Workplace Inclusion & Sustainable Employment Ethical - - PowerPoint PPT Presentation

Workplace Inclusion & Sustainable Employment

Ethical Implications of Monitoring Reviews

January 2015

Workplace Inclusion & Sustainable Employment

• Ethical principles
• Fidelity – keeping promises
• Veracity – be honest
• Code of ethics
• CRC
• LPC
• LMSW
• State and federal law

Professional Ethics and Contract Compliance

Workplace Inclusion & Sustainable Employment

Objectives

• 1. Identify and understand the purpose of

monitoring reviews.

• 2. List the most common monitoring findings

from employment service contract reviews.

• 3. Describe the possible outcomes when

unethical conduct or contract non- compliance is a finding.

• 4. Recognize methods and strategies to comply

with our contract and provide high quality consumer services.

Workplace Inclusion & Sustainable Employment

David Johnston, DRS Program Manager, Consumer Services Lynn Lemky, DARS Monitoring Team Lead, Contract Oversight and Support Sue-Ellen Woodlief, DRS Program Specialist for Community Rehabilitation Programs

Panel Experts

Workplace Inclusion & Sustainable Employment

What is the purpose of monitoring?

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• Accountability
• Performance
• Here to Stay

Emphasis of the State of Texas

Workplace Inclusion & Sustainable Employment

Determine compliance with

– policies & procedures in DRS Standards for Providers – contract terms and conditions; federal and state laws and regulations

Monitors

– quality of services consumers are receiving – expenditure of taxpayer monies

Identifies

– need for technical assistance – need for corrective action

DARS Focus

Workplace Inclusion & Sustainable Employment

What is the difference between quality services and contract/standards compliance?

Workplace Inclusion & Sustainable Employment

Demonstration of

• person centered decision making involving the

consumer, counselor, provider and other supports of the consumer;

• active participation of the consumer and provider

and when applicable, the counselor;

• following all policies and standards; and
• achievement of individual outcomes set for a

consumer.

Quality Services

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Demonstration and documentation of

• Service delivery that achieves all required outcomes

necessary for payment as prescribed in the provider’s contract, in the Standards for Providers and documentation on the forms.

Contract and Standards Compliance

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Specific questions about DARS Forms or Standards should be emailed to:

DARSstandards@dars.state.tx.us

Workplace Inclusion & Sustainable Employment

Questions

Workplace Inclusion & Sustainable Employment

• Formal monitoring
• Informal monitoring
• Process, documentation and

consumer case monitoring

How does monitoring occur?

• Monitoring contractor performance is a key function of proper

contract administration

• Systematic review of contractor records, business processes,

deliverables, and activities

• Goal of contract monitoring
• Protect the health and safety of clients that receive services
• Ensure delivery of quality goods and services
• Protect the financial interest of the State
• DARS is made aware of and able to addresses developing issues
• Need for & level of contract oversight varies by contract type

and risk level

Formal monitoring

• Comprehensive Reviews
• programmatic (consumer’s file review)
• financial / administrative
• staff qualifications
• physical facility (if services are delivered at a facility)
• Onsite or desk reviews
• Minimum 12-month review period
• Checklists mirror the Standards Manual and contract
• Cross-section of team members within DARS

Formal monitoring - continued

• Oversight of Contractor Performance is an Essential

Agency Responsibility

• The Process Begins with the Ongoing Review of Routine

Documentation Received from the Contractor.

• DARS Staff will be Sensitive to Issues Impacting

Contract Deliverables, Compliance with State Requirements, Confidentiality of Consumer Data, the Overall Service Delivery Process and Effective Use of Funds.

• The Goal is to Establish Effective Routines at the Start of

the Contract and then to Sustain them throughout the Contract Lifecycle.

Informal monitoring

• DARS Verifies instructions were followed and all sections of

the DARS forms (all questions answered) are complete and accurate.

