ODP’s Waiver Quality Strategy
Where does IM4Q fit in?
Dolores Frantz, ODP
Jennifer Fraker, ODP
Diana Ramirez, ODP
William Posavec, ODP
HCBS Quality Framework
Program design sets the stage
for achieving desired outcomes.
Program design addresses
fundamental program requirements
including:
• service standards,
• provider qualifications,
• assessment,
• service planning,
• monitoring participant
health and welfare, and
• critical safeguards (e.g.,
incident reporting and
management systems).
2
Waiver Assurances
Level of Care Determinations
Service Plans
Qualified Providers
Health and Welfare
Administrative Authority
Financial Accountability
3
CMS Vision of CQI: DDRI Model
This is
where
data
analysis
comes in
DESIGN
Plan for and set stage for
achieving positive
outcomes
IMPROVEMENT
Improve quality via
systemic changes
CONTINUOUS
CYCLE
REMEDIATION
Address negative
outcomes in a timely
manner
4
DISCOVERY
Find positive and
negative outcomes in a
systematic, timely
manner
4
CMS Vision of CQI: DDRI Model
Not a “oncea-waivercycle” event
Continuous and
Ongoing
The National HCBS Quality Enterprise, a Grant Funded by CMS
5
Improvement
Appendix H: Quality Improvement Strategy
Sums up how, where, and by whom statewide
performance results will be compiled and
trended over time each year for review and any
systemic improvement activities needed
Brings together data for analysis from a variety
of sources that support the QIS, including
IM4Q/NCI data, HCSIS, PROMISe, AE, Provider,
and SCO Monitoring data, and data from ad hoc
databases
6
CMS Expectations for QIS
• Performance measures required for all
assurances and sub-assurances
• Should be continually reaching 100%
compliance
• Should be able to aggregate remediation and
show how quickly issues are resolved
• Should be able to describe and document
methods of remediation
• Should be able to describe relevant quality
improvement initiatives (training, policy
change, etc.)
• Can use consumer surveys in conjunction
with all other data
7
Remediation
<100%
Discovery
Evidence
100%
Remediation
Evidence
100%
Compliance
The National HCBS Quality Enterprise, a Grant Funded by CMS
8
Service Plans Assurances
• The State demonstrates it has designed and
implemented an effective system for
reviewing the adequacy of service plans for
waiver participants.
Sub-Assurance A: Service Plans address all
participants assessed needs (including health and
welfare risk factors) and personal goals, either by
the provision of waiver services or through other
means.
Sub-Assurance B: The State monitors service plan
development in accordance with its policies and
procedures.
9
Sub-Assurance C: Service plans are updated/
revised at least annually or when warranted by
changes in the waiver participant’s needs.
Sub-Assurance D: Services are delivered in
accordance with the service plan, including the type,
scope, amount, duration and frequency specified in
the service plan.
Sub-Assurance E: Participants are afforded choice
between waiver services and institutional care, and
between/among waiver services and providers.
10
Service Plans Subassurance A
Consolidated Waiver
Data Source: AEOMP
Cycle 1
(CY 07-08)
n
%
Compliant
Q2.A. All assessed
needs are addressed in
the ISP.
Q4.A. The outcomes
listed on the ISP relate
to an identified
preference.
11
1254
91%
Cycle 2
(CY 09-10)
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
n
%
Compliant
435
93%
221
95%
435
97%
221
98%
Service Plans Subassurance A
Consolidated Waiver
Health and Welfare risk
factors are assessed;
Risk factors are
mitigated where
appropriate
Data Source: AEOMP
Cycle 1
(CY 07-08)
%
Compliant
n
%
Compliant
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
Q1.0H. Risk assessment
is completed.
221
99%
Q1.0I.01. If yes, services
and supports to mitigate
identified are
incorporated into the
ISP.
199
95%
12
n
Cycle 2
(CY 09-10)
Service Plans Subassurance B
Consolidated Waiver
Service Plan Development is Monitored
Data Source: AEOMP
Cycle 2: Q7.B. Do you attend your ISP
meeting?
Cycle 2 (CY 09-10)
n
%
Compliant
266
99.6%
Cycle 3: Q6.A. There is documentation
that the waiver participant attended the
ISP meeting.
Cycle 2: Q7.A. There is documentation
that the required members of the team
were invited to the ISP meeting.
Cycle 3: Q6.B. There is documentation
that the required members of the team
attended the ISP meeting.
13
435
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
96%
221
94%
87%
Service Plans Subassurance B
Consolidated Waiver
Service Plan Development is Monitored
Data Source: AEOMP
Cycle 2: Q3.B. Service frequency is
indicated in the ISP.
Cycle 2 (CY 09-10)
n
%
Compliant
435
83%
Cycle 3: Q3.A. Service frequency is
indicated in the ISP.
Cycle 2: Q1.C. Were all services and
supports in the approved ISP?
Cycle 3: Q1.C. Were all services and
supports in the approved ISP?
14
435
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
93%
221
98%
95%
Service Plans Subassurance B
Consolidated Waiver
Service Plan Development is Monitored
Data Source: AEOMP
Cycle 2: Q8.B.1. The AE authorizes
services consistent with the service
definitions.
