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How to effectively implement telehealth services

04.06.20

Read this if you are an IT Leader, CMO, CNO, CFO, or COO in a healthcare setting that may be looking at offering telehealth services.

Adopting telehealth technology is happening rapidly in response to social distancing and the strain that COVID-19 is putting on health systems. In response to this strain and with focus on "flattening the curve" by improving access amid a torrent of temporarily closed provider offices, some state and federal restrictions on telehealth have been lifted with the passage of the CARES Act.  

So, now, the question is not if your organization should implement telehealth services but how do you do it rapidly, effectively, holistically, and with an eye on wide-spread adoption?  

Telehealth is a bit more complex than other services, because it requires a patient to be able to use technology and follow through on provider advice―without physical discussion and interaction. Taking the time with your clinicians to increase their comfort using the technology can help put your patients at ease during this uncertain time while maintaining the clinician-patient relationship. Here are things to consider to become effective with telehealth programs:

  1. Identify purpose and goals. Do you want to expand access, support more patients, improve outcomes, support social distancing, or have further geographic reach? All of the above? 
  2. Choose an approach. Use existing technology within your EHR or use a third party solution.
  3. Test the solution. Check connectivity, devices (iPhone vs Android), and patient skill level.
  4. Camera placement is important. Making sure the patient can see the provider will be important for patients.
  5. Practice with a colleague and an open mind. Develop confidence and help foster patient trust. 
  6. Be adaptable to this being different. As this is new for all parties, showing patience and maintaining calm goes a long way to help ease patient worry.
  7. Consider and plan for the patient’s technical ability, or lack thereof. Be prepared to help troubleshoot minor technical barriers or utilize alternative processes without hampering the clinical encounter. 
  8. Look directly into the camera. Helps establish and maintain the patient-provider relationship. 
  9. Document in real time. Complete good notes, as the volume of telehealth visits and lack of physical proximity to the patient will make it more challenging to remember details later. 
  10. Develop “how to” content for your staff. This will help front line staff explain what the patient should expect before the visit and will outline clear follow up procedures, should there be any technical issues.

Once you have the more technical pieces planned, the keys to success will be testing technology and workflow and embracing the change. As we know, it doesn’t take much for a vulnerable patient to lose ground. Now is the time to expand your reach, lower costs, improve outcomes, improve relationships, show adaptability, sustain progress, and send healthcare directly into the home.

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If you have any questions about your specific needs, please contact the healthcare consulting team.

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Read this if you are a home health agency (HHA).

The Centers for Medicare & Medicaid Services (CMS) proposed rule, CY2021, was published on June 30, 2020. The proposed rule indicates that the Request for Advance Payment (RAP) currently permitted will be eliminated for all 30-day home health periods beginning on or after January 1, 2021. If adopted, this proposed rule will impact the timing of cash flow for HHAs. HHAs will no longer receive an advanced payment, but rather will not be paid until approximately 45-60 days after the period of care has begun. The change in timing of the payment should be considered as part of your HHA’s cash flow forecasting.

Note: Although the RAP payment has been eliminated, HHAs will still be required to submit a zero dollar RAP bill at the beginning of each 30-day period to establish home health services. 

Also included in the proposed rule is a transition from a RAP to a Notice of Admission (NOA) in 2022. This is similar to the Notice of Election under the hospice benefit, since there will no longer be a RAP. It is proposed that HHAs would submit a one-time NOA that establishes care in place of the RAP for the patient until discharged. 

There will be a payment penalty if either the zero dollar RAP in CY2021 or NOA in 2022 is not submitted within five calendar days from the start of care. The penalty is proposed to be a payment reduction of 1/13th to the wage and case-mix adjusted 30-day period of care reimbursement for each day late until submitted, reducing the total reimbursement for patient care. HHAs should be monitoring the timeliness of RAP submissions to be prepared for this proposed change and avoid potential reimbursement reduction if this proposed rule is passed. Read the entire proposed rule.

