TOC
Colorado Nurse Health Program
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Proposal for Nurse Alternative to Discipline Program
RFP Number SJN-0801
September 6, 2007, 4:00p.m.
Department of Regulatory Agencies
Procurement Office 1560 Broadway, Suite 1550
Denver, Colorado 80202
Table Of Contents
TOC 1
I. Executive Summary (5.3.1) 3
II. Technical Component (5.3.2) 4
A. Section 4 - Statement of Work 4
4.1 4
4.2 29
4.3 Fees 33
4.4 Compliance with Applicable Laws 33
4.5 Confidentiality 34
III. Management and Experience Component (5.3.3) 36
IV. Cost Component/Operational Budget (5.3.4) 38
V. References (5.3.5) 38
I. Executive Summary (5.3.1)
This proposal is submitted on behalf of the Colorado Nurse Health Program in response to RFP SJN-0801. The undersigned has the authority to commit the Colorado Nurse Health Program to provide services outlined in this response.
CNHP has provided a Table of Contents, the Response and Attachments. CNHP has outlined a willingness to participate and comply with the requirements of the RFP within the response.
Executive Summary:
The Impaired Professional Diversion Program, doing business as, the Colorado Nurse Health Program (CNHP), was established in 1995 pursuant to Colorado Revised Statute 12-38-131. CNHP is a 501(c) (3) not-for-profit organization and has served as the alternative to discipline program for the Colorado State Board of Nursing for 12 consecutive years. CNHP has provided statewide assessment, evaluation, referral for treatment, monitoring, case management, outreach, education and consultation services for nurses in Colorado.
CNHP was designed by statute to be different from its predecessor program, and also varies from the legislated monitoring programs for the medical, dental, and pharmacy professions, because CNHP includes, in its corporate structure, a professional oversight committee, with designated backgrounds required of each member of the committee. This Impaired Professional Diversion Committee (Committee) provides increased accountability, objectivity, and supervision of the program. In the Sunset Review process which resulted in CNHP’s creation, the need to mitigate the time and effort required of the Board of Nursing to provide this oversight was the reason this Committee was incorporated into CNHP’s model. Although not presently required under the new legislation, CNHP will continue this Committee model to save time for the Board, and to continue the quality of the program as it presently operates.
Since its inception, CNHP has been focused on providing and improving on quality monitoring. CNHP is a founding and active member of the National Organization of Alternative Programs and is committed to the continued development and maintenance of standards of practice and evidence-based practice within alternative to discipline programs across the United States. As a result of our commitment to excellence, CNHP has been a resource for emerging alternative to discipline programs. To that end, CNHP participates in an external peer review every three years, and all these reviews have, to date, been consistently favorable and complimentary. CNHP actively searches for quality improvement opportunities.
The needs of nurse’s in this state are many. Substance use/abuse and mental illness occur concurrently in 7 to 10 million Americans and thus these are termed "co-occurring disorders". Approximately 35% of the nurses presenting for monitoring services in FY 2005-2006 reported either a mental health or -co-occurring disorder. Whereas the treatment community continues to try to catch up with evidence based data, CNHP aligns with the theory that co-occurring disorders are the norm and must be addressed. CNHP assures that nurses are assessed and evaluated for co-occurring disorders and the multi-disciplinary staff continues to assess the nurse’s changing needs throughout participation in the program.
CNHP staff support the nurse in the development of sobriety and wellness skills. As an alternative to discipline/monitoring program, CNHP believes that it would be a conflict of interest to conduct therapy with nurse participants. The role CNHP is to provide assessment, referrals, case management and monitoring. By CNHP maintaining clear boundaries, we can effectively protect the public. This model permits a win-win situation for nurses, employers, and the public.
While CNHP currently provides the Board with quarterly and annual demographic reporting, we have remained open to suggestions for improving reporting and other processes. CNHP has actively collaborated on protocols with the Board staff to assure nurses are not lost in the transfer processes and looks forward to doing so in the future. CNHP has offered to work with the Board on shared indicators to improve quality and effectiveness of referrals to and from the Board to CNHP.
As financial reporting will conclude, CNHP has maintained fiscal responsibility since its inception. Beginning October, 2007, Colorado will become a part of the Nursing Compact. For the first time, renewing nurses who engage in the compact have an opportunity to choose Colorado as their resident state. CNHP cannot assume that all nurses renewing in this state will chose Colorado and renewal licensure fees will be affected. As the Board approved the CNHP budget for FY 2007-2008, CNHP utilized that budget as a template for the new budget for 2008. Projections for FY 2009 include about a 5% increase in most areas, however CNHP has proposed the nurses provide a fee for service to cover the Nurse Support Groups. Throughout the United States, alternative to discipline programs has required a fee for service to offset the costs of the nurse support groups and evaluations.
CNHP aspires to continue its provision of services to the nurses of Colorado. In addition to providing continuity of monitoring, CNHP believes this new legislation will afford an opportunity to further improve and tailor its services as requested by the Board of Nursing, as CNHP and the Board move forward under these new legislative requirements.
II. Technical Component (5.3.2)
A. Section 4 - Statement of Work
4.1
a. Prior Experience To be awarded a contract, Offeror must have prior relevant experience in providing (1)assessment, (2)evaluation, and (3)case management and (4)monitoring of persons with psychological, substance use and/or abuse problems. Describe in detail this relevant experience.
The Impaired Professional Diversion Program, doing business as, the Colorado Nurse Health Program (CNHP), was established in 1995 pursuant to Colorado Revised Statute 12-38-131. CNHP is a 501(c) (3) not-for-profit organization and serves as an alternative to discipline program for the Colorado State Board of Nursing.
The Impaired Professional Diversion Program was developed secondary to recommendations of the Office of Policy and Research in their 1994 Sunset Review for the Board of Nursing (the Board). The General Assembly reviewed various program structures as defined by the National Council of State Boards of Nursing and created an Alternative to Discipline hybrid, which ensures optimal safety to the public while rehabilitating the nurse.
The Program as structured includes a committee of seven individuals presently selected by the Board of Nursing to provide oversight for the program. The Impaired Professional Diversion Committee (Committee) is responsible for:
• development of the program;
• approving and disapproving of admission into the program and
• referrals to the Board of Nursing for disciplinary action;
• creation of monitoring contracts;
• supervision of cases;
• creating policies and procedures; and
• development of the annual budget and assuring fiscal responsibility.
The Committee oversees the release of quarterly reports to the Board of Nursing. The Committee meets on a monthly basis and remains available as needed throughout the year.
CNHP is a founding and active member of the National Organization of Alternative Programs and is committed to standards of practice consistent with other alternative to discipline programs across the United States. CNHP has been a resource for emerging alternative to discipline programs. CNHP participates in an external peer review every three years.
CNHP has provided assessment, evaluation, referral for treatment, monitoring, case management, outreach, education and consultation services for nurses in Colorado for over 12 years. CNHP provides the Board with demographic and financial reporting information and has remained willing and open to suggestions for improving reporting and other processes. CNHP has actively collaborated on protocols with the Board staff to assure nurses are not lost in the transfer processes. CNHP has offered to work with the Board on shared indicators to improve quality and effectiveness of referrals to and from the Board and to CNHP.
During the fiscal year July 1, 2006 to June 30, 2007 CNHP provided services for 226 nurses monitored with contracts. There were 139 nurses referred to CNHP and 113 nurses followed through with assessments. Seventy-nine nurses submitted to an evaluation and 73 signed a CNHP monitoring contract. Thirty nurses successfully completed the program last year. Forty-three nurses with signed contracts were referred to the Board of Nursing for non-compliance issues and 48 nurses were referred to the Board of Nursing either because they had failed to contact or follow through with CNHP after referral from the Board or for safety to practice issues. In addition, CNHP had 6,414 face-to-face contacts with licensees and conducted 757 nurse support group meetings throughout the state.
The present processes CNHP uses for assessment, evaluation, monitoring and case management include:
4.1a(1)Assessment:
Each applicant is assessed beginning with the first inquiry call and assessment continues throughout participation in the program. Many inquiry calls are received from employers, coworkers, friends, and family members of a nurse who has psychological and/or substance abuse problems. It is not unusual for a nurse to call or email under a false name with questions regarding the program. CNHP staff understands that asking for help is not easy and staff members make every effort to support the caller. As callers describe the precipitating event, many of them recognize for the first time that a problem exists.
The CNHP staff explains the program purpose, eligibility requirements, program structure and expectations. CNHP staff collects history on the precipitating event, gathers demographics and completes the Licensee Contact Information sheet (Appendix 4.1.a.1). CNHP staff conducts a brief assessment of the nurse’s immediate needs and provides education, anticipatory guidance and directions towards appropriate resources and referrals. CNHP staff members are prepared to make referrals to emergency agencies, if necessary. Nurses assessed by CNHP staff and found to require immediate medical or psychiatric attention are referred for treatment prior to completion of the assessment and evaluation.
As per C.R.S. 12-38-131, eligibility has been limited to licensees who admit to a psychiatric, psychological or emotional problem, or a dependence upon and/or an abuse of alcohol and/or chemicals. In assessing eligibility CNHP staff considers the nurse’s history, motivation for sobriety and wellness, and willingness to participate in the program. CNHP may not be able to determine appropriateness for participation until after the face-to-face assessment with the licensee. Nurses who demonstrate eligibility and a willingness to participate in CNHP are encouraged to fill out an application for participation in the program.
