Resolution No. 8674
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RESOLUTION NO. 8674
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A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
VERNON APPROVING AND RATIFYING THE FILING OF A
MEDICAL PROVIDER NETWORK APPLICATION WITH THE
ADMINISTRATIVE DIRECTOR OF THE DIVISION OF WORKERS'
COMPENSATION PURSUANT TO SENATE BILL 899
WHEREAS, on April 19, 2004, Senate Bill 899 was signed into
law providing for the establishment of a medical provider network on
or after January 1, 2005, by an employer or an insurer for the
provision of medical treatment to injured employees; and
WHEREAS, Labor Code Section 4616 provides that a plan for a
medical provider network needs to be submitted to the Workers'
Compensation Administrative Director (the "AD") for approval; and
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WHEREAS, by developing a medical provider network, the City,
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a self-insured employer, determines the members of its network,
provides a process for an injured employee to select a physician from
the provider network for treatment of an injury and establishes an
independent medical review process to resolve disputes regarding
treatment; and
WHEREAS, in order to meet the urgent need to establish a
medical provider network plan as soon as possible, the City
Administrator executed and submitted to the AD a Medical Provider
Network ("MPN") Application dated February 7, 2005, that included a
continuity of care policy and transfer of ongoing care policy, subject
to ratification by the City Council; and
WHEREAS, by letter dated February 9, 2005, Bruce V.
Malkenhorst, City Administrator/City Clerk, recommended that the
execution of the MPN Application be approved and ratified; and
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1 WHEREAS, the City Council desires to approve and ratify the
2 MPN Application, as executed by the City Administrator.
3 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE
4 CITY OF VERNON AS FOLLOWS:
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SECTION 1:
The City Council of the City of Vernon hereby
6 finds and determines that the recitals contained hereinabove are true
7 and correct.
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SECTION 2:
The City Council of the City of Vernon hereby
9 approves and ratifies the execution of a Medical Provider Network
10 Application by the City Administrator on behalf of the City of Vernon,
11 a copy of which is attached hereto as Exhibit A and incorporated by
12 reference.
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SECTION 3:
The City Council of the City of Vernon hereby
14 authorizes the City Administrator, or his designee, to execute any and
15 all documents necessary for the purpose of establishing the MPN plan
16 and to implement and carry out the purposes specified in the MPN
17 Application for, and on behalf of, the City of Vernon.
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SECTION 4:
The City Clerk of the City of Vernon shall
certify to the passage of this resolution, and thereupon and
thereafter the same shall be in full force and effect.
APPROVED AND ADOPTED this 16th day of February, 2005.
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BRUCE V. MALKENHORST, City Clerk
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STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
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I, BRUCE V. MALKENHORST, City Clerk of the City of Vernon, do
hereby certify that the foregoing Resolution, being Resolution No.
8674, was duly adopted by the City Council of the City of Vernon at a
regular meeting of the City Council duly held on Wednesday,
February 16, 2005, and thereafter was duly signed by the Mayor of the
City of Vernon.
BRUCE V. MALKENHORST, City Clerk
(SEAL)
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EXHIBIT
A
For DWC only: MPN Approval Number
Date Application Received: / /
Cover Page for Medical Provider Network Application
1. Name ofMPN Applicant - City of Vernon
2. Address - 4305 Santa Fe Avenue
Vernon. CA 90058
3. Tax Identification Number
2~-2QQQ~Q~
4.Type ofMPN Applicant
x Self-Insured Employer
o Joint Powers Authority
o State
o Insurer
5. Name of Medical Provider Network(s), ifapplicable: City of Vernon MPN
6. If the medical provider network one is of the following deemed entities, check the appropriate box:
o Health Care Organization (HCO)
o Health Care Se~ce Plan
o Group Disability Insurer
o Taft-Hartley Health and Welfare Trust Fund
7. Name of entity, administrator or other third-party who prepared MPN Application on behalf of MPN applicant (if
applicable): Colen & Lee
8. Signature of authorized individual: "1, the undersigned officer or employee of the MPN applicant, have read and signed
this application and know the contents thereof, and verify that, to the best of my knowledge and ability, the information
included in this application is true and correct to
23-583-8811
PhonelEmail
J. -7-oS-
Date Signed
9. Authorized Liaison to DWC:
Bruce Malkenhorst, Sr.
