Understanding PASRR: Part 2 - How to complete a Level 1 in the Qualitrac system and a brief overview of the Level 2 process - HCPF
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Understanding PASRR: Part 2 How to complete a Level 1 in the Qualitrac system and a brief overview of the Level 2 process February 2021 2017, Telligen, Inc. © 2018,
Objectives Provide background and overview and on PASRR Process – Purpose and Intent – the What, How and Why – History of PASRR – Federal and CO State – General Process Flow – Level I to Level II Discuss requirements and process steps for PASRR Level I – Requirements Federal vs Colorado Outcomes Opportunities and Take Aways – Process Steps Process Steps Process Flow Key Take Aways Discuss requirements and process steps for PASRR Level II – Brief overview 2
Background and Overview History of PASRR: Why was PASRR created? Administered by Centers for Medicare and Medicaid Services (CMS) –Created in 1987 Before the Preadmission Screening & Resident Review (PASRR) Rule: Institutionalization of individuals with disability Inappropriate Placements (Restrictive environments) Inadequate Assessments and Care Plan Inadequate Provision of Services Discrimination based on disability Now, because of the PASRR Rule: All applicants to Medicaid-certified nursing facilities must be screened for: Mental Illness (MI), Intellectual/Developmental Disability (ID/DD) or Related Condition (RC), regardless of funding Known or suspected condition must trigger evaluation To ensure appropriateness of NF placement To ensure receipt of needed services For more on the detailed history or PASRR over the years please visit https://www.pasrrassist.org/ 4
Background and Overview Purpose and Intent: What is PASRR? PASRR is made up of a two-part process: Level 1 Screen and Level 2 Evaluation, which together have the three goals we have mentioned… 1. Detection through screens and evaluations for potential diagnoses of mental illness, intellectual disabilities or related conditions; 2. Verification of appropriateness of nursing home placement level of care and opportunities for community transition; 3. Determination of need for specialized services as additions to treatment plan. Person-Centered and Strengths-Based! Objective Supportive of self-actualization, self-efficacy and self-empowerment Promote a continuity of care Support long term goals of recovery and community engagement wherever possible 5
Background and Overview Purpose and Intent: How is PASRR operationalized? SNAP = Strengths, Needs, Abilities and Preferences How is person-centered planning different? Traditional Person-Centered Approach Approach Person Patient/Client Person/Individual “In Charge” The professional The individual Focus Impairment Life Satisfaction Solution Professional intervention Removal of barriers Results Defined by the professional Defined by the individual 6
Background and Overview Definitions in CO rule 10 CCR 2505-10 8.401.182 (1 of 3) Intellectual or Developmental Disability or Related Condition - Intellectual or developmental disability refers to significantly sub-average general intellectual functioning existing concurrently with deficits in adaptive behavior and manifested during the developmental years. – Manifested before age 22 – Likely to continue indefinitely – Results in substantial functional limitations in 3 or more of the following: Self-care; Understanding and use of language; Learning; Mobility; Self-Direction; or Capacity for independent living – “Persons with related conditions” means individuals who have a severe, chronic disability attributable to: Cerebral palsy or epilepsy Any other condition, other than mental illness, found closely related to intellectual or developmental disability. These related conditions result in impairment of general intellectual functioning or adaptive behavior similar to individuals with intellectual or developmental disability, and require treatment or services similar to those required for these individuals. 7
Background and Overview Definitions in CO rule 10 CCR 2505-10 8.401.182 (2 of 3) Mental Illness - A major mental disorder is defined as: A primary diagnosis of schizophrenic, paranoid, major affective, schizoaffective disorders or other psychosis. – Exclusions: a primary diagnosis of dementia (including Alzheimer's disease or a related disorder); a non-primary diagnosis of dementia (including Alzheimer's disease or a related disorder) without a primary diagnosis of serious mental illness, or intellectual or developmental disability or a related condition Helpful to think of the 3 Ds when determining the PASRR definition of mental illness. – 1) Duration of illness – 2) Deficits of functioning and independent ADLs – 3) Dementia exclusion 8
