The Basics

For a 7-minute video on URAC-required training, click here.

In any event, read on:

Management Tips

As you know, URAC has specific requirements for staff training that relate both to the content of staff training and its administration:

Content

Most of the explicit training requirements in the URAC standards are found in the Core and Pharm Core standards: 

• Initial orientation and/or training for all staff before assuming assigned roles and responsibilities; (Core 7(a))
• Training in the P&Ps that apply to one's job is implied by Core 3(a), too
• Ongoing training, at a minimum annually, to maintain professional competency; (Core 7(b))
• Training in current URAC Standards as appropriate to job functions; (Core 7(c))
• Training in state and regulatory requirements as related to job functions; (Core 7(d))
• Conflict of interest; (Core 7(e))
• Confidentiality (Core 7(f)) and specifically HIPAA (Core 24)
• Training on identification and prevention of fraud and abuse, as appropriate to job functions; (Core 7(g))
• Delegation oversight, if necessary; and (Core 7(h))

In addition, training of employees in how to do their job consistent with company P&Ps and URAC standards  is implied throughout the standards, via Core 3(a), 7(a), and 7(c).

Administration

• There must be documentation of all training provided for staff (Core 7(i))
• There must be a signed document acknowledging training on confidentiality issues (Core 24)

Some of this is company-wide training (e.g., confidentiality); some is department-specific (e.g., P&Ps on how to follow DM P&Ps.)  Company-wide training is typically handled either through:

• company-wide meetings
• computer-based training modules required of all employees, or
• smaller, face-to-face trainings required of all employees. 

Department-specific training is typically handled through

• modular computer-based training programs or
• departmental staff meetings

URAC Accreditation Tips

The best preparation for the URAC review is the substantive training described in the previous section.  A staff member who knows his/her job as described by the applicable P&Ps, knows the URAC standards and state/federal regulations that apply to the job, and can retrieve the documents to be sought by the URAC reviewer is unlikely to get tripped up in a URAC review, even if they have no specific preparation for the onsite review process.

Additionally, the mock onsite review we conduct for our clients is valuable for staff members likely to be either interviewed or pulling documents during the onsite review.  We spend a good portion of our time onsite not only conducting document-pulls and interviews as realistically as possible, but also counseling staff members on how to improve their performance for the actual review.

The Basics

CM 8 requires that the CM program encourage professional development for its case managers.  Examples of this kind of encouragement would be direct provision of the kind of experience required for certification, training to enhance expertise in case management, or time-off or financial assistance for that training and attendance at association meetings.  Document the training and meeting attendance under this standard as you would the more general staff training requirements of Core 27.  In otherwords, document training and meeting attendance in a centralized training file or in the employees' individual personnel files.

Management Tips

URAC gives you a lot of flexibility in the implementation of this standard.  Direct reimbursement is not required; rather, only encouragement.  If your organization is not providing financial assistance, you'll be expected to document such encouragement activities as providing access to professional journals, internet resources, and the like. 

As is always the case, management's primary responsibilities are to craft P&Ps that describe the process and a system to document its implementation.

URAC Accreditation Tips

The three elements of this standard each weigh 3 points.

As usual, you should start your AccreditNet submission with a P&P that describes the CM staff training program, including any incentives the organization provides for training or meeting attendance.  In addition, evidence of implementation of that program will be useful here, for example, a couple of training agendas or certificates of attendance at professional development trainings.  Job descriptions for your case managers, too, could be helpful here, particularly if they articulate the organization's expectation that the employee participate in professional development activities.

During the onsite review, the URAC reviewer will do as he/she does for all training-related standards, that is, combine a review of personnel and training records selected from a list of case managers, with interviews of the case managers and their supervisor(s).  Likely questions for the case managers include:

• What kind of professional development activities did you participate in during the past year (e.g., conferences, trainings, in-services)?
• What kind of support, if any, did this organization provide for your professional development?
• Are you a member of a professional association?  If so, did this organization pay your dues or send you to a conference of that association?

The Basics

This standard sets forth the training requirements that are specific to your case managers.  The domains that should be covered by that training, which does not need to be annual, include:

• Your organization's case management P&Ps;
• The QM program;
• The laws and regulations that apply to your CM program (local, state and federal);
• Case Management roles, responsibilities and accountabilities;
• Your scope of practice; 
• Standards of case management practice; 
• Widely accepted knowledge domains of case management; 
• Case manager cultural competence;
• Any special requirements based on the particular consumers or clients your program serves;
• Available resources to help case managers;
• The background on your organization's use of evidence-based care plans;
• Professional conduct;
• Coordination and transitioning of care.

Management Tips

This standard should be read in conjunction with Core 27.  The training can be in-house or provided by outside organizations or other vendors, like CMSA.  Drawing on CMSA's training program, URAC specifies that this training should address "clinical competence, communication skills, problem solving and conflict resolution skills, the ability to effect change, assessment skills, organization skills, time management, customer service skills, and knowledge of how to set case management goals and how to measure outcomes."

If you are going to rely on staff meetings to meet any part(s) of this standard, be sure you record each such meeting's date, detailed training agenda, and attendees (use a sign-in sheet).  Whatever documentation you use, the URAC reviewer will need to be able to connect each of these kinds of trainings to each member of your case management staff.

URAC Accreditation Tips

Each element of this standard is weighted 4.

For the documentary submission on AccreditNet, you should submit both a P&P describing these training requirements and sample training agendas and outlines. 

