Policy Title:
Policy #:
Appeals and State
Administrative Hearings
Signature:
Created:
QM - 13
Revised:
August 20, 2018
Community Services
Department,
Justin Johnson,
Assistant Director
Community Services
Department
Signature Date:
January 18, 2023
Reviewed:
Signing by authority of Res. No. 20180036
Spokane County Regional
Behavioral Health Division
Applies to:
Internal
External
References
Washington Administrative Code (WAC)
WAC 182-538C-040 – Grievance and Appeal System for Medicaid-funded Services
subcontracted by Managed Care Organizations (MCOs) to Behavioral Health-Administrative
Services Organization (BH-ASO)
WAC 182-538C-050 - Definitions
WAC 182-538C-110 – Grievance and Appeal System and Agency Administrative Hearing for
BH-ASOs
CSD SCRBH Policy RS 21 – Available Resources
CSD SCRBH Policy QM – 3 Grievance System
CSD SCRBH Policy CSE – 5 Notice of Action
Scope
The Spokane County Community Services Department (CSD), the Spokane County Regional
Behavioral Health (Administrative Services Organization) Division (SCRBH) and its network
providers.
1.
Policy
1.1.
The CSD SCRBH must have a system in place that complies with WAC 182538C-110. The CSD SCRBH Appeals process is for non-Medicaid Individuals
who are receiving services funded by CSD SCRBH. The CSD SCRBH Grievance
System must include:
1.1.1.
A Grievance Process;
1.1.1.1.
CSD SCRBH Policy QM - 3 Grievance System provides policies
and procedures for the CSD SCRBH Grievance process.
1.1.2.
An Appeal process; and
1.1.3.
Access to an Administrative Hearing process.
Policy # and Title: QM-13 Appeals and State Administrative Hearings
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1.2.
The CSD SCRBH must have a process in place for reporting, tracking, and
resolving all Appeals in its system of care. The CSD SCRBH shall receive and
track Appeals that come to it directly and shall maintain an internal process that
meets all requirements for written acknowledgements and resolutions.
1.3.
The CSD SCRBH and network providers shall inform Individuals of the right to
appeal a CSD SCRBH Action and the right to an Administrative Hearing.
Individuals receive a written Notice of Action (NOA) regarding the approval,
denial, suspension, reduction, or termination of services including the reason for
the decision, how the Individual may initiate an Appeal and who may assist him
or her with the Appeal process. The Individual may file an Appeal without fear of
punitive Action reprisal.
1.4.
Information about Appeals must also be made available to potential users of
CSD SCRBH-funded behavioral health services and their advocates.
1.5.
Information about the Appeals resolution process shall be provided in a manner
and language that is understandable to the Individual receiving it and must be
age, culturally, and linguistically appropriate.
1.6.
Individuals may contact the CSD SCRBH to file oral Appeals at (509) 477-4570
or 1-877-304-7183. Assistance is available in filing an Appeal.
1.7.
An Individual, the Individual’s authorized representative, or a provider acting on
behalf of the Individual and with the Individual’s written consent, may appeal a
CSD SCRBH Action.
1.8.
1.7.1.
If a provider has requested an Appeal on behalf of an Individual, but
without the Individual’s written consent, the CSD SCRBH shall not
dismiss the Appeal without first attempting to contact the Individual within
five (5) calendar days of the provider’s request, informing the Individual
that an Appeal has been made on the Individual’s behalf, and then asking
if the Individual would like to continue the Appeal.
1.7.2.
If the Individual does wish to continue the Appeal, the CSD SCRBH shall
obtain from the Individual a written consent for the Appeal. If the
Individual does not wish to continue the Appeal, the CSD SCRBH shall
formally dismiss the Appeal, in writing, with appropriate Individual Appeal
rights and by delivering a copy of the dismissal to the provider as well as
the Individual.
1.7.3.
For expedited Appeals, the CSD SCRBH may bypass the requirement for
the Individual’s written consent and obtain the Individual’s oral consent.
The Individual’s oral consent shall be documented in the CSD SCRBH’s
records.
Oral inquiries seeking to appeal an Action shall be treated as Appeals and be
confirmed in writing, unless the Individual or provider requests an expedited
resolution. The CSD SCRBH shall not require an Individual or his/her authorized
representative to provide written follow up for an Appeal the CSD SCRBH
received orally. The Appeal acknowledgement letter sent by the CSD SCRBH to
an Individual shall serve as written confirmation of an Appeal filed orally by an
Individual.
