Health Plan, Version 7.0 P-NM 1 - Scope of Services</h1> <article> <h1>Health Plan, Version 7.0 P-NM 1 - Scope of Services</h1> <p>Tom Goddard — Wed, 11 Jan 2012 20:34:01 +0000</p> <p><span style="color: #3a3980; font-family: Georgia; line-height: 24px; font-size: 24px;">The Basics</span></p> <p>With this standard, you are required to answer the question, what services do we provide, and where do we provide them?</p> <p>This standard is important to URAC reviewers, because it helps them understand the nature of your network. Are you a general healthcare services network or specialty network? Do you provide health care services in a small region, statewide, or nationally? The rest of the review will be guided by the documentation and answers to interview questions that you provide in connection with this standard.</p> <p>Your organization likely answers both of these questions in official documents, such as marketing documents, regulatory filings, and the geo-access maps that help you manage your provider network. Make sure you are familiar with how your organization officially answers these questions.</p> <h1 style="margin-bottom: 0.5em; font-size: 24px; font-family: Georgia; font-weight: normal; line-height: 24px; letter-spacing: -0.5px; color: #3a3980;">Management Tips</h1> <p>Remember, you do not get credit for doing things that you do not document. So, the fact that you operate in a certain area and provide certain health care services is insufficient for purposes of this accreditation process. Rather, you need to be able to document, with official company documents, what services you provide and where you provide them. You are allowed a good deal of flexibility in how you do this. Your documentation might be in marketing materials, regulatory materials, internal policies and procedures or plans, or reports.</p> <h1 style="margin-bottom: 0.5em; font-size: 24px; font-family: Georgia; font-weight: normal; line-height: 24px; letter-spacing: -0.5px; color: #3a3980;">URAC Accreditation Tips</h1> <p>Each of the two elements of this standard is weighted 4.</p> <p>Your desktop review documentation is likely to be some combination of plans (business, marketing, strategic), service area maps, geo-access analyses, and regulatory filings.</p> <p>The on-site reviewer will verify your compliance with the standard through an examination of your organizational documents and interviews with network management and provider relations management personnel.</p> </article> <article> <h1>Core 6-9 -- Who is a delegate?</h1> <p>Tom Goddard — Wed, 11 Jan 2012 10:33:00 +0000</p> <p>Is every organization to which your organization delegates functions to be considered a "contractor" for purposes of URAC?</p> <p>No. But it has not always been easy to figure out who's a contractor and who is not.</p> <p>Here's our analysis of the current interpretation of the applicable standards:</p> <ul> <li><strong>Relevant to our accreditation? </strong>Begin with the question, "does the accreditation module under which we're seeking accreditation require our organization to do this function?" This will get rid of the things that you do that aren't in the scope of your accreditation. For example, if you are a multi-faceted medical management company but are accredited only under HUM, a function that is only under your disease management program that you delegate to a contractor would be excluded from the application of these standards because it is not within the scope of the HUM accreditation standards.</li> <li><strong>Business entity or individual? </strong>If you're required by the accreditation standards to do the function and you have hired an individual to do it, it is not delegation. Only firms can be contractors, as URAC defines the term: "A business entity that performs delegated functions on behalf of the Organization." If you hire an outside individual to do a function for you, he/she is more likely to fall under the term "staff", which is not limited to employees: "The Organization’s employees, including full-time employees, part-time employees, and consultants."</li> <li><strong>Related to key processes? </strong>The next question is whether the function you are delegating is "related to key processes". Here's what URAC has to say about this: "For the purposes of these standards, the term “contractor” includes only those contractors that perform functions related to the key processes of the Organization. It is not URAC’s intent to include contractors that provide services unrelated to key processes. Forexample, a contractor that provides catering services would not fall within the definition of “contractor” in these standards. Conversely, a company that provides specialty physician reviewers to a UM organization would clearly fall within the definition of “contractor.”"</li> <li><strong><em>Special update to the "Key Processes" issue.