1. Mental Health Data Alliance, LLC (MHData) April 5, 2018
DHCS CSI and DCR Data Quality Improvement Project Echo ShareCare County Issues
Mental Health Data Alliance, LLC
(MHData)
April 5, 2018

2. Project Goals
Support the ability to submit good data to the current state CSI and DCR mental health data systems
Close the feedback loop for counties to validate that they have good data in the CSI and DCR state mental health data systems
Improve the value of state CSI and DCR mental health data systems for counties, the state and stakeholders

3. Approach
Over 1.5 years:
Provided counties with 2 reports which provide an overview of current data and errors for CSI and DCR
Met with counties to review reports and identify potential causes of data patterns and inconsistencies
Work with counties and DHCS to improve processes to submit data to DCR and CSI
Provide counties with 2 reports which provide an overview of improved data for CSI and DCR

4. Echo ShareCare Counties
Lassen
Marin
Mono
Santa Barbara

5. General Findings
All CSI type services should be reported, regardless of funder.
Mode 05 programs may not be set up in EHR to report to CSI.
Echo ShareCare experienced various issues related to the upgrade to ICD-10.
Programs and providers may not be calibrated to report to CSI.
After initial calibration of the EHR, when a new provider or program is added, the submitting entity may not have a process in place to identify and flag appropriate programs and providers for reporting to CSI, resulting in a steady decline over time as old programs and providers are retired and new programs and providers become established.
Periodic records reporting is low in some cases.
The number of clients and services is unexpectedly dropping year on year for some counties
Counties have not been correcting errors; records remain in suspension(?)

6. Specific County Issues: Lassen
“Correcting errors is very difficult. Lassen has not corrected errors in a long time.”
There are 1,000s of fatal errors due to service records that have no matching client record in FY 2015/16 and FY 2016/17. CCN number does not match
Almost 1/3 of all services records submitted in FY 2015/16 and FY 2016/17 have unresolved fatal errors
Lassen County has never reported Mode 05 services.
There are fewer and fewer Periodic Records reported each month, with several months having 0 Periodic records since September of 2015

7. Specific County Issues: Marin
There are thousands of invalid secondary diagnoses (Not a valid ICD-10 secondary diagnosis)
There are non-fatal errors –“999444=relational field-both general medical condition summary code and general medical condition diagnosis fields are blank”
Mode 05 Adult Residential services have not been reported since FY 2004/05, although they are still provided
Mode 05 Hospital Inpatient services units drop in FY 2014/15 and forward
Mode 05 IMDs have not been reported on recently
Mode 05 Independent Living dropped with the switch to Echo ShareCare in FY 2010/11
There are a large number of unresolved fatal errors for this service in FY 2015/16 and FY 2016/17
Mode 15 (50-57) Mental Health Services units appear unexpectedly high beginning in FY 2011/12 and forward
There are unexpectedly fewer clients year over year.
There are unexpectedly fewer clients year over year, and especially after October 2015
Leading up to the initial review of our CSI county was catching up on CSI reporting and therefore the data was not current
A pattern has emerged in many of the CSI Data Quality issues surrounding unusually low number of services found in particular the Mode and Service Functions

8. Specific County Issues: Mono
Errors are not being corrected at this time
There are no Mode 05 Services showing for Mono, which are all out-of-county
Mode 15 Linkage/Brokerage increased in FY 2014/15 and FY 2015/16
The total number of clients drops in October 2015

9. Specific County Issues: Santa Barbara
There were 5% and 10% of unresolved fatal errors in FY 2015/16 and FY 2016/17, respectively
Mode 05 Adult Crisis Residential stopped being reported after FY 2014/15 and should still be showing
Mode 05 Adult Residential stopped being reported and should still be showing
Mode 05 IMDs are being used out-of-count and are not showing on report
County has Room & Board, but unsure if they would be picked up by this code
Mode 10 Crisis Stabilization facility was opened in FY 2015/16, but it is not showing
Mode 15 (30-38) Mental Health Services clients and units fell year on year
Mode 15 (40-48) Mental Health Services clients and units fell year on year
Mode 15 (50-57) Mental Health Services clients and units fell year on year
Mode 15 Collateral clients are decreasing year on year
Mode 15 Vocational Services are being provided but are not showing
Periodic Records appear to have unrealistic variability
Some of the providers which were expected to be on the Provider List are not showing