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1.9.
The Appeal process shall include all parties to the Appeal, the Individual and the
Individual’s representative, or the legal representative of the deceased
Individual’s estate.
1.9.1.
The CSD SCRBH shall cooperate with any representative authorized in
writing by the Individual.
1.10.
The Appeal process shall provide an Individual and the Individual’s
representative opportunity, before and during the Appeals process, to examine
the Individual’s case file, including medical records, and any other documents
and records considered during the Appeal process.
1.11.
The CSD SCRBH shall consider all information submitted by the Individual or
his/her representative. The Appeal process shall provide the Individual a
reasonable opportunity to present evidence, and allegations of fact or law in
writing. The CSD SCRBH shall inform the Individual of the limited time available
for this in the case of an expedited resolution.
1.12.
The CSD SCRBH shall provide individuals with any reasonable assistance
necessary to complete forms and other procedural steps for Appeals. Assistance
may be provided by a representative from the Office of Behavioral Health
Advocacy (OBHA) serving the geographic area, the CSD SCRBH or any other
person of the Individual’s choice.
1.12.1.
Assistance includes, but is not limited to, helping to prepare any written
documents or other procedural steps, the provision of interpreter and
translation services, toll-free numbers, auxiliary aids such as American
sign language, Text Telephone (TTY) or Telecommunications Device for
the Deaf (TDY) telephone services, and alternative formats to include
Braille and large print.
1.13.
Individuals may contact the OBHA at any stage of the Appeals process.
1.14.
Medicaid Individuals will be referred to their Managed Care Organization (MCO)
Apple Health Plan for filing an Appeal.
1.15.
If the Washington State Health Care Authority (HCA) receives a request to
Appeal an Action of the CSD SCRBH, the HCA will forward relevant information
to the CSD SCRBH and the CSD SCRBH will contact the Individual with
information that a provider filed an Appeal.
1.16.
The CSD SCRBH shall acknowledge in writing, the receipt of each Appeal. The
CSD SCRBH shall provide written notice to both the Individual and the
requesting provider within seventy-two (72) hours of receipt of the Appeal.
1.17.
For Appeals of standard service authorization decisions, an Individual, or a
provider acting on behalf of the Individual, must file an Appeal, either orally or in
writing, within sixty (60) calendar days of the date on the CSD SCRBH’s Notice
of Action. This also applies to an Individual’s request for an expedited Appeal.
1.18.
Decisions regarding Appeals shall be made by Health Care Professionals with
clinical expertise in treating the Individual’s condition or disease if any of the
following apply:
1.18.1.
If the Individual is appealing an Action; or
1.18.2.
If the Appeal involves any clinical issues.
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1.19.
2.
With respect to any decisions described in Subsection 1.18., the CSD SCRBH
shall ensure that the Health Care Professional making such decisions:
1.19.1.
Was not involved in previous levels of review or decision making;
1.19.2.
Has clinical expertise in treating the Individual’s condition or disease that
is age appropriate (e.g., a board-certified Child and Adolescent
Psychiatrist for a Child);
1.19.3.
A physician board-certified or board-eligible in Psychiatry or Child or
Adolescent Psychiatry if the Grievance or Appeal is related to inpatient
level of care denials for psychiatric treatment;
1.19.4.
A physician board-certified or board-eligible in Addiction Medicine or a
Sub-specialty in Addiction Psychiatry if the Grievance or Appeal is related
to inpatient level of care denials for substance use disorder (SUD)
treatment; and
1.19.5.
Are one (1) or more of the following, as appropriate, if a clinical Grievance
or Appeal is not related to inpatient level of care denials for psychiatric or
SUD treatment:
1.19.5.1.
Physicians board-certified or board-eligible in Psychiatry,
Addiction Medicine, or Addiction Psychiatry;
1.19.5.2.
Licensed, doctoral-level clinical psychologists; or
1.19.5.3.
Pharmacists.
1.20.
In any Appeal of an Action by a Subcontractor, the CSD or its Subcontractor shall
apply the CSD SCRBH’s own clinical practice guidelines, standards, protocols, or
other criteria that pertain to authorizing specific services.
1.21.
The CSD SCRBH shall comply with timeframes for resolving Appeals identified
under Section 3 Procedures, subsections 3.1.9. through 3.1.9.3., and notice of
resolutions requirements described under Section 3 Procedures, subsections
3.1.10. through 3.1.10.4.1.
