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

2. 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 grant year
10/10/2019

3. 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

4. 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)
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5. 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
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6. Number of Sub of Subs Statewide
For the RW 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

7. 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
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8. Sub of Sub Template for Submission
* DSHS will copies of the sub of sub template
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9. Sub of Sub Policy The Sub of Sub Policy is currently under revision
AAs will be notified when changes are solidified
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10. 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

11. Questions
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12. Thank you
10/10/2019