recommendations for this finding
F14
Billing charts have been updated. (See example in Attachment 5.)
No recommendations for this finding
F15
Staffing of open positions is still a problem. Certain staff skills are difficult to find. Human Resources’ hiring procedures can be lengthy. Conclusions The Grand Jury concludes as a result of its analysis of the above findings that: C-1 Compliance Training which began on November 4, 1999 is a key element of the Integrity Agreement and is proceeding and being accomplished as scheduled. F-1, F-2, F-4, F-12 C-2 The Policy and Procedures Manual, which is the second key element of the Integrity Agreement, has been completed. This manual is an evolving document, which is changed as required. F-1, F-2, F-6 C-3 Auditing of Charts is being accomplished as required by the Integrity Agreement. F-3, F-8, F-9, F-10 C-4 Billing charts are more user friendly. F-14 C-5 Staffing is a problem. Vacancies take an inordinate amount of time to be filled. F-15 C-6 More scrutiny is being exercised in background screening of contractors and employees. F-5 Recommendations
Related Recommendations (1)
R1
Revamp County hiring procedures so that appropriate priorities are estab- lished by Human Resources for filling critical vacancies. C-5 Commendations The VCMC Compliance Organization together with Patient Accounting are doing an outstanding job under difficult conditions. They are an excellent example of skillful and dedicated Ventura County personnel. C-1, C-2, C-3 , C-4 , C-6 Responses Director of Behavioral Health, R-1 Director, Ventura County Health Care Agency, R-1 Director, Human Resources Division, R-1 8 2000-2001 Ventura County Grand Jury Final Report Attachment 2- Ventura County Behavioral Health Polices and Procedures 9 Final Report 2000-2001 Ventura County Grand Jury Attachment 3-Ventura County Behavioral Health Utilization Review 10 2000-2001 Ventura County Grand Jury Final Report Attachment 4a-Ventura County Behavioral Health Utilization Review 11 Final Report 2000-2001 Ventura County Grand Jury Attachment 4b-Ventura County Behavioral Health Utilization Review 12 2000-2001 Ventura County Grand Jury Final Report Attachment 4c-Ventura County Behavioral Health Utilization Review 13 Final Report 2000-2001 Ventura County Grand Jury Attachment 5-Ventura County Behavioral Health Dept. Psychiatrist Charge Ticket Outpatient 14

Conclusions 1

Commendations 1

No Responses Found 1

Government entities assigned to respond to this report. No response documents have been linked in our database.

Ventura County County