1.22.
When available resources are exhausted, any Appeal or Administrative Hearing
process related to a request for authorization or a non-crisis service will be
terminated since non-crisis services cannot be authorized without funding,
regardless of medical necessity.
1.23.
If an Individual does not agree with the CSD SCRBH’s resolution of an Appeal,
the Individual may file a request for an Administrative Hearing within one hundred
and twenty (120) calendar days of the date of notice of the resolution of the
Appeal. The CSD SCRBH will not be obligated to continue services pending the
results of the Administrative Hearing.
Definitions
2.1.
“Action” – means the denial or limited authorization of a service covered under
the BH-ASO contract based on medical necessity. A Notice of Action (NOA) is
sent to Individuals with information about the decision and their Appeal rights.
2.2.
“Administrative Hearing” means an adjudicative proceeding before an
administrative law judge or a presiding officer that is governed by Chapter 34.05
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or the Agency’s hearing rules found in Chapter 182 WAC to review a CSD
SCRBH decision to deny or limit authorization of a requested non-Medicaid
service communicated on an NOA.
2.3.
An “Appeal” means a request by an Individual for a review by the CSD SCRBH
of a denial of a non-Medicaid service.
2.4.
“Appeal Process” means the CSD SCRBH’s procedures for reviewing an
Action.
2.5.
“Authorization” is a decision made by the CSD SCRBH or its designee that a
request for outpatient or inpatient behavioral health care meets eligibility criterion
is medically necessary and is approved for authorization/payment.
2.6.
“Authorized Representative” is a representative appointed by an Individual, or
authorized under State or other applicable law, to act on behalf of an Individual or
other party involved in an Appeal or Grievance. If the Individual gives written
permission, the Authorized Representative may include a behavioral health
practitioner working on behalf of the Individual.
2.7.
“Available Resources” means funds appropriated for the purpose of providing
community behavioral health programs, which may include federal funds, except
for those provided according to Title IX of the Social Security Act, and state funds
appropriated under RCW 71.24 or RCW 71.05 by the legislature for the purpose
of providing residential services, resource management services, community
support services and other behavioral health services. The priorities for
behavioral health resources are found in CSD SCRBH policy RS - 21 Available
Resources.
2.8.
“Behavioral Health” means mental health and substance use disorder
conditions and related benefits.
2.9.
“Behavioral Health-Administrative Services Organization (BH-ASO)” means
an entity selected by the HCA to administer behavioral health programs,
including crisis services for Individuals in a fully integrated managed care
regional area, regardless of an Individual’s ability to pay. The CSD SCRBH is the
BH-ASO for the Spokane region, which includes the following counties –
Spokane, Stevens, Ferry, Pend Oreille, Lincoln, and Adams.
2.10.
“Denial” or “Adverse Authorization Determination” is a decision by the CSD
SCRBH or its designee not to authorize a CSD SCRBH contracted behavioral
health service that has been requested by a provider on behalf of an Individual,
for reasons of medical necessity or any other reason such as lack of Available
Resources.
2.11.
“Individual” means any person in the Spokane Regional Service Area (RSA)
regardless of income, ability to pay, insurance status or county of residence. With
respect to non-Crisis Services, “Individual” means a person who has applied for,
is eligible for, or who has received General Funds State/Federal Block Grant
(GFS/FBG) services through the HCA Contract.
2.12.
“Medical Necessity or Medically Necessary” is a requested service which is
reasonably calculated to prevent, diagnose, correct, cure, alleviate, or prevent
the worsening of conditions in the recipient that: endanger life, cause pain and
suffering, result in illness or infirmity, threaten to cause or aggravate a handicap,
or cause physical deformity or malfunction, and there is no other equally
Policy # and Title: QM-13 Appeals and State Administrative Hearings
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effective, more conservative, or substantially less costly course of treatment
available, or suitable for the person requesting the service. “Course of treatment”
may include mere observation or, where appropriate no treatment at all.
2.13.
“Notice of Action” is a written notice issued by the CSD SCRBH or its designee
to an Individual to communicate an Action.
2.13.1.
3.
A Notice of Action may include:
2.13.1.1.
The denial or limited authorization of a requested service,
including the type or level of service;
2.13.1.2.
The approval of services authorized and/or a letter informing
the Individual that a requested service or level of care has
been approved.
2.13.1.3.
