1. 2010 Fee-For-Service Agreement for DHHS Networks PRESENTED BY: Michelle Naples – Delinquency and Court Services Dennis Buesing – DHHS Contract Administrator Pamela Erdman – Wraparound QA/QI Director Diane Krager – DHHS QA Coordinator Jeannine Maher – Wraparound Provider Network Coordinator Rochelle Landingham – Contract Service Coordinator (BHD)

2. MILWAUKEE COUNTY DEPARTMENT OF HEALTH AND HUMAN SERVICES 2010 Fee-for-Service Agreement OVERVIEW OF CHANGES

3. 11/3/093 Each Milwaukee County Operated Program Will Send Out Their Own Copy of the Agreement 2010 Fee for Service Agreements Each County Program will: Identify any requirements that need to be met in order to renew the agreement with that Program Establish timeframe for when the signed agreement must be returned Work with Contract Administration regarding agencies that will be unable to renew their Agreement because of pending Audit issues

4. 11/3/094 General Updates Following Items Updated State Administrative Code and Statues Web Site References – Updated to Current URL

5. 11/3/095 New Definitions Alternate Care Site Case Notes Emergency Management Plan (Disaster Plan) Fraud

6. 11/3/096 SECTION TWO General Obligations of the Provider Item A - Move within document Item C Provider accountable for accuracy and completeness of all Direct Service Provider documentation Must have written documentation of how oversight is provided to Direct Service Providers procedure for communication of Purchaser Policies and Procedures to Direct Service Providers Plan related to Supervision of Direct Service Providers including process for review and approval of Service Documentation

7. 11/3/097 SECTION TWO General Obligations of the Provider Continued Item K – References Case Note by Definition Item L – Case Notes Requirements Must be completed within 30 days of the date of services Must be completed prior to billing for service Item Q – Emergency Preparedness NEW ELEMENTS – COMPLETE REVIEW OF THIS SECTION OFFERED LATER IN THIS SESSION pandemic influenza ” added to description of an emergency to agency requirement for a written Emergency Management Plan (EMP) to address the identified emergencies

8. 11/3/098 SECTION THREE Background Checks Statement requiring Federal Background Checks for all employees that lived outside Wisconsin in past 3 years Removed from Agreement County Programs retain the right to require Federal Check in Program Policy Item A - Provider MUST submit ALL employee background checks with findings other than “no record found” on DOJ form

9. 11/3/099 SECTION EIGHT Assignment and Subcontract Limits Last Sentence –New Provider may NOT subcontract this agreement in part or in whole without prior written consent of purchaser Clinical providers will need to provide written notification of contracts with individual contract staff not employed by the agency

10. 11/3/0910 SECTION FOURTEEN Purchaser Site and Service Documentation Review Item E Added: Purchaser has authority to adjust pending billings and payments due to Providers due to Overpayment Recovery resulting from: Site Review CPA Audit Other Reviews

11. 11/3/0911 SECTION FIFTEEN Billing Provider is: Responsible for accuracy of billing Agreeing to Policies/Procedures related to Service Documentation Requirements Billing no later than 60 days following month in which service was provided

12. 11/3/0912 SECTION FIFTEEN Billing Continued Program Specific Changes Disabilities Services Billing Procedure Added WIser Choice Billing Procedure Updated “Once a Week” Reporting Requirement – Deleted Replacement Language – Billing as Outlined in Policy and Procedure Wraparound Milwaukee Unless otherwise allowed by Policy and Procedure added Agencies that document directly in Synthesis to invoice at different intervals

13. 11/3/0913 SECTION SIXTEEN Audit Requirements References to Providers reporting on a fiscal year have been removed References to “subrecipients” changed to “subcontractors” Item (1)(j) – Reference to Reporting each program or service under County contract as a separate line has been removed

14. 11/3/0914 SECTION SEVENTEEN Conditional Status & Suspension Item B.#2. Provider Subject to Conditional Status # d. Added Findings resulting for a Site Review/audit … that document quality and/or fiscal concerns related to Purchaser Policies and Procedures Item C. Suspension Last Paragraph Provider will not be allowed to provide services or sign a new agreement with Milwaukee County if an outstanding payment/repayment is due to Milwaukee County

