3 Tips to Ensure Treatment Plan Compliance

By April 10, 2019
clipboard with stethoscope

By Jon Schafer, Solutions Engineer at Remarkable Health


According to the Joint Commission, 57% of compliance issues discovered in 2017 were treatment plan related – making it the #1 ranked compliance issue. Compliance audits that result in negative findings  from authorized bodies such as Centers for Medicare and Medicaid Services (CMS) or the Joint Commission can reduce or remove federal funding from an agency in extreme cases. Prior to fund removal, there is a correction period where the agency is allotted time to bring their treatment plan documentation up to standards. The process of correcting treatment plans during this period can be costly to your organization.

Ultimately, the time your staff has to spend redesigning treatment plans (or any documentation for that matter) reduces the amount of hours to deliver services and also impacts the client. What happens when there are multiple revision periods as a result of the audit process?  More time is taken away from client services. Also consider the soft costs: unwarranted stress on the design team, frustration from the clinicians who must learn the new documentation, and the adoption time for implementing the new documentation. These factors may end up costing more than the hard dollar cost of the compliance changes. On top of that,  ever-changing processes and documentation changes can increase burn out rates, which can lead to high employee turnover rates.  And to replace an employee could cost the agency nearly seven times the replacement salary when considering ramp up time, benefits, and other onboarding costs.  The soft costs can be just as debilitating to an agency as the hard costs of maintaining compliance.

To help you avoid this additional cost, we’ve listed 3 ways your agency can meet compliance standards when it comes to treatment plans:

  1. Familiarize yourself with the requirements. Avoid a treatment plan redesign by becoming very familiar with the requirements. This will also help you stay current with any updates from the CMS or Joint Commission.
  2. Identify a compliance officer at your organization. The main responsibility of this role is to identify gaps by comparing your current version against the requirements. This person likes ‘being in the know’ and needs to excel at continual research. CMS consistently updates all manuals, which are provided on the website. In fact, there are updates that went into effect January 2019!  Another great resource, What is Expected in a Medicare Behavioral Health Treatment Plan, provides a concise overview of treatment plan expectations. Elements of Performance are detailed here, which you may also find helpful.
  3. Regularly evaluate your current Treatment Plan against these resources. If you proactively discover a change is needed, you can plan a non-disruptive (and less costly) process to implementing the changes before an unexpected audit occurs – before it can become an avoidable burdensome emergency for your organization.

To learn how Remarkable Health can help streamline workflows and reduce treatment plan costs, schedule a 30 minute meeting with one of our specialists.


Joint Commission, (2018, July).  Conquering Challenging Standard.  Retrieved from https://www.jointcommission.org/assets/1/18/Joint_Commission_Challenging_Stds_Jul20181.PDF  P. 11

CMS, (2018, December). Medicare Benefit Policy Manual.  Retrieved from https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c02.pdf

Joint Commission, (2017, January).  Phase I Revisions to Update Behavioral Health Care Requirements.  Retrieved from https://www.jointcommission.org/assets/1/6/Approved_BHC_phase_one.pdf