Georgia Association of Homes and Services for Children 

Commissioner’s LOC Transition Meeting
LOC Questions & Answers
June 21st Provider Meeting
 

Questions for DFCS: 

1.         Are the new rates for RBWO going into effect on July 1, 2007?  If so, will it be based on each individual agency's cost report or the new per diem rate set by DHR?

            The new RBWO rates will take effect on July 1st.  The rates will be based on the new per diem rates established by DFCS or the actual per diem costs from the providers' cost reports, which ever is lower."  

2.         When will the county DFCS case managers be informed of the new RBWO system?

Formal Procedures are being completed for overall field communication presently.  In the interim, the former Treatment Services unit now known as Provider Relations will continue to guide and support all placement of children in Watchful Oversight in partnership with the DFCS Operations Team and the Provider Community. 

3.         How will the new RBWO system affect the billing system?  Will the regional payment centers continue to be used throughout the next fiscal year?

      We will continue to process bills through regional payment

      centers.  The billing system is affected in that the rates for

      virtually all children in RBWO will have to be adjusted. 

4.         We have heard that billing will be diverted to the county at some point in the future and not central billing.  We have some concerns about this.  The central billing process has been an effective means of having problem solving occur and to have an efficient payment process.  What is your take on this?

There will be changes in payment processing as the SHINES system rolls out.  While we expect there to still be centralized billing and payment, the initiation of the payment transaction will be generated out of the SHINES system based upon a recorded placement.  There will be much more integration of program information and financial information in SHINES than in the current systems. 

5.         When will new waiver forms be sent out and how long of a delay is expected?  Does DFCS plan on processing all of the waivers that have been submitted?  How many waivers have been received?  What percentage of waivers has been processed?  When will we receive responses to our waiver requests?

A Total of 663 waivers have been received to date.  The greater majority were received the week of 6/18/07.  Of those waivers received prior to 6/18/07, 50% have been processed with a 6/29/07 expected completion date of those initial requests.  Due to the recent large volume, the staffing will be increased to 15 processors beginning the week of 6/25/07.  The target date for completion of those waivers received the week of 6/18/07 is mid July.    

6.         By what date should we expect to receive our new contracts?

We anticipate having finalized contracts available for the provider community by COB 6/22/07. 

7.         What are the Kenny A. Objectives that will be included in the contract?

Guidelines for services are covered in detail in the contract. 

Items include, but are not limited to, 1) placements within county or within a 50 mile radius, 2) foster home capacity, and 3) notification and coordination with county DFCS prior to any movement of a child. 

8.         What are the guidelines for services that are to be included in the contract?

Overall Service areas addressed in the contract include: 

Planning

·        assistance in and participation with DFCS during Family Team Meetings, Multi-disciplinary Team Meetings, any Provisioning of Services, and Juvenile Court Review, Citizen Panel Reviews, and Discharge planning meetings as needed by DFCS. 

Placement

·        reimbursement rates to foster parents

·        emergency placement parameters

·        sibling placement parameters

·        limit on number of children placed in a foster home (capacity)

·        group care restrictions

·        no delays or denials in placement based on race, ethnicity, or religion

·        maintenance of licensures, certifications, and accreditations

·        uniform and appropriate pre-service training for foster parents

·        uniform and appropriate on-going training for foster parents

·        timely information to foster parents of applicable laws and policies

·        no disruption of placement unless approved by DFCS in advance

·        email notification of placement/roster changes

 

Health Services to Children

·        partnering with DFCS on initial screenings and follow-ups

·        partnering with DFCS in obtaining necessary periodic health screenings and treatments

·        appropriate administration of medication

 

Supervision of Contract Agencies

·        reporting of suspected abuse and neglect of children served

·        immediate reporting of the use of corporal punishment of children

·        provisioning of data and reports concerning services (Data)

·        annual inspections of the facilities/homes

 

Training (case management support and supervisory services)

·        verification, compliance with, and certification of minimum personnel training requirements (initial/on-going)

 

Foster Parent Screening, Licensing, and Training

·        uniform training prior to a child’s placement in a foster home

·        appropriate pre-screening and preparation of foster homes

 

Abuse in Care Investigations

 