Name
City Administrator
Title
323-583-8811
PhonelEmail
4305 Santa Fe Avenue. Vernon. CA 90058
Address
323-828-1439
Fax number
Submit one original and one copy of this Cover Page for Medical Provider Network Application and one original and one
copy of the Application with the information required by Title 8, California Code of Regulations, section 9767.3 to the
following address: MPN Application, P.O. Box 420603, San Francisco, CA 94142.
[DWC Mandatory Form - Section 9767.4]
Initiated I J /09104
Revised 01-07-05 10 & mpn
Revised 01-14-05 mpn
Medical Provider Network Plan
Table of Contents
Page
Section I Definitions 1
Section II Number of Expected Employees Covered by the MPN Plan 3
Section III Geographic Service Areas(s) to be Served 3
Section IV Provider Information 4
Section V Second, and Third Opinions 4
Section VI 25% of Physicians Primarily Engaged in the Treatment of
Nonoccupational Injuries 6
Section VII Access Standards 7
Section VIII Treatment and Change of Physicians within the MPN 7
Section IX Employee Notification 8
Section X Continuity of Care Policy 9
Section XI Transfer of Ongoing Care Policy 9
Section XII Economic Profiling Policy 10
Section XIII Physician Compensation Affirmation 10
Section XIV Medical Evaluation of Clinical Issues 10
Section XV Modification of Medical Provider Network Plan 10
Initiated 11109/04
Revised 01-07-05 10 & mpr
Revised 01-14-05 mpr
Medical Provider Network Plan'
I. Definitions:
A. As used in this Medical Provider Network (MPN) Plan:
(1) "Administrative Director" shall mean the Administrative
Director of the Division of Workers' Compensation,
Department of Industrial Relations.
(2) "Ancillary services" means any provision of medical services
or goods as allowed in Labor Code section 4600 by a non-
physician.
(3) "Applicant" means the City of Vernon
(4) "Covered employee" means an employee for which the
Applicant has established a Medical Provider Network for the
provision of medical treatment to injured employees unless:
(a) : the injured employee has properly designated a
personal physician pursuant to Labor Code section 4600(d)
by notice to the employer prior to the date of inju,ry, or;
(b) the injured employee's employment with the employer
is covered by an agreement providing medical treatment for
the injured employee and the agreement is validly
established under Labor Code section 3201.5, 3201.7 and/or
3201.81.
(5) "Division" means the Division of Workers' Compensation.
(6) "Economic profiling" shall mean any evaluation of a
particular physician, provider, medical group, or individual
practice association based in whole or in part on the
economic costs or utilization of services associated with
medical care provided or authorized by the physician,
provider, medical group, or individual practice association.
(7) "Emergency health care services" means health care
services for a medical condition manifesting itself by acute
symptoms of sufficient severity such that the absence of
immediate medical attention could reasonably be expected
to place the patient's health in serious jeopardy.
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(8) "Employer" means a self-insured employer, joint powers
authority, or the state.
(9) "Group Disability Insurance Policy" means an entity
designated pursuant to Labor Code section 4616.7(c).
(10) "Health Care Organization" means an entity designated
pursuant to Labor Code section 4616.7(a).
(11) "Health Care Service Plan" means an entity designated
pursuant to Labor Code section 4616.7(b).
(12) "Insurer" means an insurer or group of insurers under
common ownership admitted to transact workers'
compensation insurance in the state of California, or the
State Compensation Insurance Fund.
(13) "Medical Provider Network" ("MPN") means any entity or
group of providers approved as a Medical Provider Network
by the Administrative Director pursuant to the application
filed' by the Applicant.
(14) "Medical Provider Network Plan" means Applicant's detailed
description for a medical provider network which will
accompany the application submitted to the Administrative
Director by Applicant.
(15) "Nonoccupational Medicine" means the diagnosis or
treatment of any injury or disease not arising out of and in
the course of employment.
(16) "Occupational Medicine" means the diagnosis or treatment
of any injury or disease arising out of and in the course of
employment.
(17) "Physician primarily engaged in treatment of
nonoccupational injuries" means a provider who spends
more than 50 percent of his/her practice time providing non-
occupational medical services.
(18) "Primary care physician" means a physician within a medical
provider network designated by the Applicant to treat injured
employees.
(19) "Primary treating physician" means a primary treating
physician within the Applicant's medical provider network
and as defined by section 9785(a)(1).