• DARS verifies that all deliverables are achieved as required.
• Standards for Providers defines the service descriptions, staff

qualifications, process, outcomes for payment (deliverables) and fees.

• Reviewing the “DARS Only” Section of forms can be used as

a tool for the provider to ensure compliance with the Standards for Providers.

Process, documentation and consumer case monitoring

Workplace Inclusion & Sustainable Employment

• Formal monitoring
• Informal monitoring
• Process, documentation and

consumer case monitoring What are the possible outcomes of a monitoring activity?

• No Findings Identified
• Technical Assistance
• Identification of Areas of Non-compliance
• Report of Findings
• Repayment of identified overpayments
• Notice of Appeal Rights
• Corrective Action Plan (CAP)
• Final Report

Formal monitoring

• Help Pro-actively Avoid the Occurrence of

Findings

• Engagement with and Support (Technical

Assistance) for Contractors Helps Sustain Service Capacity and Can Also Enhance Services

• At the Point of Service Level, Helps Identify

Potential Areas of Non-compliance Earlier in the Process

Informal monitoring

DARS staff may return copies of invoices and associated documentation for the following reasons:

• documentation is not complete
• when unable to verify such things as outcomes for

payment of service(s), employment status, consumer’s satisfaction, and employer's satisfaction

• unable to verify the staff’s qualifications such as UNTWISE

Credentials

Process, documentation and consumer case monitoring

• Formal monitoring
• Informal monitoring
• Process, documentation and

consumer case monitoring

What are the most common issues related to employment service monitoring activities?

• Invoices
• Incomplete and or inaccurate
• Service Authorizations
• Missing or invalid / expired
• Supporting Documentation
• Lacked all required information
• Not in consumer file
• Billing / Payments
• Not consistent with supporting documentation
• Inaccurate
• P & Ps
• Incomplete / inaccurate / missing

Formal monitoring

• Catching Incorrect or Incomplete Invoices with Missing

Data

• Establishing Good Habits Regarding Filing of Service

Authorizations and Follow-up on Instances in Which the Service Authorizations have not been Received or Updated

• Reports Need to Provide the Required Information

Necessary to Help Counselors Provide Services

Informal monitoring

• Referral forms not completed
• Goals, Employment Conditions are not achieved
• Services not leading to a successful closure of the consumer’s case
• Services not individualized
• Incomplete or inaccurate documentation
• Proof that the
• person centered decision making process involved the consumer,

counselor, provider and other supports of the consumer;

• consumer and provider and when applicable, the counselor, actively

participated;

• all policies and standards were followed; and
• individual outcomes set for the consumer were achieved

Process, documentation and consumer case monitoring

Workplace Inclusion & Sustainable Employment

Questions

• Keeping up to date with the standards and

forms

• Continuing education
• Document corrective actions on identified

noncompliance areas

• Seek guidance from DARS Program Specialist

for Quality Assurance

What strategies would you suggest to implement to stay compliant?

• Conflict of Interests
• Enhanced confidentiality and record keeping compliance
• Changes with regard to the VR program move to the

Texas Workforce Commission

• Changes with regard to the VR program due to federal

regulations

Emerging Topics

Region 1: Mike Lawson mike.lawson@dars.state.tx.us (806) 783-2982 Region 2: Jesus Quiroga jesus.quiroga@dars.state.tx.us (817) 436-4103 Region 3: Paula Brunson paula.brunson@dars.state.tx.us (512) 407-1339 Region 4: Stephanie Jenkins Stephanie.jenkins@dars.state.tx.us (713) 267-8546 Region 5: Andrew Ramirez Andrew.ramirez@dars.state.tx.us (210) 805-2220

If I am in doubt, with whom should I consult?

1/20/2016 31

Specific questions about DARS Forms or Standards should be emailed to:

DARSstandards@dars.state.tx.us

If I am in doubt, with whom should I consult?

Workplace Inclusion & Sustainable Employment

Questions