Transcript
Grace Blue (00:00) hey, Carl. How are you? Hey?
Kyle Rice (00:02) Grace. Good. How are you? You’re just coming back from a pto, right?
Grace Blue (00:04) Yes, and catching up on thousands of emails and slacks. I was out for a week.
Kyle Rice (00:10) I know it’s a little bit of a double edged sword going out of office. How was your time off though? It?
Grace Blue (00:15) Was good. I spent some time in New York for a few days and then we took a cruise to Bermuda for five days. So it was nice it was cold though, but it was nice to get away and it’s like you said you enjoy being off, but then it’s like coming back, you’re like, ugh, but then it’s like let me hurry up and get this wrapped up. So, at least by the end of this week, I won’t have all these emails and hopefully everything will already be cleared out and I’m just putting them in a completed folder because people already took care of things. I.
Kyle Rice (00:48) Know, I know it’s that double edged sword where you come back and you’re just sticking out for a little bit. So hopefully you get caught up here and then start to move back into, you know, the normal.
Grace Blue (00:57) Yeah. Did you have a good weekend?
Kyle Rice (00:59) Yeah, it was a quick one. My youngest is a little bit sick today, but besides that, we’re doing okay, he’s been battling something. I don’t know if it’s been like an ear infection or something and daycare just called. And so he’s at the pediatrician right now with my wife. Aww.
Grace Blue (01:13) Oh, he feels better me.
Kyle Rice (01:15) Too. Me too. He was, he’s a mess right now. We had, he’s allergic to amoxicillin, so we found that out last week. Oh, he’s going through the ringer, right?
Grace Blue (01:24) Now, I know he’s probably like, I just want to be better.
Kyle Rice (01:29) I know poor baby, we’ll get him squared away. He’s you know, he’ll be, he’s going to the pediatrician now, so we’ll get everything taken care of. So, are we waiting for anyone else for this afternoon?
Grace Blue (01:43) Yeah. You know, I would think that I know that Catherine is joining. Okay. She has some questions, but Christina looks like she rejected it. Okay? And Kelly didn’t answer. So probably just me and Catherine.
Kyle Rice (01:58) Okay. But.
Grace Blue (02:01) We probably can get started. I would say, okay, whatever questions she has, she can just jump in when she gets on. Yeah.
Kyle Rice (02:10) Yeah, no worries. No worries. I, just for today, I wanted to, here she comes. Okay. I just wanted to review the corrective action plan for the Angelica Olivia issue that we had that you had surfaced. I believe it was just about two weeks ago. And I think there’s a couple questions in here as well, from the cadence side of the house such as like Michigan, prioritization, Alabama for Rustin baker, and then some incorrect forms for Kelly chase, Alaska. And then just wanted to review the renewal status for may and then our priority providers, updates as usual, if that works for you guys. Perfect. Awesome. Hey Catherine. How you doing today?
Grace Blue (02:50) Good, good. How are you, Kyle?
Kyle Rice (02:52) Doing well. Thanks for asking. So awesome. Let’s jump into the corrective action plan real quick for review and then we can kick into our normally scheduled items for today. And I’ll share this over with you guys after the call. So, wanted just to share, the overview for our corrective action plan, for Angelica Olivia.