Please contact a BerryDunn Home Health team member to assist you with evaluating the cash flow impact these proposed changes may have to your organization. 

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Medicare Home Health Notice of Admission Proposed Rule CY2021 and its cash flow impact

Read this if you use, manage, or procure public safety and corrections technology.

Recently we discussed the benefits of developing a strong, succinct Request for Proposal (RFP) that attracts Offender Management Systems (OMS) vendors through a competitive solicitation. Conversely, we explored the advantages and disadvantages of leading a non-competitive solicitation. Industry standards and best practices serve as the common thread between competitive and non-competitive solicitations for standard implementations. So, how does an agency prepare to navigate the nuances and avoid the “gotchas” of a non-standard implementation in the corrections realm?

Functional areas in the corrections industry exist in an ever-evolving state. The ongoing functional area refinements serve to overcome potential gaps between standardizing organizations (e.g., CTA, APPA) and your agency’s operations. For example, CTA does not distinguish incidents from disciplines as distinct functional areas. While merging workflows for incidents and disciplines may align with one agency’s practice, your agency may not always correlate the two functions (e.g., disciplinary action might not always result from an incident). Moreover, your agency may not have a need for every functional area, such as community corrections, depending on the scale of your operation.

Your agency should view the industry standards as a guide rather than the source of truth, which helps you cultivate a less parochial approach driven solely by standards and follow instead a more pragmatic plan, comprised of your unique operations and best practices. CTA and APPA specifications alone will result in comprehensive solicitation. For that reason, agencies can enhance an OMS modernization initiative by enhancing solicitation requirements to include jurisdictional specifications resulting from interviews with end-users and policy research. 

Upcoming OMS webinar

On Thursday, November 5, our consulting team will host a webinar on navigating a solicitation for a new OMS. During the webinar, our team will revisit the benefits of an independent third-party on your solicitation and review industry standards, and will discuss:

  1. Crafting requirements that address common OMS functions, as well as jurisdiction-specific functions (i.e., those that address the unique statutes of the state). Crafting requirements helps your agency to ensure a replacement system addresses core business functions, provides a modern technical infrastructure, and complies with local, state, and federal regulations.
  2. Thriving with a collaborative approach when acquiring and implementing an OMS system, helping to ensure all stakeholders not only participate in the project but also buy into the critical success factors.

If you have questions about your specific situation with OMS implementations, or would like to receive more information about the webinar, please contact one of our public safety consultants.
 

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Managing non-standard Offender Management System (OMS) implementations

Read this if you use, manage, or procure public safety and corrections technology. 

In our previous post, we discussed the link between developing a technology RFP with meaning, structure, and clarity to enhance the competitive nature of the solicitation. In this article, we ask: How can your agency synthesize and unify existing business processes with industry standards to attract modern OMS providers? The answer? Your agency crosswalks. 

Industry standards, such as those set by the Corrections Technology Association (CTA) and American Probation and Parole Association (APPA), establish the benchmark for modern operations. However, legacy correction software limitations often blur the one-to-one relationship with industry standards. For that reason, crosswalk tools help agencies map current process into industry-wide standards.

CTA Functional Areas

Corrections Technology Association Functional Areas

Agencies crosswalk in preparation for a corrections technology procurement to help align system requirements with commercial-off-the-shelf (COTS) corrections management systems. In revisiting the topics of clarity, meaning, and structure, the crosswalk helps technology vendors understand your current operations, the tools your currently use to support the operations, and the way in which those operations relate to industry functional areas.

In an iterative fashion, the CTA crosswalk first helps you understand your agency’s technology and operational structure, and then communicates system requirements to correction technology providers in an industry-led framework. The approach helps you transition from your legacy processes to your new operational environment.

Although your agency can engage the market with a meaningful, structured, and clear RFP, prequalification and contract vehicles provide a viable alternative of enhancement to procuring a new offender management system. The following advantages and disadvantages can inform your agency’s decision to use a prequalification vehicle.

