1. 1915(b) Waiver Updates CBHDA Governing Board Meeting October 12, 2016

2. Service - Accountability - Innovation AGENDA OVERVIEW 2 I.Background II.Oversight Authorities III.Process Improvements IV.Enhanced Monitoring Framework V.Phase 1 Implementation VI.STC Dashboard VII.STC Website VIII.Compliance Finding Appeals IX.Next Steps

3. Background

4. Service - Accountability - Innovation Background CMS approved the 1915(b) waiver for a 5-year term, but included Special Terms and Conditions (STCs) in its approval. Heightened concerns about continued and long-standing non-compliance with regulatory and contractual requirements, as well as high disallowance rates resulting from chart audits. CMS expects significant improvement in non-compliance and disallowance rates as well as demonstrated improvement in specified areas of concern (i.e., 24/7 access line, TARs, provider certifications, etc.). DHCS included enhanced oversight and monitoring of the 56 county mental health plans (MHPs) in its 1915(b) waiver as part of strategy to address these concerns. CMS has directed DHCS to establish a process to enact fines, sanctions, penalties, and corrective actions. 4

5. Service - Accountability - Innovation 1915(b) Waiver STCs Transparency Data Access Timeliness Quality Translation services Quality Improvement 5

6. Service - Accountability - Innovation Special Terms and Conditions 1.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 CalEQRO technical report and/or other appropriate resources. Each county mental health plan dashboard must be posted on the state’s and the county mental health plan 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. 6

7. Service - Accountability - Innovation Special Terms and Conditions 2.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. 7

8. Service - Accountability - Innovation Special Terms and Conditions 3.The state will provide the CalEQRO’s quarterly and annual reports regarding the required PIPs to CMS, and discuss these findings during monthly monitoring calls. 4.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. 5.The state and the county mental health plans will provide to CMS the annual grievance and appeals reports by November 1 st of each year. Since DHCS is in the process of revising the reporting form, the first report will be provided by January 31, 2016. The state will notify CMS by December 1, 2015 if it is unable to meet the January 31, 2016 deadline. 6.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. 7.The state must, within the timeframes specified in law, regulation, or policy statement, come into compliance with any changes in federal law, regulation, or policy affecting the Medicaid or CHIP programs that occur during this waiver approval period, unless the provision being changed is expressly waived or identified as not applicable. 8

9. Oversight Authorities

10. Service - Accountability - Innovation Federal Oversight Authority Federal Medicaid Managed Care Program (42 CFR Part 438) Medi-Cal State Plan 1915(b) SMHS Waiver – Waives specific requirements related to freedom of choice for beneficiaries – Outlines DHCS’ monitoring and oversight strategies – Includes Special Terms and Conditions 10

11. Service - Accountability - Innovation State Oversight Authority California Code of Regulations, title 9, chapter 11, section 1810.380(a): Oversight Authority The MHPs shall be subject to state oversight, including the following: 1)Site visits and monitoring of data reports from MHPs and claims processing. 2)Reviews of program and fiscal operations and the books and records of each MHP to verify that services are medically necessary services are provided in compliance with [title 9] and the contract between the Department and the MHP. 3)Immediate on-site reviews of MHP program operations whenever the Department obtains information indicating that there is a threat to the health or safety of beneficiaries. 4)Monitoring compliance with problem resolution process requirements 5)Monitoring provider contracts to ensure that the MHP enters into necessary contracts…and that the MHP is accountable for any functions and responsibilities it has delegated to any subcontractor or another MHP. 6)Monitoring denials of MHP payment authorizations. 7)Annual, external, independent reviews of the quality outcomes of, timeliness of, and access to the services covered by the MHPs as required by 42CFR438.204 11

12. Service - Accountability - Innovation State Oversight Authority California Code of Regulations, title 9, chapter 11, section 1810.380(b): Oversight Authority 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 may take any or all of the following actions: 1)Require that the MHP develop a plan of correction. 2)Withhold all or a portion of payments due to the MHP from the Department. 3)Impose civil penalties pursuant to Section 1810.385 4)Terminate the contract with the MHP 5)Take other actions deemed necessary to encourage and ensure contract and regulatory compliance. 12

