CONTRACT COMPLIANCE Linda Pierce Serena Crites DCS Contract - - PowerPoint PPT Presentation

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CONTRACT COMPLIANCE Linda Pierce Serena Crites DCS Contract - - PowerPoint PPT Presentation

Dec 07, 2023 238 likes •736 views

CONTRACT COMPLIANCE Linda Pierce Serena Crites DCS Contract Compliance Clauses: Background Checks Insurance policies Non-discrimination policies Proper staff training and qualifications (including any licenses) Valid

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CONTRACT COMPLIANCE

Linda Pierce Serena Crites

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Children thrive in safe, caring, supportive families and communities

DCS Contract Compliance

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  • 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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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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DCS Invoice Validation

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  • Do they match? Case, Service, Date, Duration?
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DCS Contract Types

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Community Based Services – services provided primarily in the family’s home or community

Casework Therapy Diagnostic & Evaluation tests Drug Screens Supervised Visitation Parent Education Substance Use Treatment Homemaker Tutoring

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DCS Contract Types

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Residential Facilities – services/placement provided for children removed from homes Emergency Shelters Group Homes Child Caring Institutions Private Secure Facilities

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DCS Contract Types

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Licensed Child Placing Agency – business that trains and provides support for foster families

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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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2013 Special Review

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2013 Special Review

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2013 Special Review

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DCS Contract Compliance

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Therapist: Jane Doe Company: “Business”

FAMILY A THERAPY – 2 HRS MONDAY MORNING THERAPY – 2 HRS WEDNESDAY MORNING FAMILY B THERAPY – 2 HRS MONDAY AFTERNOON THERAPY – 2 HRS WEDNESDAY AFTERNOON FAMILY C THERAPY – 2 HRS TUESDAY MORNING THERAPY – 2 HRS THURSDAY MORNING FAMILY D THERAPY – 2 HRS TUESDAY AFTERNOON THERAPY – 2 HRS THURSDAY AFTERNOON TOTAL = 16 HRS (plus drive time)

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DCS Contract Compliance

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Visit Facilitator: JANE DOE Company: “The Agency”

FAMILY E VISIT – 2 HRS MONDAY MORNING VISIT – 2 HRS WEDNESDAY MORNING FAMILY F VISIT – 2 HRS MONDAY AFTERNOON VISIT – 2 HRS WEDNESDAY AFTERNOON FAMILY G VISIT – 2 HRS TUESDAY MORNING VISIT – 2 HRS THURSDAY MORNING FAMILY H VISIT – 2 HRS TUESDAY AFTERNOON VISIT – 2 HRS THURSDAY AFTERNOON TOTAL = 16 HRS (plus drive time)

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DCS Contract Compliance

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Residential Therapist: JANE DOE Company: “The Honest Co.”

FAMILY 1 - VISIT – 1 HR MONDAY MORNING FAMILY 2 - VISIT – 1 HR MONDAY MORNING FAMILY 3 - VISIT – 1 HR MONDAY AFTERNOON FAMILY 4 - VISIT – 1 HR MONDAY AFTERNOON FAMILY 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 AFTERNOON FAMILY 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 AFTERNOON GROUP A - 1 HR MONDAY AFTERNOON GROUP B - 1 HR TUESDAY AFTERNOON GROUP C – 1 HR THURSDAY AFTERNOON GROUP 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
  • f 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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Example

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  • DCS Service Referral to Provider A

–Visitation Facilitation

Donna Joe

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Example

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  • DCS Service Referral to Provider B

–Home Based Casework

Susie Jones

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Example

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  • John Smith reports being with both

families on the same day.

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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 between 40%-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 2016 Over 350 providers were notified that they would be party to a contract compliance review October 2016 Initial letters requesting personnel information sent

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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DCS Contract Review

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If you have any questions about our processes or this project, please contact us: Linda.Pierce3@DCS.IN.GOV Serena.Crites@DCS.IN.GOV