15. 11/3/0915 SECTION TWENTY-ONE Notices Section Rewritten Notices may be sent by “mail” (U.S. or courier) Notices may be sent by Email

16. 11/3/0916 SECTION TWENTY-TWO Agreement Content Last Two Statements Added If provision of the Agreement is waived by Purchaser, remainder of document remains in effect If a provision of the Agreement is held to be invalid, the remainder of the document is not affected

17. 11/3/0917 APPLIES TO WRAPAROUND ONLY ATTACHMENT D Applies to Payment for: Day Treatment Group Home Residential Care Progress Entries in Synthesis Required ATTACHMENT E Applies to Payment for: Crisis Stabilization Progress Entries in Synthesis Required WRAPAROUND SPECIFIC

18. 11/3/0918 APPLIES TO WIser CHOICE ONLY Quality Assurance Policy and Procedures Civil Rights Compliance Plan Complete Caregiver Background Check

19. OVERVIEW OF CHANGES RELATED TO EMERGENCY PREPAREDNESS Dennis Buesing Contract Administration

20. General Obligations of the Provider ITEM Q – EMERGENCY PREPAREDNESS In order for Provider and Service Recipients that Provider serves to be prepared for a natural or man-made disaster, or any other internal or external hazard that threatens Service Recipients, staff, and/or visitor life and safety, Provider shall: have a written Emergency Management Plan (EMP); to be retained by the Provider and made available to DHHS upon request; orient all employees to the proposed plan and trained to perform assigned tasks; identify the steps Provider has taken or will be taking to prepare for an emergency and address, minimum required elements; 11/3/0920

21. General Obligations of the Provider Item Q Emergency Preparedness Continued # 1 Provider’s order of succession and emergency communications plan # 2 Develop a continuity of operations business plan # 3 Provider to identify “essential” services to remain in operation during an emergency, and services deemed to be essential by DHHS # 8 Residential facilities, identify the location of an Alternate Care Site for Residents/Service Recipients # 9 Identify a means, other than public transportation, of transporting residents to the Alternate Care location # 10 Identify the role(s) of staff during an emergency, including critical personnel, key functions and staffing schedules 11/3/0921

22. General Obligations of the Provider Item Q Emergency Preparedness Continued # 11 Identify how meals will be provided to Residents/Service Recipients at an Alternate Care Site # 12 – Expanded – Help Service Recipient prepare for an emergency and obtain essential services during emergency Identify how Providers who offer case management or personal care shall assist Service Recipients to individually prepare for an emergency and obtain essential services, including developing a Care Plan that includes an emergency plan on an individual level. # 13 Ensure that current assessment and treatment plan for each Service Recipient with specific information about the characteristics and needs of the individual is available in an emergency and accompanies the Service Recipient to the Alternate Care Site 11/3/0922

23. General Obligations of the Provider Item Q Emergency Preparedness Continued # 14 Identify staff responsible for ensuring availability of prescriptions/medical equipment and Service Recipient information at Alternate Care Site; # 15 Communicate and Collaborate with local emergency management agencies to ensure the development of an effective emergency plan (typically the fire chief, or his/her designee); and # 16 Collaborate with Suppliers and Personal Services Providers. 11/3/0923

24. General Obligations of the Provider Item Q Emergency Preparedness Continued Providers shall have agreements or MOUs with other agencies or operators of Alternate Care Sites and Transportation Providers and assess the availability of volunteer staff for such emergencies. See Sample Mutual Aid Transfer Agreement at: http://dhs.wi.gov/rl_dsl/NHs/MutualAidTransferAgmt.htm If Provider organization serves persons with special needs receiving in-home care, or care in a supportive apartment, it should have the Service Recipient, the caregiver or someone upon whom the Service Recipient relies for personal assistance or safety complete the below referenced “DISASTER PREPAREDNESS CHECKLIST FOR INDIVIDUALS WITH SPECIAL NEEDS”. http://dhs.wisconsin.gov/preparedness/pdf_files/IndPrepCh ecklist.pdf http://dhs.wisconsin.gov/preparedness/pdf_files/IndPrepCh ecklist.pdf 11/3/09 24

