1. County Behavioral Health Directors Association of California All Members Meeting June 11, 2015

2. WELCOME AND INTRODUCTIONS
Dina Kokkos-Gonzales, Chief Mental Health Services Division
Department of Health Care Services
Lanette Castleman, Chief
Program Oversight and Compliance Branch Mental Health Services Division
Shelly Osuna, Chief
Policy Section
Mental Health Services Division
Autumn Boylan, Chief
Compliance Section

3. Agenda Overview Presentation and Discussion Q&A
1915(b) Specialty Mental Health Services Waiver Renewal
Areas of Focus
Program Oversight and Compliance
Quality Improvement Efforts
Q&A

4. 1915(b) Specialty Mental Health Services Waiver
Dina Kokkos-Gonzales, Chief
Mental Health Services Division
Shelly Osuna, Chief
Policy Section

5. Section 1915(b) Freedom of Choice
Federal Requirements Waived:
Freedom of Choice: Each beneficiary must have a choice of providers
Statewideness: Benefits must be available throughout the state
Comparability of Services: Services must be comparable for individuals (i.e., equal in amount, scope, duration for all beneficiaries in a covered group)

6. Section 1915(b) Freedom of Choice
Section 1915(b) Waiver Authority:
Allows states to implement managed care delivery systems, or otherwise limit individuals’ choice of provider
May not be used to expand eligibility to individuals not eligible under the approved Medicaid state plan
Cannot negatively impact beneficiary access, quality of care of services, and must be cost effective

7. Medi-Cal State Plan
The official contract between the Single State Medicaid Agency (DHCS) and CMS by which a state ensures compliance with federal Medicaid requirements to be eligible for federal funding.
Developed by DHCS and approved by CMS.
Describes the nature and scope of Medicaid programs and gives assurances that it will be administered in accordance with the requirements of Title XIX of the Social Security Act, Code of Federal Regulations, and other applicable federal/state policies.

8. Statutes and Regulations
Title 42, Code of Federal Regulations
California Welfare and Institutions Code commencing with et seq.
Title 9, California Code of Regulations, chapter 11, Medi-Cal Specialty Mental Health Services, commencing with et seq.

9. Mental Health Plan Contract
Contract required pursuant to state and federal law.
Delineates the MHP’s and DHCS’ responsibilities and requirements in the provision and administration of Specialty Mental Health Services.
Conforms with federal requirements for Prepaid Inpatient Health Plans (PIHPs). MHPs are considered PIHPs and must comply with federal managed care requirements (Title 42, CFR, Part 438).
Current MHP contract term: May 1, 2013-June 30, 2018.

10. 1915 (b) SMHS Waiver Sections (A-D)
Section A: Program Description
Describes the delivery system, geographic areas served, populations served, access standards, quality standards, and program operations (e.g. marketing, enrollee rights, grievance system, etc.)
Section B: Monitoring Plan
Describes the monitoring activities planned for the upcoming waiver term
Section C: Monitoring Results
Describes monitoring results for the most recent waiver term
Section D: Cost Effectiveness
Projects waiver expenditures for the upcoming
waiver term

11. 1915(b) SMHS Waiver Renewal
Current SMHS waiver term: July 1, 2013—June 30, 2015
1915(b) SMHS Waiver stakeholder meeting was held on March 2, 2015.
SMHS Waiver Renewal Application was submitted to Centers for Medicare and Medicaid Services (CMS) on March 30, 2015.
CMS has 90 days to approve, disapprove, or request additional information (RAI).
Currently responding to informal questions and negotiating special terms and conditions.

12. CMS Areas of Focus
CMS reviews MHP triennial and EQRO reports and has raised concerns about the findings and continued non-compliance with specific requirements.
CMS expects significant improvement in identified areas and expects the state to closely monitor, ensure and provide evidence of compliance.
CMS has directed DHCS to establish a process to enact fines, sanctions and penalties, and corrective actions as a way to ensure compliance.
CMS is focusing on coordination of Care between Mental Health Plans and Managed Care Plans.

13. Areas Requiring Improvement
24/7 telephone line with appropriate language access ~ Pursuant to title 9, section (c) and (d), MHPs are required to:
Provide a statewide, toll-free telephone number 24 hours a day, seven days per week.
Toll-free line must have language capability in all languages spoken by beneficiaries in the county. 
Provide required information on how to access specialty mental health services and provide information on problem resolution and fair hearing processes.