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(20) "Provider" means a physician as described in Labor Code
section 3209.3 or other provider as described in Labor Code
section 3209.5.
(21) "Residence" means the covered employee's primary
residence.
(22) "Second Opinion" means an opinion rendered by a medical
provider network physician after an in person examination to
address an employee's dispute over either the diagnosis or
the treatment prescribed by the treating physician.
(23) "Taft-Hartley health and welfare fund" means an entity
designated pursuant to Labor Code section 4616.7(d).
(24) "Third Opinion" means an opinion rendered by a medical
provider network physician after an in person examination to
address an employee's dispute over either the diagnosis or
the treatment prescribed by either the treating physician or
phy~ician rendering the second opinion.
(25) "Treating physician" means any physician within the MPN
Applicant's medical provider network other than the primary
treating physician who examines or provides treatment to the
employee, but is not primarily responsible for continuing
management of the care of the employee.
(26) 'Workplace" means the geographic location where the
covered employee is regularly employed.
II. Number of Employees Expected to be Covered by the MPN Plan
340
III. Geographic Service Areas(s) to be Served
The geographic service areas to be served by the MPN include all zip
codes provided in Exhibit A.
IV. Provider Information
A. Exhibit B is a listing of providers as described in Labor Code Section
3209.3 and other providers as described in Labor Code Section 3209.5
who will be providing occupational medicine services under the MPN
Plan. Provider information includes the name, license number,
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taxpayer identification number, specialty and location of each provider.
Applicant confirms that a contractual agreement exists either between
the MPN and the physicians, providers or medical group practice in the
MPN or the Applicant and the physicians, providers or medical group
practice in the MPN.-
B. Exhibit C is a listing of non-physicians who will be providing ancillary
services under the MPN Plan, including the name, license number (if
applicable), taxpayer identification number, specialty or type of service
and location. Applicant confirms that a contractual agreement exists
between the MPN and these ancillary services in the MPN or the
Applicant and these ancillary services in the MPN.
V. Second and Third Opinions
A. If the covered employee disputes either the diagnosis or the
treatment prescribed by the treating physician, the employee may
obtain a second and third opinion from physicians within the MPN.
During this process, the employee is required to continue his/her
treatment with the treating physician or a physician of his or her
choice pursuant to Section VIII of this document. The covered
employee will be instructed to contact his or her MPN contact for a
listing of MPN providers and/or specialists. These instructions are
included in the Employee Handbook.
B. If the covered employee disputes either the diagnosis or the
treatment prescribed by the treating physician, the employee may
obtain a second and third opinion from a physician within the MPN.
It is the employee's responsibility to: (1) inform the Applicant or
person designated by the Applicant that he or she disputes the
treating physician's opinion and requests a second opinion; (2)
select a physician or specialist from a list of available MPN
providers; (3) make an appointment with the second opinion
physician within 60 days; and (4) inform the person designated by
the Applicant of the appointment date. It is the Applicant's
responsibility to: (1) provide a list of MPN providers and/or
specialists to the employee for his/her selection based on the
specialty or recognized expertise in treating the particular injury or
condition in question; (2) contact the treating physician, provide a
copy of the medical records or send the necessary medical records
to the second opinion physician prior to the appointment date and
provide a copy of the records to the covered employee upon
request; and (3) notify the second opinion physician in writing that
he or she has been selected to provide a second opinion and of the
nature of the dispute with a copy to the employee. If the
appointment is not made within 60 days of receipt of the list of the
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available MPN providers, then the employee will be deemed to
have waived the second opinion process with regard to this
disputed diagnosis or treatment of this treating physician.
C. If, after reviewing the covered employee's medical records, the
second opinion physician determines that the employee's injury is
outside the scope of his or her practice, the physician will notify the
Applicant and employee so the Applicant can provide a new list of
MPN providers and/or specialists to the employee for his/her
selection based on the specialty or recognized expertise in treating
the particular injury or condition in question.
D. If the covered employee disagrees with either the diagnosis or
treatment prescribed by the second opinion physician, the injured
employee may seek the opinion of a third physician within the MPN.
