Georgia Association of Homes and Services for Children   

Level of Care Questions and Concerns
January 1, 2004

Contract Concern Clarifications (These clarifications are done by the GAHSC Staff.  These questions were given to DHR on January 20th without a written response to date.  These clarifications represent the best understanding of the Association of Level of Care and our collaborative effort with DHR.)

1.  Para 104 A - How will religious activities and staff be tracked? 
Religious activities and staffing for religious activities will be captured through the cost and time studies.  No state dollars shall be used to fund religious activities or religious staffing.

2.  Para 104a - Who is the customer and client?
The children served under the Level of Care Contract.

3.  Para 117a -  Are agencies responsible to submit all publicity concerning their agency to DHR for their approval and review?
Agencies are only to provide to DHR literature and other publications that deal with Level of Care and DHR's status in the provision of these services.  Provider information does not need DHR's approval.

4.  Par 119 - Are providers responsible for getting the approval of DHR for all research done by a provider? 
Providers are only responsible for DHR initiated research under the terms of this contract.

5.  Par 123 - Where can providers get criminal records check fingerprint cards? 
Donna Holcombe has the fingerprint cards.  She can be contacted at:  404 656 6760.

6.  Para 201 A.2 - Are providers expected to make a decision concerning a child with incomplete applications?
No, providers will be given completed applications in order to make their decisions within a specified time frame.  DFCS will use MATCH protocols to make decisions concerning the placement of a child. 

7.  Para 201, A.6 - Will providers be able to bill Medicaid Services?
Levels 1-4 providers will be able to have access to Medicaid Cards.  Joint custody children still will be served with language that recognizes a sponsoring agency of a joint custody child. 

8.  Para 201, A12 - Can providers do monthly reports in lieu of quarterly reports? 
Providers will be able to do monthly reports in lieu of quarterly reports.

9.  Para 201, A14 - How do providers comply with section 301 concerning the payment of foster parents? 
Providers will be expected not to keep a portion of the amount paid to foster parents for the care of a foster child.  Proper accounting procedures will be expected by the provider.

10.  Para 201, A18 - Will providers be expected to keep a child if it violates the requirements of the Office of Regulatory Services?
Providers will be expected to comply with all regulations by ORS.  This provision provides for 72 hour notice except for as provided in ORS standards for the health and safety of the child. 

11.  Para 201, A19 - Will providers be expected to provide weekly family counseling? 
This paragraph has been reworded to apply only to children in parental custody and will exclude all mention of family counseling except as it is in the treatment plan.

12.  Para 201, B3 - Will the Department provide "timely" service authorization for each child?
Yes, "timely" will be added to the contract.

13.  Para 301 - When children are placed in an emergency shelter at a level four or more, will the emergency shelter get the level four rate?
The child will be paid at the rate at which the child is leveled.  Emergency shelters will be paid at a level three or higher.

14.  Para 301 - What will Independent Living Providers be paid for former LOC children?  LOC children will have their own rate determined based on need.

Provider Questions

1.         Will all children in Level 4 services get Medicaid Cards?
Levels 1 through 4 children will have access to Medicaid Cards.

2.         Is the State planning to implement low rates with a freeze on the placement of children?
This is against Federal Medicaid Law and Regulations. DHR has no plans to put a freeze on children.

3.         Does the State expect agencies to provide family support services at these rates?
The State expects providers to meet the standards are indicated in the provider manual.

4.         Will the State mandate of a certain number of counseling sessions?
The State expects providers to meet the standards are indicated in the provider manual.

5.         Will the State expect to build capacity with these rates?  If yes, how?
The State sees this as a multi-year process and these represent the first steps for the State.

6.         Will the State expect step downs to be made within 60 days with the limited capacity implied by these rates?
This is the intention of the State and hope that providers will work with the State to step children down appropriately.

7.         Will there be a cost of living adjustment for FY’05?
A 5% COLA is not in the Governor's FY05 budget.

8.         Will the State expect strength-based work with these rates?
The State expects providers to meet the standards are indicated in the provider manual.  Providers can provide services that they choose within the parameters of LOC.

9.         How will reassessments in care be handled?
Reassessments will be done within sixty days.  Providers will be paid based on the assessment level.

10.               What will be the role of ORS?  Will they raise their new funds with increased fines?
Will the Department have equal regulations with the private providers?
ORS will not raise funds with increased fines.  Increased revenues from licensing fees were not in the Governor's budget.  Equal regulations for public providers comparable to private providers will require legislative changes.  The Legislature has not indicated their intentions in this regard.

11.        What will happen to wrap around services?
The State can provide wrap around services as part of the total LOC package for the children.

12.        How will the State assist agencies with the increase insurance costs?
The State has few opportunities to assist agencies with increase insurance costs except through capturing these cost in cost reports and providing added reimbursement.

13.        Do providers have to sign contracts to take new children?
Yes.  After March 1st, every provider will be required to sign a contract for services.  No contract, no foster chilren. 

14.        What will the rate be after July 1st?
A 5% increase will be forthcoming across the board for all rates.

15.        How will the $2 million in transition funds be handled?  Will providers be at the table?
Yes, we will ask the assistance of the provider community to maximize the $2 million in transition funds for providers.

16.        Will providers be expected to contract only with DHR for children services?
No.  Providers can provide services to whomever that want to provide services.

17.        How will children be assessed initially?
Children will be assessed by the treatment services unit of DHR.

18.        Will Level Six providers be protected from reassessments to lower levels while in the care of a hospital facility?
Level Six providers will be paid at Level six as long a the child is in the care of a Psychiatric Hospital.

19.        Will Providers help determine the curriculum for Level of Care training?
Undetermined.

20.        Will the publicity clause be modified in the LOC Contract?
The publicity clause will be clarified to the satisfaction of providers.  Presently the understanding is that it has to do only with reference to LOC Services that are in partnership with the State. 

21.        Will the patents clause be modified in the LOC Contract?
The patents clause will be clarified to the satisfaction of providers.

22.  Can agencies take a child on an emergeny basis?  See letter of clarification.

More Questions (to be answered later):   

1. How will the assignment of a child’s level be accomplished at intake?  Who will do it and how long will it take?
    
2. Will there be an assessment rate provided to providers at intake when the level of a child is unknown?
    
3. Are there any extra activities required by the providers during the time when the child in under assessment and a level is not determined yet?
    
4. What official notification will be given to providers to inform us a child’s level has been changed, both at intake and after reviews?
    
5. Will there be an appeal process if a provider does not agree with a level determination and how will it work?
    
6. How will a provider deal with a child whose level raises to one beyond which the provider is pre-approved to serve?  This could happen near intake and with children already in care.
    
7. Can DHR develop an indicator manual or guide that will be available for us as a means of explaining the requirements and conditions in the LOC Standards?
    
8. How will ORS do the review for compliance with the LOC Standards?  Will it be as exhaustive as the records review of the Revenue Maximization process?
    
9. How will the LOC reviews be handled?  Who will get them after they are done and how will perceived deficiencies be handled?
    
10. How will First Placement Best Placement services be integrated on a timely basis with children in our homes?
     
11. If a private provider wishes to serve a child of a level beyond the provider’s approved level, is there a process for submitting a waiver?
     
12. How do we obtain the billing forms?
     
13. If we have split rates for a new child (assessment rate and LOC rate), how is that reflected on the billing form?
     
14. The state office of DFACS states that MAPP will no longer be offered as of the spring of 2004 and that they are going to develop an “in house” program of training. The standards states that the agency must use MAPP or a “nationally approved training program.” How will this get resolved?