Kyle Rice (03:17) So, we know the overview, we received an email from you grace, on April eighth alerting to a compliance issue and significant data integrity error identified during a routine review of the practitioner’s provider profile in the medallion system. Specifically, while examining the profile for Angelica Olivia and LPN, it was discovered that medallion had uploaded and linked a California registered nurse license verification to her LPN profile. This is a major error as it misrepresents the practitioner’s credentials and can lead to unauthorized scope of practice and, or other regulatory issues. This is the second recorded instance of an incorrect state, RN license verification being erroneously added to an LPN’s profile in the medallion system within a short timeframe. This specific reoccurrence of this specific type of error elevates the concern from an isolated data entry mistake to a demonstrable and measurable compliance risk within medallion’s credentialing workflow, the integrity of this provider’s data is paramount into ensuring compliance with the state and federal healthcare regula regulations. And repeated errors of this nature, expose cadence health to potential regulatory scrutiny, fines and damage. So just wanted to share a quick timeline of events here. So we know that on 316, the incorrect license verification was added to Angelica’s profile, on four eight, grace, you, let us know that this was identified during a profile review. And then on four seven, the correct verification was also removed. And then the incident was escalated and reviewed by the medallion team internally. So the review included a review of Angelica Olivia’s, LPN medallion profile, including all of her existing licenses. We had several root cause analysis and corrective action plans. I just wanted to walk through. So, on four seven, you guys removed the incorrect license verification from the profile. On four seven. We also conducted an internal review of the incident. One on one coaching was also completed and given with the agent on four nine, as well as a team reminder to validate license type and verification source prior to updating records, a couple of long term measures that we’re taking to prevent this from reoccurring. Again, the team did an sop update, a standard operating procedure update to clearly outline differences between LPN lvn and RN license types, as well as a review. Was conducted to reinforce correct license validation practices. We’ve also reinforced the use of appropriate verification sources. So we updated our internal resources here just to make sure that they’re tracking along that specific practitioner type. We’ve emphasized the license type validation, LPN and lvn versus RN during our internal license verification and our quality control workflows. We’ve also strengthened our QC expectations to ensure mismatched license types are flagged prior to completion. And then we’ve again reinforced our standard operating procedure guidance around not altering core license data without proper validation. And then this last root cause seven which I just wanted to review with you where you’re going to be introducing a new product enhancement here where the quality assurance for all license verification is going to go into a secondary queue for review. So this will help safeguard new license types when they’re entered within the medallion system.
Grace Blue (06:59) Okay. I do want to, thank you. I do just want to point out that with this issue though it was the license type, it was the same name as the person. So just making sure that they’re making sure that because it’s easy to say like John doe and just put it in. So like, you know, validating all the information, not just focusing on the license type, but knowing like, okay, they’re all going to have the same name, but also making sure that it aligns.
Kyle Rice (07:34) Absolutely. Yeah. They’re going to be double checking the provider’s name and type of their license as well. So grace, if you’re entering an LPN license just for your name, for example, they’re going to double validate those demographics as well as the type as well there.
Grace Blue (07:48) Perfect. Thank you.
Kyle Rice (07:49) And then just wanted to share the impact assessment. So this incident reflects a high risk credentialing, data integrity failure where an RN license was incorrectly attributed to an LPN licensing, LPN license, creating a material misrepresentation of provider qualifications. While no downstream impact occurred due to customer identification and correction. The error introduces potential risks related to scope of practice, regulatory exposure and patient safety. Notably, this is the second occurrence with the same error type in a short period indicating a systemic control gap rather than an isolated issue. The reliance on customer detection, further highlights weaknesses in QA assurance processes which we’re working to add in that safeguard with that additional product enhancement. And then without remediation, this pattern increases the risk of regulatory scrutiny, audit findings and reputational harm. Immediate and long term actions are focused on strengthening license validation controls, agent, training, quality control, safeguards, and to ensure credentialing accuracy and prevent reoccurrence.
Kyle Rice (08:55) Cool. Any additional questions or anything? Any other concerns along with this incident that you guys want to go over? No?
Grace Blue (09:07) No, I’ll just like read through this. I’ll forward it to Christina so she can review it as well. She may have additional questions or comments, but, okay.
Kyle Rice (09:17) Yeah, thank you for.
Grace Blue (09:18) Being thorough. Yeah, no problem. But yeah, I’ll take like a deeper dive once you send this over after the meeting. And then like I said, I’ll send it to Christina and see if there’s anything she wants to ask.
Kyle Rice (09:30) Absolutely. Yeah. I know she definitely want to take a review of this as well. So awesome. I will get this sent over for you guys after the call, but just wanted to share our findings and then apologize for the error here. And we’re putting in some additional safeguards here to prevent this from happening moving forward.
Grace Blue (09:47) Perfect. Thank you.
Kyle Rice (09:48) No problem. And then the Alaska employment verifications for Kelly Shea.
Kyle Rice (09:54) I did confirm this morning that she looks like she does have the correct form uploaded for her. Excuse me in tasking right now. So she should be good to go. And I think the last note that she had indicated that was out with her previous employer for signature with Alaska for Rustin baker, that should be sent to the… this should be sent to dr cornell once the qn is approved by the Alabama board of nursing and he should get notification via his portal. I just took a look this morning. It looks like it was still in process but had not been sent over to him as of yet. With the board of nursing there. For all Michigan requests. I saw there were quite a few in there. I think there’s about 17 new requests. I think we had about 34 in total. I did ask our intake team to move those into process. And then I did add a priority tag to all Michigan initial licenses we have in process. It looks like there’s a big group of RNS and lpns in there that we’re processing as new licenses. Is this something you guys want me to report on future meetings in terms of Michigan status?
