Back-Up Staffing Guidelines
The back-up staffing plan is designed to assure the health and safety of members receiving Innovations services. Failure to provide back-up staffing is a Level I Incident and must be reported to the MCO. Partners has created electronic forms as the reporting mechanism to be used by providers/Employers of Record (EORs).
The NC Department of Health and Human Services (NC DHHS) communicated via Joint Communication Bulletin 256 (#J256) on July 3, 2017 that “It is the expectation that if a provider agency or Employer of Record (EOR) staff member is unable to provide back-up staff, the provider or EOR is required to report this lack of staffing to the LME-MCO.” This is a requirement and back-up staffing reports should be submitted semi-monthly.
In relation to back-up staffing, there are two types of service interruptions:
- Failure to provide backup staffing
- Service breaks
When to Submit a Failure to Provide Back-Up Staffing Report
1) Regularly scheduled staff is unable to provide service(s) AND a back-up staff is not available.
2) Regularly scheduled staff is unable to provide service(s) and back-up staff is available BUT is declined by the member/legally responsible person.
The purpose of the back-up staffing report is to document the reason that BACK-UP STAFF was not provided. The Back-Up Staffing report is NOT used to report service breaks.
Service Breaks
Per Clinical Coverage Policy 8P https://files.nc.gov/ncdma/documents/files/8-P.pdf , and also communicated via Joint Communication Bulletin #J266 on September 21, 2017, service breaks do not require Back-Up Staffing reporting to the MCO. Service breaks are defined as holidays, vacations, weather conditions, illnesses, and scheduling conflicts. Services breaks should be documented in the member’s record.
Service Breaks v/s Failure to Provide Back Up Staffing
Service Breaks are member driven in that the service was not provided due to the member canceling the service.
Failure to provide Back Up Staffing is provider driven in that the service is not provided because the provider is unable to provide staffing.
The following table contains scenarios regarding when to complete a Failure to Provide Back-Up Staffing Report versus document a service break in the member’s record. The scenarios are based on information provided by DHB in response to questions they have received from providers regarding completion and submission of Failure to Provide Back-Up Staffing Incident Reports.
| Scenario | Type of Incident | Provider Action Step | Submit via Cognito Electronic Form |
| Member had doctor’s appointment and services were not provided | Service Break | Document the service break in the member record
|
No |
| Member went on vacation and did not receive services | Service Break | Document the service break in the member record | No |
| Regularly scheduled staff out due to illness. Back-up staff was offered but member/family did not want another staff person or back-up staff was unavailable | Failure to Provide Back-Up | Complete Failure to Provide Back-up Staffing Incident Report | Yes |
| Regularly scheduled staff quit. Back-up staff was offered but member/family did not want another staff person or back-up staff was unavailable | Failure to Provide Back-up | Complete Failure to Provide Back-up Staffing Incident Report | Yes |
| Member/family not utilizing all authorized service units available | Service Break | Document the service break in the member record | No |
| Member/family did not notify the supervisor that regularly scheduled staff did not show up for work until several days after the fact | Failure to Provide Back-up | Complete Failure to Provide Back- up Staffing Incident Report | Yes |
| New regularly scheduled staff in the process of being hired. Back-up staff offered during interim but declined or back-up staff was unavailable | Failure to Provide Back-up | Complete Failure to Provide Back- up Staffing Incident Report | Yes |
| Member did not have services over a holiday per member/family request | Service Break | Document the service break in the member record | No |
| Member/Parent/Guardian requested no staff to come to give consumer a break | Service Break | Document the service break in the member record | No |
| Member/Family requested no services due to inclement weather | Service Break | Document the service break in the member record | No |
| Member is sick and unable to participate in services | Service Break | Document the service break in the member record | No |
| Member is in the hospital | Service Break | Document the service break in the member record | No |
| Member/Family had a scheduling conflict and requested cancellation of services | Service Break | Document the service break in the member record | No |
| Provider is closed for a holiday | Service Break | Document the service break in the member record | No |
| Provider is closed or closes early due to inclement weather | Service Break | Document the service break in the member record | No |
Submitting the Failure to Provide Back-Up Staffing Report is a requirement by the Division of Health Service Regulation (DHSR). Information from the reports submitted by providers is used in a quarterly report required to be submitted to DHSR by the MCOs. Partners also provides quarterly reporting to our Human Rights Committee and monthly reporting to our Quality of Care Committee.
