OCHN recently held four community forums to listen and respond to questions from people receiving services, their family members, and service providers about the Specialized Residential and Community Living Support (CLS) services Request for Qualifications (RFQ). The RFQ process is the first step in transitioning Specialized Residential and CLS service contracts to OCHN. The change is administrative only, and does not impact service delivery to individuals. The new contracts promote more choice and opportunity for persons served, while also complying with Michigan Department of Health and Human Services’ (MDHHS) request of the PIHPs to reduce administrative inefficiency, comply with medicaid managed care rules, and move toward conflict free case management. Questions presented during the forums, along with responses, are available in this document. All other questions regarding the RFQ can be submitted to customer services electronically (link to email) or by phone at 800.341.2003.
● PIHP: Is an acronym for Prepaid Inpatient Health Plan. Michigan has ten (10) PIHPs which receive funding from the state’s Department of Health and Human Services. PIHPs, like Oakland Community Health Network (OCHN) are responsible for managing the Medicaid resources for behavioral health and intellectual/developmental disabilities services for Medicaid and Healthy Michigan enrollees. ● Core Provider Agency (CPA): An organization funded by and contracted with OCHN to directly or indirectly provide public mental health services to people with an intellectual/developmental disabilities, mental illness, or substance use disorder. These funds include Medicaid dollars provided by the Michigan Department of Health and Human Services. ● Direct Service Provider (DSP): An organization that contracts with a CPA to deliver direct public mental health services. DSPs are also referred to as subcontractors.
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Direct Care Wages (DCW) Q. A.
With less layers of administration will DCWs increase? In addition to promoting improved choice for people by removing layers of administrative layers, this change also helps address the $30 million in Medicaid reductions that OCHN has received since 2010. Despite drastic funding cuts, OCHN continues to support increased direct care wages. (2016 DCW Press Release). (Press Release about Budget Reductions) In 2017, Michigan legislators supported an estimated $64 million statewide wage increase for direct care staff during Fiscal Year (FY) 18. OCHN received roughly $7 million of this amount. OCHN provided additional funding to the $7 million in order to achieve a $1 direct staff wage increase in FY18 to also cover employer tax increases. The $1 figure includes the original $.50 increase implemented by OCHN in 2016.
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Is OCHN aware of the staffing crisis? Yes, as noted above OCHN is dedicated to addressing DCW issues, as demonstrated by OCHN’s contribution to increase DCW wages over the last two fiscal years, involvement in state level work groups to advocate for DCW increases and working productively with providers locally to address this issue.
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How was DCW distributed? Each Core provider has a different way of paying it out and it is really confusing. OCHN distributed the total FY18 DCW funding to each core provider agency. Core provider agencies decide how the funds are distributed, in a lump sum or as a pay rate increase. Verification that the funds are distributed is required by both OCHN and Michigan’s Department of Health and Human Services.
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Direct care wage increases are impacted by state funding, and therefore are evaluated on an annual basis.
Supports & Care Coordinator / Changes in Services Q. A.
Who will provide case management to the consumers? The delivery of supports coordination and case management services to people will not change. This service is provided through agencies such as Macomb Oakland Regional Center (MORC) or Easterseals that are contracted with and funded by OCHN to provide case management, care/support coordination, and other delegated supports.
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Does OCHN want a provider network that comingles individuals with intellectual/developmental disabilities and mental illness in the same homes? Informed choice is ultimately up to an individual and where they choose to live. As has always been the case, persons served will have choice through the
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person centered planning process, including services and settings appropriate to their needs. Q. A. Q. A.
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What is the process for providers to follow when an individual’s level of services increase or decrease based on their support needs in the home? Services and the manner in which services are provided will remain unchanged and undisrupted. Who is responsible for general AFC homes/consumers? Core providers or OCHN? OCHN or its core service provider agencies never reimbursed for General Adult Foster Care settings. This is not allowable per Medicaid. Medicaid payments are only permitted for Specialized Adult Foster Care settings. However, persons residing in General Adult Foster Care settings have always been able to receive supports coordination. This practice can continue and should remain unchanged as a result of the RFQ process.