Nurses are either scheduled for an intake appointment or an application packet may be mailed to them. Either situation provides the nurse with documentation about CNHP including common monitoring requirements and appropriate consents to receive and release personal health information (PHI) information (42 C.F.R part 2, and the Health Insurance Portability and Accountability Act [HIPAA], including 45 C.F.R. parts 160, 162, and 164). As scrutiny to release patient information has heightened, the nurse may be required to provide additional information before psychiatric or medical health care facilities or treatment agencies will release personal information. In order to assure authenticity of the documents, CNHP requires that records are sent from the health care or medical facility directly to CNHP.
Collateral information is gathered from previous and/or current employers on employment issues. Medical, psychiatric, and/or addictions treatment histories are gathered from previous physicians, psychiatrists, therapists, and treatment centers. Family and significant others often offer clarifications and historical data. The case manager assures the CNHP evaluator is provided with pertinent collateral information prior to the evaluation.
4.1a(2) Evaluation:
CNHP requires all licensees to complete an evaluation. Evaluations are completed by outside evaluators to avoid conflicts of interest and to protect, respect and support the development of a therapeutic alliance. All evaluators assessing nurses with psychiatric or addictions conditions are required to include a mental status, and a multiaxial assessment and diagnoses utilizing the 4th revised edition of the Diagnostic and Statistical Manual (DSM IV TR) and other recognized diagnostic tools.
The evaluation for primary substance abuse and chemical dependency includes, but is not limited to:
• Types of drugs and /or alcohol used,
• Frequency and patterns of use,
• Severity of addiction, including history of previous treatment,
• Withdrawal history and risk,
• Previous/current treatment and medications,
• Motivation to participate in treatment,
• Psychosocial history,
• Coexisting psychiatric problems,
• Employment issues,
• Legal or criminal implications of the nurse’s drug use,
• Practice issues and safety to practice,
• Assessment of the nurse’s needs, support systems and financial resources, and
• Determination of appropriate treatment plan and additional evaluation recommendations.
Psychiatric evaluations for primary psychiatric issues are performed by CNHP approved board certified psychiatrists, licensed psychologists, or psychiatric advanced practice nurses.
Each evaluator is approved by the Impaired Professional Diversion Committee after a review of their specific qualifications, licensure and expertise. See Appendix 4.1.a.2. Just as no single treatment is appropriate for everyone, nurses are referred to an evaluator who can best assess the nurse’s needs. Case managers assist the nurse/potential participant in making an appointment for an evaluation. Evaluators are provided a copy of the application and other significant collateral data, which may include a copy of any Board of Nursing Complaint or Stipulation and Final Agency Order, and previous evaluations or treatment records, if applicable. The previous evaluation and CNHP documentation are provided to the evaluator for nurses who are returning to CNHP after a period of suspension.
Substance abuse evaluations are performed by:
• Licensed Addictions Counselor (LAC) with a at a least Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field is preferred, or
• A Certified Addictions Counselor, level II (CACII) with at a least Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field, or
• A Certified Addictions Counselor, level III (CACIII) with at least a Bachelor’s Degree in Counseling, Social Work, Nursing, Psychology or a related field.
•
Evaluations for primary mental health and psychiatric disorders include, but are not limited to:
• Identification and evaluation of the nature and severity of the mental health and psychiatric problem(s),
• Previous/current treatment and medication(s),
• Evaluation of coexisting substance use/abuse or other disorders,
• Motivation to participate in treatment,
• Psychosocial history,
• Employment issues,
• Practice issues and safety to practice,
• Assessment of the nurse’s needs, support systems and financial resources, and
• Determination of appropriate treatment plan and additional evaluation recommendations.
Licensees with a co-occurring disorder are evaluated by a licensed board certified psychiatrist who is also certified as an addictionologist or psychiatric advanced practice nurse with prescriptive authority who has significant experience in the assessment and treatment of addictions as well as psychiatric disorders.
Beyond the initial admission evaluation, some nurses may require other evaluations for specific conditions or an assessment of their unique needs. Licensees with medical problems are further evaluated by a medical doctor, doctor of osteopathy or advanced practice nurse with prescriptive privileges or a specific specialty as deemed necessary. Evaluators are asked to provide their opinion and recommendations for how the licensees’ medical conditions can best be addressed in conjunction with the specifics of their contractual agreement.
The need for these additional assessments or evaluations may not be apparent during initial engagement period with the licensee. These additional evaluations are at the nurse’s expense. With ongoing vigilance, CNHP staff, nurse support group facilitators, therapist and psychiatric clinicians continue to assess the nurse’s needs throughout participation in the program.
Nurses who need psychological and/or neuropsychological testing require an evaluation performed by a licensed psychologist or neurologist with credentials for such testing.
Nurses who need psychotropic medications and/or the ongoing prescribing of psychotropic medications are evaluated and followed by a board certified psychiatrist or a psychiatric advanced practice nurse with prescriptive authority.
Nurses who require the use of pain medications beyond the acute stage of treatment (6-10 weeks) are required to be assessed and followed by a CNHP approved physician who is board certified as a pain management specialist. Nurses with chronic pain management issues are required to have an evaluation by a CNHP approved pain management specialist. Should the licensee need to continue with mood or mind altering medication, cognitive testing is required to determine that the nurse is able to practice with reasonable skill and safety while taking their prescribed medication.
Nurses who present with significant denial of their problem, in the face of overwhelming evidence to the contrary, may require an extended evaluation and/or treatment at a residential facility that has the expertise to work with them. As such, CNHP may require an extended evaluation. Extended evaluations include, a history and physical with laboratory studies, psychosocial history, psychiatric evaluation, psychological testing, addictionist evaluation and may include a focused evaluation on co-occurring disorders and other process addictions.
4.1a(3) Case Management:
The Case Manager is responsible for monitoring program participants through assessment, planning, referral and the coordination of services. This position serves as a liaison to the participants, employers and treatment providers regarding the CNHP and as a resource person and consultant on addiction, chemical dependency, and mental illness issues in nursing. The case management team provides support and advocacy for recovery and wellness.
While the case management team maintain appropriate boundaries and do not assume the role of primary counselor/therapist or sponsor, they provide nurses with limited health care counseling and problem solving assistance. In the event a nurse has completed treatment and no longer sees a therapist, the case manager or care coordinator continues to assess for mental health wellness and recovery. The case management team assures that nurses do not fall between the cracks in the treatment
CNHP provides 16 weekly facilitated Nurse Support Groups (NSG). While all groups have a mixture of nurses with substance abuse and co-occurring disorders, one of the groups is a Wellness Nurse Support Group with nurses diagnosed with primary mental health disorders. CNHP is currently launching a web group.
Each group has an experienced facilitator who keeps the case management team abreast of changes in the nurse’s presentation and assist in the early intervention of mental health or substance abuse relapse. In addition to offering nurses an opportunity to meet peers in similar situations, each nurse participates in monthly didactic activities to build recovery maintenance skills. Appendix 4.1.a.3. Nurses who complete CNHP routinely rate the “Professional Support Group” and “Peer Support” as the one of most helpful components of the program.
Unlike other alternative to discipline programs across the United States, the costs for providing these groups have been paid by the program.
CNHP is committed to evidence/research based interventions and best practices. Each nurse who initiates contact with CNHP is assigned to a primary case manager. The case management team is responsible for assuring that the nurse is aware and understands all aspects of the monitoring contract and actively encourages contract adherence.
4.1a(4) Monitoring:
The monitoring contract is developed after the evaluation of the Nurse with consideration to each individuals specific needs. CNHP staff, with the approval of the Committee, determines contract terms which reasonably assure the protection of the public and rehabilitation of the nurse. Development of the contracts are grounded in principles of effective treatment of substance abuse and mental health treatment.
CNHP does not commit to contract terms in advance of the nurse’s evaluation and review by the oversight Committee. In general, the Committee will not negotiate contract terms, but will consider reasonable requests from its participants. CNHP modifies the terms of the contract based on the client’s history and progress.
The elements of a monitoring contract may include, but are not limited to:
• Nurse Manager/Practice Monitor Reports
• Therapist Report
• Drug and Alcohol Screening Report
• Monitored Medication report (naltrexone, disulfiram, etc.)
• Psychiatrist/Psychiatric Report
• Pain Management Physician Report.
• Pain Management Log
• Pharmacy Audit
• Medication Log
• Self-Status Report
• 12-Step (or equivalent) Meeting Attendance Report
• 12-Step Sponsor Report
• Nurse Support Group Attendance
• Wellness Plans (Recovery Maintenance/Relapse Prevention, Wellness Recovery Action Plan, and/or Pain Management)
• Periodic visits with the Case Manager
Case managers make every effort to assure that nurses understand their monitoring contract requirements. Contract requirements are explained to the participant and provided in writing. Nurses are provided with a list of CNHP approved treatment facilities and collection sites (for urine drug screens, breathalyzers and medication monitoring). Prior to signing the contract, the nurse participant is provided with a Participant Handbook and a copy of all monitoring reports.
CNHP staff receives monitoring reports on a monthly (or quarterly) basis. Reports are audited and either accepted or rejected and recorded on the participant’s Compliance Report (see utilizing policies and procedures for consistency Missing, late and unacceptable reports are investigated. Nurses who are unsafe to practice or have a relapse are pulled from practice while they undergo a re-evaluation, and contract changes are made accordingly.
The nurse and case manager will meet face to face several times in the admission process. Nurses are expected to telephone their case manager not less than monthly throughout participation in the program.
Urine drug screens, breathalyzers and blood tests provide vital objective data to determine sobriety and mental health medication compliance. In order to receive the greatest potential for ruling out illicit drug use by licensees and providing testing throughout Colorado, CNHP utilizes two laboratories for urine drug screens: Norchem and Redwood Toxicology.