Catherine (11:06) No, just that we just want them to move a little bit quickly, yeah.
Kyle Rice (11:11) No problem. Yeah. They should be moving through. I did flag those all to the team and let them know our intake team as well as licensing team. So they do have the priority tag added and they should be followed up on every five business days moving forward there, Catherine.
Catherine (11:24) So, does that mean we still have to wait for the two week intake period?
Kyle Rice (11:30) No, I asked the team to move those in the process.
Catherine (11:32) Okay, great. So it’ll be like after that, we’ve kind of skipped that. And now it’s every five days.
Kyle Rice (11:41) Yep. They should go to intake pending provider.
Kyle Rice (11:42) Just give us about a day or so just to get those in the process. And then those should be prioritized moving forward. Awesome. I want to give a quick update on April. All licenses were renewed. Nothing’s currently outstanding and we’re working on may. As of right now, we’ve renewed 40 licenses to date for April. There’s a few looks like Illinois is the theme for the month of may here. It looks like we do have quite a few clinicians that are pending their Illinois state login that we’re just needing to move that forward. And I’ll send this Guy over for you guys after the call, and there’s a few where they’re in flight with either the board or have been sent to the provider for review and approval. Dr. Kernow. I know we’re working to renew licenses 30 days out in advance. His Oklahoma renewal is in process with the board. And then dr Feldman, it looks like we have his next upcoming as of New York which is expiring on six 30 26 and that has been assigned to the team for population.
Kyle Rice (12:48) Did you guys want to touch on any provider? I cannot even talk today. The priority providers updates for this afternoon? Any specific providers or licenses in question that we want to go over a review?
Grace Blue (13:01) Not that I can think of because I’m just jumping back into everything but nothing at the top of the mind for me right now. I don’t know if Catherine there’s anything. I.
Catherine (13:13) Guess, grace, I know that you said you were following up separately on the South Carolina Dea, Jennifer apple.
Grace Blue (13:21) Yeah, I sent Kyle another message. I don’t have a chance to look at it yet, but we were talking about it earlier. So we were talking about his, her address.
Kyle Rice (13:30) Name. I just said it if you want us to put on hold while she was updating that I can do that. Just while she’s updating it or we can.
Grace Blue (13:39) Yeah. The other, yeah, the other part of it was, is it required for her to do get the RX for South Carolina? Is the Dea required? I know the application asked for it, but is it required that she has it?
Kyle Rice (13:54) Only if she’s going to be prescribing controlled dangerous substances?
Catherine (13:57) So, like, we don’t need the Dea ever, Kyle here, and we only have it turned on for, I think a couple like maybe Brittany and like, I think we gave you a list but like, for the most part, we shouldn’t be renewing or.
Kyle Rice (14:16) Completing the initial.
Catherine (14:17) Yeah, or completing a Dea. We requested… prescriptive authority applications, but that should be at least my understanding Kyle is like it should be different at least when we’ve submitted prescriptive authority applications. They’ve never been like you have to have a Dea attached to it or anything like that. So, I’d be surprised. I mean, I was surprised when Jennifer apple said that this was required for this, but maybe it’s something that you all turned down accidentally or maybe we didn’t know that we didn’t want. So I just want to make sure that if we don’t require it, we’re not moving forward with it. And yeah, I think that’s pretty.
Grace Blue (15:00) Much it. Yeah, I think the thing here is that the application asks like the one that they completed for the South Carolina RX says, do you have a Dea? So they said yes, that makes sense. Yeah. So the question, is it actually required for the RX application or is it just like a yes or no? Gotcha. That’s the?
Kyle Rice (15:21) More? So just a yes or no. They’re just asking to list it if like she’s held one previously, I believe an active one. So she’s just applying for that prescriptive authority and thanks so much for the refresher there. She would not need a net new Dea for that to get the.
Catherine (15:37) Yeah. And then grace, like if they wanna keep it, they can do that and then just renew it, but they pay for it on their own. So it’s like if she decides to answer yes, then I’m assuming she’s like wanting to keep it. But if she decides to answer no, then like that’s on her and she doesn’t have to renew it for her job here. And Kyle, so it sounds like we don’t need it and it’s just like a question that it’s asking just.
