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

2. Webinar Instructions
Webinar is being recorded and will be available on our website
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

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

4. How does Privacy and Data Sharing impact VBP discussions?

5. 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.

6. 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
address
Phone number
Health insurance numbers
Agency account/chart numbers
Vehicle identifiers
Photos
Voice recordings

7. 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.

8. 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

9. 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).

10. Questions/Comments?

11. RCHC Compliance Program Annual Review

12. 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

13. 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

14. 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!

15. 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:

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

17. 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 x 1257 or by at

18. 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.

19. 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

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

21. 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

22. Questions/Comments?

23. Measurement Year 3 Performance Results

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

25. 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

26. 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

27. 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

28. 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

29. 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

30. 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

31. 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.

32. 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 to Anne Cuddy or
via upload to the box.com secure share site

33. Questions/Comments?