Background and Overview Definitions cont. (3 of 3) Specialized Services - Specified services combined with the services provided by the nursing facility, resulting in a person-centered program designed for the specific needs of eligible individuals who require the services. – Including but not limited to: Enhanced staffing in social services and activities Specialized training for staff on behavior management Creating resident specific written guidelines with positive reinforcement Crisis intervention and/or crisis planning Psychotropic medication education Daily therapeutic groups such as anger management, conflict resolution, effective communication skills, hygiene, art therapy, goal setting, problem solving Individual psychotherapy Sober supports like Alcoholics Anonymous and Narcotics Anonymous Stress management/relaxation groups such as Yoga, Tai Chi, drumming and medication Therapeutic work programming Community safety training Life skills training that includes budgeting and learning how to navigate public transportation and shopping 9
Background and Overview General Process Flow (1 of 2) Level 1 Screen = Doorway to PASRR – The Level I screening is the process that determines which individuals will receive the more in-depth Level II evaluation, thus the initial screening serves as the gatekeeper for state PASRR system – Required for each person admitting to a Medicaid licensed NH, regardless of their individual payer source – No professional requirements for the person completing the screen Level 2 Evaluation = Looking under the hood – The Level II evaluates and confirms, or disconfirms the diagnosis and PASRR applicability, based on a more comprehensive evaluation and related documentation, but this only occurs based on the decision made at the Level I stage – Required to be completed by a trained and appropriately experienced and credentialed behavioral health professional or qualified intellectual/development disability professional who is an objective 3rd party 10
Level 1 Requirements Understanding PASRR © 2017, Telligen, Inc.
Level 1 Requirements Federal vs CO vs Best Practices Federal CO Best Practices – CFR provides little – The purpose of the – Questions should be guidance on what a PASRR Level I included that seek to Level I screening tool Identification identify possible PASRR or process looks like, screening is to conditions that have not it is clear about the identify for further been reported goals of the Level I review all those previously screening clients seeking – Questions should seek to – The Level I should nursing facility look beyond reported capture all persons admission, for diagnosis of MI/ID/RC with suspected or whom it appears a – When dementia and known, serious diagnosis of mental mental illness are both mental illness, illness or intellectual present, the Level 1 intellectual / or developmental should gather sufficient developmental disability is likely. information to help the disability or related Level II evaluator condition determine which condition is primary 12
Level 1 Requirements Outcomes (1 of 2) Reduce “False Reality Negatives” and “False PASRR Condition PASRR Condition Positives” Present NOT Present PASRR Condition Likely Correct False Positive Level 1 Present (+) Outcome PASRR Condition Likely False Negative Correct NOT Present (-) 13
Level 1 Requirements Level 1 Outcomes (2 of 2) No Level 2 Needed = Level 1 Indicators for PASRR condition NOT found (- Screen) are automatically closed out and… – PASRR process ends – Retrospective QA for representative sample of automated negative screen outcomes Provisional Admission = Level 1 Indicators for PASRR condition found (+ Screen) with indicators of qualifying Provisional Admission are automatically closed out and… – PASRR process ends – Retrospective QA for representative sample of automated Categorical Determination outcomes Level 2 Required = Level 1 Indicators for PASRR condition found (+ Screen) without a Provisional Admission are reviewed manually by appropriate staff to determine if… – Determine if… Referral to Level 2 Evaluation is warranted or, A false positive for a PASRR Condition or, A missed categorical determination – If Level 2 is warranted, then a referral is made to the scheduling team 14
Level 1 Requirements More on Provisional Admissions Provisional Admissions include: 1. Is the need for NH service regarding convalescent care due to discharge from an acute care hospital and likely will require fewer than 30 days of nursing services? (Or Exempted Hospital Discharge) 2. Emergency stays due to emergency evacuations or protective services placements not to exceed 14 days. 3. Individuals with delirium where the delirium prevents an accurate diagnosis at the time of entry into the nursing home but is expected to clear within 14 days. 4. Respite stays of up to 30 days to provide respite to in-home caregivers. 15
Level 1 Requirements Opportunities and Take Aways Data on outcomes is tracked and automated Level 1 screen determinations are consistently reviewed retroactively to determine quality (keep false + and – low). Questions raised by the Level 1 screen are meant to raise critical thinking for the professional completing the form. Level 1 is not meant to be a “one and done” check list item prior to NH admission, rather it is an opportunity to evaluate needs specific to a PASRR condition from an outside objective professional perspective. A lot relies on how the form is initially filled out so good training on the intention of this process is paramount – when in doubt, fill it out! Submitting a current H&P from within 3-6 months is crucial to avoid potential requests for additional information that could delay the process. 16
Level 1 Process Steps Understanding PASRR © 2017, Telligen, Inc.
