Refuah Community Health Collaborative PROJECT ADVISORY COMMITTEE MEETING July 26, 2018 11 am – 11:45 am webinar

Webinar Instructions Webinar is being recorded and will be available on our website www.refuahchc.org Attendees who have called in are muted To ask a question: Type the question into the box on the sidebar At the end of the presentation we will read the questions aloud & provide answers

Agenda Welcome VBP Series: Privacy and Data Sharing Annual Compliance Review Performance Metrics – MY3 Results Partner Performance Bonuses

How does Privacy and Data Sharing impact VBP discussions?

What is HIPAA? HIPAA (Health Insurance Portability and Accountability Act of 1996) is United States legislation that provides data privacy and security provisions for safeguarding individually identifiable medical information. There are no restrictions on the use or disclosure of de-identified health information.

Protected Health Information (PHI) Individually identifiable information is often referred to Protected Health Information or PHI. PHI is defined as information that can “reasonably be used to identify an individual” such as: Name Address DOB Email address Phone number Health insurance numbers Agency account/chart numbers Vehicle identifiers Photos Voice recordings

Who is Subject to HIPAA? Healthcare Providers Health Centers/Hospitals Physicians/Dentists Pharmacies Nursing Homes Health Plans Health Insurance Companies Medicare/Medicaid and other governmental programs that pay for healthcare Healthcare Clearing House Entities that process health data (e.g. Healthlinkny RHIO) Business Associates and Subcontractors of these healthcare entities If one of the above covered entities contracts with your organization to help carry out its healthcare activities, you are required to comply with HIPAA.

How can you share PHI if you are subject to HIPAA? Establish a Business Associates Agreement (BAA) between the entities doing the sharing Obtain consent to share from all clients involved If no BAA is in place between agencies, the PPS may be asked to transmit the information, provided it has a BAA on file with both agencies PPS Agency 2 Agency 1

Exception: Substance Use SUD data may be shared only with a consent from the patient that meets requirements of 42 CFR Part 2 or under a Qualified Service Organization (QSO).

Questions/Comments?

RCHC Compliance Program Annual Review

RCHC’s Compliance Program Introduction What exactly is compliance? Establishes and promotes a culture of integrity and ethical behavior Utilizes tools to prevent and/or detect violations of law or policy Encourages problems to be reported Provides a mechanism for constant monitoring Provides assistance in complying with complex governmental regulations Safeguards public and private funds; helps control fraud, waste, and abuse

RCHC’s Compliance Program Introduction As a Partner, what am I expected to do? Participate in good faith in meeting the applicable metrics of the DSRIP program Implement training and education provided by the PPS Lead Develop or maintain a compliance program where required under NYS law Observe contractual and other compliance requirements as required by the PPS Lead and state law, regulation, and policy

RCHC’s Compliance Program Consists of… Compliance Committee and oversight from EGB Compliance Plan Designation of a Chief Compliance Officer Written policies and procedures Anonymous reporting mechanism Training and education responsibilities And more!

RCHC Compliance Plan Mission is to instill a culture of prevention, detection, and resolution of all instances of non- compliance with DSRIP Rules and Regulations as well as PPS Protocols. Ensures that PPS Providers and Personnel are familiar with DSRIP conditions of participations, applicable federal and state rules and regulations, and properly implement PPS Project Plans. Compliance Plan can be found online at: http://www.refuahchc.org/compliance/

RCHC Policies and Procedures: Where can I find them? Can be found on RCHC’s website: http://www.refuahchc.org/compliance/ Includes all PPS approved policies: Compliance Policies Financial Policies Check often for new policies added and/or revisions to made to existing policies

Designation of Chief Compliance Officer RCHC has designated a Chief Compliance Officer charged with the day to day operations and monitoring of the Compliance Program. RCHC’s Chief Compliance Officer is Azizza Graziul, Esq. She can be reached at 845-354-9300 x 1257 or by email at agraziul@refuahchc.org

Standards of Conduct General Standards: Standards place affirmative duty on all personnel to report actual or perceived violations Personnel are expected to be familiar with and abide by RCHC’s Compliance Program and policies and procedures. No employment, engagement, or payment to excluded entities or persons: In order to receive federal funds under DSRIP, a partner must not be an excluded entity. Monthly exclusion checks are performed. Personnel must appropriately and accurately record and report DSRIP- related information, transactions and activities, including records related to patients and their care.

