Contract Administration and Provider Monitoring

(CAPM)

Provider Monitoring

FMSA Monitoring Overview

Presenter: Faith Moore

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FMSA Monitoring Unit Staff

FMSA Monitoring Unit Manager

• Lettie Davis, 512-438-4593

Contract Specialists

• Flecia McLaurin, 512-438-3573

• Leokham Oconnor, 512-438-4592

Financial Analyst

• Faith Moore, 713-767-2461

• Laticia Watts, 713-767-2144

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Contract and Fiscal Compliance Monitoring

Same Monitoring Process Used for:

• Contract Compliance Monitoring

• Fiscal Compliance Monitoring

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Consumer Directed Services

HHSC Programs monitored by Provider Monitoring: Fee For Service

• CDS – Community Living Assistance and SupportServices (CLASS)

• CDS – Deaf Blind with Multiple Disabilities (DBMD)

• CDS – Home and Community-based Services (HCS)

• CDS – Primary Home Care (PHC) / Family Care (FC)/ Community Attendant Services (CAS)

• CDS – Texas Home Living (TxHmL)

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FMSA Monitoring Overview (Slide 1 of

4)

Monitoring Tools:

• Designed to accommodate a combinedreview of all Fee For Service CDS contracts,regardless of program

• Services provided by a FinancialManagement Services Agency (FMSA) arethe same across all programs

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FMSA Monitoring Overview (Slide

2 of 4)

Consists of:

• Obtaining the sample

• Sending notice of monitoring

• Conducting an entrance conference

• Complete contract and fiscal compliancemonitoring tools

• Conducting an exit conference

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FMSA Monitoring Overview (Slide

3 of 4)

Obtaining the sample

• Random

• Up to 30 individuals

• Each individual in the sample has their own randomsix-month review period

Sending Notice of monitoring

• Sent at least 14 calendar days before the monitoring

• Establishes the monitoring location

• Identifies all contracts to be reviewed

• Identifies the needed documents and records

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FMSA Monitoring Overview (Slide

4 of 4)

Conducting an Entrance Conference

• Establishes the purpose of the visit(e.g., formal or intermittent; contract orfiscal/tax compliance review)

• Introduce attendees

• Obtain agency overview

• Obtain records to be reviewed

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Complete Contract and Fiscal Compliance Monitoring Tools

Monitoring Tools Comprised of:

• Monitoring Workbook

• Individual Work Papers (IWP)

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Monitoring Workbook

• Compiles findings for all standards

• Compliance score per standard

• Overall compliance score

• Demand for Payment notice for any recoupment identified

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Individual Work Papers (IWP)

• Records findings for each sample in the review

• Populates Monitoring Workbook

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Monitoring Periods

• First formal monitoring review conducted within 15 months of contract effective date

• Intermittent Reviews Conducted within 13 months of the formal monitoring review if overall compliance score is below 90%

• Ongoing formal monitoring review conducted within 24 – 36 months of the previous formal monitoring review

• Specified on Notice of Monitoring

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Conducting an Exit Conference

At the conclusion of the monitoring review, discuss:

• Monitoring findings and provide technical assistance

• Compliance score for each individual standard

• Overall compliance score

• Demand for Payment Notice and the recoupment process (if applicable)

• Request items requiring action

• Inform the contractor of recourse options

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Two Monitoring Tools Used

• Contract Compliance Monitoring tool

• Fiscal/Tax Compliance Monitoring Tool

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Contract Compliance Monitoring Tool

• Standard I: Policies and Procedures

• Standard II: Required Background Checks andEmployment Eligibility

• Standard III: Professional Licenses

• Standard IV: Orientation and Service Initiation

• Standard V: N/A (Currently not in use)

• Standard VI: Budget

• Standard VII: Employment Requirements

• Standard VIII: Reporting Requirements

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Standard I: Policies and Procedure

• Attendance of all mandatory trainings

• Written process for LEIE checks

• LEIE logs for FMSA’s employees and on behalf of the employer’s employees.

