Policy: Contracted Provider Dismissal | ||
| Policy Number: 310 | Policy Section: Quality | |
| Owner: Lolly Coleman, Director of Quality | Approved By: Doug Newton, MD - CMO | |
| Effective Date: 3/17/23 | Date of Last Review: 3/21/2023, 3/27/2024, 12/20/25 | |
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
Group is committed to the delivery of high-quality care to patients and ensuring compliance with all relevant laws, regulations, and standards of care. In the event that a contracted provider is found to have violated these expectations and compliance standards, the Company has a responsibility to investigate, intervene, and take action, ranging from educational consultation to contract termination.
Applicability
This policy applies to all providers contracted with the Group.
Definitions
Dismissal: the act of terminating a provider’s contract with Group so that they can no longer provide services to clients through Rula’s platform
Policy
- Expectations
- Providers must follow all expectations as outlined by their signed contract agreement.
B. Reporting
- Any concerns related to quality, credentialing, or clinical care should be reported to clinical quality and/or the quality and patient safety committee. This includes, but is not limited to, concerns related to patient safety, quality of care issues, patient experience, professionalism, and failure to follow established protocols and maintain all requirements for independent practice.
C. Investigation
- Clinical Quality Leadership or designee will conduct a thorough investigation of any concerns reported, including review of the concern against contract expectations.
- The Compliance Team will guide investigations in relation to concerns that are primarily compliance-related (for example, false billing allegations).
- The investigation may include interviewing patients/providers, reviewing medical records, data analysis, reviewing complaints and grievances, and/or consulting with external experts as necessary.
- While the investigation is taking place, a provider may be prevented from receiving new patients or continuing to see existing patients..
- After the investigation is complete, it must be determined whether or not a contract breach occurred. If a contract breach occurred, the provider will be terminated via administrative termination. If an objective breach is not identified, the findings will be made to the Quality Team and/or Quality Patient Safety Governance Committee for further action and can include:
- No action: No or insufficient evidence of concern
- Continued monitoring
- Email outreach from Clinical Quality team with supportive resources
- 1:1 Quality Consultation can be recommended or required
- Pausing the provider to new patient referrals can be temporary or indefinite
- An indefinite pause to new patient referrals indicates that there are no identified patient safety concerns with the provider’s existing caseload of patients, however violations have occurred that warrant the Group from withholding additional patients. To support transitional care, the provider, in this circumstance, is able to complete care with their caseload and will be considered terminated from the Group upon discharge of their final patient.
- Pausing the provider to payments for services provided: This action may be taken when there is evidence of a provider over utilizing services or in any other way displaying noncompliance with payer expectations.
- Dismissal from the network can occur when any portion of the provider contract is breached or when the quality and patient safety committee votes to terminate the provider’s contract.
- Any termination that occurs as the result of the Quality and Patient Safety Committee review and vote, will be considered eligible for appeal rights. Appeals are reviewed by the Appeals Subcommittee.
D. Termination of the Provider Contract/Dismissal from the network
- If the recommended action is dismissal, Quality will notify the provider via email with a follow-up text (SMS) message.
- Providers will be discontinued from patient care immediately after notification.
- A representative from Clinical Leadership or designee will follow the internal dismissal workflow to ensure that the provider is removed from the network and future correspondence.
- All steps involved in processing a provider’s departure from Rula will be expedited in the case of a dismissal decision.
- Some incidents may warrant a report to a provider’s licensing board. The Quality and Patient Safety Committee reserves the right to report a provider to their board when appropriate, with the guidance of the Compliance Team.
- Terminations that occur due to quality concerns are not eligible for rejoining the Group within six months. After six months, requests to rejoin will be reviewed among the standard channels (credentialing and quality patient safety).
E. Management of Patient Experience
- In the event that a provider’s contract is terminated, the organization will take steps to ensure that patient care is not compromised.
- Prior to the patient’s next scheduled appointment, the patient(s) will be notified that their provider is no longer available through Company and patient rematching is coordinated with Clinical Quality, Care Coordination, and Support Teams.
Attachments:
A: None.
Updated