Ohio MHAS Provider Audit Review Checklist

Last week, patients of OMHAS received an unwanted mailing that violated HIPAA rules by disclosing patient names and addresses.

Boards obtain SAPT funding via two methods: Board Allocations and Grant Awards. Auditors should review each award carefully, keeping a copy of both its application/proposal and assurances, before conducting compliance reviews against these specific requirements.

1. Identify the Provider
Since a privacy incident involving the mailing of satisfaction surveys to 59,000 patients in February 2016 was exposed, several county boards of developmental disabilities and SAPT providers have been subject to compliance reviews and audits to ensure they comply with state regulations and are meeting compliance obligations.

Ohio offers SAPT awards to nonprofit organizations and local governments (hereafter known as BOARDS). BOARDs may receive these funds either by an allocation or grant award.

Applications for SAPT funding must be submitted through GFMS and scored by an evaluation team based on application quality, capacity, geographic diversity and local collaborations. Once an application has been chosen by the evaluation team, its terms of agreement and assurance can be finalized through GFMS; additionally a provider must submit their Community Plan and financial budget for approval before receiving pass-through funding from OhioMHAS.

2. Review the Provider’s Policies and Procedures
As a provider, it is your duty to ensure that your policies remain up-to-date and relevant. If any policies that have fallen behind are out of date, consider revising them in order to enhance clarity and effectiveness – for instance by eliminating legalese or lengthy regulatory sections; also consider moving complex processes into standard operating procedures (SOPs) while updating your policy to direct readers towards these documents.

OhioMHAS operates regional psychiatric hospitals in six locations and provides comprehensive care at state hospitals for adults committed by criminal courts. Furthermore, this agency operates community-based mental health services and behavioral health programs as well as providing various resources such as rules, regulations and certifications.

4. Review the Provider’s Accounting Records
Ohio Psychiatric Hospital System comprises regional psychiatric hospitals which offer short-term and intensive treatments to adults suffering from severe mental illness. They serve as part of Ohio’s continuum of care for people living with mental illnesses or mental health conditions.

OMHAS conducts annual patient satisfaction surveys to obtain feedback on Ohio’s mental health services; in February 2016, however, OMHAS discovered it had sent these mailings without receiving consent, leading to privacy violations of 59,000 individuals who did not consent.

Disability Rights Ohio investigations of Acadia Healthcare-owned Ohio Hospital for Psychiatry (OHP) have unearthed serious violations of essential patient safety and care standards. We have filed numerous complaints with OhioMHAS in response to our investigations, asking it to take all steps possible to revoke OHP’s license.

5. Review the Provider’s Financial Statements
Over time, Disability Rights Ohio’s investigations of Acadia Healthcare-owned Ohio Hospital for Psychiatry (“OHP”) – an inpatient psychiatric facility serving individuals with both mental health diagnoses and developmental disabilities – have documented flagrant violations of essential patient safety, care, and treatment standards at OHP. Disability Rights Ohio is calling on OhioMHAS to take all available steps to ensure patient safety at OHP.

Before beginning an audit, it’s essential that MACs review documentation and coding guidelines in accordance with payer policies and applicable billing guidelines. Timed codes provide an example; providers need to document how much time was spent performing a service in order to support its medical necessity and comply with billing rules.