contract compliance - in.gov presentation2.pdfgroup d – 1 hr thursday afternoon total = 16 hrs....
TRANSCRIPT
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CONTRACT COMPLIANCE
Linda PierceSerena Crites
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Children thrive in safe, caring, supportive families and communities
DCS Contract Compliance
2
• Clauses:– Background Checks– Insurance policies– Non-discrimination policies – Proper staff training and qualifications
(including any licenses)– Valid sub-contracts– Drug-Free, Smoke-Free– Required reporting– Secure case file documentation practices
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Children thrive in safe, caring, supportive families and communities
DCS Service Standards
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• Proper curriculum• Reporting requirements• Minimum qualifications for Direct Worker• Minimum qualifications for Supervisor• Proper setting (clinical, community, home-based, etc.)• Case file documentation
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Children thrive in safe, caring, supportive families and communities
DCS Invoice Validation
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• Do they match? Case, Service, Date, Duration?
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Children thrive in safe, caring, supportive families and communities
DCS Contract Types
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Community Based Services– services provided primarily
in the family’s home or communityCaseworkTherapyDiagnostic & Evaluation testsDrug ScreensSupervised VisitationParent EducationSubstance Use TreatmentHomemaker Tutoring
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Children thrive in safe, caring, supportive families and communities
DCS Contract Types
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Residential Facilities– services/placement provided for children
removed from homes
Emergency Shelters Group HomesChild Caring InstitutionsPrivate Secure Facilities
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Children thrive in safe, caring, supportive families and communities
DCS Contract Types
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Licensed Child Placing Agency– business that trains and provides
support for foster families
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Children thrive in safe, caring, supportive families and communities
DCS Regions
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DCS Contract Compliance
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Contract Compliance Audit Results
• 4 years, 400+ audits
• Compliance issues resolved
• $1.3M recovered
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Children thrive in safe, caring, supportive families and communities
2013 Special Review
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Children thrive in safe, caring, supportive families and communities
2013 Special Review
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Children thrive in safe, caring, supportive families and communities
2013 Special Review
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DCS Contract Compliance
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Therapist: Jane DoeCompany: “Business”
FAMILY ATHERAPY – 2 HRS MONDAY MORNINGTHERAPY – 2 HRS WEDNESDAY MORNING
FAMILY BTHERAPY – 2 HRS MONDAY AFTERNOONTHERAPY – 2 HRS WEDNESDAY AFTERNOON
FAMILY CTHERAPY – 2 HRS TUESDAY MORNINGTHERAPY – 2 HRS THURSDAY MORNING
FAMILY DTHERAPY – 2 HRS TUESDAY AFTERNOONTHERAPY – 2 HRS THURSDAY AFTERNOON
TOTAL = 16 HRS (plus drive time)
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DCS Contract Compliance
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Visit Facilitator: JANE DOECompany: “The Agency”
FAMILY EVISIT – 2 HRS MONDAY MORNINGVISIT – 2 HRS WEDNESDAY MORNING
FAMILY FVISIT – 2 HRS MONDAY AFTERNOONVISIT – 2 HRS WEDNESDAY AFTERNOON
FAMILY GVISIT – 2 HRS TUESDAY MORNINGVISIT – 2 HRS THURSDAY MORNING
FAMILY HVISIT – 2 HRS TUESDAY AFTERNOONVISIT – 2 HRS THURSDAY AFTERNOON
TOTAL = 16 HRS (plus drive time)
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Residential Therapist: JANE DOECompany: “The Honest Co.”
FAMILY 1 - VISIT – 1 HR MONDAY MORNINGFAMILY 2 - VISIT – 1 HR MONDAY MORNINGFAMILY 3 - VISIT – 1 HR MONDAY AFTERNOONFAMILY 4 - VISIT – 1 HR MONDAY AFTERNOONFAMILY 5 - VISIT – 1 HR TUESDAY MORNING FAMILY 6 - VISIT – 1 HR TUESDAY MORNING FAMILY 7 - VISIT – 1 HR TUESDAY AFTERNOON FAMILY 8 - VISIT – 1 HR TUESDAY AFTERNOONFAMILY 9 - VISIT – 1 HR WEDNESDAY MORNING FAMILY 10 - VISIT – 1 HR WEDNESDAY MORNING FAMILY 11 - VISIT – 1 HR THURSDAY AFTERNOON FAMILY 12 - VISIT – 1 HR THURSDAY AFTERNOONGROUP A - 1 HR MONDAY AFTERNOONGROUP B - 1 HR TUESDAY AFTERNOON GROUP C – 1 HR THURSDAY AFTERNOONGROUP D – 1 HR THURSDAY AFTERNOON
TOTAL = 16 HRS
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DCS Contract Compliance
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• 16 hours
• 16 hours
• 16 hours
• TOTAL = 48 HRS
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DCS Contract Compliance
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• Services provided and billed correctly?
• Impact to families?• Case overload?• How would the providers be aware
of an employee were doing this? • Financial impact to DCS and
taxpayers?
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PHASE 2
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• Two regions selected • Personnel information requested of all providers
within that region for three contract types– Community Based Services– Residential Facilities– Licensed Child Placing Agency
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PHASE 2
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RESULTS:
• 200+ shared employees working for over 40 agencies
• Reviewed reports from 67 workers
• Over 75% had submitted fraudulent reports
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DCS Contract Compliance
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• Is this really a bigger problem?– Probably…
• So now what?– Data reported to the decision makers of DCS and the
decision was made to conduct a statewide investigation including more contract types
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DCS Contract Review
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DCS Decision Makers:• Purchasing and Pricing• Services and Outcomes• Placement Support and Compliance• Legal Department• Health Services• Program Policy• Internal Affairs• Executive Office
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DCS Contract Types
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• Community Based Services• Residential Facilities• LCPA• Older Youth Services• Healthy Families• Home Builders• Youth Service Bureaus• Community Mental Health Centers• Child Advocacy Centers • Adoption Services
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DCS Contract Types
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We need to widen the scope!
What is the impact statewide?
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Children thrive in safe, caring, supportive families and communities
Example
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• DCS Service Referral to Provider A– Visitation Facilitation
Donna Joe
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Children thrive in safe, caring, supportive families and communities
Example
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• DCS Service Referral to Provider B– Home Based Casework
Susie Jones
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Children thrive in safe, caring, supportive families and communities
Example
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• John Smith reports being with both families on the same day.
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Children thrive in safe, caring, supportive families and communities
Example
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Ini
• Both agencies bill DCS for John Smith’s services on the same day.
INVOICE TO DCS
$$
INVOICE TO DCS
$$
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Memorandum of Understanding
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DCS Contract Review
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• Results from DOR data:
– Approximately 50,000 employees reported via W-2
– 26% of the 358 providers had employees shared with another provider.
– 1099 (subcontracted employees) were between40%-50% more likely to have this issue.
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DCS Contract Review
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• IS THIS A BIGGER PROBLEM?
Highly Probable!
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DCS Contract Review
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September 2016Over 350 providers were notified that they would be party to a contract compliance review
October 2016Initial letters requesting personnel information sent
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DCS Contract Review
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