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HomeMy WebLinkAbout1415-8 Behavioral Health Software Implementation follow-up report (Final...Follow-up report of Behavioral Health - Software implementation #14/15-8 June 2015 FOLLOW-UP REPORT Behavioral Health - Software implementation (Internal audit report #12/13-3 issued May 2014) To request this information in an alternate format, please call (541) 330-4674 or send email to David.Givans@Deschutes.org Deschutes County, Oregon David Givans, CPA, CIA, CGMA Deschutes County Internal Auditor PO Box 6005 1300 NW Wall St Bend, OR 97708-6005 (541) 330-4674 David.Givans@Deschutes.og Audit committee: Shawn Armstrong, Chair - Public member Chris Earnest - Public member Lindsey Lombard – Public member Gayle McConnell - Public member Michael Shadrach - Public member Jennifer Welander - Public member Anthony DeBone, County Commissioner Nancy Blankenship, County Clerk Dan Despotopulos, Fair & Expo Director Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 TABLE OF CONTENTS: 1. INTRODUCTION 1.1. Background ………………………………………...………………................................... 1 1.2. Objectives & Scope ……………………………………..………………………….…….… 1 1.3. Methodology ……………………………………………………..…………………….……. 1 2. FOLLOW-UP RESULTS ……………….…...………………………….............................. 2 3. APPENDICES 3.1. Appendix I – Department memorandum for follow-up (dated 6/5/15) ................... 3-9 3.2. Appendix II –Updated Workplan (Status updated as of June 2015) .................. 10-11 Follow-up report of Behavioral Health - Software implementation #14/15-8 June 2015 Page 1 1. Introduction 1.1 BACKGROUND Audit Authority: The Deschutes County Audit Committee has suggested that follow-ups occur from nine months to one year after the original report issuance. The Audit Committee’s would like to make sure departments satisfactorily address recommendations. 1.2 OBJECTIVES and SCOPE Objectives: The objective was to follow-up on the outstanding audit recommendations. Scope: The follow-up included nine (9) recommendations from the internal audit report on Behavioral Health - Software implementation (#12/13-3 issued May 2014). The follow-up reflects the status as of June 2015. The original internal audit report should be referenced for the full text of recommendations and discussion. 1.3 METHODOLOGY The follow-up report was developed from information provided by David Inbody, Operations Manager. In cases where recommendations have not been implemented, comments were sought for the reasons why and the timing for addressing these. The follow-up is, by nature, subjective. In determining the status of recommendations that were followed up, we relied on assertions provided by those involved and did not attempt to independently verif y those assertions. The department provided a memorandum detailing their current activities addressing the recommendations and their transition to a new software system. This memo is included in the Appendix. Since no substantive audit work was performed, Government Auditing Standards issued by the Comptroller General of the United States were not followed. DESCHUTES COUNTY INTERNAL AUDIT REPORT DESCHUTES COUNTY INTERNAL AUDIT REPORT DESCHUTES COUNTY INTERNAL AUDIT REPORT Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 2 2. Follow-up Results Figure I - How were recommendations implemented? The follow-up included nine (9) recommendations. Management agreed with all of the recommendations. Figure I provides an overview of the implementation status of the recommendations. The details of the updated workplan are provided in Appendix I and II. With this follow-up, all of the recommendations are still underway. As indicated in their memo, they anticipate implementation of the software in the Fall of 2015. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 3 3. Appendices Appendix I – Department memorandum for follow -up (dated 6/5/15) Memo To: David Givans From: Dave Inbody cc: Jane Smilie, DeAnn Carr, Michael Ann Benchoff Date: June 5, 2015 Re: Audit Followup – Electronic Health Records System In May 2014, a Deschutes County internal audit was released regarding the Behavioral Health electronic health records (EHR) system. Through this audit, the following concerns were identified: 1. Profiler lacks effective internal controls to assure compliance. 2. A survey of Profiler users indicated an overall dissatisfaction with the system. 3. Profiler implementation work continues. 4. Profiler disruptions are numerous and impact productivity. 5. The measurement of staff productivity is difficult. 6. System lacks effective audit process for the Quality Management team. 7. Audit log controls are insufficient. In response, the Deschutes County Health Services Department (DCHS) presented a strategy to address these concerns to the Audit Committee on August 21, 2014. The primary emphasis of this presentation was the decision by the Health Services Department, Behavioral Health Division, to transition from the current Profiler EHR system to the Epic EHR system. The Epic system is currently used by the Public Health Division. The following comparison between Profiler and Epic was provided to identify the justification for pursuing this planned transition. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 4 Concern Current (Profiler) Proposed (Epic) Effective Compliance Internal controls require County development Inclusion in statement of work User Dissatisfaction Multi-screen user interface PH support & fiscal staff satisfied; behavioral health professionals use it Ongoing Implementation System updates and testing County responsibility System updates and testing OCHIN responsibility Disruptions Loss of data creates liability risk and negative financial impact No server issues or loss of data reduces risk and protects billing Measuring Productivity Report development County’s responsibility; no collaboration Collaborative reporting capabilities Quality Management Fails to meet 4 of 21 minimum compliance standards; system overhaul required Inclusion in statement of work At that time, the following timeline was provided for successfully completing this transition. DCHS can report that this plan is on schedule and the “go-live” date for the transition from Profiler to Epic is planned for September 18, 2015. Action Time Frame Participants Statement of Work 3Q14 EHR Team; Transition Team Contract (finalize statement of work) 3Q14 Health Svcs; County Admin; OCHIN System Build 4Q14 – 2Q15 OCHIN Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 5 Action Time Frame Participants System Rollout & Training Plan 1Q15 EHR Team; Transition Team System Training 2Q15 OCHIN Program-Specific Training 2Q15 EHR Team; Health Services Staff Go-Live 3Q15 Health Services; OCHIN OCHIN, the organization DCHS is contracting with for the Epic EHR system, is redesigning their current Behavioral Health module to better address the needs of their clients. As part of the scope of work for this build, an itemized list of all DCHS required changes to the current OCHIN-Epic Behavioral Health module was included. This scope of work, agreed to by OCHIN, is currently being addressed through bi-weekly design meetings between OCHIN and DCHS clinicians and EHR staff. DCHS is also meeting bi-weekly with a work group of all OCHIN Behavioral Health clients in addressing improvement to the module. The original audit provided nine specific recommendations in addressing the concerns the audit identified. Here is an update on the department’s progress toward addressing these concerns. Software system currently lacks effective internal controls to assure compliance Recommendation #1: It is recommended for DCHS management to put in place sufficient controls to assure compliance requirements are met whether they be through software design or through additional review by staff. The Systems Performance Team (formerly the Quality Management Team) conducts quarterly data integrity audits on Behavioral Health staff. These audits identify errors in documentation and are intended to meet federal and state compliance requirements. In the most recent data integrity audit, the department achieved a 88% compliance rate. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 6 A site review was conducted by the Oregon Health Authority (OHA), the Addictions and Mental Health Division, for the department’s recertification as a provider of mental health services and substance abuse disorder services, as required by the Oregon Administrative Rules. The following organizational strengths were included in the site review final report. Changes in the compliance and quality assurance department have been witnessed in the quality of documentation. Service plan structure met all rule requirements and objectives were measureable and observable. Assessments were updated annually and written thoroughly and succinctly. Great improvements in quality management and quality assurance since the last review. Clinicians and managers reported having pride in their QM numbers which in turn leads to more ownership of their work and of the agency as a whole. Staff productivity is still in question Recommendation #2: It is recommended for the department to institute sufficient controls over services to assure they are being captured and billed. To the extent needed, the department should gain better understanding of the extent services being provided by provider. The department instituted productivity standards for all clinicians last year. Each clinician is provided an annual productivity target. This, as well as other departmental actions, has resulted in a steady increase in billed services over the past year. The following graph represents the value of billable services by quarter. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 7 Recommendation #3: It is recommended the department find and enforce a solution to its scheduling needs that better addresses client and organization needs. In the FY 2016 DCHS requested budget, a scheduler position was requested. This position will be responsible for scheduling all Behavioral Health appointments. Currently, this is the responsibility of each individual clinician. The addition of a scheduler will not only address the concern identified by the County Auditor, but is expected to improve productivity and provide more rapid rescheduling of missed or cancelled appointments. The FY 2016 Deschutes County budget is expected to be adopted by the Board of Commissioners during the last week of June. $- $100,000 $200,000 $300,000 $400,000 $500,000 $600,000 $700,000 $800,000 $900,000 Encountered (Billed) Dollars 1st Qtr 2014 2nd Qtr 2014 3rd Qtr 2014 4th Qtr 2014 1st Qtr 2015 Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 8 Quality Management Team can audit more effectively Recommendation #4: It is recommended the department, after considering the integrity of the software product and data, available staffing and the progress of implementation, coordinate the compliance efforts between billing and the Quality Management Team. Success in addressing this recommendation are explained in response to recommendation #1 and recommendation #2. Recommendation #5: It is recommended the department work toward utilizing the data in the software system to develop a coordinated quality review process for billing and quality management. The department holds monthly meetings of the Systems Performance Committee to review and analyze the latest data to assess quality and productivity. The following comment was provided in OHA in their site review final report. Systems Performance Committee is collecting and analyzing data to provide improvements and program design needs, as well as developing excellent reports for outcome measurements. Recommendation #6: It is recommended the Quality Management Team focus their audit efforts on quality and compliance efforts that require more skilled assessment of clinical documentation once they have addressed the more basic compliance efforts within the system. Within the last 12 months, the Systems Performance team has hired three new staff members. These new staff members are more broadly skilled in the areas of quality and compliance, but also are adept in performance management and data analysis. Additional comments in addressing this recommendation appear in response to recommendation #1. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 9 Audit log controls insufficient Recommendation #7: It is recommended for department to establish appropriate audit logs and the underlying oversight and reporting to assure the software is working as intended. Although this was not fully achieved with Profiler, the transition to Epic will be able to successfully address this concern. Recommendation #8: It is recommended that appropriate policies and procedures be in place for handling of the audit logs. The department is currently in the process of redesigning the current structure of departmental policies and procedures. This revision includes the updating, and where necessary, addition of new procedures. This initiative will result in addressing this recommendation. Epic will also better facilitate this effort as compared to Profiler. General software control observations Recommendation #9: It is recommended the department assess how they could address identification of clients and appropriate limiting of printing and exporting of clinical records. Clinical records are only printed and/or distributed as required by coordination of care procedures with external providers. Paper charts are no longer maintained DCBH. Any historical paper documentation is scanned into the EMR. The department has one Registered Health Information Technician (RHIT) and is in the process of hiring a second RHIT. These positions are responsible for ensuring the department’s practices are not in violation of HIPAA and any other confidentiality requirements. Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 10 Appendix II –Updated Workplan for Report #12/13-3 (Status as of June 2015) Rec# Recommendation Agree Status Updated Department comments Estimated Date 1 FINDING: Software system currently lacks effective internal controls to assure compliance. It is recommended for DCHS management put in place sufficient controls to assure compliance requirements are met whether they be through software design or through additional review by staff. Agree In progress DCBH has acquired authorization to transition its Electronic Health Record system from Profiler to OCHIN (the EMR used by the Public Health division). This transition is currently underway and full implementation will occur August 2015. Fall 2015 FINDING: Staff productivity is still a question. 2 It is recommended for the department to institute sufficient controls over services to assure they are being captured and billed. To the extent needed, the department should gain a better understanding of the extent services being provided by provider. Agree In progress DCBH has fully implemented productivity expectations and tracking and has seen a steady increase in OHP encounter data. Fall 2015 3 Same as above It is recommended the department find and enforce a solution to its scheduling needs that better addresses client and organization needs. Agree In progress All direct staff have their schedule available within the EMR. DCBH requested a Main Scheduler position in FY 2016 budget proposal. This position will manage clinician appointments for greater ease and consistency of scheduling. Fall 2015 4 FINDING: Quality Management Team can audit more effectively. It is recommended the Department, after considering the integrity of the software product and data, available staffing and the progress of implementation; coordinate the compliance efforts between billing and the Quality Management Team. Agree In progress The DCBH documentation compliance has exceeded its target of 92%. The new EMR will have additional "stop gaps" in the system to prevent potential compliance errors from occurring. Fall 2015 Follow-up report of Behavioral Health - Software implementation #14/15-7 June 2015 Page 11 Rec# Recommendation Agree Status Updated Department comments Estimated Date 5 Same as above It is recommended the Department work towards utilizing the data in the software system to develop a coordinated quality review process for billing and quality management. Agree In progress The DCBH Systems Performance Program utilizes data within the EMR to generate monthly reports and dashboards to provide ongoing quality and compliance information. Fall 2015 6 Same as above It is recommended the Quality Management Team focus their audit efforts on quality and compliance efforts that require more skilled assessment of clinical documentation once they have addressed the more basic compliance efforts within the system. Agree In progress DCBH's current Data Integrity Rate is 92% and the department has received confirmation from the April 2015 state site review that documentation is both compliant and of high quality according to state standards. Compliance and quality audits will continue to be performed on a quarterly basis to ensure ongoing adherence to rules and regulations. Fall 2015 7 FINDING: Audit log controls insufficient. It is recommended for the Department to establish appropriate audit logs and the underlying oversight and reporting to assure the software is working as intended. Agree In progress Audit logs have been incorporated into the new EMR system and will be used in a standardized fashion. Fall 2015 8 Same as above It is recommended that appropriate policies and procedures be in place for handling of the audit logs. Agree In progress Audit logs have been incorporated into the new EMR system and will be used in a standardized fashion. Fall 2015 9 FINDING: General software control observations. It is recommended the department assess how they could address identification of clients and appropriate limiting of printing and exporting of clinical records. Agree In progress Clinical records are only printed and/or distributed as required by coordination of care procedures with external providers. Historical paper documentation is being scanned into the EMR. Fall 2015 {END OF REPORT}