VA Caregiver Support – Issues Part 3 (PCAFC Application Process)

In this post, Part 3, I will discuss the forms in the VA computer system nationwide to process the VA Caregiver Support (CS), Program of Comprehensive Assistance for Family Caregiver (PCAFC) and perform the monitoring home assessment after approval. Go to this link for all documents.

Note: I redacted all my personal information from the forms. Applicant = family member. Every VAMC will have slight variations to processes and procedures but every form listed is in the VA computer system nationwide.

Note: A Caregiver Support Coordinator (Social Worker) is not licensed medical doctor to make medical determinations or perform medical doctor responsibilities .

80 FR 1357 January 09, 2015 excerpt from page 1366:

… a veteran’s, servicemember’s, or caregiver’s right to appeal decisions made in connection with the Program of Comprehensive Assistance for Family Caregivers. In response, we first note that medical determinations are not subject to the jurisdiction of the Board of Veterans’ Appeals under 38 U.S.C. 7104, or pursuant to our implementing regulation, which states that ‘‘medical determinations, such as determinations of the need for and appropriateness of specific types of medical care and treatment for an individual, are not adjudicative matters and are beyond the [Board of Veterans’ Appeals’] jurisdiction.’’ 38 CFR 20.101(b).

We additionally note that the Caregivers Act expressly states that ‘‘[a] decision by the Secretary under [the Program of Comprehensive Assistance for Family Caregivers or the Program of General Caregiver Support Services] affecting the furnishing of assistance or support shall be considered a medical determination.’’ 38 U.S.C. 1720G(c)(1). Therefore, all determinations that affect the furnishing of assistance or support through the programs under 38 U.S.C. 1720G are medical determinations as a matter of law, and as such may not be adjudicated in the standard manner as claims associated with veterans’ benefits.

38 USC 1720G (c) (1) excerpt: (1) A decision by the Secretary under this section affecting the furnishing of assistance or support shall be considered a medical determination.

The VA CS application process:

  1. VA Form 10-10CG.
  • Completed by the applicant (s) (family member (s)) and Veteran;
  • Submitted to the Veteran’s local VA medical center (VAMC) CS office.
  • A CSC/social worker contacts the applicant and/or Veteran to complete a Caregiver Support Administrative Eligibility Screening Tool via telephonically or in-person.

2. Caregiver Support Administrative Eligibility Screening Tool (CSAEST).

  • First clinical eligibility assessment.
  • Isn’t an administrative eligibility screening tool, it’s a clinical eligibility assessment.
  • The CSAEST requires a medical determination.
  • A CSC/social worker is not licensed medical doctor, qualified or authorized to make medical determinations or perform medical doctor responsibilities.
  • Step 1: A CSC/social worker completes this form with applicant and/or Veteran via telephonically or in-person;
  • Step 2: Unknown to the Veteran and without a written authorization (psychotherapy notes) or medical need to know (medical record), the CSC/social worker reviews and interrupts the Veteran’s medical record and psychotherapy notes to make a medical determination of 1) does the Veteran have any physical and/or mental health injuries, 2) if the serious injuries require assistance from a caregiver and 3) if it’s in the best interest for the Veteran to have a caregiver. Note: A CSC/social worker is not a licensed medical doctor to review and interrupt medical records or perform medical doctor responsibilities or make medical determinations;
  • Step 3: A CSC/social worker will review the CSAEST and the medical record/psychotherapy notes finding to make a medical determination to approve or disapprove. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 4: If disapproved, the CSC/social worker will issue the applicant and Veteran a disapproval letter with instruction of filing an appeal; or if approved, the CSC/social worker will start the second clinical eligibility assessment process, Caregiver Program Clinical Eligibility Assessment. The form consist of 2 parts 1) Caregiver Program Clinical Eligibility Assessment and 2) Caregiver Program Clinical Eligibility Assessment Child Note.