If two people live together and one decides to move and others can’t afford the housing how will this be handled by OCHN? This type of situation will remain unchanged from current practices. OCHN is committed to ensuring that individuals receiving services have the ability to make decisions about who they live with and where they live while assuring appropriate services and supports are provided. (Click Here to View Housing/Roommate Protocols.)
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Is OCHN taking over Utilization Management? Utilization Management remains unchanged from current practices as a result of the RFQ and this transition. (View OCHN’s UM Manual)
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Who is responsible to execute referrals? OCHN will house the vacancy list for providers. However, OCHN is not responsible for the placements or visits. This function will continue to be managed by supports coordinators and case managers.
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Will respite services stay with core providers? Respite Services are not impacted by this RFQ process. Contracted respite services remain under the management of core service providers contracted with and funded by OCHN.
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Who will provide annual Person-Centered Planning? The Person-Centered Planning (PCP) process will not change as a result of the RFQ. Supports coordination and case management providers will continue to coordinate the PCP process.
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What plans are in place for the notification of families/guardians if a home does not qualify for this contract? The expectation is that providers currently contracted within the OCHN network will meet the RFQ requirements. If for some reason a provider/home does not qualify, or chooses not to contract with OCHN, appropriate transition protocols are in place. Examples of OCHN’s notification and transition procedures are available on its website in the Utilization Management Manual. (Click Here to View Protocols) Is OCHN asking providers to assume additional responsibilities that can impact persons served? No. OCHN shall implement this transition without a change in funding or service responsibilities that impact people. Providers are encouraged to share their concerns/challenges in Attachment C of the RFQ. How does OCHN measure “Quality of Service” or does it use an independent third party? Specific to licensed specialized residential and unlicensed sites under contract with an OCHN core provider, OCHN, along with core provider staff, conduct audits of all residential locations. These reviews assess the physical plant of sites, review content of clinical records, and assess health and safety requirements. These health and safety standards align closely with residential licensing requirements. In regard to vacancies, will providers be able to play a role? OCHN will manage the list of homes and vacancies. Core providers will continue to assist families and individuals with placement coordination. This includes reviewing current vacancies and choices available to the person served.
Budget and Finance / Contract Specific Q. A.
If the contract takes longer than Oct. 1, 2018, what can a provider expect? OCHN is on target for contracts to begin Oct. 1, 2018. If this changes, OCHN will work with the core providers to facilitate an effective transition without disruption of services to people.
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What audits and inspections will OCHN take on and which will remain with the core service provider agencies? OCHN is assuming responsibility for all auditing functions associated with Specialized Residential and CLS supports.
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How firm is the contact language that states any concerns need to be submitted with the RFQ? Providers are worried about viewing the contract fully and not bringing all our concerns up prior to the deadline of submission of the RFQ. Providers are given the opportunity to share all concerns in a space designated in Attachment C of the RFQ. These concerns are discussed internally and shared with OCHN’s leadership. 4
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Will there still be a dollar threshold for audits? Audits are for those making $750,000 or more, will this be required for those who make less? OCHN is requiring the provider agencies to have a Financial Audit performed. There is no dollar threshold associated with this requirement. Additionally, organizations expending $750,000 or more in Federal funds in a single year are required to have a Single Audit performed each year. This is required by the Federal Government. In regard to background checks, contracts indicate it will be a requirement of the home provider, will there be funding for that? Background checks are required by the employer as a Medicaid rule. This is the employer’s responsibility as part of their administrative cost. The RFQ does not impact this rule. In regard to new arrangements being budget neutral, I would like to point out some additional cost because of the new contract language. There will be added expenses in accounting because of reporting requirements, also an increase in insurance premiums for higher coverage limits outlined by OCHN. Providers are given the opportunity to share all concerns in a space designated in Attachment C of the RFQ. These concerns are discussed internally and shared with OCHN’s leadership. (Give examples of additional costs, ie: audits.) OCHN insurance requirements are established by its PIHP contract with the State of Michigan.