·        prohibition of use or authorization of use of corporate punishment of DFCS children

·        notification of any suspected use of corporate punishment

·        prevention of reoccurrence

·        adherence to corrective action plans/monitoring

·        DFCS discretionary right to remove children/discontinue use of foster home

 

9.         DFCS Foster Parents can submit costs for incidentals for children with traditional needs as well as children with waivers.  These incidentals include mileage, haircuts, allowance for children in foster care, and are reimbursed by the County.  Since rates will now be uniform for both DFCS and private agency Foster Parents, then it is assumed that private agency foster parents could be reimbursed for the same incidentals.  I understand that depending on the county budget, these incidentals may or may not be approved for reimbursement.  When will the individual counties notify private agencies if the county will approve these incidentals for reimbursement?

DFCS expects most routine costs to be paid out the base foster care rate.  There are cases in which county governments (and sometimes private organizations or even individual donors) donate additional funds to counties to provide additional assistance to foster parents, and county DFCS offices are relatively free to use these non-federal/state funds as they see fit (just as private agencies can use their donations as they see fit).  Foster care waivers are normally used when there are additional ongoing special needs of a child that can not be handled in the base rate.

 

10.       When will CPA's be notified of the new Program Categories being added: Intermediate and Specialized Category?  Also, when will agencies be informed of the children that qualify for those programs and what is the process to determine eligibility?

Specialty CPA Program information was delivered to the CPA Provider Community on 6/20/0, via electronic mail.

 

In working through the RBWO placement programs, DFCS identified that the established programs (Traditional / Base WO / Max WO) were insufficient to adequately cover limited numbers of clients with extraordinary needs. Consequently, partnering with several CPA providers, we have designed three (3) specialty placement programs for limited numbers of high needs children.

 

The programs will be referenced as 1) Specialty Base Watchful Oversight (SBWO), 2) Specialty Maximum Watchful Oversight (SMWO), and 3) Specialty Medically Fragile Watchful Oversight (SMFWO).  Placements into one of these three (3) programs will be heavily scrutinized, with the DFCS Provider Relations Unit ensuring that all assignments meet the established stringent criteria/requirements.  All waiver requests received to-date are being reviewed and those clients identified as qualifying for one of the newly designed programs will be placed in same effective with the July 1st transition.  The Provider Relations Unit is working diligently to finalize the review before the end of June so they can communicate the reassignments and approved waiver amounts.

 

 

Reimbursement rates for the new programs were reflected in an attached Excel document with the 6/20 communication. Rates are as follows:

 

Program Type

Fixed Payment to Agency

Payment to Foster Parent for child 0-5 years of age

Payment to Foster Parent for child 6-12 years of age

Payment to Foster Parent for child 13+ years of age

SBWO

 $  45.00

 $14.60

 $16.50

 $18.80

SMWO

 $  69.00

 $14.60

 $16.50

 $18.80

SMFWO

 $  81.00

$14.60

$16.50

 $18.80

 

While the reimbursement rate for the provider will be a fixed program per diem, the payment to the foster parent will be handled in a parallel fashion to the Base WO and Max WO programs.  The fixed payment to the foster parent will remain directly tied to the child's age.  Any reimbursement to the foster parent above and beyond the fixed "by age" rate must be requested via the waiver process.  The Provider Relations unit will review each waiver and authorize same as appropriate.

 

An attached Word document, in the CPA Provider email communication, outlined the criteria/requirements associated with each of the three (3) programs. Please refer to it.  If you have any questions concerning these new programs, please e-mail Provider Relations at liladd@dhr.state.ga.us

 

We sincerely appreciate the cooperation of the providers who joined hands in this endeavor.  As we move forward in the new RBWO arena, we may find it again necessary to address unique client populations.  In this vein, we remain committed to partnering with the provider community to address issues jointly.

