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Committee on Professional
Practice and Standards Seeks Comments on Record Keeping Guidelines
The Committee on Professional Practice and Standards (COPPS), a
committee of the Board of Professional Affairs, is in the process
of reviewing and revising the Record Keeping Guidelines adopted
as APA policy in 1993 (American Psychologist, 48,
984–986). COPPS requests input from the membership regarding
this revision. The current version of the document on which COPPS
is seeking feedback can be found at http://www.apa.org/practice/Record_Keeping_Guidelines_-_Comments.pdf.
Instructions and form for comments may be found at http://www.apa.org/practice/guidelines_cmt.html.
The Record Keeping Guidelines are intended for use by providers
of health care services. These guidelines are designed to educate
psychologists and provide a framework for making decisions regarding
professional records. The current guidelines are based upon the
General Guidelines for Providers of Psychological Services (APA,
1987) and the previous version of the APA Ethical Principles of
Psychologists and Code of Conduct (APA, 1992).
COPPS seeks your: 1) evaluation of the importance, relevance, and
adequacy of the existing guidelines and the specific aspects of
the document that are helpful and not helpful; 2) recommendations
for specific changes to the existing guidelines or language, including
descriptions of situations where you directly experienced difficulty
or uncertainty in keeping clinical records, 3) specific questions
about record keeping about which you would like more information;
4) additional questions based on the contents of the current version
of the APA Ethical Principles of Psychologists and Code of Conduct
(APA, 2002) http://www.apa.org/ethics/code2002.html;
5) recommendations for additional guidelines or language to address
any areas not covered in the current guidelines.
Possible areas for revised or new guidelines include (but are not
limited to) the following: content of records, confidentiality of
records, maintenance and retention of records, protection against
misuse, informed consent, documentation of multiple-client treatment,
assessment, managing practice transitions (moving, illness, death),
documentation in medical settings (e.g., primary care clinics, medical
inpatient units, hospices), electronic records and security issues.
Please respond with comments by March 19, 2004.
1) Current Guidelines:
http://www.apa.org/practice/Record_Keeping_Guidelines_-_Comments.pdf
2) Comment Form and Instructions:
http://www.apa.org/practice/guidelines_cmt.html
Appropriations Law Directs
Cardiac Demonstration Project
When the Fiscal Year 2004 Omnibus Appropriations Act became law
in January, it included a boon for psychology and psychological
services. The law includes a demonstration project to show the economic
and health benefits of incorporating psychological interventions
into cardiac patient care.
The Appropriations Act directs the Centers for Medicare and Medicaid
Services (CMS) to study the cost savings and quality of care benefits
that result from incorporating psychological interventions in the
treatment of Medicare beneficiaries with heart disease. Representatives
of the APA Practice Organization worked for several months leading
up to the law’s passage to secure this provision.
The demonstration project is included as part of a multi-billion
dollar appropriation for CMS, the National Heart, Lung, and Blood
Institute, and the Centers for Disease Control. The Appropriations
Act directs these federal agencies to initiate and continue research
involving behavioral interventions for treating heart disease.
The CMS project is an extension of recent psychological research.
A landmark 2002 study led by psychologist Jim Blumenthal, PhD, and
his colleagues at the Duke University Medical Center showed that
patients who were taught to manage their stress better in addition
to receiving usual medical care had fewer adverse cardiac events
and cost less to treat over a five-year period.
Unlike the Duke research, the CMS study will focus on Medicare beneficiaries.
Yet the APA Practice Organization expects that the two studies ultimately
will be similar in demonstrating substantial cost savings and improved
health outcomes.
This expectation reflects the high incidence of cardiovascular
disease among the nation’s elderly. According to the American
Heart Association, the federal government estimates the prevalence
of cardiovascular disease among 65 to 74 year-old Americans at 65
percent.
The Practice Organization is now working to help ensure appropriate
and timely implementation of the CMS study. In the long run, we
expect this project will help guide further integration of psychological
and medical treatments for cardiovascular patients.
Psychology Continues
to Challenge Managed Care Plan
The APA Practice Organization, in collaboration with the New York
State Psychological Association (NYSPA), continues to monitor Oxford
Health Plans, Inc. with regard to the company’s retrospective
audits of psychologists’ patient records. Association members
have aided the effort by providing important information to help
organized psychology address the profession’s concerns.
Oxford is a managed care company that operates primarily in New
York, as well as New Jersey and Connecticut. The company began retrospective
audits of some of its contracted mental health professionals in
2002, covering files going back seven years. Oxford often did not
show that it had obtained valid patient consent to release the records.
After performing the audits, Oxford demanded large refunds, claiming
that notes of particular client sessions were not sufficiently detailed.
In response to member complaints, the APA Practice Organization
and NYSPA sent Oxford a letter in October 2003 insisting that the
company stop making demands for large refunds from New York psychologists
following the audits. The organizations expressed their concern
that the insurance company’s actions violated Oxford’s
contractual agreements with psychologists.
The following month, in a written response from Oxford, company
representatives said Oxford would discontinue its audit and repayment
demands in connection with claims of inadequate record keeping.
The company also publicly announced that it would even return money
that providers already had repaid.
Some APA members have alerted the Practice Organization that Oxford
is not retracting its demands for payment refunds as quickly as
we had expected. As part of its ongoing communication with company
officials, APA Practice Organization representatives are flagging
this issue among others necessary for maintaining good relations
between Oxford and the psychology community.
We will continue to keep APA members apprised of important future
developments.
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