25. General Obligations of the Provider Item Q Emergency Preparedness Continued Providers can find resources for EMPs including sample plans, templates and EMP Checklist at the following websites: http://dhs.wi.gov/rl_dsl/Providers/SamplEmergPlans.htm http://dhfs.wisconsin.gov/rl_DSL/Providers/EvacSheltTemplate.pdf http://dhfs.wisconsin.gov/rl_DSL/Providers/EvacSheltTemplate.pdf http://dhs.wisconsin.gov/preparedness/emergencyplans.htm http://dhs.wisconsin.gov/rl_DSL/EmergencyPreparedness/EmP repIndex.htm http://dhs.wisconsin.gov/rl_DSL/EmergencyPreparedness/EmP repIndex.htm http://www.cms.hhs.gov/SurveyCertEmergPrep/03_HealthCar eProviderGuidance.asp#TopOfPage http://www.cms.hhs.gov/SurveyCertEmergPrep/03_HealthCar eProviderGuidance.asp#TopOfPage 11/3/0925

26. General Obligations of the Provider Item Q Emergency Preparedness Continued WIser Choice providers must submit a copy of their written plan to Rochelle Landingham,Contract Services Coordinator EMP for other DHHS FFS Networks must be made available upon request 11/3/0926

27. PROGRAM SPECIFIC POLICIES AND PROCEDURES CHANGES

28. 11/3/0928 WRAPAROUND MILWAUKEE New Procedures/Requirements Secondary Identifier Required for All Direct Service Providers Date of Birth Email Address Required for All Clinicians/Practitioners Used to inform Clinician of Updates/Changes to Service Specific Policies and Procedures Wraparound Staff will Contact Agency if New Provider Works for Multiple Agencies in Wraparound Network Agency Responsible for Monitoring Provider Service Delivery and Billing – Date and Times may NOT Overlap with Another Agency

29. 11/3/0929 WRAPAROUND MILWAUKEE Services with Training Curriculum Requirement Submit with Agreement Renewal Daily Living Skills – Individual and Group Life Skills Training – Individual and Group Supported Work/Job Coach Client record documentation should reference the topics addressed during each client contact Summarize or “Outline” how and where the training is conducted identification of standardized assessment tools (if any) used topics/subject addressed as part of the training reference materials used as part of training Provider Network staff will contact the agency if additional information is required when the summary material is reviewed

30. 11/3/0930 WRAPAROUND MILWAUKEE Services with Specific Staff Training Requirements Submit with Agreement Renewal Crisis Stabilization/Supervision Mentoring Tutoring Parent Assistance Summarize/Outline of Topics Covered and Materials Used Training Topics Covered Documents Videos Courses Publications

31. 11/3/0931 WRAPAROUND MILWAUKEE Staff Training Requirements Continued Identify The total time per module for each training component The training method used (ie: lecture, video, reading material, etc) The name and credentials of the trainer (for lecture, videos, course work) Other information that validates the service provider benefit Provider Network staff will contact the agency if additional information is required when the summary material is reviewed

32. 11/3/0932 WRAPAROUND MILWAUKEE Policy Changes Vendor Responsibilities and Guidelines Client Record Requirement Incorporated Mentor/Parent Assistance/Tutor 15 Hour Training Verification Certificate Job Description reviewed/signed off by Employee Must accompany the “Provider ADD Sheet” Recreation Policy Staffing / Presence of Crisis Stabilizers Outings – Requirement if Not all Clients Can Attend

33. 11/3/0933 WRAPAROUND MILWAUKEE Policy Changes Continued Transportation FINANCE DIRECTOR AUTHORIZATION REQUIRED Authorization Obtained by Care Coordinator More then 20 Miles from the pick-up location to the destination Pick-up location is more than 20 miles from City

34. 11/3/0934 Civil Rights Compliance Plan Requirements Presented by: Dennis Buesing, DHHS Contract Administrator

35. 11/3/0935 Civil Rights Compliance (CRC) All recipients of Federal and/or State funds are required to submit either a Civil Rights Letter Of Assurance (LOA) or a Civil Rights Plan for their agency The County Equal Employment Opportunity certificate is a separate requirement and does not qualify as a CRC document.