 

11.       How do agencies get approval to provide intermediate care and specialty care?

Agencies can obtain approval to provide care for children through the Provider Relations Unit for the Additional, Maximum, and Specialty (Dual Diagnosed and Medically Fragile) Oversight programs.  The organization will be asked to support evidence of the following:

 

CCI’s

·        Existing ratios of children to staff 

·        Staffing patterns and staff supervision in place

·        Staff training records

·        A examination of existing and proposed program services 

·        History of Compliance with ORS Rules and regulations

·        History of violations of DFCS policies/procedures

·        Existence of a recognized Medicaid approved provider for MH Services

CPA’s 

·        Review of overall Agency Program Experience

·        History of Compliance with ORS Rules and regulations

·        History of any violations of DFCS policies/procedures

·        Sampling of Foster Homes (documentation/onsite visits)

·        CPA’s ability to support Foster Home at the proposed level of oversight

·        Examination of training records (staff/Foster parents)

·        Interview of prospective Home(s)

·        Existence of a recognized Medicaid approved provider for MH Services

 

12.       What is the process for designating children "intermediate" or "specialty?"   

Under RBWO for CPAs, children are designated either Base for Traditional watchful oversight, Base with additional watchful oversight, Base with Maximum watchful oversight, Specialty Base Watchful Oversight (SBWO), Specialty Maximum Watchful Oversight (SMWO), or Specialty Medically Fragile Watchful Oversight. The programs are distinguished in accordance with exhibited behaviors and needs that determine the amount of watchful oversight and services required to bring about stability.

 

13.       How does DFCS plan on distinguishing between children labeled as SED and children who fall into the MWO program category?

DFCS is distinguishing programs based on the amount of watchful oversight and known services required to maintain the child’s stability, and assist the child in reaching their maximum potential.

 

14.       If CSB is the only provider in the area and they are extremely back-logged (psychological evaluations and therapy) will the agency be penalized in any way?

            No

 

15.       If agencies wanted to pay foster parents more than the established per diems, using money from private donations or grants, are they allowed to do so?

Yes, but they should not bill DFCS for more than the approved rate nor expect reimbursement from DFCS for more than the approved rate.

 

16.       Why does Neighbor to Family have a separate contract with the state?  At what rate are they compensated?  Are there other child placing agencies with separate contracts?  If so, who?

Neighbor to Family (N2F) was brought into the state to pilot a different model of service delivery – a professional foster parent model that specialized in large sibling groups.  Much of N2F’s efforts have focused on helping Fulton County DFCS to be responsive to issues related to the consent decree.  DFCS expects to have a specialized rate for this model of service and has been going over cost models and funding issues with N2F (since it is the only provider of this service model).  We expect to have new specialty rates for this service in place for July 1.

 

DFCS has also been testing two slightly different wrap-around service models.  One model operates in Region 1 with a vendor named South West Key, and another model operates in Dekalb County (with core service management done internally).

 

17.       If a child placed through a private child placing agency moves to a placement in a different child placing agency, will that child's waiver (if previously approved) transfer with the child?

Yes, the approved payment for the child will follow them to the new placement. Children should be reassessed periodically, and as at any assessment interval, if the child’s oversight needs have changed, the overall reimbursement for required services will be evaluated.

 

18.       How do you plan on placing children with special needs when they first come into foster care?  Agencies and foster parents will need to know what they will be paid in advance of accepting the child.  Sometimes there is no information available regarding the child's needs and the level of "watchful oversight" that the child will require.  (Currently, the assessment level and LOC application process addresses this issue.)

In cases where a placement is to be made and sufficient information is not available to firmly establish the best placement or the appropriate reimbursement to the provider and foster parent, the process is as follows:

 

The DFCS Case Manager in Conjunction with DFCS Provider Relations and the prospective Provider will determine an “initial assessment” of the child based on known and observed needs and behaviors.  As a result, a joint recommendation on the 1) most appropriate program assignment, 2) waiver amount (if appropriate) will be made to provide stability, safety, and well-being for the child.  A formal approval of the program assignment and any final waiver amounts (if applicable) will be determined by the DFCS Provider Relations Unit within 72 hours following receipt of the recommendation. As CCFA information is processed about a child and more definitive service needs are available, provider relations will coordinate any need for revisions to program rates and watchful oversight with the provider and the county case manager. 

 

Questions for ORS

 

19.       According to the new ORS Standards, the Human Service Professional’s (HSP) position scope is limited to very few duties.  Most of what the HSP does is related to LOC requirements.  Is there any plan for this  positions to be eliminated?  There is no need for the HSP.  The Director can complete the few things that are currently proposed by ORS.