Evaluation of Prior Relevant Experience:
As required by statute, CNHP participated in an external review of the program in January 2006. The BON selected Linda Smith, MN, ARNP, M.DIV, CAP, CEAP as investigator for the report. Ms. Smith is the former executive director and current program consultant of the Intervention Project for Nurses. She is the author of multiple articles on impaired nursing practice, monitoring and recovery. She served as lead reviewer and Jean D’Aprix, BA, RN, CARN assisted in the process. See Appendix 4.1.a.5.
Prior to the site visit CNHP submitted the following for review:
• Policies and Procedures
• The Participant Handbook
• Program Forms (for evaluation and suggestions for improvement)
• CNHP Committee Reports
• Board of Nursing Reports (Quarterly Financial and Demographic Reports and Annual Reports)
• External Reviews from 1999 and 2002
During the three day site visit, the evaluators randomly selected and reviewed 20% of active cases from each case manager’s caseload. They reviewed all charts of nurses who had relapsed and all dismissed cases for effective case management. Reviewers interviewed key State Board of Nursing staff, all Committee and CNHP staff members. They met and observed the Nurse Support Group Facilitators meeting. Finally, the reviewers attended the CNHP Committee retreat and provided preliminary results.
The following include salient parts of the External Review January 2006:
Model of CNHP:
The CNHP is structured as an alternative to discipline (Diversion Program). This is the most common model utilized by Boards of Nursing throughout the country and is endorsed by the National Council State Boards of Nursing. CNHP is a member of the National Organization of Alternative Programs (NOAP).
Strengths:
Review of CNHP communication with the Impaired Professionals Diversion Committee, as required per DORA rules (Article 38, Nurse Practice Act, State of Colorado):
The Reviewers attended a CNHP/Committee Retreat on January 14, 2006. The reviewers were impressed by the “Committee members’ knowledge, expertise and interest in administering the best program possible.” The Committee was particularly interested in areas associated with program efficiency and cost effectiveness.
Review of previous External Reviews from 1999 and 2002 revealed:
The results of this demonstrated full compliance by CNHP in addressing all recommendations made by the previous Reviewer.
Completion Cases:
All cases indicated stability in recovery as evidenced by negative urine drug screens, compliance reports and safety to practice nursing.
Dismissed Cases:
The reason for dismissal was clearly stated in every file. Dismissals were processed by CNHP in a timely fashion and referred to the Committee and Board of Nursing (BON).
Active Files:
These cases demonstrated clear documentation of ongoing progress of participants in CNHP. All non-compliances were documented and addressed by CNHP staff and Committee. The External Reviewers were very impressed with the overall documentation and organization of participant files.
Clinical and Operational Over-Site of CNHP:
The CNHP has a two-prong arrangement for clinical supervision and Program over-site. Both the Committee and an independent physician consultant provide regular clinical supervision. The Committee provides this through monthly meetings and regular case review. The External Reviewers were very impressed with the knowledge and experience of both the Committee members and the CNHP physician consultant.
Nurse Support Group Network:
The Nurse Support Group (NSG) Network in place through CNHP is certainly a very strong component of the Program. The NSGs provide both on-going support of participants along with close weekly monitoring. It is the Reviewers’ opinion that the NSG network responsibilities can be expanded to provide increased participant support in the local areas as a means of decreasing face-to-face meetings with CNHP, thereby increasing CNHP program efficiency.
Relapse Prevention Education:
This is a strength of CNHP. The Program requires all participants to receive relapse prevention education within their Nurse Support Groups. Various educational topics include: Looking at high-risk situations, identifying triggers for relapse, workplace risks, caring for self, etc. CNHP’s commitment to provide ongoing relapse prevention for participants sets it apart from many alternative programs.
Treatment and Evaluator Networks:
CNHP has developed a network of approved treatment providers and evaluators. See Appendix 4.1.c.
Monitoring of Participants in CNHP:
Our External Review looked carefully at all the monitoring components currently in place for monitoring both stability in recovery and mental health and fitness for practice of all CNHP participants. CNHP actually monitors well beyond the standard which provides excellent monitoring and at the same time contributes to a tremendous amount of paperwork.
CNHP Intervention in Cases of Non-Compliance:
CNHP has developed and implemented an elaborate and comprehensive Level System for addressing all non-compliances. This protocol is clearly outlined within the CNHP Policy and Procedures. Refining the current Level System would improve Program efficiency and free the Committee for more important work issues such as “patterns” of non-compliance that do not resolve with these previously stated interventions, along with relapses, issues associated with potential patient harm, violations of the Nurse Practice Act and behaviors that put the public at risk would be appropriate for Committee review and disposition. Reviewers recommended eliminating contract extensions as a form of consequence for non-compliance. If the participant cannot consistently comply following all these interventions, it may be more prudent to dismiss the participant rather than extend him/her six months or so.
Outreach:
CNHP has presented many educational programs to hospitals and other facilities that employ nurses. Continued outreach is critical for several reasons including education of nurse employers on issues of impairment and CNHP services to promote early reporting of impairment, thereby enhancing public safety. The Reviewers recommend CNHP continue its outreach efforts.
Recommendations:
Increase CNHP efficiency by:
• Stream line monitoring process
• Restructure non-compliance system
• Expand data management system
• Increase utilization of Nurse Support Groups for participant support and problem-solving in local areas
• Retain the Alternative to Discipline Model as endorsed by NCSBN
• Continue outreach efforts/training for key stakeholders (Board of Nursing Members, Nursing Admin. and Nurse Educators etc.) for increased CNHP utilization, thereby increasing public safety.
• Consider refining administrative code regarding admission criteria and how evaluations are paid for as a means of curbing Program costs.
Conclusion:
The External Reviewers were very impressed with the overall functioning of the Colorado Nurse Health Program. The Reviewers identified many program strengths which place CNHP as an above-standard alternative to discipline program. Areas recommended for refinement will serve to improve overall Program efficiency and cost-effectiveness. It is clear to the Reviewers that CNHP takes its mission seriously “to provide nurses with the opportunity and support for recovery and treatment, while reasonably assuring the protection of the public”.
b. Staffing: To be awarded a contract, Offeror must have qualified staff available, either in (1)house or through (2)subcontractors. Describe staff to be dedicated to provide recipients with the necessary (3)evaluation, (4)education, (5)diagnosis, (6)counseling, (7)case management, (8)test administration and (9)monitoring. Give staff’s qualifications, credentials and program’s supervision policy.
CNHP employ seven employees. These positions include: an executive director, three case managers, one compliance monitor/case management assistant, one program manager and one clerical staff.
4.1b(1) In-House Staff Members:
Marjorie Derozier, Executive Director
Ms. Derozier is employed as the executive director of the Colorado Nurse Health Program. She holds a Bachelors of Science degree with a major in nursing and a minor in human services. She earned a certification as a master addictions counselor (CACIII) in Colorado and certification as an addictions registered nurse (CARN). Ms. Derozier Ms. Derozier has experience working with adolescents, adults, pregnant addicts, women, impaired professionals and families in group and individual sessions. As an addictions and psychiatric nurse and counselor, she has worked in psychiatric hospitals, detoxification centers and outpatient counseling. Ms. Derozier is a member of the Society of Addictions Counselors of Colorado, Colorado Nurses Association, International Nurses Society of Addictions and the National Organization of Alternative Programs (NOAP). She serves as the secretary for NOAP. Ms. Derozier joined CNHP in 2001.
Bobbi McKevitt, Western Slope Case Manager and Outreach Coordinator
CNHP was delighted to acquire Ms. McKevitt in 1999. She has extensive experience in psychiatric and chemical dependency nursing. She is a registered nurse, a master level certified addictions counselor in Colorado (CACIII). Her experience includes 22 years employed at a psychiatric/chemical dependency treatment hospital serving as the Chemical Dependency Program Director, Director of Quality Assurance, and Director of Utilization Management. Ms. McKevitt is a member of the Colorado Nurses Association and Society of Addictions Counselors of Colorado.
Deidre Tygart, Case Manager Assistant/Compliance Monitor
Ms. Tygart is master level certified addictions counselor in Colorado (CACIII) who is currently pursuing her baccalaureate degree with a major in human services/addiction studies. Ms. Tygart joined CNHP in January 2005. Her previous experiences include management of urine collection monitoring, substance abuse counseling in out patient and therapeutic community settings and transitional care settings.
Veta Lefholz, Case Manager
Ms. Lefholz is a baccalaureate prepared registered nurse. She has experience in medical-surgical, nursing education, psychiatric and addictions nursing. Ms. Lefholz’s interest in psychiatric nursing and love of travel led her work in Australia as a psychiatric nurse. Ms. Lefholz is actively pursuing certification as an addictions registered nurse.
Nichole Asper, Case Manager
Ms. Asper is a baccalaureate prepared registered nurse. Her experience includes neuropsychiatric, addictions and psychiatric nursing in hospital, residential treatment programs and travel nursing.
Judith Estes, Program Manager
Ms. Estes holds a baccalaureate degree in office administration. She joined CNHP almost nine years ago. Her experience includes administrative management, office management, computer applications, bookkeeping, human resources, and executive and legal secretarial duties.
Joyce Muniz, Receptionist/Clerical Assistant
Ms. Muniz is the newest CNHP staff member. She is currently pursuing a baccalaureate degree in business administration. Ms. Muniz brings experience in organization, website, power point, and customer service.