13. Process Improvements

14. Service - Accountability - Innovation 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 Strengthening compliance protocol 14

15. Service - Accountability - Innovation Monitoring Process Improvements 24/7 Test Call Reporting Requirements and Statewide Results ABGAR Reporting Requirements Overdue Provider Certification Reports Training and Technical Assistance Plan of Correction (POC) Validation 15

16. Service - Accountability - Innovation Plans of Correction MHPs are required to develop a Plan of Correction (POC) for all findings of non- compliance. The POC should include the following information: 1.Description of corrective actions, including milestones 2.Timeline for implementation and/or completion of corrective actions 3.Proposed (or actual) evidence of correction that will be submitted to DHCS 16

17. Service - Accountability - Innovation POC Validation Process Compliant POC Likely Compliant As Written POC Likely Compliant With Minor Revisions POC Not Likely Compliant - Major Revisions RequiredPOC Unclear Evidence of correction was submitted by county MHP and it meets regulatory and/or contract requirements. Evidence of correction was incomplete or not yet submitted by MHP. The POC as written (description of corrective action) will likely result in compliance with regulatory and/or contract requirements. The POC includes strategies for addressing specific reasons for OOC finding and is likely to result in sustainable changes in the MHP system. Evidence of correction was incomplete or not yet submitted by MHP. The POC with minor revisions (suggestions included) will likely result in compliance with regulatory and/or contract requirements. The POC includes strategies for addressing specific reasons for OOC finding but is missing key actions (suggestions included below) and is likely to result in sustainable changes if implemented with revisions in the MHP system. Evidence of correction was incomplete or not yet submitted by MHP. The POC as written is not likely to result in compliance with regulatory and/or contract requirements. The POC does not include strategies for addressing specific reasons for OOC finding and/or the POC’s corrective action is not likely to result in sustainable changes in the MHP system. Major revisions to the POC are required to ensure compliance. Evidence of correction was incomplete or not yet submitted by MHP. The POC does not contain adequate information to determine if it is likely to result in compliance with regulatory and/or contract requirements. 17

18. Enhanced Monitoring Framework

19. Service - Accountability - Innovation Enhanced Monitoring Overview MHSD has developed an initial framework for enhanced monitoring which will be phased in over time. The framework includes: – a tiered structure with designation criteria; and, – monitoring activities representing a continuum of progressive corrective actions. Continued CBHDA and MHP input and involvement. MHSD is implementing a modified framework for Fiscal Year 2016/2017. 19

20. Service - Accountability - Innovation Enhanced Monitoring Framework Identifies criteria by which MHPs will be classified into seven tiers based on compliance rates and/or presence of significant or long-standing non- compliance. All MHPs will remain on a triennial review schedule. Enhanced monitoring activities will be implemented in addition to regularly scheduled triennial reviews. Enhanced monitoring activities to be implemented in the months/year following the triennial review. – Results from monitoring activities implemented (e.g., desk and/or onsite reviews) would determine which activities would be implemented in subsequent years leading up to the next scheduled triennial review. 20

21. Service - Accountability - Innovation Enhanced Monitoring Criteria Compliance rates are not the only factor used to determine tier status. Long-standing or significant findings in an area of concern could result in the MHP being placed in a lower tier status than would otherwise be indicated solely by the compliance percentage. Significant findings could refer to any finding of non-compliance which is either egregious in nature or a previously identified (by DHCS and/or CMS) area of concern. DHCS will operationalize definitions (e.g., significant findings, egregious in nature, substantial improvement, etc.) for criteria triggering enhanced monitoring 21