We continue to see great value in the HSP position in order to ensure the health, safety and appropriate RBWO needs of the children and therefore we will continue to require it for the facilities. DFCS has also incorporated this entity into their contractual requirements with providers.  We see some of their roles being: 

 

*           to monitor the residents progress as they receive RBWO 

*           to document the services plans of each resident(internal non-clinical services/supports as well as external clinical/therapeutic services/supports) 

 *          HSP will be the repository for all external communication/ correspondence 

*           HSP will have to insure that brokerage(not delivery) of services/supports of all residents occur 

*           HSP will review and determine the initial and on-going appropriateness of referrals and placements based the presented behaviors and RBWO needs of the residents 

 

 20.      As the current amended ORS Standards are written, there appears to be a great deal of the therapeutic/ treatment services components required under LOC, still written.  Why are they still in the requirements under RBWO?

The CCI and OCCP Rules only speak to external therapeutic services as needed by residents of RBWO, it also makes references to issues related to behavior management and emergency safety interventions. It also speaks to external medical treatment. 
 
The CPA makes references to therapeutic foster parents who at that time of drafting new rules were still on the "drawing board" for possible waiver. They have since been designated as "families providing maximum / specialty oversight", therefore the language and references to therapeutic in that section will come out at the next Rule revision. 

 

21.       When will ORS stop holding agencies accountable for LOC requirements?  For example:  If an agency had an ORS review July 2, 2007, would the reviewer be citing for treatment/LOC components?

ORS will use effective date (June 25, 2007)of new rules as cut off date.  Prior to that time, providers will be held accountable for more specific requirements where appropriate, e.g. harm, etc.; then it will be cited and a plan of correction will be required. 

 

Questions for DMHDDAD

 

22.       Will CMS decision about IFI be announced at this meeting?

            There are ongoing negotiations with the federal Centers for Medicare and Medicaid (CMS) about the best payment mechanism for this service.  While the DCH Board has approved an "unbundled" rate for IFI, this was done proactively in the event that this is a final recommendation by the CMS.  There is no decision at the writing of this answer (June 19, 2007).

 

23.       For those smaller agencies that are transitioning over to CORE, can positions overlap until we have more clients coming in through the door, basically giving a little ramp up time rather than having a full contingent of professionals when maybe only 2 clients come through the door on any given day at first?

Residential and behavioral health programs must meet their respective staffing requirements.  Staff can not work in two programs at the same time.  DMHDDAD will allow for a provisional ramp up period of up to 6 months in Core as long as each service in core has some component of staffing available ( i.e. Physician time, nurse time, at least a half-time SA staff, at least one CSI worker). Accessibility standards must be met such as appointments within 5 business days.  DMHDDAD will also monitor access to services via BHL. The Division should not receive a problematic report of access issues during this 6 month period.

 

24.       I am being told that APS is taking 45-60 days to pay. If this is accurate, is anything being done to address this?

APS does not pay claims/encounters.  APS does process encounters for state Fee for Services .  When encounters are valid, checks are cut once a month by MHDDAD and sent to providers.  Any Medicaid claims go directly to Affiliated Computer Systems (ACS) who is a Medicaid contractor.  Our data indicates that payment to providers from ACS is usually reconciled within approximately a month.

 

25.             What is the plan for children with chronic and severe mental illnesses who don't seem to improve in a PRTF to the point that they can be stepped down? This is the population who we historically have not been able to step-down and stay for years in level 6 IRTCs.  They typically will meet acute hospitalization criteria.  

When a child fails to progress in a PRTF,  it indicates a need for a change in treatment n which may be recommended within PRTF or call for a different type of treatment outside of the PRTF.  This could be a need for acute care in a hospital setting or intensive treatment in the community as an alternative strategy.   

 

26.       We understand that in order to not disrupt children as we make the transition to PRTF, the state will pick up the funding for those children in PRTFs who no longer meet criteria. However, going forward, will this continue to be the case?  

           At this time, there are no plans to continue beyond the transition period. 

 

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Updated by Normer Adams on 06/26/07 04:47 PM -0400                                  .