Wraparound Milwaukee Integrated Provider Network (WIPN) 2007 Fee-For-Service Agreement & More! Presented by: Dennis Buesing – DHHS Contract Administrator Pamela Erdman – Wraparound QA/QI Director Diane Kaas – DHHS QA Coordinator Jeanine Maher – Wraparound Administrative Coordinator Elvira Villarreal – WIPN Coordinator

11/7/2006 Overview of 2007 Fee- for-Service Agreement and Summary of Changes

11/7/2006 Summary of Changes PAGE ONE - Couple of references changed “County” changed to “Wraparound Milwaukee”. “Mental Health/Social Service Provider” changed to “Specialized Managed Care Organization”. DEFINITIONS New definitions identified for the following: Conditional Status County Suspension Some changes made to few other definitions

11/7/2006 Summary of Changes…..contd. SECTION THREE - CLIENT RIGHTS (New section) SECTION FOUR - OBLIGATIONS OF NETWORK PROVIDER Paragraph A and other areas of the agreement where reference is made to compliance with the terms and conditions of the Fee-for-Service Agreement – additional text added. Paragraph B: Wording related to maintaining of credentials and licenses more specific – references requirement to maintain credentials for agency and contract providers. Also added reference to compliance with federal, state and county regulations.

11/7/2006 Summary of Changes…..contd. SECTION FOUR - OBLIGATIONS OF NETWORK PROVIDER …. Contd. Paragraph E: New statement. Indicates that each services must have at least ONE direct service provider. Paragraph F: Opening statement added Paragraph I: Statement added to include cooperation Paragraph K: Reworded. Paragraph L: New paragraph. Addresses agency requirement for emergency preparedness plans.

11/7/2006 Summary of Changes…..contd. SECTION FIVE -OBLIGATIONS OF WRAPAROUND MILWAUKEE Paragraph B: New paragraph. References access to Synthesis. Paragraph C: New paragraph. Statement regarding complaint/grievance/appeal system added.

11/7/2006 Summary of Changes…..contd. SECTION SIX – COMPENSATION Paragraph B: Reference to online Allowable Cost Policy added. Paragraph E: Language of Prompt Payment Law added. SECTION EIGHT – COMPLIANCE WITH BACKGROUN CHECKS Paragraph D: Reference to offenses referenced in numbers 6, 7, and 11 of the Resolution Requiring Background Checks on Department of Health and Human Services Contract Agency Employees Providing Direct Care and Services to Children and Youth added.

11/7/2006 Summary of Changes…..contd. SECTION TEN - PROTECTING PRIVACY OF HEALTH INFORMATION Paragraph Three: new language added. SECTION THIRTEEN -EQUAL RIGHTS AND CIVIL RIGHTS COMPLIANCE Equal rights and civil rights combined in this section. SECTION FOURTEEN - INDEMNITY & INSURANCE Paragraph B: Coverage language added to include: malpractice, errors and omissions. Paragraph C: Automobile insurance requirements statement added.

11/7/2006 Summary of Changes…..contd. Paragraph D: Statement regarding professional liability added. Other changes: Types of Insurance Coverage Providers Working Out of Home Office Paragraph F: Exclusions to “additional insured” endorsement updated. Paragraph G: Added – evidence of insurance coverage to be furnished on or before the date of renewal. Paragraph H: New paragraph – regarding insurance that is underwritten on a Claims-Made basis. Paragraph I: Identifies when insurance “binders” will be accepted.

11/7/2006 Summary of Changes…..contd. SECTION EIGHTEEN - ASSIGNMENT LIMITATION Revised Statement added SECTION NINETEEN - PROHIBITED PRACTICES AND REQUIRED DISCLOSURES Section rewritten. References limits associated with Milwaukee County Ethics Code - Chapter 9. SECTION TWENTY - CERTIFICATION REGARDING DEBARMENT / DEBARMENT BY MILWAUKEE COUNTY (New Section) SECTION TWENTY-THREE - NETWORK PROVIDER COMPLAINTS/ APPEALS/GRIEVANCES “Appeals” added to title and new reference added.