• Complaint log and resolution

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Standard II: Background Checks and Employment Eligibility

• Required for Employees and Designated representatives

• Completion within required time frames

• Notification of results to employer within required time frame

• Eligible for employment

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Standard III: Professional Licenses

Verify license is current for all licensed service providers

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Standard IV: Orientation and Service Initiation

Orientation conducted

• Before service initiation

• With employer and designated representative, if applicable

• Required forms completed timely

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Standard V: N/A

• Currently not in use

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Standard VI: Budget

• HHSC approved/from website budget workbook is used

• Budget workbook based on service authorizations, and consistent with wage and benefits documented on Form 1730

• Written approval of the budget must be before the initiation of services and any budget revisions

• Closeout activities completed timely for individuals who transfer to another FMSA

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Standard VII: Employment Requirements

Required Forms for employees were completed as required and within the required timeframes

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Standard VIII: Reporting Requirements

• Documentation to support budget workbook(s) was provided to employer

• Documentation to support budget reports were provided to employer and case manager or service coordinator at least quarterly

• Case manager / service coordinator notified of concerns or issues regarding person’s participation

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Common Findings (Slide 1 of 2)

• LEIE policies and procedures missing required

elements

• Complaint log missing required elements

• Forms not completed by the required time

frame

• Forms 1725, 1729 and 1734 do not have the

certification box checked for the employee

(possible recoupment of the FMSA fee)

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Common Findings (Slide 2 of 2)

• Written approval of the budget not given before the initiation of services and any budget revisions

• Form 1732 not including description of the training

• Forms 1733 and 1737 not completed in their entirety

• Not obtaining the applicable Form 1735 Program Addendum

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Best Practices (Slide 1 of 2)

• Have all documents listed on notice of review readily available at the entrance conference

• Charging actual amount for conducting background checks

• Notifying the employer of background check results within 2 business days of the request

• Documenting the date quarterly reports were sent to employer and case manager or service coordinator

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Fiscal Compliance Monitoring Tool

• Standard I: IRS and TWC Submissions

• Standard II: FMSA Authorization

• Standard III: Transfers / Terminations

• Standard IV: Employee Payroll and Taxes

• Standard V: Billing

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Standard I: IRS and TWC Submissions

• IRS Form 940 and 940-R submitted timely and accurately with all employers included on Form 940-R

• FUTA calculated accurately

• TWC deposits submitted timely and accurately reflect taxes

• IRS Form 941 and 941-R Quarterly reports submitted timely and accurately

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Standard II: FMSA Authorization

New Enrollment

• SS-4 used to obtain Federal Employer Identification Number (FEIN) within 30 days of orientation

• 2678 Allows FMSA to file federal taxes on behalf of employer and done within 30 days of orientation

• 1736 document when orientation completed

Transfer In

• Documentation showing transfer date

• 2678 Allows FMSA to file federal taxes on behalf of employer and within 30 days of transfer date

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Standard III: Transfers / Terminations

• Documentation showing date of transfer

• 2678 to revoke IRS agent status and within 30 days of transfer / termination date

• Form C-43 to revoke TWC agent status and within 30 days of transfer / termination date

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Standard IV: Employee Payroll and TaxesW-2 Prepared and submitted to IRS

Form 1730

• Completed each time there’s a change in wages or benefits

• Withholdings, Required Garnishments, and Voluntary Withholdings sections completed

• Signed by employer and employee• Matches payroll

W-4• Marital status and total number of allowances

recorded• Signed by the employee• Matches payroll

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Standard V: Billing

• Verify payroll matches HHSC reimbursement

• Wages paid match Form 1730

• Hours paid are supported by service delivery records / time sheets

• Documentation to support administrative expenses that have been billed to HHSC

• Documentation to support billing of taxes to HHSC

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Best Practices (Slide 2 of 2)

• Making payments before billing HHSC

• Maintaining receipts and payment documentation for each expense billed

• Using payroll software that calculates employer and employee taxes and accommodates multiple employers

• Paying employee FIT/FICA/Med taxes and employer FICA/Med taxes with corresponding payroll

• Using the person’s effective tax rate and revising the budget each time the rate changes

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Questions ?????

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Thank You

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