10. Review of What is Required to be Reported

11. CSI Reporting Requirements
Who needs to be reported?
What needs to be reported?
Reporting Periodic Records
Health Information Systems

12. Who needs to be reported?
CSI system reflects Medi-Cal clients, non-Medi-Cal clients, and services provided in County, City/Mental Health Plan programs
County-staffed providers: all clients & services must be reported
Contract Providers: Clients & services provided in contract with County Mental Health Program must be reported.
“All persons served in treatment programs must be reported to the CSI System. This includes both Medi-Cal and non-Medi-Cal clients, and persons served by the private practitioners that were formerly in the Fee-For-Service System” (MH-Ltr98-03).
Exceptions:
State Hospital and Conditional Release CONREP clients
Phase I (Inpatient) Consolidation providers and services
References: 10-Reporting Tips - Tip One - April 2016 (Technical Supplement F); MH-Ltr98-03
Reporting Tips, Tip 1 (top 3 bullets) notice (4th bullet)

13. What needs to be reported?
Client record information at first contact
24 Hour Services (Mode 05)
Day Services (Mode 10)
Outpatient Services (Mode 15)
Periodic Records
References: 10-Reporting Tips - Tip One - April 2016 (Technical Supplement F); MH-Ltr98-03
Reporting Tips, Tip 1 (top 3 bullets) notice (4th bullet)

14. Health Information Systems
MHP HIS Requirements: 
(a) The MHP shall maintain a health information system that collects, analyzes, integrates, and reports data and provides information on areas including, but not limited to, utilization, grievances and appeals as required by title 42 CFR section (a).
(b) The basic elements of the health information system as required by title 42 CFR section (b) shall, at a minimum:
(1) collect data on a beneficiary and provider and on services furnished to beneficiaries;
(2) ensure that data received from providers is accurate and complete by verifying the accuracy and timeliness of reported data; screening the data for completeness, logic, and consistency; and collecting service information in standardized formats to the extent feasible and appropriate.
Contracted Provider HIS Requirements:
Contracted providers shall maintain a health information system that collects, analyzes, integrates, and reports data.
The system shall ensure that data received from providers is accurate and complete.
The system shall make all collected data available to the Department and, upon request, to CMS.
Reference: _MHP_Contract_pg54; 9 CCR §

15. Review of Diagnoses Fields and ICD-10

16. CSI and ICD-10 Fields
Reference: CSI Data Dictionary on and after October 2015

17. Reporting DX Reference: 10-Reporting Tips – Tip Three – April 2016
International Classification of Diseases 10th Edition (ICD-10) code is required.
The Principal and Secondary Mental Health Diagnoses must be diagnoses for which mental health services are provided.
The S-09.0 Principal Mental Health Diagnosis should reflect the diagnosis that is the primary focus of attention or treatment for mental health services.
The S-10.0 Secondary Mental Health Diagnosis should reflect the diagnosis that is the secondary focus of attention or treatment for mental health services.
Up to three diagnoses are allowed in the data field S-11.0 Additional Mental or Physical Health Diagnosis. They may include mental, substance use, developmental disorders, or physical health disorders. If there are more than three diagnoses available to be reported, list the three most important.
Up to three General Medical Condition (GMC) Summary Codes from the list of general medical conditions provided are allowed in the S-34.0 General Medical Condition Summary Code field.
Identify whether or not the client has a substance abuse/dependence issue in the S Substance Abuse/Dependence field.
If the client does have a substance abuse/dependence issue, then report the substance abuse/dependence diagnosis in the S-38.0 Substance Abuse/Dependence Diagnosis field.
Reference: 10-Reporting Tips – Tip Three – April 2016

18. Reporting Rules
DHCS originally did not allow “R69” (Illness, unspecified) and “Z0389” (Encounter for observation for other suspected diseases and conditions ruled out) but believe they are now valid codes.  They had previously accepted “ ” (DIAGNOSIS DEFERRED) and “ ” (NO DIAGNOSIS), respectively.
Reference: 10-Reporting Tips – Tip Three – April 2016; communications with DHCS

19. GENERAL MEDICAL CONDITION SUMMARY CODE by County
In FY2017/18
Kern and San Luis Obispo still had large numbers of these errors
GENERAL MEDICAL CONDITION SUMMARY CODE by County

