1. PRESENTED BY LIZZY DROBNICK, MPH/MA SENIOR ASSESSOR Preparing for a ROCA: Health and Wellness Common Concerns and Tips

2. Overview Purpose of the ROCA Report Card  Data from ROCAs Common Concerns  Recommendations  Easy fixes Tips for next ROCA

3. Purpose of ROCA What is the Regional Office Center Assessment (ROCA)?  Job Corps Regional Offices (ROs) are charged with the responsibility of providing federal oversight of the Job Corps program to ensure that it is delivered with compliance, quality, and integrity. A ROCA is part of this oversight.  The ROCA is a thorough evaluation of Job Corps centers that occurs on a need-based and risk management schedule. Every center shall have two full assessments during the life of a contract that are ideally conducted during years 2 and 5 of the life of a contract, according to the recent PRH Change Notice 15-08.  The health and wellness portion of a ROCA examines the health and wellness programs for compliance with the PRH, as well as applicable state and federal laws.

4. Who’s Who? Assessors: Lois Sacher, RN Pat Jackson, RN Cheryl Walker, APRN, MSN, MBA Gary Strokosch, MD Lizzy Drobnick, MPH

5. Who’s Who? Region 1 – Boston Shannon Bentley, RN John Kulig, MD, MPH David Kraft, MD, MPH Maria Acevedo, PhD Kevin Avery, DMD, PhD Diane Tennies, PhD Region 2 – Philadelphia Shannon Bentley, RN John Kulig, MD, MPH Valerie Cherry, PhD Kevin Avery, DMD, PhD Diane Tennies, PhD Region 3 – Atlanta Melissa Cusey, RN Gary Strokosch, MD, MPH Suzanne Martin, PsyD, MPH Kevin Avery, DMD, MPH Christy Hicks, MSW Region 4 – Dallas Shannon Bentley, RN Drew Alexander, MD Lydia Santiago, PhD Kevin Avery, DMD, MPH Christy Hicks, MSW Region 5 – Chicago Melissa Cusey, RN Gary Strokosch, MD Helena Mackenzie, PhD Pamela Alston, DDS, MPP Christy Hicks, MSW Region 6 - San Francisco Melissa Cusey, RN Sara Mackenzie, MD, MPH Vicki Boyd, PhD Pamela Alston, DDS, MPP Diane Tennies, PhD

6. Job Corps uses a Program Rating System (PRS) as a qualitative measure of performance for center/OA/CTS operations (PAG, pg 4, Aug 2008). Take home message: A satisfactory program meets PRH requirements. Scoring

7. Report Card 2014 Total number of centers reviewed: 62

8. Report Card 2015 Total number of centers reviewed: 47

9. Significance of ROCAs Identify problems on center level Influence policy Assess impact Shape trainings

10. Definitions Challenge/Weakness/Concern – refers to components that are non-compliant with the PRH or applicable state and federal laws Notable Positives/Strengths – refers to Best Practices that go above and beyond PRH requirements Observations – suggestions that can improve quality of program

11. IF IT’S NOT DOCUMENTED, IT WAS NEVER DONE! Common Concerns: Findings and Recommendations

12. Concern #1 Medication management violates state statutes or regulations:  PRH states [see 6.10, R1 (i)]: “Access to prescription medications”  PRH states [see 6.12, R5]: “are subject to prevailing state laws”  How is compliance determined?  Interview Wellness staff and subcontractors  Review of state statutes and regulations  Review of student health records and medication logs  Recommendation: Print and have available for review your state’s Physician, Nursing, and Pharmacy Practice Acts for assessors. Speak with your administration (CD, applicable staff, corporate liaison) in advance of ROCA about compliance [see PIN 15-27]. Note: There will be a webinar on Medication Management on Feb. 18th

13. Concern #2 Case management of chronic health problems not documented:  PRH states [see 6.10, R1 (b,4)]: “Students identified as having chronic health problems during the cursory or entrance physical shall be monitored as directed by the center physician or other appropriate center health-care provider.”  How is compliance determined?  Review of student health records (chronic care management plans, documentation in chronological medical record or SF-600)  Student interviews  Recommendation: Document case management in student health record. Documentation should include regular monitoring and education regarding the importance of self-responsibility and how chronic illness may affect maintaining employment.