14. Areas Requiring Improvement
System in place to track timeliness of access across the plan ~ The MHPs must have an organized system to track the timeliness of beneficiary access to services across the MHP. Increase efforts to:
Establish and measure uniform statewide standards specific to access of SMHS.
Ensure beneficiaries are receiving timely access to services (Increased focus on children and EPSDT)
TARs adjudicated in 14 days ~Title 9, Section requires the MHP to approve or deny a Treatment Authorization Request (TAR) within 14 calendar days. The goal is to establish a specific metric for TAR adjudication as one of the statewide standards.

15. Areas Requiring Improvement
System in place to log grievances and appeals, name, date, and issue ~ CCR title 9, section (d)(1) requires that MHPs maintain a grievance and appeal log that contains the beneficiary’s name, date, and nature of the problem. 
System in place to ensure providers are certified and recertified ~ CCR title 9, section (d)(e) requires MHPs to certify and recertify Medi-Cal providers within established timeframes to ensure beneficiaries are provided with specialty mental health services that meet program requirements and that providers are qualified to provide services.
Disallowance rates ~ CMS has expressed concern about the ongoing elevated inpatient and outpatient disallowance rates resulting from chart reviews.

16. Program Oversight and Compliance
Lanette Castleman, MHPA, Chief,
Program Oversight and Compliance Branch
Autumn Boylan, Chief
Compliance Section

17. Regulatory Authority
California Code of Regulations, title 9, chapter 11, section : Oversight Authority The MHPs shall be subject to state oversight, including the following: 1) Reviews of program and fiscal operations of each MHP to verify that services are medically necessary…
2) Monitoring compliance with problem resolution process requirements…
3) Monitoring provider contracts…
4) Monitoring denials of MHP payment authorizations.
If the Department determines that an MHP is out of compliance with State or Federal laws and regulations or the terms of the contract between the MHP and the Department, the Department requires that the MHP develop a plan of correction and other actions as described in title 9, State Oversight and may conduct a focused review if significant issues are identified.

18. Annual Review Protocol
Section A
ACCESS
Section B
AUTHORIZATION
Section C
BENEFICIARY PROTECTION
Section D
FUNDING, REPORTING & CONTRACT REQUIREMENTS
Section E
TARGET POPULATIONS AND ARRAY OF SERVICES
Section F
INTERFACE WITH PHYSICAL HEALTHCARE
Section G
PROVIDER RELATIONS
Section H
PROGRAM INTEGRITY
Section I
QUALITY IMPROVEMENT
Section J
MENTAL HEALTH SERVICES ACT
Section K
CHART REVIEW: NON-HOSPITAL
Section L 
CHART REVIEW—SD/MC HOSPITAL SERVICES

19. Summary of Prior Years Compliance Review Findings
Short Doyle Inpatient Chart Reviews
Outpatient Chart Reviews
Triennial System Reviews

20. Short Doyle Inpatient Disallowance Rates for Acute & Administrative Days Fiscal Years 2008-2014
# of Hospitals Reviewed
% of Acute Days Disallowed
% of Administrative Days Disallowed
% of Total Days Disallowed 6
56%
40%
52% 5
57%
70%
59% 7
50%
65%
49%
78%
55%
46%
89%
53%
54%
Averages
This table shows a small decline in the percentage of acute days disallowed during inpatient reviews since FY 2009/10 with a significant rise in FY 2013/14. The table also shows a marked increase in the percentage of administrative days disallowed since FY 2008/09 reaching the highest point in FY 2011/12 and 2012/13 followed by a marked decrease in disallowances in FY 2013/14. The average rates of disallowance for acute days, administrative days, and total days for this six-year period are 53%, 65% and 55%, respectively. The sample size for inpatient reviews are sixty beneficiaries drawn at random.

21. Outpatient Chart Review Disallowance Rates Fiscal Years 2007-2014
# of MHPs Reviewed
# of Claims reviewed
# of Claims Disallowed
Avg % of Claims Disallowed 20
5101
1207
27% 17
4059
790
22% 15
3855
1145 19
6454
1701
26%
6286
2181
36%
7439
3508
46%
Averages 18
5532
1755
31%
This table shows a continued increase of disallowance rates since FY For all FYs shown, the audit sample consisted of 10 or 20 Medi-Cal beneficiaries, depending on the size of the county population and is made up of 50% adult and 50% children/adolescent beneficiaries. The random sample is drawn from the most recent three month period for which paid claims data is complete.

