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Workplace Inclusion & Sustainable Employment

Ethical Implications of Monitoring Reviews

January 2015

Workplace Inclusion & Sustainable Employment

• Ethical principles• Fidelity – keeping promises• Veracity – be honest

• Code of ethics• CRC• LPC • LMSW

• State and federal law

Professional Ethics and Contract Compliance

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Objectives1. 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

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

Panel Experts

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What is the purpose of monitoring?

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• Accountability• Performance• Here to Stay

Emphasis of the State of Texas

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Determine compliance with – policies & procedures in DRS Standards for Providers– contract terms and conditions; federal and state laws and

regulationsMonitors

– quality of services consumers are receiving– expenditure of taxpayer monies

Identifies– need for technical assistance– need for corrective action

DARS Focus

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What is the difference between quality services and contract/standards

compliance?

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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.

Quality Services

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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.

Contract and Standards Compliance

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Specific questions about DARS Forms or Standards should be emailed to:

DARSstandards@dars.state.tx.us

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Questions

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• Formal monitoring • Informal monitoring • Process, documentation and

consumer case monitoring

How does monitoring occur?

• 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

• 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

Formal monitoring - continued

• 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.

Informal 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.

Process, documentation and consumer case monitoring

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• Formal monitoring • Informal monitoring • Process, documentation and

consumer case monitoring

What are the possible outcomes of a monitoring activity?

• 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

Formal 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

Informal 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

Process, documentation and consumer case monitoring

• Formal monitoring • Informal monitoring • Process, documentation and

consumer case monitoring

What are the most common issues related to employment service monitoring activities?

• 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

Formal 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

Informal 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

Process, documentation and consumer case monitoring

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Questions

• 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

What strategies would you suggest to implement to stay compliant?

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

Emerging Topics

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?

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Specific questions about DARS Forms or Standards should be emailed to:

DARSstandards@dars.state.tx.us

If I am in doubt, with whom should I consult?

Workplace Inclusion & Sustainable Employment

Questions