Sub of Sub Waivers 2018 Laura Jasso LCSW

Sub of Sub Waivers 2018 Laura Jasso, LCSW April Marek

History of the Sub of Sub Process • Prior to 2015, DSHS is aware sub of sub provider structure exists • DSHS needs to create a way to track sub of sub providers • Sub of sub documentation process begins: Sub of sub policy created 2015 First round of waiver submissions were collected RW 16 -17 grant year 11/4/2020 2

Vision for the Sub of Sub Process • Goals of the Sub of Sub process: • Ensure compliance at every level of the system • Monitoring • Equitable services across the state • El Paso to Houston • Provide insight of the number of sub providers across the state • 20? • 127? • Encourage direct contacting with AAs 11/4/2020 3

The Two Parts of the Sub of Sub Process: • Waivers • Why the AA cannot directly contract • Exceptions • Rare • Ex: Amount of private insurance a provider must carry to contract with the county is not reasonable 11/4/2020 • Sub of Sub Documentation • Contract • Personal Services Agreement • Memorandum of Understanding (MOU) • Letter of Agreement (LOA) 4

Sub of Sub Documentation • All sub of sub documents (contracts, MOUs, LOAs, etc. ) were reviewed for the following: • Provider to follow DSHS SOC • DSHS access to provider files • Flexible for policy changes • 3 rd party verification • Timely transition plan • Po. LR • Contract signed & dated • + additional language from sub contractor templates that would also be applicable to sub of subs • Old documentation was archived and new documentation was logged and saved 11/4/2020 5

Number of Subs Statewide • For the RW 16 -17 Grant Year the number of sub waivers and contract reviewed: • Bexar- 12 • BVCOG- 60 • Dallas- 1 • Lubbock- 15 • STDC- 22 • Tarrant- 6 • TRG- 11 • Because of the large quantity of sub providers adjustments will be made to the 2018 process. 11/4/2020 6

2018 Sub of Sub Expectations AA responsibility (by 4/1/18) • For current contracts, AA s must submit the expiration date for of the contract • AAs with outstanding contracts must continue to procure missing documents • Any contracts that are anticipated to end must be reported • Any new sub of sub contracts must to be submitted *Addendums and attachments will not be accepted for 2018 11/4/2020 7

Sub of Sub Template for Submission * DSHS will email copies of the sub of sub template 11/4/2020 8

Sub of Sub Policy • The Sub of Sub Policy is currently under revision • AAs will be notified when changes are solidified 11/4/2020 9

Next Steps • Laura Jasso will email the AAs the sub of sub template • AAs have until 4/1/18 to submit any missing sub of sub documentation and/or any updates to sub of sub contacts • Once the sub of sub policy is completed, the policy will go up for public comment (AAs will be notified) • Once the public comment period closes, the policy will be finalized 11/4/2020 10

Questions 11/4/2020 11

Thank you 11/4/2020 12