22. Disallowance Rates for Day Treatment Intensive (DTI) & Day Rehabilitation (DR)
Total # of DTI / DR Claims
# of DTI / DR Disallowed Claims
Average % of DTI / DR Disallowed Claims
Average % of DTI / DR of TOTAL Disallowed Claims
2011/12
DTI / DR
DTI: 1034
DR: 43
DTI: 653
DTI: 80%
DR: 100%
DTI: 34%
DR: 26%
TOTAL
1077
696
90%
30%
2012/13
DTI: 1086
DR: 90
DTI: 601
DR:44
DTI: 55%
DR: 49%
DTI: 28%
DR:2%
1176
645
52%
15%
2013/14
DTI/ DR
DTI: 638
DR: 362
DTI: 630
DR: 359
DTI: 99%
DR: 99%
DTI: 18%
DR: 10%
1000
989
99%
14%
This table indicates an average of 90% of DTI and DR claims were disallowed in FY 2011/12; 49% in FY 12/13; and 99% in FY 13/14. Primary reasons for disallowances of DTI and DR claims include lack of required service components, no documentation of attendance, absence of required progress notes, medical necessity not substantiated and program did not meet Medi-Cal certification requirements. It is noted that of the total disallowed claims, including claims other than DTI/DTR the average number of DTI/DTR claims disallowed out of the total claims disallowed decreased significantly between FY 2011/12 and FY 2012/13 with another slight decrease in FY 13/14.

23. Triennial MHP Review System & Chart Protocol Items Out of Compliance Fiscal Years 2007-2014
# of MHPs Reviewed
Total # of Items in the Annual Protocol
Total # of Protocol Items Out of Compliance in FY
Average % Out of Compliance
% Range Out of Compliance 20
206
503
12%
3% - 37% 18
123
428
19%
6% - 54%
106
302
16%
7% - 31%
114
337
17%
7% - 48% 17
131
557
25%
10% - 62% 19
233
11%
3% - 29%
Averages
132
393
6% - 44%
This table shows the out of compliance percentage rates for the Triennial review system and outpatient chart protocol items of which Plans of Correction(s) were required to be developed by the MHPs. The table shows that in FY the total number of items in the Triennial review Protocol was reduced. Several items were moved to an Attestation process in which the MHP Director or designee attests to compliance with specific regulatory requirements. Following FY the number of protocol items has varied slightly to reflect DHCS/MHP contractual requirements, the addition of CMS Plans of Correction protocol items and other regulatory requirements.

24. Triennial Review Findings: CMS Comments
CMS reviewed fourteen (14) DHCS Compliance Triennial Review reports for FY and and continues to receive copies of all triennial review reports. In their review CMS identified the following out of compliance protocol items as areas of concern:
 1) Chart issues:
“Out of the 14 counties reviewed, error rates for chart reviews ranged from 5% to 75%.”
“10 counties were without compliant client plans.” (Note: Mental health services rendered were not covered by a client plan, client plan did not meet requirements  and /or there was no documentation of beneficiary participation in development of their client plan or signature on the plan.)
Compliance issues not directly related to chart reviews include: 
9/14 counties did not have a 24/7 toll free line with appropriate language access.
3/14 counties were not approving or denying Treatment Authorization Requests (TARs) within the mandated 14 days of receipt.
4/14 counties had no system in place to track requests for grievances or were missing required elements on their grievance logs.
In some cases findings had been the same for 3 years before the last triennial review.

25. Changes to System Review Protocol
The FY 14/15 Annual Review Protocol was revised in an effort to tell a more accurate story about the compliance data. Recommendations from CBHDA were received and with approval from the CAC, revisions were made:
In general, where in the past there were multiple questions within one question, these have been split out into individual questions.
Where possible, a rating of Partial Compliance has been added based on number/percent in or out of compliance instead of these questions resulting in an MHP either being fully in or fully out of compliance.