4.1b(2) Contracted Service:
Marv Robbins, MBA, MD, Clinical Supervision
Dr. Robbins is a board certified psychiatrist with extensive experience with substance abuse, mental health and co-occurring disordered clients. Medical Director, Aurora Mental Health Center Aurora, Colorado Assistant Clinical Professor University of Colorado Denver Health Sciences Center. His understanding of the monitoring aspect of CNHP’s services is unparalleled.
Program Consultants:
Nancy Kehiayan, MS, PHN, RN, CS. Ms. Kehiayan has extensive experience in mental health and addictions nursing and alternative to discipline programs for nurses.
Ruby Martinez, RXN, CNS, PhD, APRN, BC. Dr. Martinez has extensive experience in psychiatric and chemical dependency disorders. She specializes in nursing management, business administration, cultural competency and clinical supervision.
Patricia Barnes-Hecht has been a public accountant for over 25 years. Ms. Barnes-Hecht provides ongoing consultation during the course of the year and assistance in the financial audit preparation in accordance with not for profit accounting procedures and preparation of year-end financial statements.
Impaired Professional Diversion Program Committee Members:
Dr. Harvey (Trey) Causey III, is the Psychiatrist/Addictionist specializing in the diagnosis and treatment of addictive diseases. Dr. Causey is a board certified in psychiatry and addictions psychiatry.
Diana Bialkowski, MSN, RN, APN, RxN, CACIII has worked in the area of chemical dependency and mental health for 25 years. She has extensive knowledge and experience in health and human service settings, educational programming, interdisciplinary staff development, clinical and administrative staff supervision and is a licensed independent practitioner in primary care medical services. Ms. Bialkowski holds the position of the licensed professional nurse specializing in chemical dependency and is the current Committee Chair.
Carolyn Reid, LPC, CACIII is the current IPDC member from the public and knowledgeable in the field of chemical dependency. Ms. Reid has extensive experience in counseling addictions, mental health and co-occurring clients. Her experience as a professional clinician with the Colorado Physician Health Program (CPHP) has been invaluable to CNHP.
Maureen Jackman, BA, RN, holds the licensed professional nurse specializing in the psychiatric nursing Committee position where she also serves as the Committee Vice Chairperson. Ms. Jackman has her Bachelorette of Arts in Organization Development and she has been involved in the development of many new programs. Ms. Jackman has over 20 years of psychiatric hospital experience in the adult inpatient and crisis units. Her experience includes emergency room psychiatric evaluations and crisis counseling. Ms. Jackman has extensive experience as a staff nurse and nurse manager.
Kathy Messman, RN, MPS, hold the Committee position as a Professional Nurse in Recovery.
Kelly Helzel, RN. Ms. Heltzel's experience includes ten years of acute care nursing in a diversified array of settings including the emergency room. She has over 18 years of experience in utilization review, quality assurance and post payment reviews preventing or investigating overcharges, fraud and misuse.
Nurse Support Group Facilitators:
Arlene Weimer, PhD (two groups) Pueblo
Cameron-K Garrett, MS, RN, CNS Denver
Dan Gormley, RN, MA Lakewood
Sheila Ash, RN, CNS, CACII Windsor
Sheila Ash, RN, CNS, CACII Ft. Collins
Bobbi McKevitt, RN Grand Junction
Judi Rheinsmith, BSN, MA, RN, CACIII Louisville
Susan Rinaldi, BSN, RN, CARN (three groups) Lakewood
Julie Subiadur, RN Lakewood
Barb Thomas, RN, MS, CS Colorado Springs
JoAnn Martinson, RN (two groups) Colorado Springs
Wellness Group (mental health wellness focus):
Karen Schoenhals MSN, CNS, RxN, CACIII Littleton
4.1b(3)Evaluations:
CNHP maintains a list of clinicians who perform the initial evaluation for the program. Evaluators are approved by the Committee and must maintain current unencumbered licenses and certifications and maintain malpractice insurance. Evaluators agree not to refer to themselves, exercise appropriate boundaries, and sign a non conflict of interest and confidentiality agreement.
Substance abuse evaluations shall have the following education are performed by:
Licensed Addictions Counselor (LAC) with a at a least Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field is preferred, or
A Certified Addictions Counselor, level II (CACII) with at least a Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field, or
A Certified Addictions Counselor, level III (CACIII) with at least a Bachelor’s Degree in Counseling, Social Work, Nursing, Psychology or a related field
Evaluations for primary psychiatric issues are performed by CNHP approved board certified psychiatrists, licensed psychologists, or advanced practice psychiatric nurses with prescriptive authority (psychiatric nurse practitioners or psychiatric clinical nurse specialists).
Licensees with a co-occurring psychiatric and addictions disorders are evaluated by a licensed board certified psychiatrist who is also certified as an addictionologist or a psychiatric advanced practice nurse with prescriptive authority who have significant experience in the assessment and treatment of addictions disorders may also provide these services.
Licensees with medical problems are evaluated by a medical doctor or nurse practitioner. The goal is to have a clear understanding of the nurse’s health status so that all pertinent health matters can be addressed.
CNHP Approved Evaluators:
Sandy Dutton MSS, LAC
Dorothy Faris, MD, Psychiatrist/Addictionist
Christian Thurston, MD, Psychiatrist/Addictionist
Laurence Freedom, M.Ed., LPC, LAC
Kelly Gaul, MS, RN, CS
Anne Napier Ed.D., RN, CS
Greg Schmidli, MSW, LAC
Margie Stewart, Psy.D
Wendy Tompkins LCSW, NCACII
Carmen Iacino, MA, LAC, CSEM
Lisa Drey, RN, MA, CNS, CACIII, PMHNP, RxN
Eric Meyer PhD, LPC, CACIII
4.1b(4) Education:
The executive director provides the majority of education and outreach services to health care facilities, schools of nursing and the Board of Nursing. The case management staff, CNHP Committee (or Board of Directors) and the nurse support group facilitators may also provide outreach and education services. Former CNHP participants have volunteered to provide assistance with exhibits at conventions and to provide an opportunity for nurses and employees to ask specific questions about addiction, mental health and recovery by someone who has personal experience on the subject. Case managers provide consultation and education to employers, family members and nurses. The nurse support group facilitators present educational presentations on a monthly basis to each of the Nurse Support Groups (NSG). The case manager and outreach coordinator for the Western Slope provide services in areas south and west of the continental divide.
4.1b(5) Diagnosis:
All nurses who follow through with the admission process have a diagnosis after the assessment or evaluation as described above. Diagnoses are comprised utilizing the revised 4th edition of the Diagnostic and Statistical Manual (DSM IV-TR). Evaluators will provide diagnosis utilizing ICD 9 or other universally accepted diagnostic tools.
Nurses who are referred for treatment will also have a diagnosis provided by their primary clinician. Changes in diagnoses are delivered to CNHP in writing by the treating clinician.
4.1b(6) Counseling:
While the CNHP case management staff has the qualifications to provide counseling, this counseling is limited to guidance/coaching, health teaching and health promotion (education) and problem solving for nurses and their family members. Case Managers maintain clear boundaries and do not assume the role of the primary counselor or sponsor in order to remain objective in monitoring compliance with the CNHP contract. It is our philosophy that this objectivity is critical to insuring public safety.
CNHP has developed a list of approved treatment providers and facilities who offer diverse treatment modalities and approaches. Counseling is performed by seasoned clinicians educated and licensed in areas specific to the needs of the nurse. CNHP recognizes that there is no single approach that is appropriate for all nurses. Nurses are matched with treatment providers and facilities that are best suited to meet their specific needs. Every effort is made to assist nurses to find experienced, educated and credentialed clinicians who are geographically close to their home or workplace.
Ideally, substance abuse counseling is performed by:
Licensed Addictions Counselor (LAC) with a minimum of a Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field is preferred, or
Certified Addictions Counselor, level II (CACII) with a minimum of a Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field, or
Certified Addictions Counselor, level III (CACIII) with a minimum of a Bachelor’s Degree in Counseling, Social Work, Nursing, Psychology or a related field
It is not unusual for substance abuse counselors in rural areas to hold no more than a high school diploma or equivalent and a CACI or CACII. In such cases, CNHP has worked with the counselor and their supervisor to assure the counselor is getting clinical supervision on a regular basis.
4.1b(7) Case Management Team: Case Manager’s must have a minimum of a associates degree in Nursing or a related field and hold any licensure in good standing, but bachelors degree preferred. Certification in mental health or a related field or certification in addictions counseling or nursing is preferred. Case managers must have not less than five years clinical experience in the treatment of mental health and chemical dependency/addiction and/or co-occurring conditions.
The Compliance Monitor/Assistant Case Manager must have a minimum of a high school diploma with preference to an associates degree or bachelor’s degree in healthcare, criminal justice, social sciences or a related field. Certification in addictions counseling, mental health or a related field is preferred. Experience in the medical field, addictions and/or behavioral health care field.
The Clerical Assistant/Testing Monitor must have a minimum of a high school diploma with preference to an associate degree or bachelor’s degree criminal justice, human services, or social work and experience medical field, addictions and/or behavioral health care field.
4.1b(8) Test Administration:
CNHP requires all nurses to have a complete physical with laboratory testing. Nurses with substance abuse disorders are required to provide a statement from their health care clinician verifying their ability to take naltrexone or disulfirim. CNHP strongly encourages participants to obtain dental and vision care.
4.1b(9) Monitoring:
Monitoring reports are received on a monthly or quarterly basis. The monitoring of nurse participants is a collaborative effort and nearly all staff at CNHP are involved.