Cycle 2 (CY 09-10)
n
%
Compliant
393
94%
Cycle 3: Q7.0A. The AE authorizes
services consistent with the service
definitions.
Cycle 2: Q8.B.2. The AE authorized
qualified providers to deliver all
services authorized in the ISP.
Cycle 3: Q7.0C. The AE authorized
qualified providers to deliver all
services authorized in the ISP.
15
435
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
97%
221
100%
97%
Service Plans Subassurance E
Consolidated Waiver
Choice of Services is
offered
Data Source: AEOMP
Q50.A Documentation
indicates choice
between and among
services was offered to
the individual/family.
Q24.0A. There is
documentation that
indicates choice
between and among
services was offered to
the individual/family.
16
Cycle 1
(CY 07-08)
n
422
%
Compliant
59%
Cycle 2
(CY 09-10)
n
%
Compliant
318
47%
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
95%
Service Plans Subassurance E
Consolidated Waiver
Choice of Providers is
offered
Data Source: AEOMP
Q51.A Documentation
indicates choice of willing
and qualified service
providers was offered to
the individual/family.
Q25.0A. There is
documentation that
indicates choice of willing
and qualified service
providers was offered to
the individual/family.
17
Cycle 1
(CY 07-08)
Cycle 2
(CY 09-10)
n
%
Compliant
n
%
Compliant
726
56%
421
67%
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
95%
Service Plans Subassurance D
Consolidated Waiver
Services and Supports are delivered
Data Source: AEOMP
Cycle 2: Q1.C.2. Based on AEO Review
of records, all services and supports in
the approved ISP were received.
Cycle 3: Q1.0D.01. Based on HCSIS
monitoring reports, all services and
supports in the approved ISP were
received.
18
Cycle 2 (CY 09-10)
n
%
Compliant
435
87%
Cycle 3 YTD
(FY 11-12)
n
%
Compliant
221
95%
Individuals receive services they need
Services Delivered in
Accordance with the Plan
FY 06-07
n
Percent of waiver participants
who indicated they received the
services they need
19
n
% Compliant
Consolidated Waiver
888
Data Source: IM4Q
% Compliant
FY 07-08
78%
1107
79%
Individuals receive services they need
20
Individuals receive services they need
21
Individuals receive services they need
22
Individuals receive services they need
23
Health and Welfare
The State demonstrates, on an ongoing
basis that it identifies, addresses and
seeks to prevent instances of abuse,
neglect and exploitation.
24
Health and Welfare
Consolidated Waiver
Data Source: HCSIS
Data Extraction Date: 06/20/12
(100% Review)
Number of
Confirmed
Incidents of
Abuse,
Neglect, and
Exploitation
25
FY
06-07
FY
07-08
FY
08-09
FY
09-10
FY
10-11
423
447
481
549
588
Individual to
Individual
Abuse
40
29
31
33
44
Other
investigated
injuries
determined
to be abuse
65
60
63
83
78
Abuse
Health and Welfare
Consolidated Waiver
Data Source: HCSIS
Data Extraction Date: 06/20/12
(100% Review)
Number of
Confirmed
Incidents of
Abuse,
Neglect, and
Exploitation
26
FY
06-07
FY
07-08
FY
08-09
FY
09-10
FY
10-11
Neglect
646
653
770
887
974
Rights
Violation
105
74
131
179
128
Misuse of
funds
324
260
262
313
313
Health and Welfare
• Critical Incident Review
# and % of critical incidents in which prompt
action (demonstrated within 24 hours) is
taken to protect the participant’s health,
safety and rights
# and % of AEs that review incidents within
24 hours of the report
# and % of critical incidents finalized within
the required timeframe (30 days)
27
Health and Welfare
• Investigation of Critical Incidents
# and % of AEs that completed investigations
in accordance with ODP standards
# and % of confirmed critical incidents where
corrective actions were carried out or planned
by the appropriate entity within the required
timeframe
# and % of AEs that maintain documentation
of incident management training
28
Health and Welfare
Consolidated Waiver
Data Source: HCSIS
Data Extraction Date: 06/20/12
(100% Review)
FY
06-07
FY
07-08
FY
07-08
FY
07-08
FY
08-09
Number of Incidents of
Restraints
2,864
2,879
2,536
3,259
3,053
369
355
344
342
330
7,984
8,388
8,172
8,405
8,458
Unduplicated Count of
Individuals with Restraints
Number of Medication
Errors
29
Health and Welfare
• Training in Reporting Abuse
# and % of waiver participants who received
information about reporting abuse, neglect,
and exploitation.
30
Individuals Feel Safe
Consolidated Waiver
Data Source: IM4Q
FY 06-07
FY 07-08
n
%
n
%
Percent of individuals who feel
safe in their homes
1541
81%
1930
80%
Percent of individuals who feel
safe during day activity
1388
87%
1662
90%
Percent of individuals who feel
safe in their neighborhood
1545
84%
2254
72%
31
Individuals Feel Safe at Day Activity
32
Individuals Feel Safe at Day Activity
33
Individuals Feel Safe at Day Activity
34
Individuals Feel Safe at Day Activity
35
36