26. Changes to System Review Protocol
Specifically, the partial compliance designation has been implemented for the following requirements:
Section A: Access
Statewide, toll-free 24/7 access number
Written log of initial requests for Specialty Mental Health Services
Section B: Authorization
Treatment Authorization Requests (TARs)
Day Treatment and Day Rehab authorizations
Standard and expedited authorizations
Section C: Beneficiary Protection
Grievances, appeals, and expedited appeals log
Notification of beneficiaries, or their representatives, of grievance, appeal and/or expedited appeal dispositions

27. Triennial MHP Review System Review Protocol Items Partial Compliance Fiscal Years 2014-2015
Protocol Item with Partial Compliance Designation
# of MHPs Receiving In Compliance Rating
# of MHPs Receiving Out of Compliance Rating
# of MHPs Receiving Partial Compliance Rating
Average % of Partial In- Compliance
Average % of Partial Out-Of-Compliance
% Range of Partial Compliance
Section A: 9a2 4 10
56%
44%
17-83%
Section A: 9a3 3 11
55%
45%
20-83%
Section A: 9a4 6
50%
Section A: 10a 1 2
47%
53%
14-80%
Section A: 10b
54%
46%
Section A: 10c
Section B: 1c 8
90%
10%
56-97%
Section B: 4a
89%
11%
83-94%
Section G: 2 7
82%
18%
55-95%
This table represents preliminary findings from the Fy triennial reviews. A total of 19 MHPs are scheduled for System Reviews in FY14/15. To date, review findings have been compiled for 14 MHPs. Data reflected in this table are preliminary and are subject to change once review findings are finalized. Data is provided as a means to demonstrate changes in compliance ratings after implementation of the new partial compliance ratings for select protocol items.

28. DHCS Process Improvements
Improving quality and substance of compliance findings reports
Developing skills and knowledge of new staff
Building consistency and inter-rater reliability amongst review team members
Enhancing collaboration between POCB and County Support

29. POCB Clinical Team
Since January 2015, the Program Oversight and Compliance Branch (POCB) has three (3) new clinical staff and as such currently has five (5) full-time clinicians, along with one (1) Retired Annuitant and contractors, that are dedicated to clinical compliance activities.
Clinical team activities include:
Making protocol updates related to CBHDA recommendations
Ensuring consistency amongst chart reviewers
Leveraging clinical expertise
Reviewing and refining chart review procedures and processes
Developing the upcoming chart documentation training.

30. Changes to FY15/16 Annual Review Protocol
Due to a short time frame CBHDA chart review recommendations were not fully reviewed and changes were not made in the FY 14/15 protocol.
These recommendations have now been reviewed and protocol changes are being made to the FY 15/16 draft protocol as a result. This includes adding Partial Compliance ratings to a number of protocol items.
Examples: Out of the total number of assessments reviewed what percent contained all required elements; Out of the total number of assessments reviewed, what number/percent of the assessments contained each required element.
These changes are being made to the draft protocol that will be reviewed during the annual CAC meeting.

31. Compliance Advisory Committee
COMPLIANCE ADVISORY COMMITTEE (CAC) Welfare and Institutions Code (WIC) Section 5614 (a)-(b)
The Department, in consultation with the Compliance Advisory Committee that shall have representatives from relevant stakeholders, including, but not limited to, local mental health departments, local mental health boards and commission, private and community-based providers, consumers and family members of consumers, and advocates, shall establish a protocol for ensuring that local mental health departments meet statutory and regulatory requirements for the provision of publicly funded community mental health services.
The Annual CAC meeting has been scheduled for July 30, 2015, and will be held
in the CBHDA/CIBHS conference room.

32. Enhanced Monitoring Activities
In response to the ongoing concerns regarding areas of continued non-compliance or high disallowance rates over time, the Department is currently considering a number of options to increase and enhance oversight and monitoring activities.
CBHDA previously provided recommendations that align with DHCS considerations.

33. Goals for Enhanced Monitoring
The ultimate goal is for the department and the MHPs to work collaboratively in creating a system of review and compliance that ensures the best possible care, treatment, and services to our beneficiaries.
Raise overall levels of compliance over the next few years so that all counties are in the top tier at which time we can focus on maintaining that level of compliance.

34. OPTIONS
Establish a 3-tier system of review where thresholds would be set for each tier and MHPs based on overall compliance percentages would be placed into Tier 1, Tier 2, or Tier 3.
Tier 1 – MHPs in this tier would be reviewed triennially
Tier 2 – MHPs in this tier would be reviewed biennially
Tier 3 – MHPs in this tier would be reviewed annually
An MHP could be in the same or a different tier for system reviews and chart reviews.
This would be a fluid system as a county could move from tier to tier after each review.