The Clerical Assistant is responsible for recording the nurse’s telephone messages and calling in for urine drug screen testing. Each document submitted by a nurse is recorded on an audit report. The clerical staff retrieves urine drug screen reports, prepares a report on the findings and searches for missing results. The clerical assistant is responsible for alerting the assistant case manager and/or case manager if the nurse abruptly stops calling for the urine drug screen color of the day, does not submit required reports on the due date, has a positive result or is non-compliant with urine drug screens. The clerical staff and assistant case manager organize nurses monitoring reports, requests for changes in contracts and other documentation into a packet for review by the case management team. The clerical staff assists with monthly letters to participants and manages the participant records.
The Case Managers and Case Manager Assistant review the documentation in the nurse’s packet. A Compliance Report on each nurse is filled out and monitoring reports are either accepted or rejected, the nurse’s compliance and participation to date is summarized and requests for changes in the contract are noted. The case management staff utilizes the CNHP Policies and Procedures for Non-Compliance and Termination and Case Management Delegation to determine consequences for non-compliances and changes to the contract. Cases are reviewed by staff on a weekly basis, changes to contracts and issues of non-compliance are reviewed regularly. Those issues that fall outside of the case manager’s delegated responsibilities are brought to the Committee for guidance, determination of consequences, or consideration of requests. Nurses with safety to practice issues are pulled from practice pending evaluation and possible changes in treatment. The Board is notified immediately in cases of severe non-compliance or safety to practice issues.
Case Managers are delegated authority to review compliance to the contracts, determine noncompliance and extend contract dates within specific parameters. See policy: Case Manager Delegation.
Nurses having difficulty in adhering to their monitoring contract are verbally coached either in person or telephonically with the executive director or case management staff for coaching and problem solving issues and roadblocks to compliance. Nurses may be required to complete a plan to move into compliance.
Case Managers provide nurses with feedback on their progress and participation with their monitoring contracts by providing correspondence on a monthly basis. All modifications and subsequent alterations to the contract will be made in writing and must be complied with or the licensee will be considered in noncompliance.
Case Managers and Assistant Case Manager are responsible investigating non-compliance, keeping the therapists, physicians, employers and Nurse Support Group Facilitators informed of critical information about the participant’s health, mental health and/or sobriety and adherence to the contract.
The Executive Director oversees the overall operation of the program. This position develops the budget for Committee approval, acts as a liaison between the Board and the Committee, and manages the case management team. CNHP staff meets regularly throughout the week for case review and staff decisions are reviewed to assure that all nurses are treated equitably. Should a situation arise where the executive is not available to consult with the CNHP staff, the Committee Chairperson and Vice Chairperson are available.
The Office Manager, Clerical Assistant and Assistant collaborate with Case Managers to assure that each nurses participant are provided monthly written documentation of their compliance and contract changes.
4.1b(10) Supervision:
CNHP staff receives regular clinical supervision by a board certified psychiatrist at least once per month and more often as needed. Nurses referred to this program present with denial and other defense mechanisms that are common with people who abuse substances and have mental illness. Anger, hostility, defensiveness, grandiosity, entitlement, perfectionism, intellectualism, intrusiveness and helplessness are examples. These emotions can lead to counter-transference by persons attempting to help the nurse. Recognition of transference and counter-transference is imperative for staff so that distortions can be addressed constructively. Clinical supervision provides an avenue for each staff member to examine their own thoughts, feelings and attitudes of the nurses we serve so we can insure that our own feelings do not interfere with appropriate monitoring of the nurses. It is important to prevent professional enabling of substance abusing behavior and to encourage nurses to address their health problems.
In order to assure public protection and equitable treatment for all nurses involved in CNHP, the staff and Committee adhere to the policies and procedures for monitoring participants in the program.
Non-compliance issues are reviewed with the executive director through an open door policy and at staff meetings. CNHP staff and Committee utilize a guide for non-compliance to assure consistency and there is an expectation of transparency among the CNHP staff members. Regular and random chart reviews, clinical supervision and Committee oversight provide accountability and ensure public safety.
Case managers work independently, but also function interdependently with other staff in the overall coordination of services for all participants. Communication, transparency and adherence to policies and procedures assure equitable treatment of all nurses.
c. Availability of Services Statewide: Awarded contractor must make program available to all potential recipients statewide in all geographical areas of the state.
CNHP’s main office is located in Lakewood, Colorado, and CNHP also has a satellite office in Grand Junction with a dedicated case manager to cover the Western Slope from that location. In addition, CNHP staff meets with participants in Pueblo, Colorado Springs, Windsor, Fort Collins and Loveland.
CNHP has established a statewide array of treatment and collection sites, as shown in Appendix 4.1.c. These maps illustrate the location of CNHP resources in relation to county populations. CNHP-approved treatment and collection facilities have been established consistent with the population density throughout the state, in order to ensure the most convenient availability for nurses, regardless of where the nurse may be living or practicing. This wide network of coverage has been a priority for CNHP since its inception, and CNHP has steadily expanded its web of services over its twelve years of operation.
In addition to all of these physical locations, CNHP also connects with and monitors nurses through the use of the internet, mail services, telephone, and face-to-face meetings where the case manager will travel to the nurse’s remote site. CNHP is also in the process of launching a web-based Nurse Support Group through its expanded website and secure login capabilities.
In all, CNHP ’s statewide availability of services is a major advantage of this program.
d. Coordination: Awarded contractor must identify statewide treatment resource network which includes treatment and screening programs and support groups. Contractor must demonstrate a process for evaluating the effectiveness of such programs.
General Overview of Statewide Treatment Resource Network/Evaluation Process
CNHP has developed an expansive array of services and resources which comprehensively cover the entire state. Specific aspects of service provision in relation to population density are visually illustrated in the maps included in Appendix 4.1.c. In addition, CNHP individualizes treatment plans for each participant, which means that appropriate treatment providers are located conveniently for each participant’s location and needs. If CNHP does not have a previously-approved treatment provider easily accessible to the participant, CNHP staff will consider an array of factors, including previous treatment received by the participant in the area, appropriateness of continuing with a prior treatment provider, expertise of the treatment providers in the area, and specific treatment needs of the participant. CNHP will then contract appropriate providers in the areas and obtain/review credentials and background in order to determine an appropriate fit for the participant. Providers must also be approved by the Committee in order to be allowed to provide treatment for a participant. Once the provider is approved in a new area, this provider is included for consideration of future participants’ needs. However, provider selection is an individualized process.
Approved treatment providers are continuously reviewed to evaluate effectiveness and appropriateness. This continuous evaluation includes assessment by case managers of the progress of the participant’s recovery and wellness; if there are shortcomings, the case managers or Executive Director will initiate review of provider performance. In addition, the Committee will evaluate providers on a regular periodic basis. Any reports of provider problems, from any source, will also instigate the review process. Even the appearance of impropriety may be cause to remove a provider from the approved list and assignment of another provider for a participant. CNHP holds its participants’ recovery and wellness paramount in this review process.
General Overview of Program Effectiveness Tenets
Evaluating the effectiveness of a program of this magnitude means understanding the scope of the program and having a definition for success. Success is loosely defined in terms of addiction. Success with addiction can be a year of sobriety, a month, or even just a day. The goal of our program is to provide nurses with the opportunity and support for recovery and treatment, while reasonably assuring the protection of the public. CNHP’s success is defined by how well we manage the participant’s ability to work, stay off drugs, and be a productive member in society. These factors in turn keep the community safe and the nurse safe to practice.
Participants are monitored with work-site evaluations from their manager, random urine drug screens, group participation, and monthly self reports. The CNHP program defines participants as compliant or non-compliant, and uses this definition as a basis for success in the program. A compliant participant is one who follows the program closely and follows the steps of the program. Our goal is to minimize the amount of non-compliant participants. We understand there are certain occasions where a participant may be non-compliant; in this event, we look for immediate and sustained improvement, and we strive to minimize these circumstances with the participant.
Understanding there are many levels of success throughout the program, our ultimate measure of success is completion of the program. We believe tracking the success of a participant from day one through completion by measuring the amount of participants that are successfully discharged over the life of the program is crucial. We also track where referrals come from, the demographics of a participant, the length of a contract, the number of extensions, the types of treatments received, and any reasons for leaving the program. We also believe it is important to follow-up with the successful participants after completion of the program.
In evaluating our effectiveness, we look to similar, successful programs nationwide and compare completion rates. We make improvements to our program based on these figures, the reasons why participants may not complete our program, and what successful participants are saying about our program.
We currently have an evaluation form for participants upon completion that rates their opinion of the program and how the program can be improved. In the fiscal year 2006-2007, 76% of successfully discharged participants completed the form. We learned from these evaluations that participation in a 12 step program was considered the most helpful aspect of the program; we also learned our monthly self reports were reviewed as the least helpful. From these evaluations all the feedback is considered and reviewed for changes. See Appendix 4.1.d.2.
Specifics on Treatment Providers and Facilities.
CNHP maintains a list of approved providers and treatment facilities from across Colorado. The Denver metro area and the more densely populated areas of the state have adequate resources available. CNHP will search for suitable clinicians as close to the nurses as possible, in rural areas of the state should a nurse reside in an area which does not have an approved clinician.
CNHP was instrumental in collaborating with therapists to develop services to meet the needs of nurses and other health care professionals. CNHP prompted highly qualified therapists in Alamosa, Denver, Broomfield and Pueblo to develop and provide relapse prevention groups for health care professionals. These relapse prevention groups provide the participant with a place to explore profession-specific triggers, back to work or work re-entry issues, and teach coping strategies the nurse can use to attain balance between their personal, family and professional life.
