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From "Pennsylvania Psychiatrist - Newsletter of the Pennsylvania Psychiatric Society" - January 2001

NCQA Site Visit Requirements Change

In July the National Committee on Quality Assurance removed its requirement for accredited behavioral health managed care organizations to review actual patient records during site reviews. At least one managed care organization, Pittsburgh's Community Care Behavioral Health Organization (CCBHO), has altered its requirements accordingly.

The requirement that physicians allow managed care site reviewers to view patient records has long been a bone of contention for many of Pennsylvania's psychiatrists. The Pennsylvania Psychiatric Society has always maintained that psychiatrists should not comply unless they had a signed, informed (and thus contemporaneous) consent from the patient for the specific purpose of the site review, and that the managed care organization should procure the consent.

CCBHO, which was reviewing its policy in light of the NCQA changes, accelerated its revision process after receiving objections to its former policy from psychiatrist Daniel Shrager. After consulting with the Pennsylvania Psychiatric Society, CCBHO, under Chief Program Officer John Lovelace, issued a new policy giving psychiatrists three options for providing material necessary for assessing the adequacy of the psychiatrist's record keeping practices. All are consistent with the new NCQA requirements.

Providers seeking accreditation with CCBHO will receive a written copy of its record-keeping requirements in advance of the credentialing review. Physicians and other practitioners may provide a mock treatment record, the record-keeping form used by the practice, or actual records either blinded or with the patient's informed consent (or both) for purposes of establishing record-keeping practices. Once a provider's record-keeping practices have been reviewed and found to be in compliance, no further review will be required.

Dr. Shrager, the PPS member decredentialed by Magellan after he raised the same issues with them, was reinstated by Magellan after a judge granted his request for a preliminary injunction. PPS is unaware, however, of any change in Magellan's site review requirements.