Kyle Rice (16:01) A question. Yep. Okay, perfect. Yeah, just a question. They’re just more so asking for like licensure history in terms of prescribing?
Grace Blue (16:10) Actually, it does say you will need to provide a current state issued license verification or a current de, registration that reflects current prescriptive authority licensure. Do you have another state? Yes? I’m just reading the application to make sure that they answered it correctly?
Catherine (16:31) Maybe Kyle, if you could look into it separately just to make sure. And because I feel like the way grace is wording, it does seem kind of confusing. Like it does seem like they want it. So could you get back to us on that?
Kyle Rice (16:44) Yeah, absolutely. I’m just taking a look now. I’m thinking she should have a license with prescriptive authority. Yeah, she has a couple licenses with prescriptive authority that we can just send the evidence over to that. Okay, perfect. So I don’t think she should need that Dea, but I’ll close the gap there with that email as well.
Grace Blue (17:02) Yeah. The wording is, yeah, if you could just verify because it is confusing when you read the question on the application. So, yeah. Okay. We’ll wait for you to come back and then I’ll.
Catherine (17:11) respond back to her. And then Kyle, just so you know, this is also probably one where we need to pause the South Carolina prescriptive authority application just because right now we don’t have a collaborator for those. I don’t know if you remember, but with Brittany, we also paused it. So, yeah, if we could just like move forward with the application and pause the prescriptive authority, that would be great. So.
Kyle Rice (17:37) Move forward with the South Carolina NP and then pause the prescriptive authority for Jennifer apple.
Kyle Rice (17:43) Okay. So I’ll move that on hold as well. And then I’ll get some investigation and confirmation for you guys on that Dea aspect too.
Grace Blue (17:49) Thank you.
Kyle Rice (17:51) Yeah. No problem. Any additional priority providers that we want to touch on for today or Hawaii updates at all or what works best for the rest of the call?
Grace Blue (18:02) No, I mean, I think you have pretty good updates. If we just look at them, you don’t need to go through each of them, but, okay.
Kyle Rice (18:11) Yeah, I’ll send these over after the call too. So you guys are tracking.
Catherine (18:13) Yeah, that looks good. I.
Kyle Rice (18:15) Did see a couple licenses that were issued. So I’ll make sure that those are closed out as well. I’ll send you guys a copy of the corrective action plan as well. And then I’ll get the confirmation on Jennifer apple, and we’ll move her over to holdstaff for her prescriptive authority. I just want to check in anything else that I can assist with in terms of questions or?
Catherine (18:38) Updates. I guess Kyle, for Rustin bakers, Alabama. I guess I’m reading, did you respond should be sent to dr nutterportal once QA plan is approved? Okay? So we’re waiting on Alabama to approve the QA plan.
Kyle Rice (18:54) Yes. Yeah. And then they should, I believe the notice should go directly to dr nutterportal’s Alabama portal since that’s approved, and he should be able to electronically get her added. Excuse me, get Rustin added over there. I took a look this morning. I saw that he had a couple of their collaboratives that were approved on his profile, but did not see the notice yet for Rustin. Oh, okay. That’s still under review with Alabama? Oh?
Catherine (19:19) Okay. And then I did have one question that I did not add here.
Catherine (19:23) But do you remember when I asked you about collaborators for Ohio? And basically, I was like, hey, can you tell me who we’ve uploaded the cpa for? Yes, for the Ohio renewal? So for those like, Ohio is a ratio capped state. So like they want, they cap the number of NPS that we’re allowed to have with each provider in terms of a collaboration. Do you happen to know if… I’m assuming that we are able to terminate a collaborative practice agreement and not, and still keep their license? I just like the point that confuses me is that they do require us to upload the cpa so I just want to make sure that like when I go in or when each provider goes in and terminates the agreement or notifies the board that the agreement is terminated, that the NP license will still stand. Okay? Yeah.
Kyle Rice (20:20) The NP license will still be active. If you guys terminate any of those or make any changes, definitely understand around the ratio, and that gets problematic in terms of adding a specific number of NPS under one provider, an MD, or a do it should be changed their status either to inoperable, which will keep the license active. It just means they’re pending a collaborative agreement or it’ll say pending cpa, but it should keep the nurse practitioner agreement active or see the nurse practitioner license active.