22. Service - Accountability - Innovation Enhanced Monitoring Activities MHSD’s monitoring framework includes the following activities: – Triennial Reviews – POC Validation Reviews – Statewide or Regional TA and Training – MHP Submission of Evidence of QI Actions – Targeted MHP Specific Trainings – POC Validation Visits – Focused Desk Reviews – Focused, Modified or Comprehensive Onsite System and Chart Reviews – Fines, Sanctions and Penalties 22

23. 23 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIASYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Excellent (Very Good) Outcome/MHP Accountability: Continue triennial review period with MHP Plan of Correction (POC) (if not 100%) TIER 1 Compliance Rate Non-Compliance and/or Disallowance Rate 95 - 100% 5% - 0%  Triennial Review  POC Validation  Statewide Technical Assistance (TA) and Training  Triennial Review  POC Validation  Statewide Technical Assistance (TA) and Training  Triennial Review  POC Validation  Statewide Technical Assistance (TA) and Training AND No Long-Standing or Significant Findings of Non-Compliance TIER 2 Compliance Rate Non-Compliance and/or Disallowance Rate 90 - 94% 10% - 6%  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted Remote TA  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non- Compliance Findings in Two Consecutive Reviews)

24. 24 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIA SYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Good Outcome/MHP Accountability: Continue triennial review period with MHP POC TIER 3 Compliance Rate Non-Compliance and/or Disallowance Rate 80-89% 20% - 11%  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Desk or Onsite Audit  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Desk or Onsite Audit AND /OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non- Compliance Findings in Two Consecutive Reviews

25. 25 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIA SYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Acceptable (Average) Outcome/MHP Accountability: Continue triennial review period with MHP POC. DHCS may choose to monitor POC progress between review periods. TIER 4 Compliance Rate Non-Compliance and/or Disallowance Rate 70-79% 30% - 21%  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Focused Modified Onsite Review  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Desk or Onsite Audit  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Desk or Onsite Audit  Fines, Sanctions and Penalties AND /OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non-Compliance Findings in Two or More Consecutive Reviews

26. 26 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIA SYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Needs Improvement (Poor) Outcome/MHP Accountability: Consider increasing review period to every two years with close monitoring of the progress of the Plan of Correction by DHCS. TIER 5 Compliance Rate Non-Compliance and/or Disallowance Rate 60-69% 40% - 31%  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Focused Modified Onsite Review  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Onsite Audit - Small  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Onsite Audit - Small  Fines, Sanctions and Penalties AND /OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non-Compliance Findings in Three or More Consecutive Reviews

27. 27 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIASYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Requires Immediate Improvement (Weak) Outcome/MHP Accountability: Consider increasing review period to yearly with very close monitoring of the progress of the Plan of Correction by DHCS. TIER 6 Compliance Rate Non-Compliance and/or Disallowance Rate 50-59% 50% - 41%  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Modified Onsite Review  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Onsite Chart Audit - Standard  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Onsite Chart Audit - Standard  Fines, Sanctions and Penalties AND /OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non-Compliance Findings in Three or More Consecutive Reviews

28. 28 CBHDA RECOMMENDATIONS DHCS RECOMMENDATIONSENHANCED MONITORING ACTIVITIES TIER CRITERIASYSTEM REVIEW OUTPATIENT CHART REVIEW INPATIENT CHART REVIEW Grade: Requires Immediate Improvement (Weak) Outcome/MHP Accountability: Consider increasing review period to yearly with very close monitoring of the progress of the Plan of Correction by DHCS. TIER 7 Compliance Rate Non-Compliance and/or Disallowance Rate 0-49% 51% and above  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Full Onsite Review  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Onsite Chart Audit - Large  Fines, Sanctions and Penalties  Triennial Review  POC Validation  Statewide or Regional TA and Training AND, AS APPROPRIATE, MAY INCLUDE:  Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Onsite Chart Audit - Large  Fines, Sanctions and Penalties AND /OR Long-Standing or Significant Findings of Non-Compliance (i.e., Significant Finding or Lack of Substantial Improvement in Area of Concern and/or Non-Compliance Findings in Three or More Consecutive Reviews