The reduction, suspension, or termination of a previously
authorized service;
2.13.1.3.1.
Reduction means the decision by the CSD SCRBH to
decrease a previously authorized behavioral health
service. The clinical decision by a provider agency to
decrease or change a covered service in the Individual
Service Plan (ISP) is not a reduction.
2.13.1.3.2.
Suspension means the decision by the CSD SCRBH to
temporarily stop previously authorized behavioral
health services described in the Level of Care
guidelines or addressed by the American Society of
Addiction Medicine (ASAM) Criteria. The clinical
decision by a provider agency to temporarily stop or
change a covered service in the ISP is not a
suspension.
2.13.1.3.3.
Termination means the decision by the CSD SCRBH or
designee to stop a previously authorized behavioral
health service described in the Level of Care
Guidelines. The clinical decision to temporarily stop or
change a covered service in the ISP is not a
termination.
2.13.1.4.
The denial, in whole or in part, of payment for a service; and
2.13.1.5.
The failure to provide services in a timely manner, as defined
by the state.
Procedures/Mechanisms
3.1.
Appeal Process
3.1.1.
An Individual, the Individual’s authorized representative, or a provider
acting on behalf of the Individual and with the Individual’s written consent,
may appeal a CSD SCRBH Action.
3.1.1.1.
If a provider has requested an Appeal on behalf of an Individual,
but without the Individual’s written consent, the CSD SCRBH shall
not dismiss the Appeal without first attempting to contact the
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Individual within five (5) calendar days of the provider’s request,
informing the Individual that an Appeal has been made on the
Individual’s behalf, and then asking if the Individual would like to
continue the Appeal.
3.1.1.2.
If the Individual does wish to continue the Appeal, the CSD
SCRBH shall obtain from the Individual a written consent for the
Appeal. If the Individual does not wish to continue the Appeal, the
CSD SCRBH shall formally dismiss the Appeal, in writing, with
appropriate Individual Appeal rights and by delivering a copy of
the dismissal to the provider as well as the Individual.
3.1.1.3.
For expedited Appeals, the CSD SCRBH may bypass the
requirement for the Individual’s written consent and obtain the
Individual’s oral consent. The Individual’s oral consent shall be
documented in the CSD SCRBH’s records.
3.1.2.
If the HCA receives a request to appeal an Action of the CSD SCRBH,
the HCA will forward relevant information to the CSD SCRBH and the
CSD SCRBH will contact the Individual with information that a provider
filed an Appeal.
3.1.3.
For Appeals of standard service authorization decisions, an Individual, or
a provider acting on behalf of the Individual, must file an Appeal, either
orally or in writing, within sixty (60) calendar days of the date on the CSD
SCRBH’s NOA. This also applies to an Individual’s request for an
expedited Appeal.
3.1.4.
The Appeal process shall provide the Individual a reasonable opportunity
to present evidence, and allegations of fact or law in writing. The CSD
SCRBH shall inform the Individual of the limited time available for this in
the case of an expedited resolution.
3.1.5.
The Appeal process shall provide the Individual and the Individual’s
representative opportunity, before and during the Appeals process, to
examine the Individual’s case file, including medical records, and any
other documents and records considered during the Appeal process.
3.1.6.
The Appeal process shall include as parties to the Appeal, the Individual
and the Individual’s representative, or the legal representative of the
deceased Individual’s estate.
3.1.7.
In any Appeal of an Action by a provider, the CSD SCRBH or its provider
agency shall apply the CSD SCRBH’s own clinical practice guidelines,
standards, protocols, or other criteria that pertain to authorizing specific
services.
3.1.8.
The CSD SCRBH shall resolve each Appeal and provide notice, as
expeditiously as the Individual’s health condition requires, within the
following timeframes:
3.1.8.1.
For standard resolution of Appeals and for Appeals for
termination, suspension, or reduction of previously authorized
services a decision must be made within fourteen (14) calendar
days after receipt of the Appeal, unless the CSD SCRBH notifies
the Individual that an extension is necessary to complete the
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Appeal; however, the extension cannot delay the decision beyond
twenty-eight (28) calendar days of the request for Appeal.
3.1.9.
3.1.8.2.
For any extension not requested by an Individual, the CSD
SCRBH must give the Individual written notice of the reason for
the delay.
3.1.8.3.
For expedited resolution of Appeals or Appeals of behavioral
health drug authorization decisions, including notice to the
affected parties, no later than three (3) calendar days after the
CSD SCRBH receives the Appeal.
