Workplace Inclusion & Sustainable Employment
Ethical Implications of Monitoring Reviews January 2015
Professional Ethics and Contract Compliance • Ethical principles • Fidelity – keeping promises • Veracity – be honest • Code of ethics • CRC • LPC • LMSW • State and federal law Workplace Inclusion & Sustainable Employment
Objectives 1. Identify and understand the purpose of monitoring reviews. 2. List the most common monitoring findings from employment service contract reviews. 3. Describe the possible outcomes when unethical conduct or contract non- compliance is a finding. 4. Recognize methods and strategies to comply with our contract and provide high quality consumer services. Workplace Inclusion & Sustainable Employment
Panel Experts David Johnston , DRS Program Manager, Consumer Services Lynn Lemky , DARS Monitoring Team Lead, Contract Oversight and Support Sue-Ellen Woodlief , DRS Program Specialist for Community Rehabilitation Programs Workplace Inclusion & Sustainable Employment
What is the purpose of monitoring? Workplace Inclusion & Sustainable Employment
Emphasis of the State of Texas • Accountability • Performance • Here to Stay Workplace Inclusion & Sustainable Employment
DARS Focus Determine compliance with – policies & procedures in DRS Standards for Providers – contract terms and conditions; federal and state laws and regulations Monitors – quality of services consumers are receiving – expenditure of taxpayer monies Identifies – need for technical assistance – need for corrective action Workplace Inclusion & Sustainable Employment
What is the difference between quality services and contract/standards compliance? Workplace Inclusion & Sustainable Employment
Quality Services Demonstration of • person centered decision making involving the consumer, counselor, provider and other supports of the consumer; • active participation of the consumer and provider and when applicable, the counselor; • following all policies and standards; and • achievement of individual outcomes set for a consumer. Workplace Inclusion & Sustainable Employment
Contract and Standards Compliance Demonstration and documentation of • Service delivery that achieves all required outcomes necessary for payment as prescribed in the provider’s contract, in the Standards for Providers and documentation on the forms. Workplace Inclusion & Sustainable Employment
Specific questions about DARS Forms or Standards should be emailed to: DARSstandards@dars.state.tx.us Workplace Inclusion & Sustainable Employment
Questions Workplace Inclusion & Sustainable Employment
How does monitoring occur? • Formal monitoring • Informal monitoring • Process, documentation and consumer case monitoring Workplace Inclusion & Sustainable Employment
Formal monitoring • Monitoring contractor performance is a key function of proper contract administration • Systematic review of contractor records, business processes, deliverables, and activities • Goal of contract monitoring • Protect the health and safety of clients that receive services • Ensure delivery of quality goods and services • Protect the financial interest of the State • DARS is made aware of and able to addresses developing issues • Need for & level of contract oversight varies by contract type and risk level
Formal monitoring - continued • Comprehensive Reviews • programmatic (consumer’s file review) • financial / administrative • staff qualifications • physical facility (if services are delivered at a facility) • Onsite or desk reviews • Minimum 12-month review period • Checklists mirror the Standards Manual and contract • Cross-section of team members within DARS
Informal monitoring • Oversight of Contractor Performance is an Essential Agency Responsibility • The Process Begins with the Ongoing Review of Routine Documentation Received from the Contractor. • DARS Staff will be Sensitive to Issues Impacting Contract Deliverables, Compliance with State Requirements, Confidentiality of Consumer Data, the Overall Service Delivery Process and Effective Use of Funds. • The Goal is to Establish Effective Routines at the Start of the Contract and then to Sustain them throughout the Contract Lifecycle.
Process, documentation and consumer case monitoring • DARS Verifies instructions were followed and all sections of the DARS forms (all questions answered) are complete and accurate. • DARS verifies that all deliverables are achieved as required. • Standards for Providers defines the service descriptions, staff qualifications, process, outcomes for payment (deliverables) and fees. • Reviewing the “DARS Only” Section of forms can be used as a tool for the provider to ensure compliance with the Standards for Providers.
What are the possible outcomes of a monitoring activity? • Formal monitoring • Informal monitoring • Process, documentation and consumer case monitoring Workplace Inclusion & Sustainable Employment
Formal monitoring • No Findings Identified • Technical Assistance • Identification of Areas of Non-compliance • Report of Findings • Repayment of identified overpayments • Notice of Appeal Rights • Corrective Action Plan (CAP) • Final Report
Informal monitoring • Help Pro-actively Avoid the Occurrence of Findings • Engagement with and Support (Technical Assistance) for Contractors Helps Sustain Service Capacity and Can Also Enhance Services • At the Point of Service Level, Helps Identify Potential Areas of Non-compliance Earlier in the Process
Process, documentation and consumer case monitoring DARS staff may return copies of invoices and associated documentation for the following reasons: • documentation is not complete • when unable to verify such things as outcomes for payment of service(s), employment status, consumer’s satisfaction, and employer's satisfaction • unable to verify the staff’s qualifications such as UNTWISE Credentials
What are the most common issues related to employment service monitoring activities? • Formal monitoring • Informal monitoring • Process, documentation and consumer case monitoring
Formal monitoring • Invoices • Incomplete and or inaccurate • Service Authorizations • Missing or invalid / expired • Supporting Documentation • Lacked all required information • Not in consumer file • Billing / Payments • Not consistent with supporting documentation • Inaccurate • P & Ps • Incomplete / inaccurate / missing
Informal monitoring • Catching Incorrect or Incomplete Invoices with Missing Data • Establishing Good Habits Regarding Filing of Service Authorizations and Follow-up on Instances in Which the Service Authorizations have not been Received or Updated • Reports Need to Provide the Required Information Necessary to Help Counselors Provide Services
Process, documentation and consumer case monitoring • Referral forms not completed • Goals, Employment Conditions are not achieved • Services not leading to a successful closure of the consumer’s case • Services not individualized • Incomplete or inaccurate documentation • Proof that the • person centered decision making process involved the consumer, counselor, provider and other supports of the consumer; • consumer and provider and when applicable, the counselor, actively participated; • all policies and standards were followed; and • individual outcomes set for the consumer were achieved
Questions Workplace Inclusion & Sustainable Employment
What strategies would you suggest to implement to stay compliant? • Keeping up to date with the standards and forms • Continuing education • Document corrective actions on identified noncompliance areas • Seek guidance from DARS Program Specialist for Quality Assurance
Emerging Topics Conflict of Interests Enhanced confidentiality and record keeping compliance Changes with regard to the VR program move to the Texas Workforce Commission Changes with regard to the VR program due to federal regulations
If I am in doubt, with whom should I consult? Region 1: Mike Lawson mike.lawson@dars.state.tx.us (806) 783-2982 Region 2: Jesus Quiroga jesus.quiroga@dars.state.tx.us (817) 436-4103 Region 3: Paula Brunson paula.brunson@dars.state.tx.us (512) 407-1339 Region 4: Stephanie Jenkins Stephanie.jenkins@dars.state.tx.us (713) 267-8546 Region 5: Andrew Ramirez Andrew.ramirez@dars.state.tx.us (210) 805-2220
If I am in doubt, with whom should I consult? Specific questions about DARS Forms or Standards should be emailed to: DARSstandards@dars.state.tx.us 1/20/2016 31
Questions Workplace Inclusion & Sustainable Employment
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