UPDATED ONLY FOR LOGO AND BRANDING

Provider Notice

To: HealthChoices Network Providers

From: Sheryl M. Swanson, MBA, VP, Provider Network Operations

Date: November 30, 2011

Subject: AD 11 117 OMHSAS Policy Clarification Regarding BSC Education Requirements and Applicability Across the Network

The Attached policy clarification speaks to the importance of closely investigating the education credentials of staff hired. While this policy clarification focuses on Behavioral Specialist Consultant, it exposes a concern regarding education for all clinical staff hired. Education provides the foundation for solid treatment delivery and as such, providers must be diligent in assuring that each employee received their education from a valid, recognized entity. The policy clarification indicates that The United States Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA) recognize accreditation agencies that ensure their accredited schools "meet acceptable standards of quality" and "maintain standards requisite for its graduates to gain admission to other reputable institutions of higher learning or to achieve credentials for professional practice" (http://www.ed.gov). A CHEA and USDE-recognized accrediting organization is considered a "reliable authority as to the quality of postsecondary education within the meaning of the U.S. Federal Higher Education Act of 1965" (http://www.chea.org). A complete list of USDE and CHEA accrediting agencies as of August 2011 is attached to the policy clarification. Licensed Provider organizations and supervising clinicians have a responsibility to verify the credentials of their staff. Prior to credentialing any Agency Provider, PerformCare verifies that there is an acceptable process in place for Provider staff credentialing. Providers must verify and maintain documentation of the verification of certain credentialing elements for their staff. Please review the PerformCare Provider Manual for additional detail about credentialing expectations. Please know that from this point forward, PerformCare will be monitoring policies and procedures for evidence of proper verification of education, including that education requirements of staff are met through properly accredited entities. PerformCare and the counties are committed to supporting our providers and ensuring that they provide the highest possible quality service delivery in our networks. You are encouraged to contact your Provider Relations Representative with any questions or concerns.

ATTACHMENT

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Office of Mental Health And Substance Abuse Services Bureau of Policy and Program Development

Issue Clarification #: 02-11 Applicability: All Zones Date of Receipt: 06-09-2010 Source Documentation: MAB 01-94-01 Submitted by: Pamela Hunter, Bureau of Program Integrity County Authority: Butler Topic Area: Educational requirements for behavioral Specialist Consultant (BSC) Question:

HealthChoices Behavioral Health Policy Clarification

We are requesting interpretation of MAB# 01-01-05 and # 01-94-01.

Can an individual with a BSC's Master Degree obtained from a non-accredited, online organization be considered as having met the minimum staff qualifications to provide behavioral health services?

Background: A current referral received by the BPI, involves an individual who obtained a BSC degree from Ashwood University with an Education major and a Master of Arts Degree.

The BSC's degree is being deemed invalid by a Behavioral Health MCO audit. The Plan has found the documentation for the Master Degree to be from a non-accredited, online organization and has considered the documentation to show inadequate education or work experience.

Ashwood University advertises it is a fully recognized University awarded the status of accreditation from the Board of Online Universities Accreditation (BOUA) and the World Online Education Accrediting Commission (WOEAC).

However, the BOUA and WOEAC are accrediting bodies that award degrees on the basis of employment and life-learned experiences.

Both bulletins contain staff qualification language relating to "degree" requirements and staff who obtain a "level" of achievement. However, there is no information in either bulletin with regard to staff who has obtained degrees online.

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OMHSAS Answer/Response:

The United States Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA) recognize accreditation agencies that ensure their accredited schools "meet acceptable standards of quality" and "maintain standards requisite for its graduates to gain admission to other reputable institutions of higher learning or to achieve credentials for professional practice" (http://www.ed.gov). A CHEA and USDE-recognized accrediting organization is considered a "reliable authority as to the quality of postsecondary education within the meaning of the U.S. federal Higher Education Act of 1965" (http://www.chea.org). A complete list of USDE and CHEA accrediting agencies as of August 2011 is attached.

Neither BOUA nor WOEAC are recognized by the US Department of Education or the Council for Higher Education Accreditation; and as such, they have no authority to provide nationally recognized accreditation. Therefore, the "degrees" from unaccredited institutions such as Ashwood University are not acceptable as proof that an individual has satisfied any academic requirements to meet job qualifications.

In this particular case, the MA degree in Education would not be sufficient to meet the requirements set forth in Medical Assistance Bulletin 01-94-01 for a BSC, regardless of the granting institution, because an Education degree does not qualify a graduate as a "master's level mental health clinician."

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