Laura Jasso, LCSW April Marek Sub of Sub Waivers 2018 Laura Jasso, LCSW April Marek

History of the Sub of Sub Process Prior to 2015, DSHS is aware sub of sub provider structure exists DSHS needs to create a way to track sub of sub providers Sub of sub documentation process begins: Sub of sub policy created 2015 First round of waiver submissions were collected RW 16-17 grant year 10/10/2019

Vision for the Sub of Sub Process Goals of the Sub of Sub process: Ensure compliance at every level of the system Monitoring Equitable services across the state El Paso to Houston Provide insight of the number of sub of sub providers across the state 20? 127? Encourage direct contacting with AAs 10/10/2019

The Two Parts of the Sub of Sub Process: Waivers Why the AA cannot directly contract Exceptions Rare Ex: Amount of private insurance a provider must carry to contract with the county is not reasonable Sub of Sub Documentation Contract Personal Services Agreement Memorandum of Understanding (MOU) Letter of Agreement (LOA) 10/10/2019

Sub of Sub Documentation All sub of sub documents (contracts, MOUs, LOAs, etc.) were reviewed for the following: Provider to follow DSHS SOC DSHS access to provider files Flexible for policy changes 3rd party verification Timely transition plan PoLR Contract signed & dated + additional language from sub contractor templates that would also be applicable to sub of subs Old documentation was archived and new documentation was logged and saved 10/10/2019

Number of Sub of Subs Statewide For the RW 16-17 Grant Year the number of sub of sub waivers and contract reviewed: Bexar- 12 BVCOG- 60 Dallas- 1 Lubbock- 15 STDC- 22 Tarrant- 6 TRG- 11 Because of the large quantity of sub of sub providers adjustments will be made to the 2018 process. 10/10/2019

2018 Sub of Sub Expectations AA responsibility (by 4/1/18) For current contracts, AA s must submit the expiration date for of the contract AAs with outstanding contracts must continue to procure missing documents Any contracts that are anticipated to end must be reported Any new sub of sub contracts must to be submitted *Addendums and attachments will not be accepted for 2018 10/10/2019

Sub of Sub Template for Submission * DSHS will email copies of the sub of sub template 10/10/2019

Sub of Sub Policy The Sub of Sub Policy is currently under revision AAs will be notified when changes are solidified 10/10/2019

Next Steps Laura Jasso will email the AAs the sub of sub template AAs have until 4/1/18 to submit any missing sub of sub documentation and/or any updates to sub of sub contacts Once the sub of sub policy is completed, the policy will go up for public comment (AAs will be notified) Once the public comment period closes, the policy will be finalized 10/10/2019

Questions 10/10/2019

Thank you 10/10/2019