36. 11/3/0936 CRC (Cont’d)…….. Agencies with 25 or more employees AND awarded at least $25,000 in federal, state & county funds are required to submit a full CRC plan Agencies with fewer than 25 employees AND/OR receive less than $25,000 in funding may opt to submit a Letter of Assurance instead, which includes AA, EO and LEP policies Agencies who subcontract are also required to ensure the subcontractor maintains CRC requirements

37. 11/3/0937 Other Required Forms & Appendixes to be Attached to the CRC LOA Submitted to DHHS Required Items Appendix A: Contact Info & Signature page Appendix B: Funding Relationship to DCF, DHS or DWD Appendix C Funded Program Checklist Appendix D EO in Employment & Service Delivery Policy Appendix E LEP Policy Statement Profit & Nonprofit Entities Required by DHHS Not Required by DHHS Required by DHHS

38. 11/3/0938 CRC (Cont’d)…….. New CRC plan requirements for years 2010-13 have been posted at DHFS web sites. LOA and CRC Plan Requirements, Instructions & Templates including links for Training webcasts are available at: http://dhfs.wisconsin.gov/civilrights/Index.HTM

39. 11/3/0939 Wisconsin Civil Rights Compliance Officer Questions may also be directed to: David Duran, CRC Officer PO Box 7850 One West Wilson Street, Room 561 Madison, WI 53707-7850 durand@dhfs.state.wi.us Phone: (608) 266-9372 Fax: (608) 267-2147

40. 11/3/0940 BREAK

41. 11/3/0941 DHHS Provider Networks/Contract Administration Interface Engage in Centralized QA Committee Discuss/approve audit/review indicators Assist with site audits/reviews Dialogue regarding audit/review agency reports Collaborate regarding FFS Agreement yearly revisions

42. 11/3/0942 Insurance Requirements Audit and Accounting Requirements Maintaining Financial Records General Information on Allowable Costs Audit Requirements and Waiver Procedures Insurance & Audit Requirements

43. 11/3/0943 Insurance Requirement Auto Liability: required for all agency vehicles (owned, non-owned, and/or hired). Coverage: $1 million per accident Employees of Providers using personal vehicles to transport participants, or for any other reason related to the provision of Covered Services shall have Automobile Insurance providing the same liability limits as required of the Network Provider Commercial General and/or Business Owner’s Liability: Required of ALL Providers and must include premises and off premises liability coverage (may include Umbrella policy)

44. 11/3/0944 Insurance (Professional Liability) Professional Liability: If the services provided constitute professional services, Provider shall maintain Professional Liability coverage (i.e. if a license or certification is required to perform the service). Includes Certified/Licensed Mental Health & AODA Clinics and Providers and 1MM/3MM

45. 11/3/0945 Insurance (Professional Liability) Hospital, Licensed Physician or any other qualified healthcare provider under Sect 655 : 1MM/3MM Changed last year: Other Licensed Professionals, CPAs, Engineers, Attorneys, etc., $1,000,000 per Occurrence $2,000,000 Annual aggregate or Statutory limits whichever is higher

46. 11/3/0946 Insurance (cont’d) Additional Insured: Milwaukee County shall be named as, and receive copies of, an “additional insured” endorsement, for general liability, automobile insurance (except for hired or non- owned vehicles), and Umbrella/excess insurance Exceptions of compliance with “additional insured” endorsement are: 1. Transport companies insured through the State “Assigned Risk Business” (ARB). 2. Professional Liability where additional insured is not allowed.