Level 1 Process Steps Process Steps For CO Medicaid recipients, when Medicaid is the primary payor, The Single Point Entry shall complete the Level 1 screen For non-Medicaid individuals admitted from the community, the NH staff shall complete the Level 1 Screen For non-Medicaid individuals admitted from the hospital, the hospital staff shall complete the Level 1 Screen Screen results are entered into the Qualitrac portal, which we will demo Staff manually review all positive screens with no provisional admission indicators and render an outcome within 6 business hours of receipt of complete information – If more information is determined to be necessary to complete the Level 1 screen review, information is requested and if returned within 3 BD, the review will continue immediately 18
Level 1 Process Steps Process Flow for 3 Outcomes of PASRR Level 1 1 Automatically Filtered QA’d at Random - Results Out Sample Level 1 Screen 2 completed in Automatically Filtered Qualitrac + Provisional Admission QA’d at Random Sample Out + Results 3 + Level 2 - Provisional Admission Manually Reviewed False + Results or False – Provisional Admission 19
Level 1 Process Steps Key Take Away of Level 1 – If the answers to the questions trigger an automated review, you will receive an immediate outcome – If the answers to the questions trigger a manual review, you will be contacted through Qualitrac to either present additional information or be informed of the review outcome 20
Level 1 Process Steps Vendor Transition Timeline February 16th 2021 February 25th 2021 March 1st 2021 • Known Triggered PALs emailed via • All PALs emailed to • Qualitrac Portal opens secure email to Coloradoreviews@telligen.com • Create user accounts Coloradoreviews@telligen.com • Begin processing all Level 1 screens via • All other PALs submitted via current Qualitrac process 21
Level 1 Form Understanding PASRR © 2017, Telligen, Inc.
Level 1 Form Form Fields PASRR Level 1 form in Qualitrac – Yes or No Questions – Section A = PASRR Condition indicators – MI Does the individual have a known or suspected diagnosis of a major mental illness? Does the individual have any indications of a major mental illness? Is the individual on antipsychotic or antidepressant medication? – Section B = PASRR Condition indicators – ID/D or RC Does the individual have a known or suspected diagnosis of intellectual or developmental disability? Does the individual have a diagnosis of a related condition such as Cerebral Palsy, autism, or seizures? Has the individual ever received services from, or been referred to, an agency serving persons with an intellectual or development disability? Does the individual have any indicators of intellectual or development disability or a related condition? Does the individual have a brain injury? – Section C = Provisional Admission Indicators Is the need for NH service regarding convalescent care due to discharge from an acute care hospital and likely will require fewer than 30 days of nursing services? Emergency stays due to emergency evacuations or protective services placements not to exceed 14 days. Individuals with delirium where the delirium prevents an accurate diagnosis at the time of entry into the nursing home but is expected to clear within 14 days. Respite stays of up to 30 consecutive days to provide respite to in-home caregivers. Manual Review triggered by a (+) in either Section A or B, and all (-) in C 23
Level 1 Form Form Demo Supporting documentation for this process with screen shots will be available as a PDF file following this online presentation and demo. First a few brief points… – There is skip logic built in so that for every Yes/No question, if you select the Yes option, more fields will appear. – You will also have the ability to upload additional documentation necessary directly to the Level 1 screen, at a minimum we require the most recent, not to exceed 6-months old, H&P and a current medication list. 24
Level 1 Form Supporting Documentation Step-by-step handouts Summary Cheat Sheets A recording of this training Support staff and resources through Telligen, HCPF, OBH and SIDA 25
Level 2 Overview Understanding PASRR © 2017, Telligen, Inc.