</em></strong> There has been a good bit of discussion lately about whether a company that stores PHI (like Iron Mountain) is a contractor. URAC seems to have, sensibly in our view, decided that the answer is "no." If the entity is performing an administration function and does not perform independently of the organization, this function would not be considered a delegated function. This is true even if PHI is involved. In such a case, all you need is a Business Associate agreement and a vendor agreement with the organization. Core 6-9 will not apply.</li> </ul> </article> <article> <h1>New URAC Accreditation Summary Report Offers More Detail (as of 10/1/11)</h1> <p>Tom Goddard — Tue, 04 Oct 2011 14:07:26 +0000</p> <p>Effective October 1, 2011, the Accreditation Summary Report that URAC provides to organizations that have completed the accreditation process, has been expanded to provide more detail than ever before. The new ASR includes:</p> <ul> <li>Overall application scores</li> <li>Individual module score</li> <li>Description of the accreditation category</li> <li>Books of business excluded from the scope of the accreditation</li> <li>Locations of sites included within the accreditation</li> <li>Individual standard/element scoring category</li> <li>Terms of the accreditation</li> <li>Notes</li> </ul> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 15 - Compounding</h1> <p>Tom Goddard — Wed, 15 Jun 2011 10:09:35 +0000</p> <h1>The Basics</h1> <p>If your organization compounds drugs, its P&Ps must, at a minimum address these four issues:</p> <ul> <li>the promotion of safety;</li> <li>the prevention of drug contamination;</li> <li>the promotion of a sterile environment; and</li> <li>compliance with laws and regulations that apply to drug compounding.</li> </ul> <h1>Management Tips</h1> <p>The US Pharmacopeia is a good resource for guidelines on compounding. </p> <h1>URAC Accreditation Tips</h1> <p>All four elements of this standard are mandatory.</p> <p>For the desktop review, submit the drug compounding P&P.</p> <p>The onsite reviewer will examine documentation demonstrating implementation of your compounding P&P. In addition, she will interview pharmacists and other staff members involved in the compounding process to assure their familiarity with your P&Ps and applicable laws and regulations.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 14 - Quality and Error Management in the Facility</h1> <p>Tom Goddard — Wed, 15 Jun 2011 10:04:29 +0000</p> <h1>The Basics</h1> <p>This standard requires, for each distribution channel, </p> <ul> <li>mechanisms to address quality and safety of drug inventory, distribution, and service;</li> <li>the means to track, report, and analyze errors; and</li> <li>report findings regarding errors to the quality management committee (or other appropriate committee).</li> </ul> <h1>Management Tips</h1> <p>Be specific in your P&P as you address criteria for quality and error reduction/elimination. Provide for the assessment of performance related to correct drug, directions, dosage, quantity, patient, labeling, as well as proper handling and distribution. Include near misses in your error reporting.</p> <h1>URAC Accreditation Tips</h1> <p>Four of the elements are mandatory, and the remaining two are weighted 3.</p> <p>For the desktop review, submit your P&Ps as well as any evidence of tracking distribution accuracy. Error logs would be appropriate for submission at this phase.</p> <p>The onsite reviewer will examine quality management committee minutes to assess error reporting frequency and completeness. In addition, the reviewer will talk to both the QM leadership and other senior management members regarding implementation of quality and error policies. She also will examine recent error reports.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 13 - Facility Safety and Security</h1> <p>Tom Goddard — Wed, 15 Jun 2011 09:57:36 +0000</p> <h1>The Basics</h1> <p>This standard imposes a number of oversight and safety responsibilities that relate to the pharmacy's facilities. The facility oversight program should address:</p> <ul> <li>access to the facility and within the facility;</li> <li>clear identification of individual employee access to machines;</li> <li>management and security of controlled substances;</li> <li>security clearances for controlled substances;</li> <li>technology controls to minimize fraud;</li> <li>systems back-up and disaster recovery;</li> <li>safe storage, handling, and disposal of hazardous materials and drugs;</li> <li>access to the Material Safety Data Sheets;</li> <li>preparedness for emergencies;</li> <li>employee safety, including spill kits and eye wash stations.</li> </ul> <h1>Management Tips</h1> <p>In addition to the above-described specific issues addressed in the standard, your facilitites P&P may also include issues such as air flow, separation of mail opening from the main building, and any additional federal or state legal requirements. </p> <h1>URAC Accreditation Tips</h1> <p>All but two of the elements of this standard are mandatory.</p> <p>Submission of the applicable facilities P&P should suffice at the desktop review stage.</p> <p>The onsite review will focus on an interview of facilities management staff members.