47. 11/3/0947 Insurance (cont’d) Upon Renewal, Provider shall furnish County annually on or before the date of renewal, evidence of a Certificate indicating the required coverage (with the Milwaukee County Department of Health and Human Services named as the “Certificate Holder ”) CERTIFICATE HOLDER Milwaukee County Dept. of Health & Human Services Contract Administrator 1220 W. Vliet Street, Suite 109 Milwaukee, WI 53205

48. 11/3/0948 Insurance (cont’d) Binders are not acceptable except during preliminary application period Failure to comply with insurance requirements may result in suspension or non-renewal of contract

49. 11/3/0949 Who Must Have An Audit? Audits are required by State Statute if the care & service purchased with State funding exceeds $25,000 per year Statutes allow the Dept. to waive audits. Audits may not be waived if the audit is a condition of state licensure, or is needed to claim federal funding (e.g. Group Foster Care or CCIs) Standards for audits are found in DHFS/DWD/DOC Provider Agency Audit Guide, 1999 Revision (on line at www.dhfs.state.wi.us/grants) www.dhfs.state.wi.us/grants Non-profit providers that receive $500,000 or more in federal awards must also have audit performed in accordance with OMB Circular A-133 Audit of State, Local Governments, and Non-Profit Organizations.

50. 11/3/0950 What Must the Audit Contain? Items Frequently Omitted Summary of Auditor’s Results and Schedule of Findings and Questioned Costs Copy of Management Letter, if any Corrective action plan for all current-year audit findings related to County funded programs & Management’s response to each audit comment and item identified in the Management Letter. Schedule of Federal and State Awards

51. 11/3/0951 What Other Schedules Are Required? Per contract, Schedule of Program Revenue & Allowable Cost by Contract (program), or program/facility within a contract. If program receives revenue from more than 1 funding source, all funding sources must be listed separately. If applicable, Incorporated Group Home/Child Caring Institution Supplemental Schedule Nonprofit providers paid on a unit-times-unit-price contract, Reserve Supplemental Schedule For-profit providers, Schedule of Allowable Profits

52. 11/3/0952 Allowable Costs & Allowable Profits or Reserves Per State Statute, ultimately, all agreements with Milwaukee County DHHS for care & services paid with dept. funding are cost reimbursement contracts For-profit providers may retain up to 10% in profit per contract; 7½% of allowable costs, plus 15% of net equity (Allowable Cost Policy Manual, Section III.16)Allowable Cost Policy Manual Nonprofit providers paid on a unit-times-unit-price contract may add up to 5% of contract amount in excess revenues to reserves each yr., up to a cumulative maximum of 10%

53. 11/3/0953 Allowable Costs & Allowable Profits or Reserves The County does not have to allow either a profit or reserves to providers who do not include a Schedule of Allowable Profits, or Reserve Supplemental Schedule with their audit

54. 11/3/0954 Other Allowable Cost Issues Generally interest expense, except for purchase- money mortgages to purchase real estate, or equipment is not an allowable cost. Interest paid under Working Capital Loans, a line of credit or refinancing to pull money out of a property is not an allowable cost Generally, advertising expense, except for costs associated with hiring and recruiting, is not an allowable cost Alcohol, Entertainment, Contributions & Donations and repayment of audit recoveries and other debt, are never an allowable cost

55. 11/3/0955 Special Allowable Cost Rules for S Corporations Distributions to Shareholders are not an allowable cost, and will be treated as a distribution of profits or dividends, not as wages Per 48 CFR part 31, for costs to be allowable, the cost must be deductible on the entity's federal income tax return per IRS regs To be allowable, salaries accrued for 2% or more shareholders must be paid in the current contract year

56. 11/3/0956 Allowable Cost & Related Party Issues Allowable Cost Rules under rental agreements with Related Parties contain additional restrictions Allowable rent expense under related party leases may not exceed the actual costs to the related party that owns the property. (Generally, mortgage interest, RE taxes, insurance, maintenance /utilities & depreciation) Rental expense under sale lease back arrangements are only allowable to the extent of expense which would have been incurred had title to the property remained vested with the renter Per contract, the auditor must disclose related party rental arrangements, rent paid to the related party, the related party’s actual expenses on the property, & the amount of unallowable rent on each property charged to any contract with Milwaukee County