20. GENERAL MEDICAL CONDITION SUMMARY CODE

21. GENERAL MEDICAL CONDITION SUMMARY CODE

22. GENERAL MEDICAL CONDITION SUMMARY CODE

23. ADDTL MENTAL/PHYS DIAGS by County
In FY2017/18
Imperial, Marin, Mono, Monterey, San Bernardino, San Luis Obispo, Santa Clara, Sonoma, and Ventura still had large numbers of these errors

24. ADDTL MENTAL/PHYS DIAGS

25. SUBSTANCE ABUSE / DEPENDENCE DIAGNOSIS
In FY2017/18
No County had large numbers of these errors

26. SUBSTANCE ABUSE / DEPENDENCE DIAGNOSIS

27. Review of Reporting Periodic Records

28. Reporting Periodic Records
Periodic Records, which contain data elements that change such as living arrangement, are collected and submitted at three intervals:
First Contact with County Mental Health Plan
Annually thereafter for active or continuing clients
Formal Discharge from County Mental Health Plan
After initial collection at admission, it is expected that the periodic data would be collected concurrently with outcome measures.
References: Reporting Periodic Data, MH-Ltr98-03.
97-17 and (same info in both). Also Reporting Tips, Tip 5 (pretty much same thing).

29. Periodic Records Periodic Fields: P-01.0 DATE COMPLETED
P EDUCATION
P EMPLOYMENT STATUS
P CONSERVATORSHIP / COURT STATUS
P LIVING ARRANGEMENT
P-10.0 CAREGIVER

30. Reporting Periodic Records
1. AT “FIRST CONTACT” WITH THE COUNTY MENTAL HEALTH PLAN
“First contact” Periodic data collection and reporting: Collection and reporting of Periodic record data for all County Mental Health Plan clients at “first contact,” or prior to the initial provision of mental health services, ensures baseline functioning level data are collected at the beginning of each client’s contact with the County Mental Health Plan.
2. “ANNUALLY THEREAFTER” FOR ALL ACTIVE OR CONTINUING COUNTY MENTAL HEALTH PLAN CLIENTS
“Annual” Periodic data collection and reporting: Collection and reporting of Periodic record data on an annual basis for all active or continuing County Mental Health Plan clients ensures that current functioning level data are collected for analysis with baseline functioning level data to relate changes in a client’s functioning levels over time.
County Mental Health Plans are encouraged to utilize a client’s annual Universal Method to Determine Ability to Pay (UMDAP) appointment to collect Periodic record data for annual reporting. Ideally, CMHPs should report Periodic record data annually (e.g., within a twelve month period) for all active or continuing clients.
3. AT “FORMAL DISCHARGE” FROM THE COUNTY MENTAL HEALTH PLAN
“Formal discharge” Periodic data collection and reporting: Collection and reporting of Periodic record data at formal discharge (i.e., no further mental health services needed, client has reached treatment goals) from the County Mental Health Plan ensures that functioning level data as of “formal discharge” are collected for analysis with baseline and annual functioning level data to assess treatment efficacy of services delivered by the County Mental Health Plan.
References: Reporting Periodic Data
97-17 and (same info in both). Also Reporting Tips, Tip 5 (pretty much same thing).

31. Date Completed

32. Periodic Record Example

33. Example of Submissions
Clients served:
Periodic Records Submitted:

34. Example of Submissions
Clients served:
Periodic Records Submitted:

35. Periodic Record Analysis
Looked at Children 6-16 in grades 1-11 who had periodic records two fiscal years in a row and found:

36. Periodic Record Analysis
Looked at Children 6-16 in grades 1-11 who had periodic records two fiscal years in a row and found:

38. Next Steps
Request for vendors to attend Webinar for Correction and Batch correction of CSI errors on May 31.
Register:
Ask EHRs to work with counties to set up all CSI type services to report to CSI (regardless of if they are funded by Medi-Cal or other funders).
MHDATA will visit Marin and provide updated report
Ask EHRs to establish a process for identifying new programs/services which should be flagged for reporting to CSI as they come online.

39. Next Steps
Ask EHRs to comply with DHCS guidelines for Periodic Records:
Periodic information should be collected at initial contact, discharge and annually
Periodic records should only be sent when information is collected
The “Date_Completed” field in the periodic record should reflect the date the information was gathered from the client
If information is not collected, then information should not be sent

40. Discussion Other issues? Comments? Next Steps? Email Support
DHCS:
MHData:

41. DHCS CSI and DCR Data Quality Improvement Project
Mental Health Data Alliance, LLC
(MHData)