FootNotes - August / September 2020







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What's New in AWARDS
Connect With Us!
Tip of the Month - Metadata in AWARDS
Social Enterprise Directory - Share Your Work and Stories Today!
Customer Testimonials - MedSupport Success in AWARDS!
News from the Field - With Senior Advisor David Bucciferro
Customer News - Meet the 2020 AWARDS Impact Prize Winners!

What's New in AWARDS?

The following new features, enhancements, and updates will be available in your AWARDS database beginning on Wednesday, September 9th.  To read more about these changes in detail, please visit our What's New Online Help page.

BillingBuilder - New "Sender Code" Option for 837 Files

A new 837 file data configuration option - Sender Code (if different from Sender ID) (GS02) - is now available in the Program Billing Groups feature.  This option should only be used when the sender position of the GS segment in the 837 claim file for the payer’s program billing group needs to report a code that is different from the value entered in the Sender ID text field.

Calendar - New Design!

We're excited to release the newly designed Calendar for all agencies this month. Key features include enhanced navigation and filtering, streamlined events, and more documentation options!  Click here for more information, including a video preview.

Client File Cabinet - Enhanced Navigation and Organization!

Like Calendar, the AWARDS file cabinet functionality is something we hear about regularly and are eager to make more powerful and user-friendly for our customers.  As a first phase of this enhancement work we're introducing improved navigation that is consistent with other parts of AWARDS, a ReportBuilder for easy file review across clients and programs, a secondary point of access from within the Services-Individual module, AND the option to categorize your files for better organization.  Click here to read more, and then stay tuned for additional improvements in coming months!

HMIS Funding Update - New Options Added for CV Funding Streams

Two new Funding Source options have been added to System Setup > Agency Program Information > Add/Edit Entire Program:  "47 HUD:ESG-CV" and "48 HUD:HOPWA-CV," where "CV" stands for Coronavirus.  In addition, the ESG CAPER now includes programs with HUD: ESG-CV funding.

Connect With Us!

For more information on upcoming FootholdConnect events, please go to FootholdConnect on the AWARDS Home screen's navigation bar, or visit the Upcoming Events page of the Foothold Technology web site.  And don't forget... If you've missed any recent FootholdConnect events, you can access the recordings for those in Online Help here!

News You Can Use

Tip of the Month - Metadata in AWARDS
Social Enterprise Directory - Share Your Work and Stories Today!
Customer Testimonials - MedSupport Success in AWARDS!
News from the Field - With Senior Advisor David Bucciferro
Customer News - Meet the 2020 AWARDS Impact Prize Winners!

Tip of the Month - Metadata in AWARDS

Did you know... that metadata (data about data), can provide valuable insights into when records - including those in AWARDS - were created or last updated and by whom?  Not only that, but if you have access to AWARDS ReportBuilders, metadata is right at your fingertips.  You'll find a variety of useful metadata selections in a distinct "Record Information" section on each relevant ReportBuilder's data variable selection page.

Social Enterprise Directory - Share Your Work and Stories Today!

We recently launched our Social Enterprise Directory initiative and we wanted to share the great news! We want to continue to promote the great work providers like you are doing in our community, so we are curating a centralized resource to promote agencies' social enterprises and their positive impacts. We're looking to collect submissions by Wednesday, September 16th so if you're interested please fill out this form to share your work and your stories with us. 

Customer Testimonials - MedSupport Success in AWARDS!

If you have eMAR needs, Foothold Technology has you covered! Over the past year we have partnered with CaraSolva to integrate their MedSupport feature directly into AWARDS.  MedSupport streamlines and automates the scheduling and administration of medications, as well as vitals and tasks. With this integration, medication information and client census data is shared across the two systems, keeping everything current and ensuring no duplicate data entry needs. There is also a Single Sign On for staff access, avoiding the need for staff to remember and use multiple login credentials.  

Many Foothold customers have implemented MedSupport in their AWARDS database and have swiftly seen improvements in their medication administration documentation and oversight processes. As described by one Direct Support Professional at Prospectus Berco, a nonprofit corporation established to provide quality services to adults with intellectual disabilities and special needs in Berks County, PA, "I love it because it is so easy!!! It is very hard to make a mistake. A resident  got 2 antibiotics yesterday and it already figures it out for you... you cannot make a mistake! It is easy to follow!" Other DSPs have responded with similar enthusiasm about how much CaraSolva has improved their workflow as they support the individuals in their programs.

