Provider Update: June 28, 2018
ADvantage and State Plan Personal Care FY19 Updated Audit Process
(July 1, 2018- June 30, 2019)
- A copy of each audit tool that relates to the service(s) your agency provides is enclosed (ADvantage Case Management, ADvantage Home Care, ADvantage Assisted Living, ADvantage Adult Day Health, &/or State Plan Personal Care) as well as the Financial Staffing Quality Review (FSQR) tool. Specific questions about the Quality Assurance/Improvement Provider Audit tool(s) should be directed to the Oklahoma DHS/Aging Services (AS) Quality Assurance/Improvement Programs Assistant Administrator, Miranda Kieffer, at 405-522-0278 or email Miranda.Kieffer@okdhs.org.
Preparation for Audit
- The Lead Auditor will contact your agency 10-14 calendar days prior to your audit to inform you of the audit date/time and the audit timeframe. If the person that is responsible for Quality Assurance at your agency will not be present during the audit, please provide the Lead Auditor with the name and contact information of the designee. FY2019 audits will be conducted onsite.
- At the conclusion of the Entrance Interview, the Lead Auditor will provide your agency with a list of Members and PCAs, if applicable, to be audited. The Member Sample is a proportionate random sample. Your agency will have one hour following the Entrance Interview to make available all requested Member Records and all requested PCA files to the audit staff; an additional 30 minutes may be given only in the event the provider agency is required to pull PCA names for the sample Members. The Lead Auditor will confirm that the requested Member Records/PCA files are present at the end of the allotted time, or sooner if the records/files are provided earlier. Records/files not made available to the audit staff during the designated time will receive deficiencies for all conditions related to that Member Record or PCA file respectively. When your agency is notified of the upcoming audit, please inform the Lead Auditor or the QAI Programs Assistant Administrator if you have circumstances that would prevent you from complying with this process.
- The audit timeframe for ADvantage Home Care and ADvantage Assisted Living agencies will continue to be 12 months; however, the auditor will only review PCA files for PCAs that served Members in the last 3 months of the audit timeframe.
- Additional information/documentation your agency may be requested to provide, includes:
- Policy/Procedure Book
- Incident Log
- Critical Incident Log
- High Risk Policy
- Sample Member Packet
- Sample PCA Orientation Packet
- Community Integration Logs
- Members will be contacted to answer Member Perception conditions by telephone or by home visit. The auditor will utilize information found in the agency file to determine the type of contact to be conducted.
- Member Perception conditions are not included in your agency audit score; however, Member responses will be recorded and provided on your audit reports.
Annual Audit Exit Meeting
- Exit Meetings are conducted from the Lead Auditor's desk, utilizing SmarterMail or the Harmony system as applicable.
- After the Lead Auditor emails and reviews the Preliminary Audit Findings with you, your agency will be given two hours to review the document and determine if the auditor overlooked or misinterpreted information that was present in the Member Record or PCA file during the audit.
- All relevant documentation you would like considered for refute needs to sent, utilizing the QAI directions for SmarterMail or Harmony, (whichever is applicable for the audit date) provided by the Lead Auditor by the end of the allotted two hour timeframe.
- The Final Audit Report and recommendations will come from the Quality Assurance/Improvement Programs Assistant Administrator or designee via SmarterMail or Harmony, as applicable.
- If it is determined that a Plan of Correction is needed, the electronic template will be sent with the final report via SmarterMail or you will be notified in Harmony as applicable.
- Your agency will receive email or Harmony notification, (whichever applies at the time of your audit), once your Plan of Correction (POC) is approved. The Progress Report template, including the due dates of the required Progress Reports (PR), will be available at that time. Review the POC/PR Purpose of Form/Instructions and contact us with any questions regarding expectations. Delinquent remediation documents may result in removal from the Certified Agency Report for a minimum of 90 days.
- While MSU Provider Question (firstname.lastname@example.org) is always used for specific Member-relatedinquiries, questions about the audit process or Final Audit Findings should be directed to the Oklahoma DHS/Aging Services Quality Assurance/Improvement Programs Assistant Administrator, Miranda Kieffer, at 405-522-0278 or email@example.com in the Subject line ATTN: Miranda Kieffer – QAI PAA.
