LOS Angeles County Fire Departmet Workers Compensation

Recommendations 5

• R1

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  Medical Coding Backlog (Priority 1) - The DHS management implement a plan to resolve the medical coding backlog to ensure patient services are billed within insurance provider’s billing deadlines. Recommendation Status: Partially Implemented - LCAC-C confirmed DHS management implemented processes to help ensure they are coding and billing patient services within insurance provider’s billing deadlines and also confirmed DHS staff adhered to procedures by examining management’s review of a performance report. DHS plans to fully implement this recommendation
• R2

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  Medical Coding Process (Priority 1) - DHS management strengthen the medical coding process to ensure coding is timely and accurate before billing by: a) Evaluating enhancing ORCHID, and in the interim establishing manual processes, to notify coding staff when incomplete patient records are updated, and notify medical and coding supervisory personnel 9 Interview March 17, 2023 with LACA-C representative 10 Op Cit, (Report # K19FZ) Priority Ranking: Recommendations are ranked from Priority 1 to 3 based on the potential seriousness and likelihood of negative impact on the Agency’s operations if corrective action is not taken. MEDI-CAL REIMBURSEMENT THE FINAL RESOLUTION OF AN ONGOING ISSUE 2022-2023 LOS ANGELES COUNTY CIVIL GRAND JURY when incomplete records remain unresolved for extended periods (e.g., 15 or 30 days). b) Implementing a process to review coding accuracy (e.g., on a sample basis) before billing. c) Maintaining documentation to support billing error investigations. Recommendation Status: Partially Implemented - LACA-C noted DHS management implemented parts b and c of the recommendation and continues to work to fully implement part a. Specifically: LACA-C confirmed DHS is working to modify ORCHID to improve the accuracy and timeliness of the medical coding process including modifying reports to assist coding staff in identifying patient records that have new or updated clinical notes and are ready to be coded. DHS plans to fully implement this recommendation by August 31,
• R3

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  Problem Solving. The process of engaging in the proactive and systematic examination of identified problems to develop and evaluate effective responses. Referring back to the Kolts Commission’s 1992 recommendation that the LASD orient around COPS models of policing, the Special Counsel outlined that, “the department should do far more to teach and reinforce the message that all people are to be treated at all times with dignity and respect under a community-oriented policing strategy. The need to impose discipline will diminish as persons are trained and encouraged to deal in a respectful way with all persons. So then will jury verdicts and judgments against the LASD.”60 LASD did not formally adopt COPS in deputy training materials until 1999,61 and during the course of our research, our Committee found the practice had been inconsistently active or utilized. COMPARABLE LAW ENFORCEMENT AGENCIES Although the LASD is the largest agency of its kind in the country, it is not the only law enforcement agency in the County. LAPD and LBPD have a lot of interaction overlap with the citizens served by the Department. Both city LE agencies have instituted policies clearly outlining LEG policy, have adopted models of constitutional policing and have dynamic community engagement. We believe that it is in the best interest of the LASD to follow suit. Bobb, Merrick J. & Staff (Special Counsel), “The Los Angeles County Sheriff’s Department 1st Semiannual Report. Kotlz Report and Implementation. September 1, 1993.” Civil Rights Litigation Clearinghouse. (p. 293-294) https://clearinghouse.net/doc/10910/. Los Angeles Sheriff’s Department History. 2005. http://shq.lasdnews.net/content/captains/LASD_History.pdf (Last Accessed April 3, 2023). SHERIFF’S OPERATIONS: AN EROSION OF TRUST Examining Transparency, Accountability and Community Policing within the LASD 2022-2023 LOS ANGELES COUNTY CIVIL GRAND JURY LOS ANGELES POLICE DEPARTMENT • LAPD Gang Policy: Their department’s policy clearly states, “Building and preserving trust between the community and law enforcement is crucial to effectively maintaining Department operations… All Department personnel are prohibited from participating in a law enforcement gang. A violation of this policy shall be grounds for termination.”62 • Office of Constitutional Policing and Policy: Their priority is to assist their personnel by supporting effective, constitutional policing through policies, procedures, analysis, advice, guidance, and other essential information.63 Their primary mission is to develop policies and procedures, analyze and review upcoming local, state and federal legislation and create, promote, and foster cultural competency in policing. LAPD also incorporates Constitutional policing in order to embrace diversity, equity, and inclusivity by enacting a formal, transparent, and progressive policy that safeguards every employee and community members’ rights.64 Additionally, the LAPD webpage outlining its department’s constitutional practices also contain all active consent decrees, controversial incidents and UOF reviews.65 LASD currently does make its UOF incidents public, but our Committee believes it should match LAPD by updating its website to include access to any and all consent decrees, restraining orders, etc. LONG BEACH POLICE DEPARTMENT • LBPD Gang Policy: A “Law enforcement gang” means a group of peace officers within a law enforcement agency who may identify themselves by a name, may be associated with an identifying symbol, and engage in a pattern of on-duty behavior that intentionally violates the law or fundamental principles of professional policing [Penal Code §13670 (a)(2)]. To read the LAPD’s policy in full, please refer to
• R6

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  Privileged User Activity Reviews (Priority 2) - DHS management strengthen the process for reviewing their employee’s privileged user activity in ORCHID by reviewing activity from all privileged users/areas and documenting the review to support the activity is appropriate and authorized. Recommendation Status: Partially Implemented LACA-C confirmed DHS management strengthened the process for reviewing their employees' privileged user activity in ORCHID by reviewing the Department’s Access and Security Management Controls procedures, and maintaining documentation of their reviews. DHS plans to fully implement this recommendation by August 31,
• R8

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  Standards and Procedures (Priority 2) - DHS management ensure written standards and procedures adequately guide supervisors and staff in the performance of their duties for all ORCHID processes. Recommendation Status: Partially Implemented - LACA-C confirmed DHS management established written standards and procedures to adequately guide supervisors and staff in the performance of their duties over the following processes: -Medical coding of patient services, including management monitoring of coding controls (Noted in Issue No. 7). -Monitoring of disaster recovery and business continuity services. However, DHS has not developed written standards and procedures over the following processes: -Management monitoring of privileged user activity reviews for DHS employees with high-level capabilities in ORCHID. - Maintenance of the medical code dictionary. The Department plans to fully implement this recommendation by July 1, 2023. Further communications with the Auditor's Office and a review of the April 4, 2023 interim audit report summarized above11 indicate that the problem is being resolved. That report indicates that, of the eight (8) outstanding recommendations proposed in conjunction with their March 19, 2021, Department of Health Services-ORCHID Review, two (2) have 11 April 4, 2023, Los Angeles County Auditor Controller Report: Department Of Public Health – ORCHID Review (Report #K19FZ - First Follow-Up Review) https://file.lacounty.gov/SDSInter/auditor/audit_ reports/1139699_2023-04-04DHS-OnlineReal-TimeCentralizedHealthInformationDatabaseSystemReview- FirstFollow-UpReview.pdf 7 MEDI-CAL REIMBURSEMENT THE FINAL RESOLUTION OF AN ONGOING ISSUE 2022-2023 LOS ANGELES COUNTY CIVIL GRAND JURY been fully implemented and six (6) were partially implemented. All were due to be fully implemented no later than September 30, 2023.12