57. Milwaukee County Allowable Costs Special Considerations Milwaukee County follow Federal and state allowable cost policies and OMB circulars: Non profit Circular A-122 For Profit Rules under 48 CFR part 31 Single audit rules under Circular A-133 11/3/0957

58. Special Considerations (cont’d) Other Rate based services: Non-profit agencies are allowed to keep 5% of contract surplus as reserve,for the year with an 10% of contract overall limit (over all years) Other Consideration: Compensation including Bonus etc to owners/ shareholders of Closely held companies restricted to allowable per Income Tax rules Related Party Rent: allowable up to the actual cost of owner (usually allowable under Schedule E by IRS) Other Related Party Services: Allowable up to comparable free market rate. Allowable profit for For-Profit Agencies: 7.5% -10% of the allowable costs 11/3/0958

59. Unallowable Costs Under Federal Allowable Cost Rules Following costs are not allowable under federal cost rules and is reduced from allowable costs to determine the surplus: Advertising except as part of contract for outreach or for hiring or selling of the assets. Trade Show Expenses Trade Show Labor Promotional Material/Brochures Souvenirs/Imprinted Clothing Provided to Public Membership in Civic and Community Organizations Bad Debts 11/3/0959

60. Unallowable Costs (cont’d) Collection Costs Personal Use of Company Vehicles Contributions or Donations Employee Gifts and Recreation Membership in Social/Dining/Country Clubs Social Activities Fines/Penalties Key-Man Life Insurance (unless considered compensation) Re-Work Insurance (errors and omissions) 11/3/0960

61. Unallowable Costs (cont’d) Interest Expenses except interest paid for Mortgage to acquire fixed assets Lobbying Costs Losses on other Contracts Organization/Re-Organization Costs like Legal Fees, Accounting Fees, Incorporation Fees Capital Raising (Equity or LT Debt) Cost like Legal Fees,Accounting Fees Lender Fees Patent Costs Retainer agreements Relocation Costs (in certain circumstances) 11/3/0961

62. Unallowable Costs (cont’d) Goodwill Alcoholic Beverages Amortization of Intangibles 11/3/0962

63. 11/3/0963 Maintaining Financial Records Both Federal and State contracting guidelines require provider agencies to maintain proper books and adequate financial records Providers should maintain an accurate and up-to- date general ledger and timely financial statements for management & board members Financial Statements must be prepared in conformity with generally accepted accounting principles (GAAP) and on the accrual basis of accounting. Contractor must request, and receive written consent of County to use other basis of accounting in lieu of accrual basis of accounting

64. 11/3/0964 Maintaining Financial Records Amounts recorded in the books should be supported by invoices, receipts or other documentation Providers should maintain a separate cost center for each contract, or program/facility within a contract Whenever possible, costs should be charged directly to a contract, all other costs should be allocated using a reasonable and consistent allocation method and supported by an Indirect Cost Allocation Plan Providers must not commingle personal and business funds. A separate checking account should be established & providers should not use personal credit cards for agency business All Provider agencies should maintain and adhere to a board approved, up-to-date Accounting Policy & Procedures Manual and bonus policy

65. 11/3/0965 Audit Waiver Statutes allow the Dept. to waive audits. Audits may not be waived if the audit is a condition of state licensure, or is needed to claim federal funding (e.g. Group Foster Care or CCI) Waiver request can only be entertained if agency does not need to have an audit according to Federal Audit requirement Waivers need to be approved on case by case basis by regional office based on a risk assessment (Funding <$75,000 is considered low risk) Waiver Request S/B submitted DHHS Contract Administration prior to audit due date

66. 11/3/0966 Audit Waivers DHHS has been approving Audit Waivers for Fee for Service contracts mainly on basis of economic hardship In case of small residential care providers (Family group home and AFH) county has the authority to grant a waiver Waiver Form is available at: http://www.milwaukeecounty.org/contractmgt1548 3.htm2009 Audit Waiver Form http://www.milwaukeecounty.org/contractmgt1548 3.htm2009 Audit Waiver Form