Level 2 Requirements Purpose and Intent As noted by PTAC, the PASRR Level II evaluation must not merely rubber stamp the outcome of the Level I. Rather it must “look behind” the diagnosis of record to identify the “true” diagnosis. The Level II must include the following elements: A history and physical (H&P), performed by a physician; A functional assessment, including activities of daily living (ADLs) and instrumental activities of living (IADLs); A history of medication and drug use; An assessment of psychiatric history performed by a qualified assessor (e.g., a psychiatrist, a licensed social worker or BHP, or a nurse with substantial psychiatric experience). 27
Level 2 Requirements Outcomes and NOD letters Outcomes are focused on – Is there a PASRR Condition? – Is the Nursing Home the Most Appropriate Level of Care? – Is there a need for Specialized Services? Once the outcomes are recommended by Telligen (within 1 BD of completed evaluations), then the applicable state authority (SMHA or SIDA) will turn the above recommendations into determinations through a Notice of Determination (NOD) letter which will be added to the case in Qualitrac. – The goal is to complete the entire PASRR process within 5-7 business days from start to finish This NOD letter should be made available to: – The Individual or representative – To the Nursing Home – And the referral source, if different from the nursing home itself 28
Level 2 Requirements Outcomes and NOD letters A word on Contingent NOD letters, – If the I/DD determination has not yet been formally made by the appropriate CCB, the PASRR process will result in a contingent NOD which means any recommendations resulting from the PASRR II evaluation should be implemented to the extent possible, knowing that the sub set of services specifically supported by I/DD funding streams will not be accessible until the I/DD determination can be confirmed. – NH staff are responsible for continuing to advocate for an I/DD determination with the relevant CCB, and if the I/DD determination is completely more than 30 days from the Contingent NOD letter, a 2nd Level 1 screen should be completed to initiate the resident review process. 29
Level 2 Requirements PAS vs RR New – Preadmission: A Level II evaluation is a comprehensive and individualized evaluation of an applicant to a Medicaid certified NF. The Level II evaluation is the function of evaluating and determining whether NF services and specialized services are needed. The exception would be for admissions to a dually certified NF under an Exempted Hospital Discharge (EHD). A Resident Review is similar to the Level II, but is conducted for a current NF resident and triggered by: An EHD stay that is exceeding 30 days The conclusion of a time limited Advanced Group Determination admission Notification to a State Authority of a resident having a significant change in condition 30
Level 2 Requirements Opportunities and Take Aways It is the responsibility and expectation of the one submitting the Level I screen into Qualitrac to provide supplemental clinical documentation that will be crucial to an effective and timely Level 2 evaluation such as: – The most recent H&P within the last 6 months, – A current medication list, – Any other relevant clinical to support any Yes answers indicated on the screen It is the expectation that the one submitting the Level I screen will share the Level I Outcome letter and the Level 2 NOD letter (if applicable) with the individual, and/or the individuals representative – In particular, the notice of recommendation for the Level 2 evaluation 31
Level II Form Form Fields PASRR II Evaluation Sections: Information about PASRR II Patient Demographics Narrative HPI Biology Free Text Discrete Data Diagnosis History Fields Medication List Medical Treatment History Behavioral Health and Support Services Treatment History Substance Use History Social Systems Social and Communication and Comprehension Environmental Psychology MSE Factors Current Behaviors ADLs Diagnostic Results of Evaluation Case Formulation Bio-Psycho-Social Evaluation 32
Summary BH Program: Understanding PASRR © 2017, Telligen, Inc.
Summary Putting it All Together PASRR is a person-centered process to provide an objective clinical assessment for folks that could potentially benefit from additional services at the nursing home level of care, specific to addressing an intellectual or mental health disability. PASRR has been around for over 3 decades and continues to maintain relevance and provide benefit for individuals, as evidence by continued resources through PTAC and a new notice of proposed rule making. PASRR is a clinical opportunity and not paperwork compliance requirement. Turnaround times and utility of output documentation matters and is key to the success of a PASRR program Telligen is committed to hearing directly from all stakeholders and evolving the process as needed to maintain the best efficacy and satisfaction for all involved. 34
Closing 1. What was a key take-away for you from this training? 2. What, if anything, will you do differently as a result? 35
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