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Language in the contracts states providers will be required to take individuals, Can you please explain? OCHN will not enforce inappropriate referrals. However, patterns of denials for service will need to be discussed with providers on an as need basis. There is a clause regarding collusion in the contract; should providers be concerned with sharing information, example like questions and answers? Please refer to application directions provided by OCHN when responding to RFQ questions, and refrain from collaborating with other providers during the selection process.
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Will there be an exception request process for individuals? Currently it is not part of the process. Providers are given the opportunity to share all concerns in a space designated in Attachment C of the RFQ. These concerns are discussed internally and shared with OCHN’s leadership.
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What financial information is OCHN requesting for the required monthly and quarterly reporting? OCHN will require quarterly financial statements from providers.
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Budgets – Are budgets requested for each specialized residential location or is it an organizational budget? Please provide program cost projections at an organizational level. Should providers allocate budget projections using the number of people currently being served or should it include vacancies? Providers are encouraged to provide actual revenue and costs over the past two fiscal years. This includes periods of vacancies. Providers are also encouraged to discuss cost considerations, with evidence of revenue variances, if they perceive added costs as a result of prolonged vacancies. If providers are operating under a management agreement in newly acquired AFC homes, what information is being requested by OCHN? Changes in management and operation of AFC homes requires advanced coordination with OCHN, including completion of the provider application process, a home review, and ensurance of HCBS compliance. At this time, as a foster parent I don’t receive a “Budget,” but do receive difficulty of care payments for care which I give to my foster son. This money is non-taxable income. Will this stay the same? (I do not have staff and I am not a business.) When organizations and foster families contract with OCHN, OCHN will only oversee payments for the services addressed in the RFQ - Community Living Supports. Do providers complete a separate monthly program budget document for each setting - Both licensed AFC and unlicensed CLS? Please provide a separate cost projection for both licensed and unlicensed. How should providers respond to the request for a Medicaid verification number if they do not have one? N/A can be entered in the Medicaid Number and Medicare Number sections of the RFQ Application. Providers do not need a Medicaid number. However, all providers do need a National Provider Identifier (NPI) number issued by the Centers for Medicare and Medicaid Services (CMS). The state is requiring all providers to enroll in the Community Health Automated Medicaid Processing System (CHAMPS). The application can be completed electronically (Online Application) or a paper version can be requested by phone: 1.800.465.3203.
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Could the deadline for the RFQ be extended? No. Once the RFQ timeframes are set, each date within the process impacts subsequent steps. This is necessary to result in timely contracts.
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lease expand upon the training requirements and what/how providers can P demonstrate this in the RFQ?
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Currently OCHN pays MORC and Training and Treatment Innovations (TTI) to provide network training. This process is not changing. Training requirements for service providers is remaining the same and outlined in the RFQ.
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What is built into a provider rate? Providers do not have a good break down and it is unclear how providers break out food stamps etc.? The rate determination process is currently being developed. This process involves information gathered through discussions with the core provider agencies, from data review, and documentation obtained from providers. The goal is not to change funding for service delivery to people.
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Article 111 section A.1 Q. A.
Attachment A references Skill Building and Supported Services in the Residential contract, why? Please note that the contract that was provided is merely a sample.
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Section B. Contractor Compensation, please clarify it being cost settled? The contract is fee for service.
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Section C. Is there an appeal or reconsideration for audit findings? No.
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Section D. Monthly Reporting is adventitious; can quarterly reporting suffice? OCHN will require quarterly financial statements.
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Section D. Provider Cost worksheet has not been provided. Provider cost worksheets are not required as part of this RFQ.
Article V Section II Q. A.
What are uniform Administrative requirements cost principles and standards? Uniform administrative requirement costs are regulated by federal guidelines. (Click Here to View Requirements)
Article VIII Q. A.
What is the need for OCHN to have a monthly financial report from Providers? The monthly cost projection required in the RFQ will help OCHN to establish rates going forward. Monthly financial status reporting is not required during the contract period.