3. Caregiver Program Clinical Eligibility Assessment (CPCEA) (has 2 parts).

  • Second clinical eligibility assessment.
  • The form has two (2) parts: 1) Caregiver Program Clinical Eligibility Assessment (CPCEA) and 2) Caregiver Program Clinical Eligibility Assessment Child Note (CPCEACN). The CPCEA, Part 1, consist of questions only (no approval/disapproval or tier level assignment) completed by a nurse or provider (qualified or not), and the CPCEACN, Part 2, consist of the approval/disapproval and tier level assignment completed by the CSC/social worker. The CSC/social worker will make the medical determination to approve or disapprove and assign the tier level. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities.
  • A CSC/social worker makes a medical determination not to allow a Veteran to use their primary care provider (PCP) or their other treating providers to perform the clinical responsibilities. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities.
  • Step 1: A CSC/social worker sends the Veteran’s primary care provider (PCP) a request for evaluations and/or test to input consults on. The PCP enters the consults. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 2: A CSC/social worker schedules the evaluations and/or tests;
  • Step 3: The Veteran completes the evaluations and/or tests;
  • Step 4: A CSC/social worker reviews the evaluations and/or tests. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 5: A CSC/social worker has a nurse or provider (not on Veteran’s treatment team) complete the CPCEA, Part 1. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 6: A CSC/social worker reviews the CPCEA, Part 1, and completes the CPCEACN, Part 2. The CSC/social worker makes the medical determination to approve or disapprove and assign a tier level. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 7: A CSC/social worker makes a medical determination to not provide a Veteran with a treatment plan. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 8: A CSC/social worker makes a medical determination to not allow a Veteran’s primary care team to complete the clinical responsibilities. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 9: A CSC/social worker makes a medical determination to not allow an applicant to receive an assessment from the Veteran’s primary care team to perform 1) being able to complete caregiver education and training, 2) communicate and understand details of the treatment plan and any specific instructions related to the care of the veteran, 3) capable of following without supervision a treatment plan, 4) demonstrate the ability to carry out the specific personal care services, core competencies, and other additional care requirements prescribed by the eligible veteran’s primary care team. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 10: A CSC/social worker instructs applicant to complete online caregiver core competency training;
  • Step 11: a CSC/social worker makes a medical determination to not allow the Veteran’s primary care team to collaborate with clinicians performing home visits. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 12: A CSC/social worker makes a medical determination to not allow the Veteran’s primary care team to collaborate with clinicians performing the initial home assessment. The CSC/social worker makes a medical determination to schedule and complete a Caregiver Program Initial In-Home Assessment. The CSC/social worker will or will not complete with a CS nurse (some VAMC do not have CS nurses). Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 13: A CSC/social worker makes a medical determination to approve or disapprove then notifies applicant and/or Veteran of the decision. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 14: A CSC/social worker makes a medical determination to not allow a Veteran’s primary care team to determine the frequency of monitoring home assessments. The CSC/social worker makes the medical determination on the Caregiver Program Interim In-Home Monitoring Assessments frequency of every 90 days for the first year then annually thereafter. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 15: A CSC/social worker makes a medial determination to not allow the Veteran’s primary care team to collaborate with clinicians performing the Caregiver Program Interim In-Home Monitoring Assessments. The CSC/social worker, with or without a CS nurse, will complete the home monitoring assessment  and review the Veteran’s medical records and psychotherapy notes every 90 days to determine continued clinical eligibility. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities;
  • Step 16: A CSC/social worker reviews the Veterans and/or caregivers (if caregiver is seeking treatment at VA) medical records and psychotherapy notes every 90 days while enrolled. The CSC/social worker reviews and interrupts the medical records and psychotherapy notes to make a medical determination of continued eligibility. Note: A CSC/social worker is not a licensed medical doctor to make medical determinations or perform medical doctor responsibilities.

So, the CSC/social worker controls the clinical processes, makes medical determinations, performs medical responsibilities and is the approval authority for both clinical eligibility assessments. The CSC/social worker is accessing Veteran’s medical records and psychotherapy notes to interrupt and make medical decisions on physical and mental health injuries.

In the next post, I provide the details of our personal journey in the CS, Program of Comprehensive Assistance for Family Caregivers (PCAFC).

 

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