Advantages:

  1. Non-competitive procurement can often be accomplished more quickly given the absence of the timeframe usually dedicated to the development of the RFP, posting to potential vendors, and evaluation of proposals.
  2. Reduced uncertainties in terms of what a vendor is able to provide since an open dialog starts immediately.
  3. Competitive procurement (secondary competition) under a contract vehicle is limited to the vendors who proposed and were awarded. Only higher performing vendors are likely to be able to respond, particularly if only certain vendors are selected from the list.
  4. Potentially better pricing as a vendor can eliminate unknowns through open communication, so less risk is priced into the proposal.
  5. A better environment around requested changes, as a vendor that has maintained a certain margin in their pricing may be more amenable to no-cost change orders.

Disadvantages:

  1. The agency loses some negotiating advantage when a vendor knows they are the only ones in the procurement conversation. 
  2. A vendor may have less incentive to “put their best foot forward” and offer higher levels of service and functionality.
  3. Competitive cost may not be obtained because the vendor doesn’t have to worry about beating a competitor.
  4. Secondary competition may take a somewhat similar timeframe because the solicitation, evaluation, and award processes take a similar amount of time to an RFP for larger projects.

The trajectory to develop an RFP for new corrections management software spans assessing existing operations and technology to including mapping current operations into industry standards clarity. At the same time your agency should consider the driving and constraining factors for using a prequalification or contract vehicle.

BerryDunn has experience with cross-walking agencies into industry-leading practices, and we also understand the need for non-standard RFPs that extend beyond CTA and APPA guidelines. Reach out to our public safety consultants if you have questions, or look out for our next blog providing insight on adapting to and overlapping challenges in non-standard corrections technology procurements.

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Leveraging industry standards to optimize Offender Management Systems (OMS)

Read this if you are a Maine business or organization that has been affected by COVID-19. 

The State of Maine has released a $200 million Maine Economic Recovery Grant Program for companies and organizations affected by the COVID-19 pandemic. Here is a brief outline of the program from the state, and a list of eligibility requirements. 

“The State of Maine plans to use CARES Act relief funding to help our economy recover from the impacts of the global pandemic by supporting Maine-based businesses and non-profit organizations through an Economic Recovery Grant Program. The funding originates from the federal Coronavirus Relief Fund and will be awarded in the form of grants to directly alleviate the disruption of operations suffered by Maine’s small businesses and non-profits as a result of the COVID-19 pandemic. The Maine Department of Economic & Community Development has been working closely with affected Maine organizations since the beginning of this crisis and has gathered feedback from all sectors on the current challenges.”

Eligibility requirements for the program from the state

To qualify for a Maine Economic Recovery Grant your business/organization must: 

  • Demonstrate a need for financial relief based on lost revenues minus expenses incurred since March 1, 2020 due to COVID-19 impacts or related public health response; 
  • Employ a combined total of 50 or fewer employees and contract employees;
  • Have significant operations in Maine (business/organization headquartered in Maine or have a minimum of 50% of employees and contract employees based in Maine); 
  • Have been in operation for at least one year before August 1, 2020; 
  • Be in good standing with the Maine Department of Labor; 
  • Be current and in good standing with all Maine state payroll taxes, sales taxes, and state income taxes (as applicable) through July 31, 2020;
  • Not be in bankruptcy; 
  • Not have permanently ceased all operations; 
  • Be in consistent compliance and not be under any current or past enforcement action with COVID-19 Prevention Checklist Requirements; and 
  • Be a for-profit business or non-profit organization, except
    • Professional services 
    • 501(c)(4), 501(c)(6) organizations that lobby 
    • K-12 schools, including charter, public and private
    • Municipalities, municipal subdivisions, and other government agencies 
    • Assisted living and retirement communities 
    • Nursing homes
    • Foundations and charitable trusts 
    • Trade associations 
    • Credit unions
    • Insurance trusts
    • Scholarship funds and programs 
    • Gambling 
    • Adult entertainment 
    • Country clubs, golf clubs, other private clubs 
    • Cemetery trusts and associations 
    • Fraternal orders 
    • Hospitals, nursing facilities, institutions of higher education, and child care organizations (Alternate funding available through the Department of Education and Department of Health and Human Services for hospitals, nursing facilities, child care organizations, and institutions of higher education.)