14. Concern #3 Missing documentation from off-center referrals:  PRH states [see 6.10, R1 (j)]: “An off-center specialist referral system”  How is compliance determined?  Review of student health records  Recommendation: Request documentation from all referral sources to ensure that information on the current health status of the student is complete and available. Send a signed authorization for release of information along with the student when he/she goes off center for medical reasons.

15. Concern #4 Authorizations and/or health care guidelines (HCGs) are not up to date  PRH states [see 6.12, R9 (a,b,c)]: “ All health care guidelines shall be approved and signed annually by the center physician, CMHC, or center dentist, as appropriate. Current signed and dated HCGs shall be kept in the Health and Wellness Center. Annually, each center shall submit a memorandum to the Regional Office indicating which HCGs have been modified. Copies of any individual health staff authorizations and health care guidelines that have changed shall be sent to the Regional Office for approval.”  How is compliance determined?  Review of health care guidelines  This includes review of all authorizations, treatment guidelines, and symptomatic management guidelines  Recommendation: Update health care guidelines as new ones become available. Have new subcontractors sign authorizations. Have a copy of the signed and dated memorandum from the Regional Office.

16. Concern #5 Inadequate staffing:  PRH states [see 6.12, R1(a,b)]: Ensure that health services staffing is in compliance with the staffing levels presented in Exhibit 6-5 and the minimum staff qualifications identified in Chapter 5, Exhibit 5-3b. Employ or subcontract with medical, dental, TEAP, and mental health professionals subject to the prior approval of the RO, in consultation with the Regional HS.”  PRH states [see 6.12, R5]: “subject to prevailing state laws”  How is compliance determined?  Review of staffing charts  Interview of Wellness staff  Review of credentials, licenses, waivers, and other materials  Review of state statutes and regulations  Recommendation: Hire staff that meet PRH requirements and if an exception is made obtain a waiver from the Regional Office. Print and have available for review your state’s various Practice Acts for assessors [see PIN 15-27]. Speak with your administration (CD, applicable staff, corporate liaison) in advance of ROCA about compliance. Note: There will be a webinar on State Practice Acts on Feb. 10th

17. EASIER FIXES Other Common Concerns and Observations

18. Other concerns – 6.10 Student Health Services Oral Health and Wellness Program  Treatment plan not developed or documented – See 6.10, R2(c)  No documentation that students have been informed about the elective oral examination (observation)  No documentation that students consent to basic oral care – See 6.12, R5(b,d) Mental Health and Wellness Program  No documentation of case conferences - See 6.10, R3(d,5) Document!

19. Other concerns – 6.11 Related Health Programs TEAP – See 6.11, R1(b,2):  CDP, CTP presentations are not done TUPP – See 6.11, R3(f):  Minor students are not provided with a referral to TUPP from staff outside of Wellness. Family Planning Program – See 6.11, R4(c,2):  The CP in conjunction with an OBGYN provider and the student do not agree on a care-management and separation plan. HIV/AIDS – See 6.11, R5(a,4):  HIV testing is not done when a student is diagnosed with a newly contracted STI. HEALs – See 6.11, R7(c,2):  Lack of weight management program Document!

20. Other concerns – 6.12 Health Administration Professional Standards of Care – See 6.12, R5(d)  Dentist, CMHC, or TEAP specialist do not document on the main chronological record or progress note (SF-600)  Lack of problem list or not consistently updated FECA/OWCP – See 6.12, R8  Students sign form that says injuries from horse play are not covered Continuous Quality Improvement – See 6.12, R15  Centers must have regular student surveys, chart audits, and CQI activities. Document!

21. Tips for your next ROCA Review this webinar: Preparing for a ROCA: Health and Wellness Review common concerns and make sure they are addressed Have pre-ROCA forms complete and available to assessors prior to ROCA Review and print federal, state, and local laws and regulations to ensure compliance List Best Practices! Document, document, DOCUMENT!

22. CONTACT INFORMATION: LIZZY DROBNICK, MPH/MA LIZZY.DROBNICK@HUMANITAS.COM Questions?