Human Resources

URAC has long required organizations to demonstrate that they train their employees and senior clinical staff members in a variety of areas, including confidentiality, conflict of interest, and the applicable URAC standards.  The current (v. 3.0) Core 27 reads:

The organization has an ongoing training program that includes: (No Weight)
    (a) Initial orientation and/or training for all staff before assuming assigned roles and responsibilities; (2)
    (b) Training in current URAC standards as appropriate to job functions; (2)
    (c) Conflict of interest; (4)
    (d) Confidentiality; (Mandatory)
    (e) Documentation of all training provided for staff; and (2)
    (f) Ongoing training, at a minimum annually, to maintain professional competency. (2)

The question here is "what do I submit on AccreditNet for Desktop Review?"  The Interpretive Information suggests:

• Training program outlines/agendas for all levels of program staff (employee and senior clinical staff person) that include all elements of the standard.
  

• Tools used to document orientation and training activities.

The first bullet is similar to the earlier versions of Core, while the second bullet is new.  What is also new is that URAC reviewers are more rigorously enforcing this documentation requirement.  There was a time when it would have been sufficient for most URAC reviewers to submit, at the Desktop Review phase, a P&P outlining training requirements and a couple of examples of agendas and sign-in sheets of various trainings. 

In recent weeks, however, we've seen evidence that URAC reviewers are taking this submission requirement more literally than in previous years.  So, we recommend that you do exactly as suggested -- submit for Desktop Review a full complement of training program outlines and agendas for all employees across all the required types of training.  

I talk a bit more about this in the following 3-minute video.

For a 7-minute video on URAC training, click here.

In any event, read on:

It is useful to think about the issue of "training" in two compartments -- (1) training required by URAC and (2) training for the onsite review.  I will handle them separately.

1.  Training required by URAC

As you know, URAC has specific requirements for staff training that relate both to the content of staff training and its administration:

Content
Most of the explicit training requirements in the URAC standards are found in the Core and Pharm Core standards: 

• Initial orientation and/or training for all staff before assuming assigned roles and responsibilities; (Core 7(a))
  • Training in the P&Ps that apply to one's job is implied by Core 3(a), too
• Ongoing training, at a minimum annually, to maintain professional competency; (Core 7(b))
• Training in current URAC Standards as appropriate to job functions; (Core 7(c))
• Training in state and regulatory requirements as related to job functions; (Core 7(d))
• Conflict of interest; (Core 7(e))
• Confidentiality (Core 7(f)) and specifically HIPAA (Core 24)
• Training on identification and prevention of fraud and abuse, as appropriate to job functions; (Core 7(g))
• Delegation oversight, if necessary; and (Core 7(h))

In addition, training of employees in how to do their job consistent with company P&Ps and URAC standards  is implied throughout the standards, via Core 3(a), 7(a), and 7(c).

Administration

• There must be documentation of all training provided for staff (Core 7(i))
• There must be a signed document acknowledging training on confidentiality issues (Core 24)

Some of this is company-wide training (e.g., confidentiality); some is department-specific (e.g., P&Ps on how to follow DM P&Ps.)  Company-wide training is typically handled either through:

1. company-wide meetings
2. computer-based training modules required of all employees, or
3. smaller, face-to-face trainings required of all employees. 

Department-specific training is typically handled through

1. modular computer-based training programs or
2. departmental staff meetings

2.  Training for the URAC Review Process

The best preparation for the URAC review is the substantive training described in the previous section.  A staff member who knows his/her job as described by the applicable P&Ps, knows the URAC standards and state/federal regulations that apply to the job, and can retrieve the documents to be sought by the URAC reviewer is unlikely to get tripped up in a URAC review, even if they have no specific preparation for the onsite review process.

Additionally, the mock onsite review we conduct for our clients is valuable for staff members likely to be either interviewed or pulling documents during the onsite review.  We spend a good portion of our time onsite not only conducting document-pulls and interviews as realistically as possible, but also counseling staff members on how to improve their performance for the actual review.