35. OPTIONS
Phase in enhanced monitoring activities based on resource availability, for example:
Start with implementing annual reviews for Tier 3, while Tiers 1 and 2 remain on a triennial review cycle until resources are available for full implementation of the tiered system.
Set a yet-to-be-identified threshold where for MHPs falling below the set threshold the state would conduct a POC validation review 6-months after the full review to validate POCs have been implemented and are effective for out of compliance areas.

36. CBHDA Recommendations
OVERALL SCORE
GRADE
OUTCOME / MHP ACCOUNTABILITY
 90 – 100%
Excellent (Very Good)
Continue triennial review period with MHP Plan of Correction (POC) (if not 100%)
 80 – 89%
 Good
Continue triennial review period with MHP POC
 70 – 79%*
Acceptable (Average)
Continue triennial review period with MHP POC. DHCS may choose to monitor POC progress between review periods.
* NOTE: DHCS believes the acceptable range would likely need to start at 75% or 80%.
 60 – 69%
 Needs Improvement (Poor)
Consider increasing review period to every two years with close monitoring of the progress of the Plan of Correction by DHCS.
 < 59%
Requires more immediate improvement (Weak)
Consider increasing review period to yearly with very close monitoring of the progress of the Plan of Correction by DHCS. (Here CMS may appreciate seeing possible sanctions—and
it may be better to recommend it here as they may otherwise end up recommending them at even higher scores.)

37. Statewide Training, Focused Reviews and Targeted Site-specific Training
Annual statewide training, whereby the department is providing ongoing training events for the MHPs.
Focused reviews and/or targeted site-specific trainings of identified MHPs where there are significant ongoing rates of noncompliance
The focus of these reviews and/or trainings will be to improve performance around specific non or low compliance issues.
Some MHPs may have overall acceptable levels of compliance, but continue to be found out of compliance with key areas of concern as identified by the department and/or CMS which may result in a focused review of these areas.
EXAMPLE: DHCS may conduct test calls of all MHPs over a set period of time (e.g., 2-3 months) to establish a baseline using the new ‘Partial Compliance’ rating in order to gage statewide performance in this area of concern; rather than waiting for a full 3-year cycle to have this information for all of the MHPs.

38. Chart Documentation Training
To support the effort of working toward increased compliance and decreased disallowances as a result of chart reviews there are three (3) chart review trainings that will be conducted by the Program Oversight and Compliance Branch clinical staff in August 2015.
These will be 2-day trainings with Inpatient Chart Documentation on Day 1 and Outpatient Chart Documentation on Day 2.
August 5-6 in Sacramento
August in Visalia
August in Los Angeles
MHPs are encouraged to send the relevant staff, including staff
from the Short Doyle/Medi-Cal Hospitals.

39. SAVE THE DATE – July 16th
DHCS County Support Unit is offering web-based training to MHPs for the 24/7 Telephone Access Line
Webinar will be held on July 16, 2015 (CHECK TIME AND DETAILS)

40. Targeted Dates for Protocol Review, CAC and QIC Training
March 2015 Begin internal review of the Annual Review Protocol for updates June 2015 Distribution of Draft FY 15/16 Annual Review Protocol to CBHDA and stakeholders for review and input prior to the CAC meeting July 2015 CAC meeting August 2015 Chart Documentation Trainings September 2015 Regional QIC Protocol Training October 2015 Next Review Cycle Begins

41. WANTED MHP Peer Reviewers
DHCS invites the participation of representatives from MHPs as Peer Reviewers for the System and Inpatient Chart Reviews
Benefits of participation include:
Exchange information and best practices with peers about the administration and implementation of federal and state regulatory and contractual requirements.
Learn how other MHPs organize and prepare for the System Reviews and/or Inpatient Hospital Reviews.
Observe an evidence-based system review process for determining compliance with federal and state regulations.
Obtain first-hand knowledge of medical necessity criteria, regulatory criteria, and the assessment of UR plans and Medical Care Evaluation studies, etc.
If interested please contact for System Reviews or for SD/MC Psychiatric Inpatient Hospital reviews.