For more information

If you feel you qualify, you can find more details and the application here. If you have questions about your eligibility, please contact us. We’re here to help. 

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$200 Million Maine Economic Recovery Grant Program released

Read this if you use, manage, or procure public safety and corrections technology. 

When initiating the selection of a new technology platform to replace legacy software, how does an agency ensure the new system addresses functional and technical requirements while also complying with procurement standards? Request for Proposals (RFP) serve as an effective purchasing vehicle, particularly when agencies seek to identify modern technology with professional services to implement the software. While correctional agencies may use an RFP to engage a new Offender Management System (OMS) provider, the complexities of the industry and vast range of best practices complicate the planning, scoping, issuance, and evaluation process. 

With the long-term vision set to complete projects on time, under budget, and within scope, independent third-parties write technology RFPs to enhance traceability and accountability during implementation.

An independent third-party can help your agency:

  1. Define a meaningful project scope to scale the vendor market and guide quality proposals
  2. Develop effective forms, worksheets, and attachments to supplement RFP requirements to support compliance and meet proposal standards
  3. Build a balanced evaluation committee with impartial scoring criteria to represent agency-wide needs and fairly rank vendors
  4. Craft a structured procurement package that attracts multiple vendors to find the solution that best fits your needs
  5. Design a reasonable and achievable RFP schedule of events to finish the project in a timely manner
  6. Reduce ambiguity and increase clarity of RFP terms to streamline the process

If your agency incorporates a sound strategy to craft a meaningful RFP, then a lengthy, meandering procurement journey will become a well-defined, objective, and seamless process to identify new software. Furthermore, you can enhance competitive responses with an RFP free from ambiguity―and full of clarity.

If your corrections agency does engage outside help to facilitate development of an RFP for new OMS software, you should ensure that the third party you engage has experience supporting a meaningful, balanced, and structured purchasing process. BerryDunn injects best practices from the Corrections Technology Association (CTA) and American Probation and Parole Association (APPA). Pairing CTA and APPA standards with an RFP tailored to the technology markets will help an agency boost vendor responses to ultimately improve critical operations.

Reach out to our public safety consultants directly for questions, or look out for our next blog providing insight on leveraging industry standards (e.g., CTA, APPA) when crafting an RFP for corrections technology.
 

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Sourcing new IT systems: Third-party advantages

Read this if your organization, business, or institution is receiving financial assistance as a direct result of the COVID-19 pandemic.

Updated: August 5, 2020

Many for-profit and not-for-profit organizations are receiving financial assistance as a direct result of the COVID-19 pandemic. While there has been some guidance, there are still many unanswered questions. One unanswered question has been whether or not any of this financial assistance will be subject to the Single Audit Act. Good news―there’s finally some guidance:

  • For organizations receiving financial assistance through the Small Business Administration (SBA) Payroll Protection Program (PPP), the SBA made the determination that financial assistance is not subject to the Single Audit.
  • The other common type of financial assistance through the SBA is the Emergency Injury Disaster Loan (EIDL) program. The SBA has made the determination that as these are direct loans with the federal government, they will be subject to the Single Audit. 

It is unlikely there will be guidance within the 2020 Office of Management and Budget (OMB) Compliance Supplement related to testing the EIDL program, as the Compliance Supplement anticipated in June 2020 will not have any specific information relative to COVID-19. The OMB announced they will likely be issuing an addendum to the June supplement information specific to COVID-19 by September 2020.