11/7/ Fee for Service Agreements Wraparound Milwaukee will not be signing new contracts with providers who are not in compliance with following: Have not provided a copy of 2005 Audit Report; Have not submitted their CRC plan; Have not complied with the Insurance requirement; Have not provided Resource Guide Description for Synthesis.

11/7/2006 Wraparound/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

11/7/2006 Insurance Requirements Audit and Account Requirements Maintaining Financial Records General Information on Allowable Costs Audit Requirements and Waiver Procedures

11/7/2006 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 WIPN participants, or for any other reason related to the contract shall have Automobile Insurance providing the same liability limits as required of the Network Provider

11/7/2006 Insurance (cont’d) Commercial General and/or Business Owner’s Liability: Required of ALL Providers and must include premises and off premises liability coverage 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. Coverage: 1MM/3MM

11/7/2006 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.

11/7/2006 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 Behavioral Health Division named as the “Certificate Holder”) Binders are not acceptable except during preliminary application period Failure to comply with insurance requirements may result in suspension or non-renewal of contract

11/7/2006 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) Statutes require audits to be performed at least every other year. County contracts typically require annual audits Standards for audits are found in DHFS/DWD/DOC Provider Agency Audit Guide, 1999 Revision (on line at 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. Fed audit requirements are for an annual audit

11/7/2006 What Must the Audit Contain? Opinion on the Financial Statements and all Supplementary Schedules Report on Compliance & Internal Control (I/C) Based on Audit of Financial Statements Performed in Accordance with GAS and PAAG If applicable, Report on Compliance with Requirements Applicable to Each Major Program and I/C over Compliance in Accordance with OMB Circular A-133 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.

11/7/2006 What Other Schedules are Required? Schedule of Expenditures of Federal & State Awards Per contract, Schedule of Program Revenue & Allowable Cost by Funding Source and by Contract, 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

11/7/2006 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%.

11/7/2006 Allowable Costs & Allowable Profits or Reserves The County will not fund a program’s cumulative prior year’s deficits with current year funding (i.e. a program cannot have a negative reserve balance). 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

11/7/2006 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

11/7/2006 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 with whom title vests. (Generally, mortgage interest, real estate taxes, insurance, maint./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

11/7/2006 Maintaining Financial Records Both Federal and State contracting guidelines require provider agencies to maintain orderly books and adequate financial records Maintain a uniform double entry accounting system and a management information system compatible with cost accounting and control systems. 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 accounting principles generally accepted in the U.S. (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.

11/7/2006 Maintaining Financial Records Amounts recorded in the general ledger should be adequately supported by invoices, receipts or other documentation Providers should maintain a separate cost center or dept. in their general ledger 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

11/7/2006 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) 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 the bottom of the web page:

11/7/2006

Common Errors or Omissions 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)

11/7/2006 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

11/7/2006 Names & Address for Submissions Submit Audits to: Dennis Buesing DHHS Contract Administration 1220 W. Vliet St., Suite 109 Milwaukee, WI Ph: Wraparound Confirmation Requests to: William Herd Wraparound Milwaukee 9201 W. Watertown Plank Rd., Room 255 Milwaukee, WI Ph:

11/7/2006 Submissions (cont’d) Wiser Choice Confirmation Requests to: Paul Neymeyr Behavioral Health Division 9201 W. Watertown Plank Rd., Day Hospital, Room 316 Milwaukee, WI Ph: All Other Confirms (Purchase of Service Contracts & Children’s Court Services Network) Howard Felix DHHS Accounting 1220 W. Vliet St., Suite 109 Milwaukee, WI Ph:

11/7/2006 BREAK

11/7/2006 Quality Assurance Policies and Procedures Client Chart Maintenance Audit/Review Indicators

11/7/2006 Quality Assurance – Policies and Procedures Provider policy and procedure manual sent to all provider agencies, updated annually. Agency Director responsible for in-servicing employees on applicable policies and procedures Director signs the Policy and Procedure QA “Sign-Off” form and returns to: Wraparound QA Department as specified

11/7/2006 Noncompliance with Policies and Procedures Will be reflected in agency audit report Can result in: Fiscal recoupments Suspension Termination from Network Restriction of future contracts with Milwaukee County Corrective Plan of Action required