42. Other Quality Improvement Efforts
Increased assistance and monitoring by County Liaison staff
Established a DHCS and CBHDA work group to make recommendations on statewide uniform metrics
Increase Transparency
Increase Oversight and Monitoring
Establish a Quality Improvement Committee
Establish a process for sanctions, fines, penalties, and statewide implementation

43. Developing Metrics
Establishing Times Standards for Non-Emergency Specialty Mental Health
Percentage of non-urgent specialty mental health services (SMHS) appointments offered within business days of the initial request by the beneficiary or legal representative for an appointment.*
Number and percentage of acute psychiatric discharges that are followed by a psychiatric readmission within 30 days during a one year period.**
Percentage of acute (psych inpatient and PHF) discharges that receive a follow up outpatient SMHS (face to face, phone or field) within 7 days of discharge, except for those transferred to an IMD or SNF.
Percentage of acute (psych inpatient and PHF) discharges that receive a follow up outpatient SMHS (face to face, phone or field) within 30 days of discharge, except for an IMD or SNF.
Percentage of TARs approved or denied within 14 calendar days of receipt.  

44. Developing Metrics In Process
Discuss time frame for transition from 15 to 10 days
Define measures, identify data sources, data validation, and implement statewide.
Add measures for the other areas of CMS focus
24/7 access line and language availability
Grievance and appeal logs
Provider certification and recertification
Treatment Authorization Requests

45. 1915(b) SMHS Waiver Renewal
Currently responding to informal questions and negotiating Special Terms and Conditions (STCs)
Waiver Renewal Options:
Option 1: A 2-Year waiver renewal. Will result in CMS intense monitoring and the need for immediate and significant improvement.
Option 2: A 5-year renewal will involve STCs that allow time for improvement between waiver renewal periods.

46. Special Terms and Conditions
TRANSPARENCY ACCESS TIMELINESS QUALITY TRANSLATION SERVICES IMPROVEMENT

47. Special Terms and Conditions
On an annual basis, the state must make readily available to beneficiaries, providers, and other interested stakeholders, a mental health plan dashboard that is based on performance data of each county mental health plan included in the annual EQR technical report and/or other appropriate resources. Each county mental health plan dashboard must be posted on the state’s and the county MHP website. Each dashboard will present an easily understandable summary of quality, access, timeliness, and translation/interpretation capabilities regarding the performance of each participating mental health plan. The dashboards must include the performance of subcontracted providers. The state will determine how the data on the performance of subcontracted providers will be collected and the associated timeframe. The state will update CMS on this process. Between July 1, 2015 and July 1, 2016, the state and CMS will collaborate on developing the format for the dashboard. The first dashboard is due on September 1, 2016, and may not include information on the subcontracted providers; however, that information should be included in subsequent dashboards. The state will note when a plan doesn’t have subcontractors, or if a plan is unable to report on subcontractors on a particular dashboard.

48. Special Terms and Conditions
The state must require each county mental health plan to commit to having a system in place for tracking and measuring timeliness of care, including wait times to assessments and wait time to providers. The state needs to establish a baseline of each and all counties that includes the number of days and an average range of time it takes to access services in their county. If county mental health plans are not able to provide this information so that the state can establish a baseline, this will be accomplished through the use of a statewide performance improvement project (PIP) for all county mental health plans. In addition, a PIP to measure timeliness of care will be required for those counties who are not meeting specified criteria. The criteria will be developed collaboratively between the state and CMS. This has significant potential for improving patient care, population health, and reducing per capita Medicaid expenditures.

49. Special Terms and Conditions
The state will provide the EQRO’s quarterly and annual reports regarding the required PIPs to CMS, and discuss these findings during monthly monitoring calls.
The state will publish on its website the county mental health plans’ Plan of Correction (POC) as a result of the state compliance reviews. The state and county mental health plans will publish the county mental health Quality Improvement Plan. The intent is to be able to identify the county mental health plan’s goals for quality improvement and compliance.
The state and the county mental health plans will provide to CMS the annual grievance and appeals reports by November 1st of each year Since DHCS is in the process of revising the reporting form, the first report will be provided by January 31, The state will notify CMS by December 1, 2015 if it is unable to meet the January 31, 2016 deadline.
All information required to be published pursuant to these STCs, will be placed in a standardized and easily accessible location on the state’s website.

50. QUESTIONS?

51. Contact Information
Dina Kokkos-Gonzales,
Lanette Castleman,