It is the employee's responsibility to: (1) inform the Applicant or
person designated by the Applicant that he or she disputes the
treating physician's opinion and requests a third opinion; (2) select
a physician or specialist from a list of available MPN providers; (3)
make an appointment with the third opinion physician within 60
days; and (4) inform the person designated by the Applicant of the
appointment date. It is the Applicant's responsibility to: (1) provide
a list of MPN providers and/or specialists to the employee for
his/her selection based on the specialty or recognized expertise in
treating the particular injury or condition in question; (2) contact the
treating physician, provide a copy of the medical records or send
the necessary medical records to the third opinion physician prior to
the appointment date and provide a copy of the records to the
covered employee upon request; and (3) notify the third opinion
physician in writing that he or she has been selected to provide a
third opinion and of the nature of the dispute with a copy to the
employee. Upon notice of the employee's selection of a third
opinion physician, the MPN Contact will notify the employee of the
independent medical review process (see Exhibit D). If the
appointment is not made within 60 days of receipt of the list of the
available MPN providers, then the employee will be deemed to
have waived the third opinion process with regard to this disputed
diagnosis or treatment of this treating physician.
E. If, after reviewing the covered employee's medical records, the third
opinion physician determines that the employee's injury is outside
the scope of his or her practice, the physician will notify the
Applicant and employee so the Applicant can provide a new list of
MPN providers and/or specialists to the employee for his/her
selection based on the specialty or recognized expertise in treating
the particular injury or condition in question.
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F. The second and third opInion physicians will render his or her
opinion of the disputed diagnosis or treatment in writing and offer
alternative diagnosis or treatment recommendations, if applicable.
Any recommended treatment will be in accordance with Labor
Code section 4616(e). The second and third opinion physicians
may order diagnostic testing if medically necessary. A copy of the
written report will be served on the employee and the person
designated by the Applicant within 20 days of the date of the
appointment or receipt of the results of the diagnostic tests,
whichever is later.
G. If the injured covered employee disagrees with the diagnosis or
treatment of the third opinion physician, the injured employee may
file with the Administrative Director a request for an Independent
Medical Review. Information regarding the covered employee's
right to an Independent Medical Review (IMR) and how an IMR
may be requested and received is included in the MPN Employee
Handbook.. A separate notification letter will also be sent to the
employee llpon notice of the employee's selection of a third opinion
physician. Exhibit D is a sample of IMR notification letter written in
English and Spanish. The notification letter will be given to the
covered employee upon notice of the employee's selection of a
third opinion physician.
VI. 25% of Physicians Primarily Engaged in the Treatment of
Nonoccupational Injuries
The MPN meets the legislative and regulatory requirements that at least
25% of the MPN physicians be primarily engaged in the treatment of non-
occupational injuries based on the following criteria:
It is presumed that if a physician does not declare his/her practice as
Occupational Health Medicine, then the practice contains less than
50% workers' compensation patients. This MPN is composed of 2% of
physicians with a declared practice of Occupational Health Medicine,
and 98% of physicians who do not have a declared practice of
Occupational Health Medicine, thus meeting stated requirements.
VII. Access Standards
Applicant's Medical Provider Network Plan utilizes the Concentra network. The
MPN was built to ensure that access standards are met in accordance with those
outlined in Section 9767.5 of the Emergency Regulations, both for primary care
physicians and for specialists utilized in the treatment of occupational injuries. In
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assessing the access and capacity needs for the MPN, Concentra performed a
number of calculations based on the Bureau of Labor Statistics workforce
estimates by county, assuming a 5% annual incident rate for each county. While
our model assures that we have coverage meeting the mileage access
requirements, Concentra's study also indicates that in the physician portion of the
network alone there is adequate coverage to treat approximately half of the
annual volume of statewide injuries. This assumes that a provider can treat 6
new occupational injuries per day, a statistic that is based on Concentra's
extensive experience in managing over 250 Occupational Medical practices
nationally. This does not include the additional capacity that exists in ancillaries,
including physical therapy, imaging, hospitals, DME, etc. Given that this MPN
will most likely serve less than 20% of the statewide injuries, we believe it has
sufficient capacity in primary care, specialists, ancillaries and hospitals to provide
both geographic coverage and timely access for initial treatment, second and
third opinions, and transfer of care on existing claims.
The attached Exhibit E sets forth the access standards for this MPN, including
but not limited to:
1. access standards for primary care physicians and occupational health
services and specialists;
2. how the covered employee who is temporarily working outside the
MPN's geographical service area will be provided with medical
treatment;
3. how the MPN arranges for providing ancillary services to its covered
employees; and
4. a description of the employee notification process and sample
notification material.