Administrators are finding the incorporation of MedSupport equally beneficial, as noted by Michele Casey, the Residential Program Nurse at Midland Adult Services, an organization that provides a lifelong continuum of services to children, teenagers, and adults with intellectual and developmental disabilities, and their families. Michele notes that "MedSupport has helped with ease of administration and has significantly decreased documentation errors at our agency due to the ease of which medication administration is documented. It also allows administrative staff, such as myself, to remotely monitor medication administration, vital signs, and medication changes. I find this to be my favorite part of MedSupport. If I am doing weight tracking of a client for example, I can check this information on my computer without having to physically go to the home or asking staff to email or fax me the information. The real-time access to a client's MAR has been so helpful and convenient."

You too can benefit from this exciting new integration option in AWARDS! To learn more, see our Online Help section on MedSupport.

News from the Field - With Foothold Senior Advisor David Bucciferro

As noted last month, we are excited to bring you this new segment in FootNotes, where Foothold Senior Advisor David Bucciferro highlights key issues he is seeing in the field, and helps make sense of if and how they affect the important work you do. This month David digs into the recent changes to 42 CFR Part 2.

What is 42 CFR Part 2? You have heard it in the news, but what does it mean to you? You know it governs the information you share but what is it really about and what is happening to it? To review, 42 CFR Part 2 is a set of regulations to protect patient records created by federally funded programs for the treatment of substance use disorder (SUD). Just recently, SAMHSA released the first of two major changes to 42 CFR Part 2. In part, these changes came about simply because the rules were old and did not keep pace with the changes to healthcare and healthcare technology that have occurred since it was first created. Before we delve into what these changes (referred to as the Final Rule) mean, it is important to provide some background to help better understand why these changes were made.  

42 CFR Part 2 was enacted as part of the Drug Abuse Office and Treatment Act of 1972, as a way to encourage people to seek treatment. Up to this point, there were no focused laws or regulations prohibiting the release of an individual's substance use treatment information upon request. It was very easy for employers, the criminal justice system and anyone trying to use this information for their personal gain, to obtain these records. At the time, this information could be used to deny work, access to education or even housing, and law enforcement could look at treatment records and use that information to explore criminal charges. Many of the employment, education and housing protections that are in place through various laws today did not exist at the time 42 CFR was enacted. It is important to remember that HIPAA was not enacted until 21 years later, as part of the Kennedy‐Kassebaum Bill of 1996, and the rule also predated the use of electronic health information systems. At that time, no one was using Electronic Health Records, and the vision of using an EHR and health information exchanges had not even been thought of by the creators of the bill. Over the years, technology has changed and substance treatment best practices have been developed, but 42 CFR Part 2 has not changed with them. Only recently has 42 CFR been touched, and up until the most recent Final Rule was released, the regulation has remained essentially the same as it did in 1972, 48 years ago. 

As stated earlier, there are sets of two changes being made to 42 CFR Part 2. The first changes were released for comment by SAMSHA last year, and implemented this August. The second set of changes pertains to requirements set forth in the Coronavirus Aid, Relief and Economic Security Act ("CARES Act"). The CARES rules will become effective in March 2021, with the specifics of the rules set to be released in comment form very soon. These changes are split into two sets because although SAMSHA was in favor of a more thorough overhaul, they did not have the legislative authority to make all the desired changes and needed Congressional action for most of them. For this piece, we will focus on the first part of the rule changes identified in SAMSHA's Final Rule, as currently constructed.  SAMHSA has not included in the Final Rule the changes set forth in CURES Act of 2020 which, most notably for Part 2 purposes, will seek to align more closely Part 2 confidentiality rules with HIPAA regulations. SAMHSA has stated that a new group of rule changes will be issued in the near future to reflect the CARES Act requirements. We will continue to monitor any subsequent rulemaking and changes to the Part 2 regulations and provide you with updates when they are available. 

So let us now dive into the first part of the Final Rule, looking first at what has not changed, and then digging into the actual changes. For ease of review, we will refer to 42 CFR Part 2 as the Rule, providers who provide SUD services as Part 2 Providers, and providers who do not provide SUD services as Non-Part 2 Providers. SAMSHA has made it clear on numerous occasions that the new Rule will not alter the basic framework for confidentiality protection of SUD patient records created by federally funded treatment programs. The Rule will continue to prohibit law enforcement use of SUD patient records in criminal prosecution against the patient. The Rule will also continue to restrict the disclosure of SUD treatment records without patient consent, other than as statutorily authorized in the context of a bona fide medical emergency; or for the purpose of scientific research, audit, or program evaluation; or based on an appropriate court order for good cause.

What has changed with the Rule is a start toward alignment with HIPAA, as well as improving treatment information for the purposes of further improving care and patient safety. Although the new Rule pertains to the work you do as an SUD provider and the information you generate in your work, many of the changes are focused on other parts of the healthcare and non-healthcare community. Although some of these rules may not pertain to you as a Part 2 provider, there is still value in understanding and reviewing all of the major changes. Below is a summary of all the major changes. 