Support and Community Resources
CNHP provides Nurse Support Groups in Windsor, Greeley, Lakewood, Denver, Aurora, Louisville, Colorado Springs, Pueblo and CNHP is introducing a web based Nurse Support Group. Statewide access to nurse support groups is available through the web based nurse support group.
CNHP maintains a list of community resources available by city, county and service type. For example:
• Depression Support
• Bipolar Support
• Eating Disorder Support
• Hepatitis C
• Emergency Financial Resources
• Emergency Food
Most counties have at least one Alcoholics Anonymous (AA) Meeting. Web based meetings are also gaining in popularity as are nursing chat rooms and support Blogs. CNHP provides all participants with websites of interest to the recovering nurse (International Nurses Anonymous, Nurses in Recovery, etc.).
Collection Sites
CNHP has agreements with 44 regular collections sites across the state of Colorado for participants to provide urine drug screen and/or breathalyzers with the capability to utilize several (see Appendix 4.1.c). With appropriate notification, CNHP can locate collection sites for Redwood and Norchem Laboratories across the United States and often in other countries.
Evaluation Tools
Program evaluations are given to nurse participants who successfully complete the CNHP contract (see Appendix 4.1.d.1). Each nurse is asked to rate in three categories: program components, program affiliation and other. AA/12-Step Meetings were rated as the most helpful component of the program aspect of the program and the over all most helpful aspect of the program. Coincidentally when nurses return to CNHP after a relapse, they overwhelmingly report they had stopped going to their meetings and within months, relapsed.
Nurse Support, Professional Support Groups, Network Support and Connection with the Program are within the top five most helpful components of the program.
Nurses will complete a satisfaction survey after their completion of therapy. Participants produce recovery maintenance plans (relapse prevention, wellness, and/or pain management) to demonstrate the participant’s understanding of their personal high risk situations and a plan to maintain wellness. CNHP will monitor each nurse’s participation in their treatment program and document outcomes: sustained abstinence, relapse, relapsing behaviors.
e. Performance Data Reporting: Awarded contractor must provide quarterly reports to the Board which show, at a minimum, the current number of recipients, the program services that were provided, and demographic details.
CNHP has experience in providing the Board with quarterly reports and looks forward to working with the Board to further tailor quarterly reports to meet the Boards needs. In addition to the quarterly demographic reporting, CNHP provides an annual year end report and internal evaluation which integrates specific queries from the Board. CNHP reports provide a current and cumulative snapshot of CNHP activities including the number of recipients/participants, program services and demographics. See Appendix 4.1.e.
f. Reporting of Participant Violations of Issues: Awarded contractor must notify the Board within 24 hours but not later than the end of the next business day of any recipients with active cases who:
• Display an imminent danger to self or others by virtue of alcohol or substance abuse, chemical dependency or suffering any other impairment.
• Is not in compliance with their monitoring contract for more than 2 months
• Have had two relapses
CNHP will provide the Board of Nursing with verbal notification of the above-listed violations to the monitoring contract within 24 hours, but not later than the end of the next business day, and will also provide written verification and substantiation of this notification within two business days. CNHP will work with the Board to develop a weighted guideline for non-compliance and reporting. The current guidline used by CNHP is included in Appendix 4.1.a.4.
g. Providing Reports on Stipulated Agreements: Awarded contractor must provide timely reports to the Board as required by Stipulated Agreements.
CNHP agrees to provide the Board of Nursing with reports on licensees with Stipulations and Final Agency Orders. CNHP proposes a monthly report listing names of BON Stipulated participants, the date of their signed CNHP contract, estimated discharge date and compliance status. CNHP will work with the Board of Nursing to develop reporting which captures useful information for the Board.
h. Releasing Information to the Board: Awarding contractor must obtain an authorization from incoming recipients to release records and information to the Board, including records received from other sources in the contractor’s custody pursuant to a subpoena issued by the Board.
CNHP already requires all participants to sign a consent for the exchange of information with the Board of Nursing and its agents (Assistant Attorney Generals Office, Office of Expedited Settlement, and Department of Regulatory Agencies). In addition, CNHP already complies with all aspects of federal confidentiality laws (42 C.F.R. part 2, inter alia) in order to allow the Board to subpoena all underlying information under specifically defined circumstances, such as where a release already exists. See Appendix 4.4.2 and, in general, Sections 4.4 and 4.5 below.
i. Testimony: Awarded contractor must provide testimony by the appropriate person(s) in contested cases if requested by the Board.
CNHP is prepared to provide fact testimony regarding CNHP referrals should the Board of Nursing require it. Should a former participant contest the referral, the most appropriate person to testify would be the person who provided supervision of the case. In most cases, the executive director or program chairperson would testify. CNHP has a history of providing testimony and support in contested cases when requested by the BON. The fee for testimony would be consistent with the Board’s policies.
j. Financial and Organization Strength: The Offeror, together with any subcontractors, must demonstrate that they have the financial resources to perform all requirements of this RFP. Awarded contractor must have adequate insurance.
Per CRS 12-38-131(2)(a), the Board of Nursing created the Colorado Nurse Health Program for the purposes of administering the impaired professional diversion program, as such all revenues received from the Board have been dedicated to that end, as documented in the financials regularly provided to the Board over CNHP’s existence. CNHP has also had regular independent audits conducted, although not required by statute. Hull & Associates is the auditing firm which has conducted these audits for the past two years; no problems were found. Copies of the audit findings are available upon request.
CNHP will maintain adequate insurance as required by the State's Solicitation Instructions and Terms and Conditions
CNHP already has (or will obtain), and will maintain at all times during the term of the contract, insurance in the following kinds and amounts which meets or exceeds the insurance requirements mandated by the State:
1) Workers' Compensation Insurance as required by state statute, and Employer's Liability Insurance covering all of CNHP's employees acting within the course and scope of their employment.
2) Commercial General Liability Insurance, covering premises operations, fire damage, independent contractors, products and completed operations, blanket contractual liability, personal injury, and advertising liability with minimum limits as follows:
a. $1,000,000 each occurrence;
b. $1,000,000 general aggregate;
c. $1,000,000 products and completed operations aggregate; and
d. $50,000 any one fire.
If any aggregate limit is reduced below $1,000,000 because of claims made or paid, CNHP will, as required by the State's Solicitation Instructions and Terms and Conditions, immediately obtain additional insurance to restore the full aggregate limit and furnish to the State a certificate or other document satisfactory to the State showing compliance with this provision.
3) Automobile Liability Insurance - CNHP does not own any automobiles, and does not rent or otherwise provide automobiles for employee or officer use.
4) Professional liability insurance (amounts undefined in current model contract) - CNHP's present coverage is $1,000,000 per occurrence, and $3,000,000 in the aggregate (maximum during policy term).
CNHP will name the State of Colorado as additional insured on the Commercial General Liability policy. Coverage required by the contract will be primary over any insurance or self-insurance program carried by the State of Colorado. The insurance shall include provisions preventing cancellation or non-renewal without at least 45 days prior notice to the State by certified mail.
CNHP will require all insurance policies in any way related to the contract and secured and maintained by CNHP to include clauses stating that each carrier will waive all rights of recovery, under subrogation or otherwise, against the State of Colorado, its agencies, institutions, organizations, officers, agents, employees and volunteers.
All policies evidencing the insurance coverages required hereunder either are or shall be issued by insurance companies satisfactory to the State.
CNHP shall provide certificates showing insurance coverage as required by the contract to the State within seven business days of the effective date of the contract, but in no event later than the commencement of the services under the contract. No later than 15 days prior to the expiration date of any such coverage, CNHP shall deliver to the State certificates of insurance evidencing renewals thereof. At any time during the term of the contract, the State may request in writing, and CNHP shall thereupon within 10 days supply to the State, evidence satisfactory to the State of compliance with the provisions of this section.
k. Avoidance of Conflict of Interest: Awarded contractor must ensure that, to the extent practicable, the licensed professionals involved in the evaluation of recipients entering the Program shall not also provide treatment of same recipients. The awarded contractor must also ensure that such professionals hold an unrestricted license from their respective board.
With the exception of customary evaluations in conjunction with f treatment, CNHP makes every effort to discourage licensees from entering treatment with the same individual who initially evaluated them. This has been challenged throughout the history of CNHP, particularly in rural areas, however those nurses who chose to go to the therapist who evaluated them must provide a written statement regarding the decision to go to the evaluator.
Evaluators will sign a conflict of interest statement which discourages/prohibits nurses from pursuing treatment from them. In order to avoid the any appearance of impropriety, avoid conflicts of interest and dual relationships, I agree I will not solicit a treatment relationship with any participant that I have evaluated for CNHP. In addition, to the evaluators, CNHP staff, Board of Directors, nurse support group facilitators, and treatment providers will sign conflict of interest statements.
4.2
a. Education: The awarded contractor must offer assistance and education to recipients concerning the recognition, identification, and prevention of physical, emotional, psychiatric, psychological, drug abuse, or alcohol abuse problems and provide intervention when necessary.
Education is a strong component of CNHP and exists on multiple levels. Education is integrated into all aspects the nurse’s support system. CNHP recognizes that, with education, each nurse, their significant others, nurse manager/supervisor, the hospital or institution for which they work, and the Board of Nursing have the potential to intervene and assist the impaired nurse to move into wellness. Education provides the foundation for recognition, identification and prevention of physical, emotional, psychiatric, psychological, drug abuse, or alcohol abuse problems.
