Peer Review Policy

SUD Specialty Group – CA, Mental Health Specialty Group, P.A., Mental Health Specialty Group NJ, PC, and Mental Health Specialty Group KS, P.A. (collectively, “Group”) contracts with Path, CCM, Inc. d/b/a Rula (“Rula”) for management and administrative support services. Each entity within the Group and Rula may be referenced herein as a Company and, collectively, as the Companies.

Policy Statement

This policy outlines a comprehensive peer review process to ensure service records adhere to required standards. The purpose of peer review is to provide routine evaluation of documented practice standards to examine clinical care and service delivery, which may support the identification of opportunities for improvement that will produce the highest quality of care. 

Applicability:

This policy applies to all team members. For purposes of this policy, the Companies’ team members include individuals who would be considered part of the workforce, such as employees, independent contractors, and other persons whose work performance is under the direct purview of the Companies’  business practices.  

Definitions

Peer Review:  a process in which trained, qualified, licensed clinicians (and/or a software tool overseen by licensed clinicians) evaluate the clinical competence, documentation practices, and the quality and appropriateness of care delivered by service providers by way of reviewing patient records.   

Peer Reviewer:  any physician, nurse practitioner, social worker, psychologist, licensed therapist, or licensed counselor who has the clinical expertise and training to conduct an evaluation of documentation.  The peer involved in the review shall have the same level of license/credentials, or higher, as the person being reviewed.  

Provider: an individual who is qualified by licensure and experience to provide services to patients and who is employed or contracted by the Group to provide those services

Policy

1. Clinical chart review protections
   1. Clinical chart reviews are considered peer review, the confidentiality of which is protected by HIPAA.  Clinical chart reviews are used for ongoing quality improvement efforts related to the necessity, appropriateness, or quality of services rendered to a patient, or the qualifications, competence, or performance of a provider. Clinical chart reviews may also be used for the retroactive review of patient safety incidents, determination of record release, or by individual payer request. 
   2. The record of the clinical chart review, including but not limited to the associated review form, the data collected, and the resulting reports, findings, and conclusions are confidential and are not part of the designated medical record set, are not shared externally, are not public record, are typically not discoverable, and shall not be used as evidence in a civil or administrative proceeding. 
2. Clinical chart review may be completed or requested for various reasons, including, but not limited to:
   1. Review of a specific provider based on issues identified by a patient or the patient’s representative, a payer, a submitted Complaint, and/or any issue brought to the attention of Rula’s Quality team. 
   2. A provider may request assistance from the Rula clinical care reviewer team to review specific patient charts or an aggregate of patient charts focused on a specific concern. 
   3. Routine (monthly) monitoring occurs by choosing a sample of 8 patient charts per eligible provider within Rula’s network. The eligible population are providers with enough clinical documentation to warrant a review, and clients who have been seen within the month prior to the month the peer review is completed. This is an ongoing process that occurs monthly.  
3. Documentation of reviews and results
   1. Peer review findings will be documented in a format that fits the request.  
   2. Results of clinical peer review will be sent to the appropriate party for the purpose of quality/practice improvement.  The information contained in the peer review may be incorporated into decision making related to the provider’s contract. 

Updated December 18, 2025 14:24