The CSD SCRBH shall provide notice of the resolution of the Appeal in a
language and format which is easily understood by the Individual. The
notice of the resolution of the Appeal shall:
3.1.9.1.
Be in writing and sent to the Individual and the requesting
provider. For notice of an expedited resolution, the CSD SCRBH
shall also make reasonable efforts to provide oral notice;
3.1.9.2.
Include the date completed and reasons for the determination;
and
3.1.9.3.
Include a written statement of the reasons for the decision,
including how the requesting provider or Individual may obtain the
review or the decision-making criteria.
3.1.9.4.
For Appeals not resolved wholly in favor of the Individual:
3.1.9.4.1.
3.2.
Include information on the Individual’s right to request
an Administrative Hearing and how to do so.
Expedited Appeals Process
3.2.1.
The CSD SCRBH must establish and maintain an Expedited Appeals
process for Appeals when the CSD SCRBH determines or a provider
agency indicates that taking the time for a standard resolution of an
Appeal could seriously jeopardize the Individual’s life or health and ability
to attain, maintain, or regain maximum function.
3.2.2.
The Individual may submit an expedited Appeal either orally or in writing.
3.2.3.
The CSD SCRBH shall make a decision on the Individual’s request for an
expedited Appeal and provide written notice, as expeditiously as the
Individual’s health condition requires, within three (3) calendar days after
the CSD SCRBH receives the Appeal. The CSD SCRBH shall also make
reasonable efforts to provide oral notice.
3.2.4.
The CSD SCRBH may extend the timeframes by up to fourteen (14)
calendar days if the Individual requests the extension, or the CSD
SCRBH shows there is a need for additional information and how the
delay is in the Individual’s best interest.
3.2.5.
For any extension not requested by an Individual, the CSD SCRBH must
give the Individual written notice of the reason for the extension.
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3.2.6.
The CSD SCRBH shall ensure that punitive Action is not taken against a
provider who requests an expedited resolution or supports an Individual’s
Appeal.
3.2.7.
If the CSD SCRBH or designee denies the request for the expedited
Appeal and resolution of an Appeal, it must transfer the Appeal to the
timeframe for standard resolutions (found in the Standard Appeals
process section of this policy) and make reasonable effort to give the
Individual prompt oral notice of the denial and follow up within two (2)
calendar days with a written Notice.
3.2.8.
The written decision must:
3.2.8.1.
Clearly state the decision on the Appeal, the reason for the
decision, and the date the decision was made;
3.2.8.2.
Inform the person of the right to an Administrative Hearing if the
person disagrees with the decision, how to request a hearing, and
the following timeframes for requesting a hearing:
3.2.8.2.1.
A hearing must be requested within one hundred
twenty (120) days from the date on the notice of the
decision; and
3.2.8.2.2.
There is no right to continuing benefits.
3.2.8.3.
3.3.
Be in an easily understood format following which requires that
each notice:
3.2.8.3.1.
Be written in the person’s non-English language, if
applicable;
3.2.8.3.2.
Contains the CSD SCRBH’s toll-free and TTY/TDY
telephone numbers; and
3.2.8.3.3.
Explains the availability of free written translation, oral
interpretation to include any non-English language,
auxiliary aids such as American Sign Language and
TTY/TDY telephone services, and alternative formats
to include large print and Braille.
Administrative Hearings
3.3.1.
Only the Individual or the Individual’s Authorized Representative may file
a request for an Administrative Hearing. A provider may not request an
Administrative Hearing on behalf of an Individual.
3.3.2.
If an Individual does not agree with the CSD SCRBH’s resolution of the
Appeal, the Individual may file a request for an Administrative Hearing
within one hundred and twenty (120) calendar days of the date of notice
of the resolution of the Appeal. The CSD SCRBH will not be obligated to
continue services pending the results of the Administrative Hearing.
3.3.3.
The CSD SCRBH Behavioral Health Medical Director shall review all
cases where an Administrative Hearing is requested and any related
Appeals.
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3.3.4.
If the Individual requests an Administrative Hearing, the CSD SCRBH
shall provide the HCA and the Individual, upon request, and within three
(3) business days, all CSD SCRBH-held documentation related to the
Appeal, including, but not limited to, transcript(s), records, or written
decision(s) from participating providers or delegated entities.
3.3.5.