REINSTITUTION OF NC INNOVATIONS WAIVER BACK-UP STAFFING REPORT
On July 22, 2022, DHSR issued Joint Communication Bulletin #J427 to announce the reinstitution of the NC Innovations Waiver Backup Staffing Reporting, effective August 16,2022. The requirement for backup staffing reporting by providers/EORs had been put on hold at the beginning of the COVID-19 Public Health Emergency.
Dates of failure to provide backup staffing incidents beginning August 16, 2022 should be reported by providers/EORs to Partner Health Management using the online forms discussed in the sections below.
BACK-UP STAFFING REPORTING
Partners has developed a new reporting mechanism for backup staffing reporting. Backup Staffing reports will be reported through online forms located in the Provider Knowledge Base and in the EOR section of the Partners Public Website. The information required is the same for providers and EORs.
Failure to Provide Backup Staffing Incident Form
Basic information required at the beginning of the form is: Name of Provider Agency/EOR, Provider/EOR Address, Name (first and last), title, phone number, and e-mail of person submitting the form.
Reporting Period: The reporting period choices in the dropdown are the 1st-15th or 16th-last day of the month. This is based on J#266 9/21/17, requiring semi-monthly reporting. When you have selected your reporting period, you will then select the month and year in the drop-down boxes.
Innovations Incident Reporting for Failure to Provide Back-Up Staffing: This section includes the Date of Incident, Member Name, Member Date of Birth (DOB), Member ID (ID# assigned in Alpha+), Service chosen from the drop-down box, # of hours missed, County of Service (drop-down), Reason back-up staffing not provided (drop-down)-if reason is “Other”, explain in the Comments box, Reason for No primary staff (drop-down_-if reason is “Other”, explain in the Comments section, and How was the Health and Safety of Member Assured (drop down), and Comments for additional explanation if needed.
You will click on “+Add Item” to create additional lines to complete your reporting.
Verify information being reported.
Signature: When your reporting is complete, click on either “draw” or “type”, then draw or type your signature, then click “Submit” to send to Partners.
Providers Failure to Provide Backup Staffing Form: Provider Knowledge Base > Care Management > NC Innovations > NC Innovations Forms
https://www.cognitoforms.com/PartnersHealthManagement9/failuretoprovidebackupstaffingincidentform
EOR Failure to Provide Backup Staffing Form: partnersbhm.org > Services > Intellectual and Developmental Disabilities > Employer of Record
https://www.cognitoforms.com/PartnersHealthManagement9/failuretoprovidebackupstaffingincidentform
Attestation of No Backup Staffing Incidents
Providers/EORs with no backup staffing incidents for a reporting period will submit the Attestation of No backup Staffing Incidents form via an online form on the Provider Knowledge Base and the EOR section of the Partners Public website.
This is a new piece of the backup staffing process and will help assure we have better data to assist the providers/EORs. It is a very quick and simple process with the online form.
The basic information needed on the first part of the form is the Name of Provider Agency/EOR, address, Name (first and last) of person submitting the form, phone number, and e-mail address.
Reporting Period: The reporting period choices in the dropdown are the 1st-15th or 16th-last day of the month. This is based on J#266 9/21/17, requiring semi-monthly reporting. When you have selected your reporting period, you will then select the month and year in the drop-down boxes. The deadline for submitting failure to provide back-up staffing and attestation of no back-up staffing incident reports is the last day of the next reporting period Example: Back-up staffing reports and attestations of no back-up staffing incidents for dates 12/1/22-12/15/22 should be submitted by 12/31/22.
Signature: When your reporting is complete, click on either “draw” or “type”, then draw or type your signature, then click “Submit” to send to Partners.
Providers Attestation of No Backup Staffing Incidents: Provider Knowledge Base > Care Management > NC Innovations > NC Innovations Forms
https://www.cognitoforms.com/PartnersHealthManagement9/attestationofnobackupstaffingincidents
EORs Attestation of No Backup Staffing Incidents: partnersbhm.org > Services > Intellectual and Developmental Disabilities > Employer of Record
https://www.cognitoforms.com/PartnersHealthManagement9/attestationofnobackupstaffingincidents
If you have questions, please contact: backupstaffing@partnersbhm.org