For the onsite review, be prepared to submit the full training files showing compliance with this standard, not just samples.  In addition, any documentation of CEs received by the case managers should be available.  Finally, the interviews with case managers and the case management supervisor is likely to cover orientation and ongoing training.

Management Tips

URAC has long required organizations to demonstrate that they train their employees and senior clinical staff members in a variety of areas, including confidentiality, conflict of interest, and the applicable URAC standards.  The current (v. 3.0) Core 27 requires training at initial orientation.  URAC also prescribes the content of ongoing training of staff members, requiring training in those URAC standards that apply to a staff member's particular job functions, conflict of interest, confidentiality, and in the staff member's field, in order to maintain professional competence.  All staff traiing needs to be documented under this standard, as well.

The question here is "what do I submit on AccreditNet for Desktop Review?"  The Interpretive Information suggests:

• Training program outlines/agendas for all levels of program staff (employee and senior clinical staff person) that include all elements of the standard.
  

• Tools used to document orientation and training activities.

The first bullet is similar to the earlier versions of Core, while the second bullet is new.  What is also new is that URAC reviewers are more rigorously enforcing this documentation requirement.  There was a time when it would have been sufficient for most URAC reviewers to submit, at the Desktop Review phase, a P&P outlining training requirements and a couple of examples of agendas and sign-in sheets of various trainings. 

In recent weeks, however, we've seen evidence that URAC reviewers are taking this submission requirement more literally than in previous years.  So, we recommend that you do exactly as suggested -- submit for Desktop Review a full complement of training program outlines and agendas for all employees across all the required types of training.  

I talk a bit more about this in the following 3-minute video.

The Basics

As you know, URAC has specific requirements for staff training that relate both to the content of staff training and its administration:

Content

 Most of the explicit training requirements in the URAC standards are found in the Core standards: 

• Initial orientation and/or training for all staff before assuming assigned roles and responsibilities; (Core 7(a))
  • Training in the P&Ps that apply to one's job is implied by Core 3(a), too
• Ongoing training, at a minimum annually, to maintain professional competency; (Core 7(b))
• Training in current URAC Standards as appropriate to job functions; (Core 7(c))
• Training in state and regulatory requirements as related to job functions; (Core 7(d))
• Conflict of interest; (Core 7(e))
• Confidentiality (Core 7(f)) and specifically HIPAA (Core 24)
• Training on identification and prevention of fraud and abuse, as appropriate to job functions; (Core 7(g))
• Delegation oversight, if necessary; and (Core 7(h))

In addition, training of employees in how to do their job consistent with company P&Ps and URAC standards  is implied throughout the standards, via Core 3(a), 7(a), and 7(c).

Administration

• There must be documentation of all training provided for staff (Core 7(i))
• There must be a signed document acknowledging training on confidentiality issues (Core 24)

Some of this is company-wide training (e.g., confidentiality); some is department-specific (e.g., P&Ps on how to follow DM P&Ps.)  Company-wide training is typically handled either through:

1. company-wide meetings
2. computer-based training modules required of all employees, or
3. smaller, face-to-face trainings required of all employees. 

Department-specific training is typically handled through

1. modular computer-based training programs or
2. departmental staff meetings

URAC Accreditation Tips

The best preparation for the URAC review is the substantive training described in the previous section.  A staff member who knows his/her job as described by the applicable P&Ps, knows the URAC standards and state/federal regulations that apply to the job, and can retrieve the documents to be sought by the URAC reviewer is unlikely to get tripped up in a URAC review, even if they have no specific preparation for the onsite review process.

Additionally, the mock onsite review we conduct for our clients is valuable for staff members likely to be either interviewed or pulling documents during the onsite review.  We spend a good portion of our time onsite not only conducting document-pulls and interviews as realistically as possible, but also counseling staff members on how to improve their performance for the actual review.

Management Tips

Core 7(c) requires that the organization's training program includetraining in URAC Standards.  That training need not be across all the URAC standards, but only those that are appropriate to job functions.

Historically, organizations seeking to comply with this subsection have focused their documentation efforts on staff training. Indeed, the Program Guide itself focuses on employees:

• Organizations may keep documentation of ongoing training in personnel files located in the personnel department, or these files may be a part of staff records held within the program’s department.
• In-house training on performance of job functions may be documented in staff meeting minutes, if the presentation occurred at that time. Please use sign-in sheets or record staff participating to document attendance.
• Staff located remotely or off-site, who are unable to participate in orientation provided at the organization’s site may sign a statement that they have read and understand the URAC standards related to their job responsibilities, and the orientation materials provided including policies and procedures and clinical decision support tools used to implement the program.

Yet, a literal reading of the standard would not limit its application to employees, but would have it extend to contractors to whom the accredited company has delegated functions, as well. Conversations that I've had in recent days with URAC-accredited companies that have recently gone through either a full on-site review or a monitoring on-site review reveal that URAC reviewers seem increasingly likely to look for documentation demonstrating that the accredited company's delegates, too, have received training in the applicable accreditation standards.

This training need not be at a URAC seminar. The company being reviewed may design its own training, hire a consultant, or use online training (such as that provided by Integral Healthcare Solutions) to provide that training, so long as it is clear to the URAC reviewer that the training is based on the most recent URAC standards that apply to the functions performed by the contractor.

URAC has long been well ahead of other accreditation organizations in recognizing the prevalence of the use of delegation in managed health care. It should come as no surprise, then, that URAC would make sure that contractors performing functions for URAC-accredited companies be adequately trained in the URAC standards that they are required by contract to uphold (see Core 17(b)).