67. Common Errors or Omissions and Findings In Year 2007 with Changes to GAS requirements auditor’s now need to report certain issues as “Significant Deficiencies” and not “Reportable Conditions” as required earlier. So certain finding which was reportable conditions or not are now a finding and need a response for management as a significant deficiency like: Agency’s ability to prepared financial Statements with Note per GAAP. Passing of significant journal entries during audit. This has also increased our workload as we now need to follow these up too. So it is always better to address these with the finding by telling The auditor your proposed action like hiring outside professional temp help to address these issues. 11/3/0967

68. Common Errors or Omissions and Findings (cont’d) Audit indicates issuance of Management Letter, but agency fails to submit letter & management’s response Failure to submit corrective action plan when audit discloses Finding or Questioned Costs Failure to report all DHHS Programs separately by Contract, or program/facility within a contract Failure to identity all funding sources on Sch’l of Program Rev. & Exp’s (all funding sources must be listed as a separate line item) 11/3/0968

69. 11/3/0969 Common Errors or Omissions (cont’d) Nonprofits - Failure to provide Supplemental Reserve Schedule for all programs or contracts Failure to submit audit in a timely manner (results in Admin. Probation & inability to renew contract) Failure to submit written Extension requests Failure to submit written Waiver requests Failure to submit evidence of Insurance renewal in a timely manner Audits are sent to wrong address Audit confirmation are sent to wrong address

70. 11/3/0970 Names & Address for Submissions Submit Audits to: Dennis Buesing DHHS Contract Administration 1220 W. Vliet St., Suite 109 Milwaukee, WI 53205 Ph:414-289-5853 Wraparound Confirmation Requests to: Janet Friedman Wraparound Milwaukee Finance 9201 W. Watertown Plank Rd., Room 255 Milwaukee, WI 53226 Ph:414-257-7597

71. 11/3/0971 Submissions (cont’d) WIser Choice Confirmation Requests to: Paul Neymeyr Behavioral Health Division 9201 W. Watertown Plank Rd., Room 607 Milwaukee, WI 53226 Ph:414-257-7912 All Other Confirms (Purchase of Service, Children’s Court Services Network & DSD) Anita Anselmo DHHS Accounting 1220 W. Vliet St., Suite 109 Milwaukee, WI 53205 Ph:414-289-5834

72. Policies and Procedures Audits/Reviews Documentation QUALITY ASSURANCE

73. Quality Assurance – Policies and Procedures Refer to the applicable Division’s/Program’s policies and procedures as they may differ. Agency is responsible for inservicing all Direct Service Providers on all relevant policies and procedures, i.e. – Mentors should be inserviced on the Mentor Policy and Procedure.

74. Noncompliance with Policies and Procedures Will be reflected in agency review report Can result in: Fiscal recoupments Suspension Termination from Network Restriction of future contracts with Milwaukee County Corrective Plan of Action required

75. Risk Assessment Criteria Factors that may determine which agencies are audited/reviewed: Prior Audits identifying problems; Agencies receiving combined billings in auditable services equal to or > $100,000 in prior 12 month period within 3 DHHS FFS Provider Networks; Agencies with billing patterns above the average utilization for each respective service within a program; Agencies for which DHHS or program staff have received recent grievances, complaints, critical incidents, evidence of client health & safety concerns or client reports of non-delivery of service; Agencies in the network less than 2 years, with billings equal to or > $50,000.