Small- and medium-sized for-profit organizations, and now not-for-profit organizations, are able to access funds through the Main Street Lending Program, which is comprised of the Main Street New Loan Facility, the Main Street Priority Loan Facility, the Main Street Expanded Loan Facility, the Nonprofit Organization New Loan Facility, and the Nonprofit Organization Expanded Loan Facility. We do not currently know how, or if, the Single Audit Act will apply to these loans. Term sheets and frequently asked questions can be accessed on the Federal Reserve web page for the Main Street Lending Program.

Not-for-profits have also received additional financial assistance to help during the COVID-19 pandemic, through Medicare and Medicaid, and through the Higher Education Emergency Relief Fund (HEERF). While no definitive guidance has been received, HEERF funds, which are distributed through the Department of Education’s Education Stabilization Fund, have been assigned numbers in the Catalog of Federal Domestic Assistance, which seems to indicate they will be subject to audit. We are currently awaiting guidance if these programs will be subject to the Single Audit Act and will update this blog as that information becomes available.

Healthcare providers are able to access Provider Relief Funds (PRF) through the US Department of Health & Human Services. PRF help with healthcare-related expenses or lost revenue attributable to COVID-19. Guidance on what qualifies as a healthcare-related expense or lost revenue is still in process, and regular updates are posted on the FAQs of the US Department of Health & Human Services website. According to the Health Resources and Services Administration (HRSA), PRF funds will be subject to the Single Audit Act requirements. It is important to note that while an organization may have received funds exceeding the threshold, it is the expenditure of these funds that counts toward the Single Audit threshold.

If you have questions about accounting for, or reporting on, funds that you have received as a result of the COVID-19 pandemic, please contact a member of our Single Audit Team. We’re here to help.

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COVID-19: Single audit and uniform guidance clarifications

Read this if your organization, business, or institution is receiving financial assistance as a direct result of the COVID-19 pandemic.

Updated: September 8, 2020

We expect to receive guidance on how to determine what qualifies as lost revenue sometime in the fall, and will post additional information when that becomes available. If you would like the information sent to you directly, please contact Grant Ballantyne.

New information continues to surface about the reporting requirements of the CARES Act Provider Relief Funds (PRFs). The most recent news published by the Health Resources and Services Administration (HRSA) states the funds will be subject to the Single Audit Act requirements. What does this mean and how does it impact your organization? Here’s a brief synopsis. 

A Single Audit (often referred to as a Uniform Guidance audit) is required when total federal grant expenditures for an organization exceed $750,000 in a fiscal year. It is important to note that while an organization may have received funds exceeding the threshold, it is the expenditure of these funds that counts toward the Single Audit threshold.  

PRFs help with healthcare-related expenses or lost revenue attributable to COVID-19. Guidance on what qualifies as a healthcare-related expense or lost revenue is still in process, and regular updates are posted on the FAQs of the US Department of Health & Human Services website.

You may remember, there were originally quarterly reporting requirements related to PRFs. On June 13, 2020 HHS updated their FAQ document to reflect a change in quarterly reporting requirements related to PRFs. According to the updated language, “Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision.”

Organizations that receive more than $150,000 in PRFs must still submit reports to ensure compliance with the conditions of the relief funds, but the content of the reports and dates on which these are due is yet to be determined (as of August 4, 2020). The key distinction to remember here is that this limit is based on total funds received, regardless of whether or not expenditures have been made. 

As more information comes out, we will update our website. At the moment the main takeaways are:

  • Expending $750,000 of combined relief funds and other federal awards will trigger a Single Audit
  • Receiving $150,000 of PRFs will cause reporting requirements, on a to-be-determined basis
  • Tracking PRF expenditures throughout the fiscal year will be essential for the dual purpose of reporting expenditures and accumulating any potential Single Audit support

If you would like to speak with a BerryDunn professional about reporting under the Single Audit Act, please contact a member of our Single Audit Team.

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Provider Relief Funds Single Audit