29. Service - Accountability - Innovation MHP Distribution 29 TierCriteria System Review Outpatient Chart Review Inpatient Chart Review Tier 1 100-95% Compliance Rate 23 MHPs3 MHPs 0 MHPs No Long-Standing/Significant Findings Tier 2 94-90% Compliance Rate 11 MHPs4 MHPs 0 MHPs Long-Standing/Significant Findings Tier 3 89-80% Compliance Rate 16 MHPs9 MHPs0 MHPs Long-Standing/Significant Findings Tier 4 79-70% Compliance Rate 4 MHPs8 MHPs0 MHPs Long-Standing/Significant Findings Tier 5 69-60% Compliance Rate 2 MHPs5 MHPs3 MHPs Long-Standing/Significant Findings Tier 6 59-50% Compliance Rate 0 MHPs7 MHPs3 MHPs Long-Standing/Significant Findings Tier 7 49-0% Compliance Rate 0 MHPs20 MHPs 12 MHPs Long-Standing/Significant Findings

30. Service - Accountability - Innovation Phase I Implementation COMPLIANCE REVIEW PROCESSSYSTEM REVIEWOUTPATIENT CHART REVIEWS TARGET MHP SELECTION CRITERIA Greater than 30% non-compliance in most recent system review (Tiers 5-7) Greater than 50% disallowance rate in most recent chart review (Tier 7) RATIONALE FOR TIER SELECTION IN PHASED IMPLEMENTATION There are only 2 MHPs in tiers 5-7 for system review compliance. There are 20 MHPs in tier 7 for chart review based on disallowance rates. ENHANCED MONITORING ACTIVITIES (Tier 1-4 Activities*)  Triennial Review  POC Validation  Statewide or Regional TA and Training  Evidence of QI Actions  Targeted MHP Specific Training  POC Validation Visit  Focused Desk Reviews  Focused Onsite Reviews  Triennial Review  POC Validation  Statewide or Regional TA and Training  Utilization Review and Chart Audit Reports (Annual)  Evidence of QI Actions  POC Validation Visit  Targeted Training  Focused Desk Reviews  Focused Onsite Reviews 30 *Inpatient Chart Reviews TBD for Phase I Implementation

31. Service - Accountability - Innovation FY16/17 Implementation Activities Outpatient Chart Reviews - 20 MHPs in Tier 7 Triennial Review (9 MHPs already on schedule) POC Validation – All MHPs Evidence of QI Actions – POC Status Report (20 MHPs) Evidence of QI Actions – Chart Audit Report Submission (20 MHPs) Focused Review for MHPs with Greater than 70% Disallowance Rate (4 MHPs) System Reviews – 2 MHPs in Tiers 5-7 POC Validation – All MHPs Evidence of QI Actions – POC Status Report (2 MHPs) POC Validation Visit (2 MHPs) Inpatient Chart Reviews TBD 31

32. Sanctions, Fines, and Penalties 32

33. Service - Accountability - Innovation Sanctions, Fines, and Penalties CMS directed DHCS to develop a process for levying sanctions, fines, and penalties (SFP) and to identify enhanced monitoring activities. MHSD internal workgroup currently developing a framework document which will guide the process of identifying criteria for imposing SFP and will be shared/discussed with CBHDA. Reviewing comparable processes within DHCS (i.e., Managed Care and SUDs) to align MHSD’s SFP policy Applicability and criteria for imposing SFP to be determined, but may include: – System and Chart Review Findings – EQRO and PIP Findings – Timeliness of Services – Compliance with Managed Care Requirements – Compliance with 1915(b) Waiver STCs and POS 33