State Plan Personal Care Audit (SPPC)
The SPPC Audit will be conducted at the same time as your ADvantage Home Care Audit. When the auditor contacts your agency 10-14 calendar days prior to your audit to inform you of the audit date/time and the audit timeframe, it will be inclusive of ADvantage Case Management (CM), ADvantage Home Care (HC) and/or SPPC, unless otherwise noted on the call. The SPPC Annual Audit Exit Meeting and the Final Report will be conducted the same as previously detailed in conjunction with the ADvantage audit(s). Please remember that in the same manner as ADvantage audits, SPPC scores of 70% or less will result in removal from the Certified Agency Report for HC and SPPC services.
Home & Community Based Settings Providers-Assisted Living (AL) and Adult Day Health (ADH)
As indicated in previous trainings, the grace period for Assisted Living and Adult Day Health Providers to obtain annual audit scores of 70% or greater to remain on the Certified Agencies Report ended in FY 2018. Providers are now subject to the threshold outlined in the bulletin dated July 18, 2013.
If your agency requires completion of a Plan of Correction for any Annual Audit, you will also be required to have a Follow-Up Audit. The Follow-Up Audit will be conducted either on-site or off- site. If conducted off-site, the Follow-Up Audit Nurse will conduct the audit from her desk, utilizing SmarterMail or Harmony as applicable. On-site reviews may be conducted if your agency's Plan of Correction contained a large number of deficiencies, if the agency score was below 70% on the annual audit, or a deficiency is found for a Home and Community Based Settings condition. The Follow-Up Audit Exit Meeting and the Final Report will be conducted the same as previously detailed.
Following any audit, if your agency enters into the remediation process requiring a Plan of Correction (POC) and Progress Reports (PR), the QAI Programs Assistant Administrator or designee will send a one-time reminder via email 7-10 days prior to the due date of the POC or PR. This email will be sent to the agency recipient listed on the Exit Meeting Sign-In sheet.
Progress Reports are due no later than one week after completion of the 30-day self-monitoring period and will be accepted any time within that week. They will not be accepted prior to the completion of 30 days of self-monitoring. If the POC or PR is not received by the due date, your agency may be removed from the Certified Agency Report for a minimum of 90 days.
The POC and PRs must be submitted on the MSU POC/PR template provided by QAI for all audits, (or in Harmony if applicable). Submission of a POC or PR on any other form will not be accepted and will be returned to your agency for completion prior to review.
The QAI Advisor will be utilized to complete agency specific sessions with new provider agencies regarding the audit process and tools and with provider agencies that are removed from the Certified Agencies Report due to Annual Audit score of less than 70%. The QAI Programs Assistant Administrator and Lead Auditors may also make referrals to the QAI Advisor for agencies requiring or requesting advisement assistance.
Financial Staffing Quality Review Audit (FSQR)
FSQR audits may be conducted randomly or on an as needed basis.
Please be advised electronic signatures are still not accepted at this time; any document requiring a signature must have a signature obtained using paper and pen.
Please also be advised the auditors have been instructed to maintain an established professional code of ethics at all times.
- Auditors are instructed NOT to discuss the anticipated audit results with the Provider. The Preliminary Audit Findings will be presented during the Exit Meeting.
- Auditors have been advised that during the Exit Meeting, they are to present the Preliminary Findings as determined by review of information provided by the Provider Agency (Member/PCA files and supporting documentation). Refute documentation will be accepted at the Exit Meeting; however, decisions regarding amendments to the final report will NOT be decided at the Exit Meeting. Your agency will receive a final report that will indicate if an amendment was made.
- Auditors are expected to refrain from giving suggestions or recommendations to the Provider regarding processes to use with their staff to aid in complying with Program Standards, this information may be provided by the QAI Advisor.
- Any questions from the Provider regarding the formation of contractual documents or any concerns related to decisions and processes from Aging Services Medicaid Services Unit-ADvantage Administration (MSU-AA) should be referred to Provider Questions via SmarterMail.
- Any information or documents that the Provider needs to submit to the MSU-Tulsa office is to be forwarded by the Provider through the appropriate submission procedure, (see provider update dated March 18th, 2016). These documents/submissions are not to be discussed, reviewed or accepted by the auditor(s).
We appreciate your cooperation. We understand that your time is of value and, therefore, we strive to be of as little disruption to you and your staff as possible.
Recommendations provided by Provider staff are always evaluated for feasibility to assist us in providing quality outcomes for our Members.
If you have any questions regarding the information provided above, please feel free to contact us via email at: firstname.lastname@example.org.