Behavioral Health Organizations/Programs: Does your Health Screening Process Meet the New 2012 Requirements?
Does your organization operate a non-24 hour program that is surveyed under TJC's Behavioral Health Standards? This includes programs such as PHPs, IOPs, and outpatient methadone maintenance programs. If so, you should have updated your health screening process to comply with the new requirements that went into effect January 1, 2012.
The relevant standard is CTS.02.01.05 in the Care, Treatment and Services chapter of the 2012 Behavioral Health Manual. Element of Performance # 3 is new for 2012. It requires the organization to determine whether the date of the client's most recent physical exam exceeds one year. If the date exceeds one year, an H&P is to be performed.
This is a new requirement that was not included in the 2011 standard. It essentially requires the organization to take the following three steps:
- Include as one of the screening triggers for your health screening "client's physical exam exceeds one year."
- Determine the date of the client's last physical exam when conducting his/her health screening.
- If the date of the last physical exam exceeds one year, "a medical history and physical examination is performed."
There are two important notes that are included with this element of performance:
- Securing the client's agreement to obtain a physical exam may be undertaken as a "process" and may be incorporated into the treatment plan.
- If performing a physical exam is not within the organization's scope of service, it may refer the individual to another organization.
In addition, the following points were clarified by TJC at their annual Behavioral Health Conference in November 2011:
- This standard does not apply to organizations that provide physical exams to all clients based on their own policy and/or applicable law and regulation. (Essentially, performing a physical exam supersedes the requirement for conducting a health screening.)
- A medical professional does not need to review the health screening. The determination of whether the client needs to have an H&P can be made based on the screening triggers that have been established.
- If the client refuses to have a physical exam done (despite the recommendation of the organization), this should be documented in the record.
So, if this standard is applicable to you, be sure to review your health screening process to ensure it's compliant with the new 2012 requirements.