34. Special Terms and Conditions 34

35. Service - Accountability - Innovation STC Deliverables Annually publish a performance Dashboard on the MHP website and DHCS website (STC #1) Require MHPs that are unable to establish a baseline for timeliness of care to conduct a Performance Improvement Project (PIP) (STC #2) Require MHPs that are unable to meet a standard for timeliness of care conduct a PIP to improve performance (STC #2) Make available quarterly EQRO PIP Summaries and the Annual Report for review by CMS (STC #3) Publish MHP Plan of Correction on DHCS website (STC #4) Publish QI Plans on MHP and DHCS websites (STC #4) Annually submit a statewide Summary of Grievances and Appeals to CMS (STC # 5) Establish an accessible Website for all information related to the STCs (STC #6) The state must come into compliance with any changes in federal law, regulation, or policy affecting the Medicaid or CHIP programs that occur during this waiver approval period. 35

36. Service - Accountability - Innovation MHP Performance Dashboards DHCS, in consultation with MHPs and stakeholders, has identified indicators to measure: – Quality – Access – Timeliness – Translation/Interpretation Capabilities Indicators for the MHP Performance Dashboards were selected based upon availability of existing data sources and statewide mechanisms for data collection. 36

37. Service - Accountability - Innovation MHP Performance Dashboard Indicators Enrollment data on the unique count of beneficiaries receiving SMHS. Demographic data by age, gender, race, and ethnicity. Penetration rates for beneficiaries served and not served, and also arrayed by demographic characteristics. Utilization rates of services reported by dollar amount, and by service in time increments. Time to step-down services, i.e., time to next contact after an inpatient discharge. 37

38. Service - Accountability - Innovation Performance Dashboard Publication State-level aggregate MHP Performance Dashboard: Scheduled for publication in December 2016. County-specific MHP Performance Dashboard: Scheduled for publication beginning December 2016 on a flow basis. 38

39. Service - Accountability - Innovation Client and Services Information System DHCS is making system design changes to Client and Services Information System (CSI) to capture wait times to assessment and wait times to providers. The following metrics are being developed for system design modifications in CSI: – Date of initial request for an appointment (assessment) to date of first offered appointment (assessment). – Date of last claimed assessment appointment to date of first offered provider appointment. – Date of last claimed assessment to date of first provider claimed (treatment) appointment. Target date for CSI System Changes – May 2017 39

40. Service - Accountability - Innovation STC Webpage 40 http://www.dhcs.ca.gov/services/MH/Pages/ 1915(b)_Medi-cal_Specialty_Mental_Health_Waiver.aspx

41. Compliance Findings Reports and Appeal Timelines

42. Service - Accountability - Innovation Compliance Findings Report and Appeal Timelines 42 Findings Report A findings report will be sent to the MHP Director after DHCS compiles the findings. The report will include the following: 1.System Review Findings 2.Chart Review Findings 3.Chart Compliance Summary Metrics Report 4.Chart Recoupment Summary Plan of Correction A POC is due within 60-days of the receipt of the findings report for all findings of non- compliance. Appeal The MHP may appeal findings of non-compliance and disallowances by submitting a written appeal, with the required supporting documentation, within 15-business days after receipt of the findings report. Final Report DHCS will adjudicate appeals submitted by the MHP and make necessary adjustments to the findings report, if the MHP’s appeal is successful. STC Website Posting DHCS will post the final report on its website per the 1915(b) STCs.

43. Next Steps

44. Service - Accountability - Innovation Next Steps Continue to refine framework for enhanced monitoring Finalize initial framework for sanctions, fines and penalties Establish workgroup with CBHDA and possibly stakeholders to solicit input on enhanced monitoring processes Inform CMS of progress implementing 1915(b) Waiver activities Finalize and post STC dashboard Continue planning and implementation of STC requirements 44

45. THANK YOU! 45

46. Service - Accountability - Innovation Contact Information Dina Kokkos-Gonzales, MHSD Division Chief Dina.Kokkos-Gonzales@dhcs.ca.gov 916-323-3582 Erika Cristo, PPQAB Branch Chief Erika.Cristo@dhcs.ca.gov 916-552-9055 Autumn Boylan, System Compliance Chief Autumn.Boylan@dhcs.ca.gov 916-440-7568 46