You may have already been contacted by an Aptiva partner regarding a performance review. What’s behind this new requirement?
The answer lies in recent (2015) guidance provided by CMS to field auditors, and subsequent interpretation by credentialing agencies such as the Joint Commission, CHAPS and ACHC, that all clinicians engaged in home health, including contractors, must be able to demonstrate compliance with the Code of Federal Regulations Section 484.14 (c). That section requires that agencies demonstrate that they use “qualified personnel” and have adequate “staff education and evaluation.” These guidelines have been interpreted by the accrediting organizations as requiring that staffing firms (including Aptiva) fulfill certain basic practices including: (1) a basic orientation regarding policy and procedures; (2) annual performance and competency/skill assessments; and (3) on-going continuing education.
In practice, employee and contract clinicians engaged by staffing firms have been able to avoid these administrative processes, since they were not considered as subject to the same requirements as an agency’s directly hired employees. Unfortunately, the implementation of the 2015 audit guidelines has made it clear that independent contractors must present evidence of the same levels of orientation, performance review and in-service content as agency employees. We have been receiving a steady increase in requests for this information from our home health agency customers, and we are now at the point where it has become critical we accomplish these in short order. We hope to complete the processes by August 1st, 2016.
We are also sensitive to the fact that contractors are often engaged in multiple relationships and may in fact be receiving in-service and performance reviews from other resources, such as an agency or full time employer. We also recognize that many individuals may not have access to these resources and may not have had in-service or a performance reviews in the recent past.
To address these issues, we are initiating programs to meet the related requirements.
Contractor Guidebook or Employee Handbook
All three accrediting bodies noted above view a new clinician orientation as an important part of of establishing policy and procedure guidance, and are requesting documentation of the orientation. For individuals new to Aptiva, we have been documenting orientation since the middle of 2015 by means of a written Handbook (for employees) or Guidebook (for contractors). Clinicians working with us from before middle 2015 have not necessarily had a documented Aptiva orientation. If you have not reviewed the Handbook or Guidebook, please review the appropriate version of the document (located in the forms section of this website) and sign the acknowledgement found on the last page. Note that if you transition from a contractor to an employee, you must complete a new employee acknowledgement form. An acknowledgement must be submitted by all employee and contracted clinicians who have not previously done so.
If you have received a performance review from any other source within the past year, and are are comfortable sharing the written review with us, please submit a copy. That may serve as sufficient documentation. Please forward a copy directly to firstname.lastname@example.org, along with a note of explanation as to when, where and by whom the review was completed.
If you have not had a performance review within the last year, then we require that you participate in a performance review process. To complete our performance reviews, we are using a peer-review process, where our clinician partners and a small number of other experienced clinicians perform the reviews.
The reviews are very simple and straight-forward based on one observed visit. Performance is judged as either “competent” or as “needs work.” The review takes into consideration elements of the visit including patient communications, therapeutic techniques and treatment plans. The process consists of three steps: a pre-visit discussion & planning call, the actual visit, and the post-visit follow-up discussion, which can typically occur immediately after the visit. The pre-visit discussion establishes the specific patient, the time and sets the stage for the reviewer. The visit portion is an observation of actual application of skills. It is likely to include discussion of goals and treatment plans, patient or care giver communications, and may include other topics such as exercise dosing or other facets of care. The post-visit process is a review of the probable documentation, follow up on care-team communications if appropriate, and a summary performance discussion between the reviewer and the clinician. These steps are documented on a simple form and that form will become a credential that may be shared with agencies.
In addition, all clinicians must update their skills inventory on an annual basis. This consists of a simple review and self-rating on the various skills associated with your clinical discipline.
The performance review and the skills inventory must be completed by August 1st of this year and annually thereafter.
If you wish to use a review from another source, please submit it as soon as possible. If not, you will be contacted to schedule a review.
Part of the competency requirement is demonstrating staff education. We ask you to provide us with a list of the courses which you have completed as part of your CEUs. You can do that via email list with the date, offering resource, content description and including certificates of completion. We will enter those in our database to document your continuing education. You may also fax or send copies of certificates, so long as they clearly state the relevant information.
In addition, Aptiva will be offering a series of Webinars aimed specifically at clinicians. We are in the process of getting Illinois CEU certification for these offerings, which will be provided by outside vendors. The initial session we have is scheduled for Wednesday, September 21st, 2016 at 1:00 pm CDT. That session will focus on PT Therapy Test & Measures.
A second session is tentatively scheduled for Tuesday, November 1st, 2016, at 1:00, with that topic to be determined.
There are also a number of in-service sessions currently available on-line on the Aptiva Website. These sessions fulfill requirements in Kansas and Missouri for annual in-service education on specific topics, including Infectious Diseases and Blood Borne Pathogens, Alzheimer’s and Dementia, and HIPAA and Patient Privacy. You are welcome to take any of these courses, and will receive a certificate of completion based on your test results, although they are not currently eligible for Illinois CEU credit.