VIII. Treatment and Change of Physicians Within the MPN
A. When the injured covered employee notifies the employer of the
injury or files a claim for workers' compensation with the employer,
an initial medical evaluation with an MPN physician will be arranged
in compliance with the access standards set forth in Exhibit E.
B. Within one working day after an employee files a claim form under
Labor Code section 5401, the Applicant will authorize the provision
of all treatment, consistent with guidelines adopted by the
Administrative Director pursuant to Labor Code section 5307.27 or,
prior to the adoption of these guidelines, the American College of
Occupational and Environmental Medicine's Occupational Medicine
Practice Guidelines (ACOEM). For all injuries not covered by the
ACOEM guidelines or guidelines adopted by the Administrative
Director, authorized treatment will be in accordance with other
evidence based medical treatment guidelines generally recognized
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by the national medical community and that are scientifically based.
The Applicant will authorize the treatment with MPN providers for
the alleged injury and will continue to provide the treatment until the
date that liability for the claim is rejected. Until the date the claim is
rejected, liability for the claim will be limited to ten thousand dollars
($10,000).
C. At any point in time after the initial medical evaluation with an MPN
physician, the covered employee may select a physician of his or
her choice from within the MPN. Selection by the covered
employee of a treating physician and any subsequent physicians
shall be based on the physician's specialty or recognized expertise
in treating the particular injury or condition in question.
D. At the time of referral for initial care, the employee will be notified
by the site coordinator of his or her right to be treated by a
physician of his or her choice within the MPN after the first visit.
The notice will include the method by which the list of participating
providers rT}ay be accessed by the employee.
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IX. Employee Notification
A. Applicant will notify each employee in writing about the use of the
Medical Provider Network Plan as required by Labor Code section
4616.3 prior to the implementation of an approved MPN, at the time
of hire, or when an existing covered employee transfers into the
MPN, whichev~r is appropriate to ensure that the employee has
received the initial notification. The notification will also be sent to
the covered employee at the time of injury. The notification will be
available in English and Spanish. The notification materials will
include the following information:
(1) the name of the person designated by the Applicant to be
the MPN contact for covered employees;
(2) a description of MPN services;
(3) how to review, receive or access the MPN provider directory.
Applicant may initially provide covered employees with a
regional list of providers in addition to maintaining and
making available its complete provider listing;
(4) how to access initial care and subsequent care;
(5) how to choose a physician within the MPN;
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(6) what to do if a covered employee has trouble getting an
appointment with a provider within the MPN;
(7) how to change a physician within the MPN;
(8) how to obtain a referral to a specialist;
(9) how to use the second and third opinion process;
(10) how to request and receive an independent medical review;
(11) a description of the standards for transfer of ongoing care
into the MPN; and
(12) a copy of the continuity of care policy as required by Labor
Code section 4616.2.
B. At the time of the selection of the physician for a third opinion, the
covered employee will be notified about the Independent Medical
Review process. The notification will be written in English and
Spanish. :
C. A covered employee will be notified 30 days prior to a change of
the medical provider network and a copy of the notification will be
provided to the employer. The notification will be written in English
and Spanish.
X. Continuity of Care Policy
At the request of a covered employee, the Applicant will allow for the completion
of the treatment by a terminated provider as set forth in Labor Code section
4616.2(d) and (e). Applicant's Continuity of Care Policy is set forth in the
attached Exhibit F.
XI. Transfer of Ongoing Care Policy
Applicant's Transfer of Ongoing Care Policy is set forth in the attached Exhibit
G.
XII. Economic Profiling Policy
Applicant's Economic Profiling Policy is set forth in the attached Exhibit H.
Con centra affirms a copy of the Economic Profiling Policy has been provided to
all MPN providers.
XIII. Physician Compensation Affirmation
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Applicant does not offer financial incentives to its MPN providers. All medical
decisions will be rendered by qualified health care providers based on medical
necessity and appropriateness of medical care and not based on financial
motivation. In addition, MPN providers are contractually obligated that provider
fees will not exceed the provider's usual and customary rate for health services
and fees will not exceed those charged to nonparticipants. Typical
reimbursement language utilized in provider contracts requires payment to the
provider at the lesser of a certain percentage of the provider's usual and
customary rate, billed charges or maximum fee schedule amount established by
law. Physicians who overbill for services or who make medical decisions based
on financial gain will be reviewed and removed from the MPN, as appropriate.