Standards of Conduct Confidentiality- Patient Information: All personnel must abide by HIPAA privacy and security standards regarding protected health information Patient information must be treated with utmost confidentiality Confidentiality- Business Information: Personnel may gain access to confidential information by virtue of his/her participation in or position within their respective organization. Personnel may not communicate confidential information about its organization, partners, or any patients covered by the DSRIP program as it pertains to RCHC, including information of or about another RCHC participating entity or its patients, to anyone and may not be used as a basis for personal or family gain

Who Do I Contact with DSRIP Related Compliance Concerns? Speak with your supervisor or manager Contact RCHC’s Chief Compliance Officer, Azizza Graziul at 845-354-9300 x 1257 or agraziul@refuahchc.org You may report any potential instances of non- compliance anonymously through the Compliance Hotline: By Phone: (844) 280-0009. The Hotline is open 24/7/365 and its focus is encourage reporting of any fraud, waste, and abuse. By Email: reports@lighthouse-services.com

Training and Education Partners are expected to disseminate all trainings and education to their organization from RCHC Partner will attest to the dissemination of all trainings to RCHC “Targeted” trainings will be provided to individual partners engaged in RCHC projects Go to http://www.refuahchc.org/compliance/

Questions/Comments?

Measurement Year 3 Performance Results

Potentially Preventable Events Performance Metric Met Annual Improvement Target High Performance Target Statewide Goal Low Avoidable ER Visits Low Readmissions

Behavioral Health Follow-up Measures Performance Metric Met Annual Improvement Target High Performance Target Statewide Goal Seen within 7 days of BH discharge Seen within 30 days of BH discharge Initiation of Alcohol/SUD treatment (1st visit within 14 days of initial diagnosis submitted on a claim) N/A Engagement of Alcohol/SUD treatment (3 visits within 44 days of diagnosis submitted on a claim) ADHD Medication Initiation phase (1 follow-up visit within 30 days of med dispensing date) ADHD Medication Continuation phase (2 more visits within 9 months of first follow-up visit) Highlight ADHD

Medication Adherence Measures Performance Metric Met Annual Improvement Target High Performance Target Statewide Goal Antidepressant – Acute Phase (12 weeks) Antidepressant – Continuation Phase (6 months) Antipsychotics (80% compliance) N/A Number of days medication was dispensed

Screening for BH conditions Performance Metric Met Annual Improvement Target High Performance Target Statewide Goal Screen + Follow up for Depression N/A Diabetes screen in people on antipsychotics

Access Measures: Primary Care visit within the year Performance Metric (Age) Met Annual Improvement Target High Performance Target Statewide Goal 12-24 months N/A 25 mos – 6 7-11 yrs 12-19 yrs 20-44 yrs 45-64 yrs 65+ yrs Our PPS has about 49k Medicaid members attributed to it. 6k of them are randomly assigned “nonutilizers” enrolled in Medicaid but not using any billed services

Annual Improvement Target High Performance Target CAHPS Survey Measures Consumer Assessment of Healthcare Providers and Systems Performance Metric Met Annual Improvement Target High Performance Target Statewide Goal Timely appointments, care and information N/A Length of primary care relationship Care provided by usual source of care Provider up-to-date about care received from hospital/other providers Saw provider within 15 minutes of appointment time and got Got appointment for check - up or routine care as soon as you needed

High Performance Fund Distribution Partner rosters of clients served during the measurement period will be matched against the state-provided list of patients whose outcomes enabled us to meet performance targets. Partner roster State list

Next Step – Provide the Rosters Provide Refuah a list of Medicaid CINs for each unique patient “served” by your organization during the following measurement periods: 7/1/2016-6/30/2017 7/1/2017-6/30/2018 Provide Refuah a list of Medicaid CINs for each unique patient treated by a licensed mental health professional in your organization during above time periods.

Deadline for submission August 15 Rosters must by submitted to the PPS by Aug 15 to be eligible for the high performance bonus Submit via encrypted email to Anne Cuddy acuddy@refuahchc.org or via upload to the box.com secure share site

Questions/Comments?