The CSD SCRBH is an independent party and is responsible for its own
representation in any Administrative Hearing, Board of Appeals, and
subsequent judicial proceedings.
3.3.6.
The Individual must exhaust all levels of resolution and appeal with the
CSD SCRBH’s Grievance System prior to filing a request for an
Administrative Hearing with the HCA.
3.3.7.
The CSD SCRBH will be bound by the final order, whether or not the final
order upholds the CSD SCRBH’s decision.
3.3.8.
If the final order is not within the purview of the CSD SCRBH’s contract
with the HCA, then the HCA will be responsible for the implementation of
the final order.
3.3.9.
The Administrative Hearings process shall include as parties to the
Administrative Hearing, the CSD SCRBH, the Individual and the
Individual’s representative, or the legal representative of the deceased
Individual's estate and the HCA.
3.3.10.
Petition for Review
3.3.10.1.
3.3.11.
Effect of Reversed Resolutions of Appeals and Administrative Hearings
3.3.11.1.
4.
Any party may appeal the initial order from the Administrative
Hearing to the HCA Board of Appeals in accordance with Chapter
182-526 WAC. Notice of this right shall be included in the Initial
Order from the Administrative Hearing.
If the CSD SCRBH’s decision not to provide Contracted Services
is reversed, either through a final order of the Washington State
Office of Administrative Hearings or the HCA Board of Appeals,
the CSD SCRBH shall provide the disputed services promptly,
and as expeditiously as the Individual’s health condition requires.
Record-keeping and Reporting Requirements
4.1.
The CCD SCRBH shall maintain records of all Grievances, Adverse
Authorization Determinations, including Actions and Appeals.
4.2.
The records shall include Grievances, Adverse Authorization Determinations,
including Actions and Appeals handled by delegated entities, and all documents
generated or obtained by the CD SCRBH in the course of these activities.
4.3.
The CSD SCRBH shall provide separate reports of all Actions, Grievances, and
Appeals related to contracted services to the HCA in the format specific by the
HCA quarterly, due the fifteenth (15th) of the month following the end of the
quarter.
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4.4.
The CSD SCRBH is responsible for maintenance of records for and reporting of
any Actions, Grievances, and Appeals handled by delegated entities.
4.5.
Delegated Actions, Grievances, and Appeals are to be integrated into the CSD
SCRBH's report.
4.6.
Data shall be reported in HCA and CSD SCRBH agreed upon format. Reports
that do not meet the Grievance System Reporting Requirements shall be
returned to the CSD SCRBH for correction. Corrected reports will be resubmitted
to the HCA within thirty (30) calendar days.
4.7.
The report medium shall be specified by the HCA and shall be in accord with the
Grievance System Reporting Requirements published by the HCA.
4.8.
Reporting of Actions shall include all medical necessity determinations but will
not include denials of payment to providers unless the Individual is liable for
payment in accord with WAC 182-502-0160 and the provisions of this Contract.
4.9.
The CSD SCRBH shall provide information to the HCA regarding denial of
payment to providers upon request.
4.10.
Records shall be accurately maintained and contain, at a minimum, all of the
following:
4.11.
5.
4.10.1.
A general description of the reason for the Appeal or Administrative
Hearing;
4.10.2.
The date received;
4.10.3.
The date of each review or, if applicable, review meeting, including staff
interviews if applicable;
4.10.4.
Resolution at each level of the Appeal or Administrative Hearing, if
applicable;
4.10.5.
Date of resolution at each level, if applicable; and
4.10.6.
Name of the Individual for whom the Appeal or Administrative Hearing
was filed.
When Available Resources are exhausted, any Appeals or Administrative
Hearings related to a request for authorization of a non-Crisis Contracted Service
will be terminated since non-Crisis Services cannot be authorized without funding
regardless of medical necessity.
Monitoring
5.1.
The CSD SCRBH shall monitor any Appeal and Administrative Hearing patterns
or trends in the quarterly Quality Assessment Performance Improvement (QAPI)
Committee meetings.
5.1.1.
5.2.
As part of its QAPI Plan, the CSD SCRBH will incorporate the results of
Appeals and Administrative Hearings into its QAPI Plan and will address
any trends in a Quality Action Plan.
The CSD SCRBH will be monitored by the HCA for compliance with Grievance
System and reporting requirements for Appeals and Administrative Hearings with
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the appropriate recommendations, findings, and/or corrective Actions required in
performance improvement.
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