Options to Bring Greater Oversight and
Accountability to
Georgia's Mental Health, Mental Retardation,
and Substance Abuse System
Submitted by MHMRSA on January 20, 1999
In order to assure Georgians of the state's commitment to protect
consumers and preserve fiscal accountability of public funds by contractors
in the provision of services, the following recommendations are made for
consideration:
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Consumer Safety and
Protection
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The Department will set forth standards for inspection of all residential
sites paid for by providers contracted through the regional boards, and
the Office of Regulatory Services will implement inspections and certification
provision.
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All providers of services receiving $250,000 or more in contracts from
the regional boards are required to obtain accreditation by a national
accrediting bodies which include the Joint Commission on Accreditation
of Healthcare Organizations, Commission on Accreditation of Rehabilitation
Facilities, Council on Quality and Leadership in Supports for People with
Disabilities and Council on Accreditation of Services for Families and
Children by July 1, 1999. Providers who receive less than $250,000 will
be certified by the Department.
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By February 1, 1999, a statewide policy requirement for reporting of all
deaths to regional boards and Division will be implemented and questionable
or unusual deaths will be reviewed.
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Redirected mental health, mental retardation and substance abuse funds
will be used to establish a statewide investigation capacity within the
division and in each region. This will permit prompt review of questionable
deaths and serious or unusual incidents. Training in conducting investigations
and risk management for contracted providers will be created and delivered
in order to develop and strengthen agency internal review processes. Some
funds for this initiative have been requested as a part of the FY 2000
Budget. Additional funds will need to be identified.
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Consumer Quality of Care
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An external utilization management system will be implemented that will
sample clinical records to:
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Validate an appropriate match of consumer to the services provided;
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Validate services provided are in compliance with standards; and
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Validate that services provided match service billing and provide for a
mechanism for payback to the Department of Medical Assistance of identified
exceptions will be implemented beginning July 1, 1999.
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A Consumer Quality Services Unit will be established within the Division
to implement a system-wide continuous quality improvement policy by July
1, 1999. The unit in partnership with the regions will:
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Conduct on a random basis a provider performance evaluation review that
focuses on consumer outcomes, the quality of clinical processes and adequacy
of the clinical record;
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Assist regions in designing performance measures to be included in provider
contracts and in analyzing the performance data; and,
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Working in partnership with the regions, conduct focus management and system
reviews to identify problems and resolution.
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A consumer/family approach to monitoring to assure quality of care and
consumer satisfaction will be required by the Division of each region by
July 1, 1999.
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To improve the quality of services and to assure professional standards
are maintained, the Department's contract with providers will require licensed
professional staff to conduct diagnostic assessments, grant agency service
authorizations and provide clinical/programmatic supervision beginning
July 1, 1999.
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The Division will implement the collection and tracking of statewide performance
measures for each disability that have been established to measure consumers
service outcome, consumers' access to care, the acceptability of services
delivered and the value of the services provided.
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The Department will include in FY 2000 provider contracts a requirement
that calls for the development and implementation of corrective action
plans as a result of any Department reviews, inspections, evaluations or
monitoring activities. If upon reinspection it is found that the provider
is still out of compliance, the Department will impose financial and/or
contract sanctions.
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Fiscal Accountability
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The Division will establish a cap on administrative cost within its contracts
with all providers and will limit the amount of state and federal funds
that may be used toward the compensation of directors of provider organizations.
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The Department has sought the Attorney General's opinion and, upon receipt
of the advice, if appropriate the Division will place contractual restrictions
that clearly state that public funds will not be used to compete with private
providers in the provision of services not otherwise purchased by the state
through the regional boards; contracts with the provider.
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By July 1, 1999, begin to phase in the implementation of performance-based
contracts and payment systems as opposed to the current expense reimbursement
contracting system.
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Proceed in working with DMA in order for DHR to manage all public funds
expended by community service boards (state funds and Medicaid funds) by
July 1, 1999. This action also removes the current community service board
monopoly under the clinic option for Medicaid funds.
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To initiate greater competition and contingent on the two previous items,
the Division will take the necessary steps to begin to include more private
providers under contract to gain greater efficiency and effectiveness of
programs.