Applicability and Re-Disclosure - The new Rule clarifies that treatment records created by non-part 2 providers, based on their own patient encounter(s), will not be covered by part 2. If  however any SUD records previously received from a part 2 program are incorporated into such records, there must be segmentation or "holding apart" of any Part 2 patient record information previously received, in order to ensure that new records created by non-part 2 providers will not become subject to part 2. 

Disposition of Records - SAMSHA sought to ensure that personal devices of employees would not need to be confiscated or destroyed if Part 2 information is received on the personal device of an employee of a Part 2 program, through an incidental message. SAMSHA has stated that an employee may fulfill the requirement of "sanitizing" the device by simply deleting the message. 

Consent Requirements - Prior to this change, an SUD client had to identify the specific person they were giving consent to at an entity (e.g. Peter Rabbit at the Social Services Administration).  Under the new Rule, an SUD patient may consent to the disclosure of his/her part 2 treatment records to the entity (e.g., the Social Security Administration), without naming a specific person as the recipient for the disclosure.

Disclosures Permitted w/ Written Consent - In order to resolve lingering confusion under part 2 about what activities count as "payment and health care operations," the list of examples will be moved into the reg text from the preamble.

Disclosures to Central Registries and PDMPs - SAMHA revised the central registry and PDMP provisions  to help prevent duplicative enrollments in SUD care, duplicative prescriptions for SUD treatment, and adverse drug events related to SUD treatment. The Rule allows Non-OTP (opioid treatment program) providers to query a central registry, in order to determine whether their patients are already receiving opioid treatment through a member program.  It also allows OTPs to enroll in a state prescription drug monitoring program (PDMP), and be permitted to report data into the PDMP when prescribing or dispensing medications on Schedules II to V, consistent with applicable state law.

Medical Emergencies - To ensure clinically appropriate communications and access to SUD care, in the context of declared emergencies resulting from natural disasters, SAMSHA clarified the Medical Emergency exemption. Medical Emergency Declared emergencies resulting from natural disasters (e.g., hurricanes) that disrupt treatment facilities and services will meet the definition for a "bona fide medical emergency," for the purpose of disclosing SUD records without patient consent under part 2.

Research - To facilitate appropriate disclosures for research, SASHA streamlined overlapping requirements under part 2, the Privacy Rule and the Common Rule. This allows disclosures for research under Part 2 to be permitted by a HIPAA covered entity or business associate to individuals and organizations who are neither HIPAA covered entities, nor subject to the Common Rule (re: Research on Human Subjects).

Audit and Evaluation - To resolve current ambiguity under part 2 about what activities are covered by the audit and evaluation provision, revisions were made to clarify that some specific situations fall within the scope of permitted disclosures for audits and/or program evaluation.

Confidential Communications - A correction is being made to the standard for court ordered disclosure to correct a technical error from the 2017 rule. The standard for court ordered disclosures of SUD records for the purpose of investigating "an extremely serious crime" will be revised, and the phrase "allegedly committed by the patient" will be dropped.

Undercover Agents and Informants - To address DOJ concerns that the existing policy for court-ordered placement of an undercover agent or informant within a part 2 program is overly restrictive to some ongoing investigations of part 2 programs, the new policy allows for a court ordered period of 12 months and to further extend through a new court order.  

We hope you have found this information helpful! We understand that many of these changes may not be entirely clear, and welcome you to reach out for more clarity as needed. We will continue to update you on these changes as we learn more.

Customer News - Meet the 2020 AWARDS Impact Prize Winners!

In 2015, Foothold established the AWARDS Impact Prize to recognize customers who have leveraged AWARDS to measurably impact the health and well-being of the communities they serve. We are excited to use this section of FootNotes to share their amazing work with all of you. 

This month we highlight Alliance for Positive Health, an Albany-based agency that embarked on their AWARDS implementation with a goal of moving away from an almost exclusively paper-based system to record and track consumer data and services. Although they had already begun to use another third-party database to centralize their data, they found the process to be inefficient, redundant, and time-consuming.

The move to AWARDS finally gave them their own centralized agency-wide database where data could be shared across programs - ensuring more accurate and comprehensive service documentation, eliminating double and sometimes triple data entry, and giving staff the opportunity to focus more of their time on doing what they do best - providing mental health, substance use, and homeless services to their clients.

Quality Assurance Coordinator Jessica Adrian and Data Entry Specialists Christiana Booker and Brad Morgan met with front line staff to evaluate the existing workflows and identified ways to improve them. They took staff’s feedback and worked with their Foothold Implementation Consultant to guide the agency away from "the way we've always done it" and truly create a digital environment that increased staff productivity, ownership, and overall satisfaction.   

Congratulations to Jessica Adrian, Christiana Booker, and Brad Morgan of Alliance for Positive Health as a 2020 Impact Prize winner!

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