76. AUDIT/REVIEW INDICATORS What We Look for During an Audit/review Network Provider cooperation Compliance with Requirements : Fee-For-Service Agreement Policies and Procedures HFS 12: Wis. Adm. Code State of Wis. Caregiver Program Other applicable Federal, State, and County regulations

77. Basic Review Indicators Agency Indicators Required Licenses: i.e. Current Outpatient Clinic Mental Health State Certification, AODA Clinic License, etc. Required Insurance Coverage's: i.e. Gen. Commercial Liability ($1MM min. w/ MC named as addit. insured), Professional Liability, Wisc. Workers’ Compensation, etc. Required Training Manuals (service specific- Wraparound only)

78. Basic Review Indicators (cont’d) Provider Indicators Current Professional Licenses or Certifications Evidence that Counselors meet Minimum Credential Requirements Evidence of Minimum Training Prior to Provision of Service (service specific) Valid Driver’s Licenses, Auto Insurance, Driving Abstracts on File Compliance with 3 components of Background Check and Wisc. Caregiver Law and Milwaukee County Resolution (refer to program specific policy)

79. Criminal Background Checks Your agency is required to complete a State-wide criminal background check through the Department of Justice Crime Information Bureau (CIB) on all prospective direct service providers. When hiring direct service providers/employees that lived outside the State of WI within the prior 3 years, the agency must make a good faith effort to get a background check from the previous State of residence.

80. Criminal Background Checks (cont’d) Three parts to Caregiver Background Checks: 1.Background Information Disclosure (BID) Form 2. Response from Dept of Justice 3.Letter from Dept of Health Services (DHS) Repeat every 4 years for ongoing Providers (or at any time within that period when an agency has reason to believe a new background check should be obtained).

81. Reporting of Criminal Background Checks Before requesting to add a new Provider to the Network, agency must follow-up on any charges without dispositions Contact: Milwaukee County Clerk of Courts Milwaukee County Courthouse 901 N. Ninth Street Report convictions to Network (submit criminal background check with Add Sheet for new providers – Wraparound only) Must be completed before service provider is authorized to provide services. If a current/authorized Provider is arrested and/or has been charged with or convicted of any crime specified in the Caregiver Law/ County Resolution, the Provider must notify the Network within two (2) business days.

82. Basic Audit/Review Indicators (cont’d) Client Indicators Provider Referral Form/Service Plan on File Prior to Provision of Services, clearly identifying each Service being requested. Consents (Consent for Service/Treatment &/or Transportation Consent) Signed/Dated by Legal Guardian/Client Prior to Provision of Services.

83. Basic Review Indicators (cont’d) Client Indicators Plan(s) of Care (POC) &/or Treatment Plan(s) in File for Duration of Service. Monthly Logs/Reports/Sign-In Logs and/or Progress Notes in File for each month billed. Logs and/or Progress Notes Contain all Required Elements. Discharge Summary in File, if applicable.

84. Basic Review Indicators (cont’d) Fiscal Indicators Documentation must be reflective of the service provided and billed. Documentation must include all Required Elements. Hours (units) billed must match hours (units) documented.

85. Documentation Agency is responsible to ensure adequate and accurate documentation is maintained in the client file. Client files/records must be kept in secure cabinet or room. Documentation reflective of service provision must be in file before a service is billed.

86. Documentation (cont’d) Unless indicated by specific policy, Bulletin, statute, etc., documentation must include minimum elements:  Client/Recipient Name  Date of Service: i.e. 6/11/06  Times and Duration: i.e. 2:00-4:00 p.m., 2 Hrs.  Location of Service: i.e. Office  Summary of activity/interaction/intervention, including client’s response to activity.  Signature of provider.

87. Documentation Reminders Provider Referral Forms must clearly identify service being requested (i.e. should read “In-Home Therapy (5160)”; not “Therapy.” ) PNs and Logs must be filled out completely. Progress Notes must be specific to client served and descriptive of the session provided & the client’s response to the treatment. PNs cannot be simply copied and pasted from session to session. Service Logs or Sign-In Logs (if applicable); signatures must be obtained at the time the client receives the service and match the corresponding PN (date, time/duration). Any pre- signing of Logs by a provider or client is considered fraudulent and may be grounds for termination from Network and future contractual agreements with the County/DHHS. REVIEW FILES/RECORDS ON REGULAR BASIS FOR ACCURACY & COMPLETENESS

88. 11/3/0988 THANK YOU FOR YOUR PARTICIPATION! Have a Great Day!