Each nurse renewing their license in Colorado is provided with information about the existence of CNHP. The purpose of the program and how CNHP monitors patient safety is outlined. The notice provides nurses and managers with information regarding the symptoms of impaired practice and how to contact the program. CNHP has a quarterly advertisement of services in the Colorado Nurse, which reaches all nurses in the State of Colorado. It is not unusual for a nurse to contact CNHP after carrying around the renewal insert or advertisement for some time.
CNHP staff seeks every opportunity to educate nurses about impaired professionals and prevention, but moreover, CNHP tries to “plant seeds” for recovery. It is not unusual for nurses to call CNHP several times, just to seek information about the program and share just a little bit more about themselves and their problem each time. Nurses may make plans to come in for an intake assessment or evaluation, but become fearful and cancel, or not show up at all. A nurse may avoid contact from CNHP all together, only to come back months or even years later, often after a significant external motivator such as the threat of divorce, termination of employment or by an invitation from the BON in the form of an Agreement to Participate in CNHP or Stipulation and Final Agency Order.
CNHP offers monthly educational opportunities to nurse participants in the Nurse Support Groups. Additionally, educational presentations are available, upon request any facility which educates or employs nurses. We offer have presentations on:
• Impaired Practice: Risk, Recognition, Recovery and Retention
• Crossing the Line: When Professional Boundaries are Violated
• Self-Care for Nurses: Take Care Before Assisting Others
Each educational presentation is customized to fit the audience (students, staff nurses, nursing educators, nurse managers etc.) and culture. These presentations are provided at no cost to facilities which employ nurses or provide education to nurses.
The staffs of the State Board of Nursing, State Attorney General’s Office, Office of Expedited Settlement and Office of Investigation have all received consultation and educational services from CNHP.
CNHP will continue to build awareness and provide employers and schools of nursing with consultation when developing policies and procedures regarding identification, and prevention of physical, emotional, psychiatric, psychological, drug abuse, or alcohol abuse problems. CNHP will meet with the Board to clarify roles and expectations.
b. Evaluation: The awarded contractor must evaluate all licensees referred to the program, either for participation or evaluation only, to determine the extent of physical, emotional, psychiatric, psychological drug abuse, or alcohol abuse problems and provide assessment, intervention, or write a treatment plan.
CNHP is prepared to evaluate all licensees referred to the program for participation. The cost of these evaluations will come from licensing fees. CNHP will assess licensees referred by the Board to determine the complexity of the physical, emotional, psychiatric, psychological, substance and/or alcohol abuse problems. CNHP will communicate with Board on any licensee who presents requiring specialized or extensive evaluations. Licensees will be referred for such evaluations at their own expense.
Additionally, nurses who present with significant denial of their problem, in the face of overwhelming evidence to the contrary, may require and extended evaluation and/or treatment at a residential facility that has the expertise to work with them. Extended evaluations include, a history and physical with laboratory studies, psychosocial history, psychiatric evaluation, psychological testing, addictionist evaluation and may include a focused evaluation on co-occurring disorders and other process addictions. Licensees will be required to arrange for payment of the evaluation on their own.
The evaluation process has been described in section 4.1.a(2) and 4.1.b(3) of this proposal.
c. Testing: Awarded contractor must at a minimum require all recipients to complete a history and physical screening.
CNHP requires that all participants receive a current history and physical. Participants may have additional testing required as indicated by CNHP or treatment providers. Testing is paid for by the licensee.
d. Screening: Awarded contractor must provide urine drug/alcohol or blood drug/alcohol or other types of screening procedures.
CNHP utilizes Redwood Toxicology Laboratory and Norchem Drug Testing. These two nationally recognized and reputable laboratories provide CNHP with an opportunity to test for a multitude of substances commonly abused by the healthcare professional while continuing to provide affordable testing for the participant. Please see attached written drug testing policy, collection site agreement, laboratory information and drug screening information (see appendix 4.1.d.2)
e. Counseling: Awarded contractor must provide counseling with a therapist who meets Board approved criteria.
CNHP has a list of approved counselors which meet or exceed the minimal requirement as indicated by the BON. Approved therapists provide documentation of their experience and are interviewed by the executive director. Licensure is verified utilizing the Automated Licensure Information System On-Line (ALISON) through the Department of Regulatory Agencies. Approved providers are oriented to the policies and procedures related to their interface and expectations of CNHP and receive a Therapist Packet containing an outline explaining CNHP, consents for the release of information, a Therapist Acknowledgement Form, and a Therapist Report
Substance abuse counseling is performed by:
Licensed Addictions Counselor (LAC) with at least a Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field, or;
A Certified Addictions Counselor, level II (CACII) with at least a Master’s Degree in Counseling, Social Work, Nursing, Psychology or a related field, or;
A Certified Addictions Counselor, level III (CACIII) with at least a Bachelor’s Degree in Counseling, Social Work, Nursing, Psychology or a related field
Nurse’s requiring counseling for health, psychiatric or co-occurring disorders (psychiatric and addictions) will see a CNHP approved clinician who has expertise and licensure such areas.
Each counselor shall have experience working with healthcare professionals and provide documentation of malpractice insurance.
f. Participant Contracts: Awarded contractor must place all recipients under a contractual agreement for completion of any planned treatment as identified in the evaluation.
All licensees will have a monitoring contract (see appendix 4.1.f) which is developed in specifically for each individual and their circumstances, and considering and incorporating, where appropriate, the evaluation. The contract outlines the requirements for participation in the program and the consequences for noncompliance.
Upon acceptance into CNHP, a letter with the proposed contract and certificate of service is mailed to the licensee. The contract is due back to CNHP within 10 days of the date of the letter.
Upon receipt of a signed contract, the Executive Director reviews and signs as well. A copy of the fully executed contract is then sent to the licensee and the original contract is placed in the licensee’s file. If the licensee has been ordered into CNHP through a Stipulation & Order or Agreement to Participate, the Case Manager will remind licensee to send a copy of the contract to the Board.
The Board is notified of receipt of a signed contract if the licensee is participating in CNHP pursuant to a Complaint (Agreement to Participate) or Stipulation & Order.
If a contract is not received within the 10-day period, the Case Manager will do a follow-up phone call.
The Board determines contract deadlines. Should a licensee fail to contact CNHP by the Board deadline, CNHP will contact the Board. Only the Board can extend deadlines for applications and contracts. Should a situation arise where CNHP is unable to meet the Board’s deadlines, CNHP staff will contact the Board for instruction and extension of deadline. The Board will provide amended deadline dates and other pertinent instructions in writing and the notification will remain a part of the licensees CNHP record.
g. Treatment Monitoring: contractor must develop a monitoring contract for each recipient and report contract compliance and progress to the Board.
Monitoring reports are reviewed for compliance on a monthly basis. CNHP will provide a summary of compliance and progress for nurses participating pursuant to a Stipulation and Final Agency Order or Complaint/Agreement to Participate. Information on compliance and progress for nurses voluntarily participating in the program can be provided utilizing an anonymous process. (show example)
h. Coverage: Awarded contractor must have services available to all licensees statewide and have program coverage 24 hours a day, 7 days a week.
CNHP agrees to have services available to all licensees statewide (see 4.1.c). CNHP has 24 hour coverage through confidential voice mail. Calls received outside of hours of operation are returned during the next business day. CNHP will provide a cell phone number/pager to be used for urgent issues that arise 24 hours a day, 7 days a week. CNHP does not provide crisis intervention counseling and does not provide medical, psychiatric or substance abuse treatment. CNHP’s advices, on its outgoing message 24 hour access number should not be used in lieu of accessing the appropriate emergency system.
4.3 Fees
Quote the total fees per year for providing all services described in this RFP. Allocated amount available to fund the 2008 program is dependent upon the actual revenues and the number of licensees in Colorado. Estimated amount can be derived from section 3.2 Overview. Payment will be disbursed monthly for the period January 1, 2008 through December 31, 2008. Any money received pursuant to a contract with the Board that is unspent by the Contractor as of December 31, 2008 shall be returned to the administering entity selected by the Board pursuant to the provisions of paragraphs 9(b) of Subsection 12-38-131 for subsequent appropriation and disbursement.
The funds provided under this contract may be used only for educational, intervention and administrative services and services related to the identification of the physical, emotional, or psychological problems and the evaluation, diagnosis, treatment and monitoring of licensed Colorado recipients.
Concisely and clearly describe your agency’s ability to manage the ongoing costs associated with the ensuing contract. Include any information that may be used to supplement expenses of the Program above the amount provided by the Fund. Include your budget for this program and detail the costs of your services per line item.
Total fees, with complete breakdown demonstrating compliance with these requirements, are listed in Appendix 4.3, which is being submitted in a separate envelope as required.
4.4 Compliance with Applicable Laws
The contractor is to administer the program pursuant to, and demonstrate compliance with, all statutory and rule requirements as well as terms and conditions outlined in this RFP, the contract, and any other applicable laws including the Health Insurance Portability and Accountability Act (HIPAA) and federal confidentiality laws and regulations.
CNHP understands the importance of compliance with all statutory, rule, and contract requirements. In particular:
• CNHP is fully compliant with all provisions of State requirements, including but not limited to the Colorado Board of Nursing Rules, Chapter XII, Rules and Regulations for the Impaired Professional Diversion Program.
• CNHP complies with all requirements of CRS 12-38-131 as it present stands, and also as that statute will be as repealed and re-enacted on January 1, 2008.
• CNHP meets all terms and conditions outlined in this RFP, as described herein.