Catherine (20:55) So then does that mean that for Ohio, in order to practice as a nurse practitioner, you have to be under a collaborator?
Kyle Rice (21:02) I believe so.
Catherine (21:03) Yes. Oh, okay. Do you know if that’s the case for Tennessee as well?
Kyle Rice (21:08) I’m not sure for Tennessee, but I can look into it and give you some additional guidelines there. Yeah?
Catherine (21:14) Just because we want to, we have a nurse practitioner that we want to keep their license active, but we don’t want to use them up under a collaborator. So we’re just not having them see any patients or not wanting to have them see any patients. But once we, I guess like we’re just wondering that like if we, if they’re not seeing any patients and they’re still under a collaborator, like I don’t know if that question makes sense, but I.
Kyle Rice (21:44) kind of see where you’re going there. So like just kind of she’s kind of in like a hold status right now until you guys get the additional like ratio there for like a nurse.
Catherine (21:51) So, Tennessee’s not ratio, but it’s like they make you kind of meet with the provider in person. So like we’re just not having them see any patients. So if this NP continues to be under this collaborator but not see patients, any patients. Does that mean that we’re still… taking.
Kyle Rice (22:11) up a seat? Yeah, it should be taken. Yeah, if they’re not seeing any patients but they do have an active collaborator, they should still be, it should still keep the license active and it would not move over to like inactive or anything like that unless they make any like collaborative agreement changes. Yeah. But I believe the license, it should be similar to Ohio. If you guys make the change or pull the collaborating physician, it should stay she’ll, stay active and until a new collaborative agreement is received or updated and they should reflect the status too. Yeah.
Catherine (22:45) And so then for Ohio, they’re just inoperable as in they can’t practice as an NP, but their NP license is still active.
Kyle Rice (22:54) Yeah. It’s going to be a similar status to that. It might even still remain active. I just need to confirm the verbiage there.
Catherine (22:59) Oh, okay. Could you get back to me on the exact verbiage so that I am able to share that? But apart from that, do you guys terminate agreements ever, or is that not something that you really do?
Kyle Rice (23:13) Not right now. We do not, we only can facilitate the assist with the initial, if it’s required as part of the licensing process. Okay? Or if you guys are updating it with renewal, we can certainly help terminate the agreement but only during those times if it falls out of cycle. Unfortunately, we’re not able to support those as of yet.
Catherine (23:32) Oh, okay. No, that makes sense. I was just wondering if you guys had that as a request option and maybe I just didn’t know it, but it doesn’t seem like you do.
Kyle Rice (23:41) Not this time, but hopefully coming down the line here and I will definitely keep you guys in the loop there if anything changes there.
Catherine (23:46) Yeah. Okay. Sounds good.
Kyle Rice (23:49) No worries. Awesome. So I will get you guys a copy of the notes for today. Take a look at Jennifer apple, get you guys confirmation on the prescriptive authority and Dea issue there. I will also confirm the Ohio verbiage… for the inoperable status and I’ll get that over to you guys. Anything else in terms of updates or anything in process that I can assist with for today?
Catherine (24:12) No, Kyle, but I guess when you guys do terminate Ohio licenses, have you done collaborating terminations? I called the board and they were basically like you just go into the portal and say this collaboration is terminated, but it seems very informal to me. So, does that sound like what you guys do usually when you terminate collaborations in Ohio? Yeah.
Kyle Rice (24:36) I think it’s yeah, I believe it all can be done via the portal. Once you pop it open, it should say like request to change collaborating physician and there should be an option for that. But yeah, that does sound familiar and in line with process with Ohio.
Catherine (24:49) Okay. Sounds good. Thanks, Kyle.
Kyle Rice (24:51) Yeah, no problem. Awesome. Cool. Anything else for today?
Catherine (24:55) No, I think I’m good.
Kyle Rice (24:58) Awesome. Well, I will get you guys a summary for everything we talked about for this afternoon. I’ll get you guys a copy of this cap as well, and then just give me a little bit to follow up on our action items here and I will close the gap on those as well.
Catherine (25:12) Okay. Thank you. Thanks.
Kyle Rice (25:14) Guys. Hope you all have a great day you.
Catherine (25:15) Too. Bye, bye bye.