Be aware there are some revisions coming to the Care, Treatment, and Services chapter of the Behavioral Health Care Manual effective July 1, 2017. One is a fairly substantive addition to treatment planning requirements and the other is a wording clarification regarding health screenings. Highlights are as follows:

Discharge Criteria and Process Included in Treatment Plan

The most significant new requirement is an addition to the treatment planning standard CTS.03.01.03 EP # 2. Currently, this standard requires that the treatment plan include:

  • Goals expressed in a manner that captures the individual’s words or ideas
  • Goals that build on the individual’s strengths
  • Factors that support the transition to community integration when identified as a need during assessment

The new requirement specifies that the treatment plan must also include “the criteria and process for the individual’s expected successful transfer and/or discharge, which the organization discusses with the individual.” Essentially, this means that the treatment plan needs to include discharge (or transfer) criteria and that the goals/objectives on the treatment plan should reflect measurable steps the individual will take toward meeting those discharge criteria. It also means that these discharge criteria must be discussed with the individual. This new requirement reinforces the adage that “discharge planning begins at admission.” It takes that concept a step further by stressing the importance of engaging the client/family in a discussion about discharge criteria and discharge related goals and incorporating those into the treatment plan.

To be prepared for how this new requirement will be surveyed, we recommend you review your current treatment planning process and clinical record formats with the following questions in mind:

  • What is the process for identifying discharge criteria?
  • How and where are discharge criteria documented in the record?
  • Is there a process for discussing these discharge criteria with the client/family?
  • Do treatment plans currently include discharge related goals and objectives?
  • How can the current discharge planning process be more integrated with the treatment plan?

Also, keep in mind that if you are a psychiatric hospital with a program surveyed under the BH standards, this new requirement applies to that program.

Clarification Regarding Health Screenings

The other revision is really simply a wording clarification. It’s in CTS.02.01.05 which covers the requirement for a health screening in non-24 hour settings to determine the need for a medical history and physical exam. The wording of Note 2 has been revised to clarify that if the BH organization conducts a physical exam on all individuals served, then the organization is in compliance with this standard. (This makes sense because, indeed, the organization is exceeding the requirement to conduct a health screening by actually conducting an H&P.) The same wording clarification has been added to CTS.02.01.06 which covers residential care.

Both of these revisions are part of TJC’s project to review and update the Behavioral Health standards manual. We will be sure to keep you informed of additional revisions that impact organiztions and programs surveyed under these standards.

Compliance Catch-Up Welcome The Sanctuary at the Woodlands