XIV. Medical Evaluation of Clinical Issues
Describe how the Applicant will ensure that no person other than a licensed
physician who is competent to evaluate the specific clinical issues involved in the
medical treatment services, when these services are within the scope of the
physician's practice, will modify, delay, or deny requests for authorization of
medical treatment. Applicant will incorporate Utilization Review program into the
MPN program. .
XV. Modification of Medical Provider Network Plan
A. The Applicant will notify the Administrative Director on the
appropriate state form before any of the following changes occur:
(1) A change of 10% or more in the providers participating in the
network.
(2) A material change in the continuity of care policy.
(3) Change in policy or procedure that is used by the Applicant
to conduct "economic profiling of MPN providers" pursuant to
Labor Code section 4616.1.
(4) Change in the name of the MPN.
(5) Change in geographic service area.
(6) Change in how the MPN complies with the access
standards.
B. If the Applicant elects to change to a new MPN, the Applicant will
file a new application for a medical provider network plan for
approval.
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C. The Applicant will notify the Administrative Director on the
appropriate state form within 5 business days of a change of the
DWC liaison.
D. If the Administrative Director has not acted on a plan within 60 days
of submittal of a Notice of MPN Plan Modification, the Applicant will
act according to the Notice of MPN Plan Modification as if it had
been deemed approved. If, within 60 days of the Administrative
Director's receipt of a Notice of MPN Plan Modification, the
Administrative Director disapproves the plan change based on
information provided in the Notice of MPN Plan Modification, the
Applicant may work with the Administrative Director to address any
perceived concerns. With the exception of a change in the MPN
name or DWC liaison, modifications will not be made until the
Administrative Director has approved the plan modification or until
60 days have passed, which ever occurs first. If the Administrative
Director disapproves the MPN plan modification, he or she will
serve the Applicant with a Notice of Disapproval within 60 days of
the submittal of a Notice of MPN Plan Modification.
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E. If Applicant is denied approval of a MPN plan modification, it may,
but is not required to, pursue either of the following options:
(1) Submit a new request addressing the deficiencies; or
(2) Request reconsideration by the Administrative Director.
F. Applicant may, but is not required to, seek further review of the
Administrative Director's decision by filing an appeal with the
Workers' Compensation Appeals Board, and serving a copy on the
Administrative Director, within twenty days after receipt of the
decision.
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Exhibit A
(See Complete Document in the. City Clerk's Office)
ezIP CODES
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Exhibit B
(See Complete Document in the City Clerk's Office)
LIST OF PROVIDERS FOR OCCUPATIONAL
MEDICINE SERVICES
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Exhibit C
(See Complete Document in the City Clerk's Office)
LIST OF NON-PHYSICIANS PROVIDING
ANCILLARY SERVICES
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Exhibit D
(See Complete Document in the City Clerk's Office)
SAMPLE INDEPENDENT MEDICAL REVIEW NOTIFICATION
LETTER
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Exhibit E
(See Complete Document in the City Clerk's Office)
ACCESS,STANDARDS FOR MEDICAL PROVIDER NETWORK
ATTACHMENT I:
SAMPLE MPN EMPLOYEE HANDBOOK)IN ENGLISH AND SPANISH
ATTACHMENT~; Continuity of Care Policy
ATTACHMENT II: Transfer of Ongoing Care Policy
ATTACHMENT II: SITE COORDINATOR GUIDE
ATTACHMENT I:
ATTACHMENT II:
Transfer of Ongoing Care Policy
Continuity of Care Policy
.
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Revised 1-7-05
1-12-05
1/J.4/05
.-..
Exhibit F
(See Complete Document in the City Clerk's Office)
VERNON'S CONTINUITY OF CARE POLICY
.
.
1
MPN Plan
11/9/04
Revised 117/05
1/12/05
1/14/05
, .
Exhibit G
(See Complete Document in the City Clerk's Office)
TRANSFER OF ONGOING CARE POLICY
1
MPN Plan
11/9/04
Revised 117105
1/12/05
1/14/05
j: .' '" '"
~
.
~
, f
Exhibit H
(See Complete Document in the City Clerk's Office)
ECONOMIC PROFILING_POLICY
.
.
1
MPN Plan
11/9/04
Revised 117105
1/12/05
1/14/05