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 12 - Oversight of Pharmacy Safety</h1> <p>Tom Goddard — Wed, 15 Jun 2011 09:49:22 +0000</p> <h1>The Basics</h1> <p>This standard requires that your organization properly oversees pharmacy operations. Proper oversight involves:</p> <ul> <li>pharmacist accountability;</li> <li>clearly stated roles in the dispensing process;</li> <li>direct supervision in preparation and dispensing of drugs; and</li> <li>compliance with requirements of the FDA and drug manufacturers.</li> </ul> <p>URAC will look for evidence of compliance with this standards both in your documents and in the understanding of staff members of oversight mechanisms.</p> <h1>Management Tips</h1> <p>The P&Ps and organization documents should clearly describe reporting relationships and job responsibilities at both the pharmacist and technician level. Clarity in this area is considered an important safety precaution for patients. </p> <h1>URAC Accreditation Tips</h1> <p>All the elements of this standard are mandatory.</p> <p>The desktop submission will consist of P&Ps that clearly describe reporting and accountability responsibilities of pharmacists and pharmacy technicians.</p> <p>Onsite, the reviewer will examine job descriptions and interview staff members to test for their understanding of staff member roles and responsibilities.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 11 - Handling and Removal of Unacceptable Drugs</h1> <p>Tom Goddard — Wed, 15 Jun 2011 09:43:22 +0000</p> <h1>The Basics</h1> <p>This standard establishes minimum requirements for your organization's policies that address the removal and disposal of medications that have been recalled, discontinued, damaged, contiminated, or have expired or been determined to be counterfeit. The P&P should address:</p> <ul> <li>handling notifications from either the manufacture or the FDA;</li> <li>how to properly notify appropriate staff members;</li> <li>notification of patients and providers;</li> <li>reviewing and removing drugs from inventory;</li> <li>intervening in the shipping process to prevent shipping of unacceptable drugs; and</li> <li>disposal of affected drugs.</li> </ul> <h1>Management Tips</h1> <p>Make sure your P&P takes into account such issues as the fact that some drugs may not be flushed down the toilet because of the risk of environmental damage and any regulatory requirements for the return or disposal of unacceptable drugs. This P&P also relates to the inventory policies required in previous standards, as you'll need to be able to track down all the drugs in need of proper disposal.</p> <h1>URAC Accreditation Tips</h1> <p>All the elements of this standard are mandatory.</p> <p>The desktop review requires the submission only of the applicable P&P.</p> <p>The onsite reviewer will interview staff members who are charged with overseeing the processes described in this standard. Furthermore, she will examine reports and logs to assure readiness to comply in the event of the need to implement the applicable P&Ps. Finally, if your organization has had to dispose of or remove from inventory unacceptable drugs, your reviewer will examine records of how that process was handled.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 10 - Claims Processing</h1> <p>Tom Goddard — Wed, 15 Jun 2011 09:34:53 +0000</p> <h1>The Basics</h1> <p>This standard simply requires that your claims processing complies with the requirements of the National Council for Prescription Drug Program (NCPDP) standard claims transactions. These standards address claims, eligibility, and benefit coordination. This set of standards are the code set standards under HIPAA. </p> <h1>URAC Accreditation Tips</h1> <p>This is a mandatory standard.</p> <p>Your desktop submission should be your NCPDP policy.</p> <p>The onsite review wil consist of an interview with the claims processing staff to assure an understanding of the NCPDP code set.</p> </article> <article> <h1>Specialty Pharmacy Accreditation, Version 2.0 PHARM-OP 9 - Machine and Equipment Maintenance</h1> <p>Tom Goddard — Wed, 15 Jun 2011 09:30:11 +0000</p> <h1>The Basics</h1> <p>This standard requires that your machine and maintenance policies and procedures address the following specific areas:</p> <ul> <li>calibration</li> <li>cleaning</li> <li>auditing</li> <li>testing.</li> </ul> <h1>Management Tips</h1> <p> The scope of your equipment maintenance P&P is broad, and should include equipment used for dispensing, labeling, and shipping of drugs.</p> <p>The testing of your equipment needs to be randomized and routinized.<br /> Keeping accurate maintenance logs will be essential to ensuring<br /> compliance with your P&Ps. Some state and federal laws can apply to equipment maintenance, so make sure your P&Ps comply with applicable regulations.</p> <h1>URAC Accreditation Tips</h1> <p>All four elements of this standard are mandatory.</p> <p>For the desktop review, it should be sufficient to submit you equipment maintenance P&P.</p> <p>The onsite reviewer will examine logs of machine and equipment maintenance, as well as interview management staff members who oversee the process.</p> </article> </main></body></html>