11/7/2006 Client Chart Maintenance See upcoming Provider Bulletin # chart per client (Wraparound Program/FISS) If sibling or caregiver of identified enrollee, must be clearly indicated Separate file into sections, i.e. Referral, Consents, Plans of Care, Notes, Correspondence, etc. Most recent correspondence and notes on top in each section

11/7/2006 Client Chart Maintenance (cont.) Chart should be orderly, neat, accessible Keep files in alphabetical order Separate current files from disenrolled files. Maintain file until youth turns age 19 or until 7 years after treatment is completed, whichever is longer

11/7/2006 What Contract Administration Looks for During a Site Audit/Review 1. Network Provider cooperation. 2. Compliance with Requirements:  WIPN Fee-For-Service Agreement,  Policies and Procedures,  Provider Bulletins,  HFS 12: Wis. Adm. Code State of Wis. Caregiver Program,  Other applicable Federal, State, and County regulations.

11/7/2006 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)

11/7/2006 Basic Review Indicators (continued) 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) Compliance with 3 components of Background Check and Wisc. Caregiver Law and Milwaukee County Resolution Valid Driver’s Licenses, Auto Insurance, Driving Abstracts on File

11/7/2006 Criminal Background Checks Agency signs certification statement pledging compliance with Milwaukee County Resolution. Agency signs FFS Agreement pledging compliance with the State of Wisconsin Caregiver Law. Must complete a State-wide criminal background check through the Department of Justice Crime Information Bureau (CIB) on all prospective direct service providers Obtain Federal criminal background check for caregivers living in Wisconsin less than 3 years Three parts to Background Checks: 1.Background Information Disclosure (BID) Form 2. DHFS Letter 3. Criminal/No Record Report

11/7/2006 Criminal Background Checks (continued)  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).

11/7/2006 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 North Ninth Street Report convictions to WIPN (submit criminal background check with Add Sheet for new providers) 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 network Provider must notify the WIPN within two (2) business days. Questions? Please contact Pam Erdman - QA Director at

11/7/2006 Basic Audit/Review Indicators (continued) Client Indicators Provider Referral Form 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 Prior to Provision of Services.

11/7/2006 Basic Audit/Review Indicators (continued) Client Indicators Plan(s) of Care (POC) &/or Treatment Plan(s) in File for Duration of Service. Monthly 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.

11/7/2006 Documentation Agency is responsible to ensure adequate and accurate documentation is maintained in the client file. Client files/records must be kept in secure, fireproof cabinet or room. Documentation reflective of service provision must be in file before a service is billed.

11/7/2006 Documentation (continued) 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.

11/7/2006 Basic Audit Indicators (continued) 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.

11/7/2006 Risk Assessment Criteria Factors to 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 will be reviewed for that program; Agencies for which DHHS or program staff have received recent grievances, complaints, or evidence of health & safety concerns or client reports non-delivery of service; Agencies in the network less than 2 years, with billings equal to or > $50,000.

11/7/2006 Civil Rights Compliance Plan Requirements Presented by: Dennis Buesing, DHHS Contract Administrator

11/7/2006 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 Equal Employment Opportunity certificate is a separate requirement and does not qualify as a CRC document.

11/7/2006 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

11/7/2006 OTHER REQUIRED ITEMS (ATTACHMENTS) FOR SUBMITTING WITH THE CRC LOA Required Items Attachment 1: AA EO in Employment Policy Attachment 2: Form DOA-3607 Approval to be in Vendor Directory Form DOA-3024 Request for Exemption for Submitting AA Strategies for achieving a balanced workforce Form DOA-3023 Vendor Subcontractor List Profit & Nonprofit Entities Required Not Required

11/7/2006 CRC (Cont’d)…….. New CRC plan requirements for years have been posted at DWD and DHFS web sites. LOA Instructions & Templates are available at: _contents_page.htm _contents_page.htm CRC Plan Requirements & Templates are available at: an_07_09.doc an_07_09.doc Plan instruction and resources are available at Training webcasts are available at:

11/7/2006 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 Phone: (608) Fax: (608)

11/7/2006 Thank you for your participation! Have a Great Day!

11/7/2006 Thank you for your participation! Have a Great Day!