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Discussions with Deb: New DOL Restrictions

May 21, 2019

May 21, 2019

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There has been a fair amount of upset lately over Department of Labor’s (DOL) new Circular 19-03 which restricts the amount of time DOL allows a Case Manager to spend helping sick workers each week.  DOL has decided that 15 minutes a week is all the time that is needed.

15 minutes a week doesn’t seem like much time, but I don’t have a medical background. I thought it would make sense for me to back up a step and learn what a Case Manager actually does so I could better understand if 15 minutes is a reasonable amount of time or not.

DOL, in their DEEOIC Policy and Procedure Manual, mentions only that a case manager needs to be a Registered Nurse.

The Commission for Case Manager Certification, defines case management as, “a collaborative process that assesses, plans, implements, coordinates, monitors, and evaluates the options and services required to meet the client’s health and human service needs. It is characterized by advocacy, communication, and resource management and promotes quality and cost-effective interventions and outcomes.”

That certainly seems worthwhile, but what does it mean?  It means a case manager:

  • Coordinates care with the sick worker’s doctors and other health care providers
  • Implements the doctors’ orders
  • Documents plans for the sick worker’s healthcare activities
  • Evaluates the sick worker’s needs, available resources, and current services
  • Connects the sick worker to needed services
  • Educates the sick worker, family members, and caregivers to better understand the sick worker’s symptoms, medical care, and medication.
  • Advocates for the sick worker to make sure the treatments and services are what the sick worker wants
  • Makes clinical decisions for routine care of the sick worker
  • Documents and submits medical records
  • Reviews and explains the results of medical tests to the sick worker.
  • Provides emotional support to patients and families

It seems pretty clear that for most sick workers, especially those with complex medical needs, 15 minutes a week is not enough time to do all the above.

And while I have no medical background I do have an understanding of the value of a case manager.  For the past 14 years I have been a caregiver to a young adult with disability issues.  I have done much of what a case manager does, excluding the medical knowledge part.  I spend well over an hour a week managing the care.  Keeping a vulnerable person as healthy as possible can be very tricky.

The field of case management was developed to improve patient care and lower costs, both of which seem like laudable goals. There are a number of studies available that show that when a case manager is part of a patient’s medical team the patient is hospitalized less often than when no case manager is involved.  This makes sense, and the cost saving involved in NOT being hospitalized seems like it could be significant.

All this brings up a question.  I’m sure DEEOIC supports both improved medical care and lower costs for sick workers.  It seems clear that a case manager is part of the team necessary to improve medical care and lower costs.  So why was Circular 19-03 developed?  What was DEEOIC hoping to achieve beyond saving a minimal amount of money on each sick worker receiving services?  This seems very short sighted if sick workers then spend more time (and money) for hospitalizations.

I’ve asked DOL these questions.  I’ll let you know what the answers are when I get their reply.