CHAPTER 3 – PROVIDER RESPONSIBILITIES

3.1 – Provider Deliverables

Based on each provider's contract-specific requirements, providers may be required to submit various deliverables either as requirement under AHCCCS and Arizona Department of Health Services/Division of Behavioral Health Services (ADHS/DBHS) or the HCIC Provider Subcontract Agreement. Providers are expected to ensure all submitted deliverables are timely, complete and accurate. If you have any questions regarding the deliverables, contact your Provider Representative at (928) 774-7128 or (877) 923-1400.

COMPLIANCE

Providers who are compliant with Deliverable’s standards require no further action until the next submission.

Providers who are “Out of Compliance” with Deliverables standards will be contacted by the Provider Relations representative to re-educate the Provider on compliance requirements related to Deliverables standards. The Provider Relations representative will continue to monitor provider compliance each month.

CORRECTIVE ACTION PLAN

Health Choice Integrated Care will require a corrective action plan (CAP) from all Providers identified as “Out of Compliance” with Deliverable’s standards. CAP’s will be due from the Providers within 15 business days of notice for non-compliance. The Provider Relations representative will send a follow up letter to the Providers reminding them of the CAP due date and content.

If compliance is not evident after additional interventions, the case will be escalated to the Health Choice Integrated Care Chief Operating Officer (COO) with recommendations for further actions, which may include referral restrictions, sanctions or possible termination from the network for breach of contract.

3.2 – Business Continuity and Disaster Preparedness (NEW)

Health Choice Integrated Care provides health care benefits to its Members. In order to provide benefits, the Contracted Facilities, Providers and Vendors must be able to recover from any disruption in services as quickly as possible. This recovery can be accomplished by the development of Business Continuity and Incident Management Plans that contains strategies for recovery. The Business Continuity and Incident Management Plans are part of the Federal Government’s Continuity of Operations Programs (COOP) requirements.

RESPONSIBILITIES

The Facility, Provider or Vendor shall develop and maintain a Business Continuity and Incident Management Plan which assures Health Choice Integrated Care that the provision of covered services will occur as stated in 42 C.F.R. 438.207 and 42 C.F.R. 438.208. A summary of the Business Continuity and Incident Management Plan should be submitted with the Business Continuity and Incident Management Plan Checklist to the designated Compliance Officer, within 15 days from the start of each contract year. The comprehensive summary shall be no longer than five pages and shall address all Business Continuity and Incident Management Plan requirements outlined below. Facilities, Providers or Vendors shall prepare adequate Business Continuity and Incident Management Plans that are reviewed and tested at least annually, and updating them as needed.

BUSINESS CONTINUITY AND INCIDENT MANAGEMENT PLAN

• The Business Continuity and Incident Management Plan (Plan) shall be reviewed and updated at least annually by the Facility, Provider or Vendor.

• The Facility, Provider or Vendor shall ensure that its staff is trained and familiar with the Plan.

• The Plan should be specific to the Contractor’s operations in Arizona and reference local resources. Generic Plans which do not reference operations in Arizona and their relationship to Health Choice Integrated Care are not appropriate.

• The Plan should contain, at a minimum, planning and training for:

o Complete loss of use of the main site (e.g. major fire or flood).

o Complete loss of systems and applications (e.g. data center disaster).

o Loss of a critical Third Party Supplier (e.g. internet and telephones).

o Wide-spread Severe staffing Shortage (e.g. pandemic).

o How the Facility, Provider or Vendor will communicate with Health Choice Integrated Care during a business disruption. (Plan should include Nicole Larson, (480) 760-4902 or by e-mail at as the specific contact at Health Choice Integrated Care). The Plan shall contain a listing of key customer priorities and key factors that could cause disruption and timelines for when a Facility, Provider or Vendor will be able to resume critical customer services when a disruption occurs. The Facility, Provider or Vendor shall also include any additional priorities as identified to be critical key priorities or factors.

o How Health Choice Integrated Care will contact the Facility, Provider or Vendor in the event of a business disruption outside of normal business hours. (The name and phone numbers for two contacts)

o Provisions for periodic testing, at least annually. Results of the tests are documented.

• The Plan should identify the Facility, Provider or Vendor’s greatest priorities and provide recovery guidelines and procedures to respond to an event impacting the critical functions at a basic level until normal functions have been restored.

• The Plan should address how, during a business disruption, the Facility, Provider or Vendor will provision for facilities, hospitals or other locations in the event members are being displaced.

• The Plan should provide the procedures to follow during a disruption when transporting members and other critical resources to alternate operating locations.

• The Plan should include realistic timelines for the resumption of basic services for the Facility, Provider or Vendor’s greatest priorities.

• The Plan should include primary and alternate Business Continuity Planning Coordinators and includes primary and alternate methods of contact for each.

• The Plan should include actions performed by the Facility, Provider or Vendor that benefit the general public before a disruption occurs (e.g. educational outreach, protecting vulnerable populations, having appropriate interventions).

• The Plan should include plans and procedures can be performed by the Facility, Provider or Vendor to benefit the general public during a disruption (e.g. limiting adverse public health effects, coordinating efforts with government departments and agencies, reducing public health risks, and other activities designed to mitigate health adverse effects and/or deaths.)

• The Plan should include procedures for providing counseling to their employees and volunteers during and after the most severe disruptions.

RESOURCES

The Federal Emergency Management Agency (FEMA) has a website which contains additional information on Business Continuity and Incident Management Planning, including checklists for reviewing a Plan. Health Choice Integrated Care encourages the Facility, Provider or Vendor to use relevant parts of these checklists in the evaluation and testing of its own Business Continuity and Incident Management Plans. The Facility, Provider or Vendor can also reference the Arizona Governor’s Office of Homeland Security and Emergency Preparedness and the Ready websites for supplementary information. Links to these websites are provided:

Federal Emergency Management Agency: http://www.fema.gov/ FEMA Continuity of Operations Program: http://www.fema.gov/continuity-operations Arizona Division of Emergency Management: http://www.dem.azdema.gov/index.html Arizona Department of Emergency & Military Affairs: http://www.azdema.gov/ Arizona Department of Homeland Security: http://www.azdohs.gov/ Arizona Emergency Information Network: https://ein.az.gov/ Ready: http://www.ready.gov/

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Last Revised: October, 2015