DBHDS Plans Substantial Reduction in Document Submission Requirements for QSR

August 07, 2020

In response to our request, we received today the following from Dr. Alexis Aplasca, Chief Clinical Officer for DBHDS:

“DBHDS is always interested in feedback on things we can review and adjust and will continue to look for ways to facilitate this internally to decrease the burden on the provider but those changes may occur during later stages of the PQR process since HSAG will begin before some of these changes could occur. In reviewing your questions, the core of them are at the need for duplicate submissions when access or information may already be available elsewhere, and so this information aims to summarize what we have done to minimize the burden and the limitations that currently exist.

“Regarding document submission:

• HCBS policies and procedures: HSAG will not require submission of policies and procedures related to HCBS Settings rule requirements. HSAG’s review will assess the status of the provider’s implementation of HCBS settings rule in service provision through PCR reviews. If a question concerning implementation of HCBS settings rule is identified, HSAG may ask to see the related policy.
• ISPs: HSAG will utilize WaMS to access ISPs. The provider will need to submit the signature page as this is not available in WaMS. If the ISP is not updated and current in WaMS, HSAG will request it from the provider. 
• CHRIS Reporting: DBHDS will generate a SIR report for HSAG. If HSAG identifies what might be a SIR/HR reportable incident (where no report was submitted) they will send an alert to DBHDS and DBHDS(Licensing/HR) will determine whether or not a report should have been made.
• QM/RM Plans: If OL has a copy of the QM/RM plans, this information will not be requested. However, HSAG will still need documentation that the QM processes are being implemented (as this is clearly in the SA and indicators).
• HSAG will revise their document request list and will repost it (they have provided an updated list but it will need to be reviewed prior to being finalized).

She continues in response to our concerns about the Quality Improvement Plans and whether or not they will have requirements which exceed current regulations:

“As you noted, the QSR activity also suggests requirements which are not contained in either code or regulation. The QSR process is not intended to be focused on code and regulations (we have made our best effort to avoid duplication of the regulatory process).  The purpose of the Quality Service Review (Provider Quality Review)  is to ensure continuous quality improvement in the services provided to individuals with developmental disabilities through the assessment of individual outcomes and provider services.

“These assessments determine whether services are meeting the needs/desires of individuals (individuals are receiving services that meet their needs, maximize their participation in the community, ensure individuals are safe and free from harm etc) and whether provider services support individuals to meet these outcomes and providers are meeting the intent of the Home and Community-Based Services Settings Final Rule and the Department of Justice Settlement Agreement. The Quality Service Reviews evaluate the quality of services delivered by providers, support coordinators, and home and community-based service providers. Data collected from the QSRs will assist DBHDS to evaluate services from an individual, provider and system level and identify strengths and where improvements may be needed.

We are very appreciative of this response and will continue to work with Dr. Aplasca and her team as the process unfolds to try to minimize the impact on all the the providers.  What a good way to end the week!