• CNHP will meet all terms and conditions of the Model Contract, attached to this State’s solicitation.
• CNHP is aware of, and fully compliant with, all requirements of the federal confidentiality laws and regulations protecting drug and alcohol abuse patient records, including 42 CFR Part 2 and its enabling statute(s) (see Appendix 4.4.1 CNHP Initial Disclosures and Appendix 4.4.2 Releases).
• CNHP takes safeguards in addition to those required by statute to further protect confidential information (see Appendix 4.4.3 Employee Nondisclosure Agreement).
• CNHP is compliant with of all requirements of the Health Insurance Portability and Accountability Act (HIPAA) (see Appendix 4.4.4. HIPAA Notice of Privacy Practices, and Appendix 4.4.5 HIPAA Business Associate Agreement).
• CNHP has researched and understands the conflicts and differences between the federal confidentiality laws and HIPAA, and has notices and releases required by those federal laws, which meet the requirements of both, while addressing the mandates of each.
• CNHP is compliant with Sarbanes-Oxley pending requirements for non-profit corporations. (see Appendix 4.4.6 CNHP Code of Ethics Form).
4.5 Confidentiality
The contractor is to identify specific methods for providing and assuring confidentiality for participants. Identify specific procedures to be followed for maintaining confidentiality of active cases, access and control of computerized information, and storage of medical records. Attach documentation which demonstrates compliance with federal confidentiality requirements and HIPAA.
CNHP has established procedures to assure protection of the public while maintaining confidentiality of participant information, by implementing procedures mandated by federal statutes and regulations, as well as practical considerations. An array of measures safeguards confidential information and records from inappropriate or inadvertent disclosure.
• Confidentiality of active cases. CNHP implements physical precautions, handling procedures, and documentation to preserve the confidentiality of active cases.
o Physical Precautions. Case files for active cases are kept in locked file cabinets, either in assigned case manager’s office or in a separate file room, which is not accessible by the public or by other participants. CNHP’s offices have an entrance lobby which is separate from the main office area; in order to enter the main office, participants or members must first ring for access, be viewed through a window by CNHP staff, and only allowed access if no files or other participants are in view. This “screening before entry” procedure is just one more safeguard against inadvertent compromise of sensitive information.
o Handling Procedures. Case managers are required to keep all case information and files in the office at all times. This way, there is no potential of losing documentation or inadvertently displaying protected information in a public venue.
o Documentation. All CNHP employees sign a confidentiality agreement, which provides personal acknowledgment of the importance of the confidentiality of CNHP information; a copy of this form is attached as Exhibit 4.4.3 CNHP Employee Nondisclosure Agreement. All directors review and sign a Code of Ethics annually, which also acknowledges the obligation of confidentiality. A copy of this form is attached as Exhibit 4.4.6 CNHP Code of Ethics Form.
• Access to and control of computerized information. CNHP has multiple safeguards in place to restrict access to and ensure control of computerized information relating to its participants and the program in general. These include:
o State-of-the-art firewall and security systems. CNHP has implemented state-of-the-art firewall and security systems on its office server and individual network terminals. Access is allowed via secure log-in only, with unique passwords assigned to all personnel for their level of access. Sensitive and confidential information is not accessible by the internet, and personnel are not allowed to transfer information to disks for use outside of the office.
o No internet access to confidential participant database. All information relating to participants is kept in the CNHP office server, and there is no access to this information over the internet. Although CNHP is implementing a secure participant log-in, no sensitive file information will be available even through this log-in procedure. Instead, participants with an assigned and unique user name and password will be able to access participant-specific program data only (such as color information, policies and procedures, release forms, support group calendars, and the like).
• Storage of medical records. Case files with medical records are kept in locked file cabinets, either in assigned case manager’s office or in a separate file room, which is not accessible by the public or by other participants. As stated above, CNHP’s offices have an entrance lobby which is separate from the main office area; in order to enter the main office, participants or members must first ring for access, be viewed through a window by CNHP staff, and only allowed access if no files or other participants are in view. Medical records of inactive cases, where there has not been successful program completion, are kept in a locked file room in CNHP’s office. Pursuant to CRS 12-38-131 as it currently stands, records of participants who have successfully completed the program are purged and destroyed, pursuant to subsection. Once this version of the statute is no longer effective, it is anticipated that records of participants who have successfully completed the program will also be stored in locked file cabinets in the same locked file storage room and will not be destroyed, pursuant to pending requirements for non-profit corporate entities under Sarbanes-Oxley.
Documentation which demonstrates compliance with federal confidentiality requirements:
CNHP distributes an initial disclosure to all new contacts and participants as required by 42 CFR Part 2, and also has this documentation available in its lobby and on its website at . A copy is attached in Appendix 4.4.1 CNHP Initial Disclosures.
CNHP releases include all language required by federal confidentiality statutes and regulations. See Appendix 4.4.2 Releases.
Documentation which demonstrates compliance with HIPAA:
• CNHP’s Notice of Privacy Practices as required by HIPAA is distributed to all participants, and also published on its website at . A copy is attached in Appendix 4.4.4 HIPAA Notice of Privacy Practices.
• CNHP also has a HIPAA Business Associate Agreement, which is attached in Appendix 4.4.5 HIPAA Business Associate Agreement.
III. Management and Experience Component (5.3.3)
A. Describe how your company will manage this project.
As indicated in sections 4, CNHP has experience with all aspects of RFP-SJN-0801. CNHP has provided
B. Indicate key personnel who will be assigned to the project and describe their experience. Explain how you will ensure that equally qualified persons are assigned to the project if these individuals leave the project. The state expects that the awarded Offeror will continue to make the key project personnel available through the life of the contract as long as they remain in the Offeror’s employ. The state reserves the right to approve any replacement personnel.
Key Staff (resumes attached):
Marjorie Derozier, Executive Director
Bobbi McKevitt, Western Slope Case Manager and Outreach Coordinator
Deidre Tygart, Case Manager Assistant/Compliance Monitor
Judith Estes, Program Manager
Joyce Muniz, Receptionist/Clerical Assistant
Case Manager (2 FTE) CNHP will hire two case managers qualifications and expertise as indicated in the job description provided under Staffing page 14.
C. Describe your firm’s experience with similar projects. For the two most closely related projects: state the actual audited savings and the time period over which it accrued; give examples of before-and-after pricing and indicate how long vendors honored the new pricing; describe in detail the role and level of state employee involvement during the contract period, including but not limited to the Governor’s office personnel, cabinet-level personnel, central purchasing office manager(s) and buyers, IT personnel, accounting personnel.
CNHP has provided monitoring services for the State of Colorado’s Board of Nursing for over 12 years. The table below shows the CNHP budget and actual monies spent.
BUDGET VS. ACTUAL PER FISCAL YEAR
FOR THE COLORADO NURSE HEALTH PROGRAM
|Fiscal Year |Budget |Actual |
|7/1/97 – 6/30/98 |358,641 |362,730 |
|7/1/98 – 6/30/99 |316,473 |306,719 |
|7/1/99 – 6/30/00 |383,277 |382,884 |
|7/1/00 – 6/30/01 |392,329 |379,185 |
|7/1/01 – 6/30/02 |436,428 |420,844 |
|7/1/02 – 6/30/03 |467,045 |472,726 |
|7/1/03 – 6/30/04 |501,622 |509,515 |
|7/1/04 – 6/30/05 |507,773 |498,399 |
|7/1/05 – 6/30/06 |578,776 |560,845 |
|7/1/06 – 6/30/07 |599,770 |599,690 |
The Colorado Nurse Health Program understands that funding provided under this contract is to be used for educational, intervention and administrative services and services related to the identification of the physical, emotional, or psychological problems and the evaluation, diagnosis, treatment and monitoring of licensed Colorado recipients. Please see appendix 4.3 for the proposed budget for FY 2008 and projection for FY 2009.
State employees included: Board of Nursing Staff and appointed Board of Nursing Members.
IV. Cost Component/Operational Budget (5.3.4)
See appendix 4.3 in separate sealed envelope.
V. References (5.3.5)
|Company Name |Contact |Telephone |Brief Description |
|Memorial Hospital Colorado Springs |Kathy Romstad, MA, LPC, CACIII |719-365-6677 |Coordinated monitoring of nurses with|
| |Coordinator of Behavioral Health | |addiction issues for memorial |
| | | |hospital. |
|Nurse-Family Partnership National |Patricia Uris RN, PhD |303-327-4256 |Prior Director for the Board of |
|Service Office | | |Nursing |
|Colorado Board of Nursing |Mark Merrill |303-894-2416 |Current Director of the Board of |
| | | |Nursing |
|LLSA Inc. (Recovery Maintenance for|Linda Smith |404-509-5931 |Former Director of the Intervention |
|Nurses) | | |Project for Nurses in Florida and |
| | | |program evaluator for the CNHP |
| | | |program in 2005 |
|Washington State Health |Jean Sullivan |360-236-2880 |Executive Director of the Washington |
|Professionals | |206-999-9689 |State Health Professionals and former|
| | | |evaluator of the CNHP program |
|Arapahoe Community College School |Karen Hecomovich |303-797-5895 |Provided educational services for |
|of Nursing | |303-773-1969 |student nurses |
Confidentiality
Pursuant to RFP Section 1.12, CNHP requests that all financials be held confidential, except in the event of a contract award to CNHP (these financials are already physically separated from the technical proposal). Further, CNHP requests that all appendices with copyright designation (which are also separate from the body of the proposal) be held confidential pursuant to (C.R.S. 240720203(4)(Open Records Act).
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