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Will the RFQ be required annually? The RFQ is not required annually, but the OCHN QM department will require 7
providers complete an annual or biannual re-credentialing application to ensure that providers in the OCHN Service Network maintain qualifications and eligibility. Q. A.
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Is there an individual from OCHN who I can speak to regarding completing my RFQ? Specifically, to speak about the monthly program budget docs? All questions regarding the RFQ shall be directed to Jen Hillier, Contract & Procurement Specialist (phone: 248-975-9765 or email:
[email protected]). The Contract has a requirement for a rider endorsements from our insurance carriers who don’t really provide that anymore. What would you like us to do? OCHN was made aware of this issue during the community forum and is looking into the matter. OCHN insurance requirements are established by its PIHP contract with the State of Michigan. People have heard OCHN will no longer fund transportation to and from programs as they have in the past. What is the reason for not funding? OCHN is continuing funding for transportation. Does OCHN know of any specialized residential contracted providers that DO NOT meet the minimum Medicaid requirements? If yes, how many?? Not to the current knowledge of OCHN. OCHN anticipates providers currently contracted within the OCHN network will meet requirements. The RFQ process will provide a system-wide assessment for confirmation. Why a disparity in state funding between the West side of the state and the Detroit Area? In 2010, MDHHS began the process of rebasing to ensure that all 10 of the state’s Prepaid Inpatient Health Plans (PIHP), like OCHN, were funded equally. Communities located on the west side of the state are funded at the same rate as in the Detroit area.
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Where did OCHN get the money to pay for this building? OCHN obtained a $8 million mortgage for five years. A complete funding analysis of the purchase, including anticipated rental income, was made to OCHN’s Board in February 2018. (Click Here to View Presentation)
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Does the RFQ add another administration layer or additional expense to the service delivery system? No. The RFQ process will result in a reduction of administrative layers within the OCHN system. Additionally, funding going to services should not be impacted by this transition.
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Is there historical data to benchmark the change? Yes, OCHN is using historical data for this process. 8
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Are the steering committee “recommendations” available to review? The summary of the scoring made by the RFQ review committee will be available after the selection process is complete.
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How many contracts do you anticipate with this RFQ? Approximately 109 residential and 40 CLS service providers.
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Will you ever have a meeting just for foster families? The RFQ seems more in line for businesses. Will there be a simple application for foster families? All questions were answered that were asked by foster families during the meetings. Foster families are encouraged to complete the application as best they can. The process is not intended to be complicated. OCHN will reach out to providers to obtain additional information and clarification after a provider’s application is submitted. Landlords pay for more than a typical landlord should like paint and repairs. Will these dollars be addressed in the contract? OCHN is intending to make this a budget neutral transition. Providers are encouraged to bring these types of concerns forward during contract negotiations.
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Will State AFC requirements remain the same for obtaining licensing? This process will remain the same. Licensing is overseen by the Michigan Department of Licensing and Regulations (LARA).
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Will the training process and training requirements remain the same for providers and staff? Currently OCHN pays MORC (I/DD Population) & TTI (MI population) to provide training to the network and this process is not changing. Training requirements for service providers is remaining the same and is outlined in the contract that is part of the RFQ.
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Housing assistance ended, will this be brought back? Housing assistance is intended to be for short-term and emergency use. Medicaid doesn’t allow reimbursement for rent on an ongoing basis.
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The contract asks if providers have policies in place. Are policies and templates available to be shared? OCHN policies are available on our website for review and the format and content, where appropriate, can be used by providers as a template. (Public Policies)
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In what format does OCHN want to receive the RFQ? (Written, typed, ect.) There are no requirements, although typed is prefered.
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Will OCHN standardized Rates? Not at this time. OCHN does intend to move in the direction of outcome and performance-based contracting, to include incentives for providers based on performance and outcomes. Any such change would occur at a later date, after planning, development and discussions involving providers and persons served.
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What is the status of individuals who are Self-Determined? The RFQ will NOT affect individuals who are receiving CLS through self-determined arrangements and will only affect individuals who are receiving CLS and Specialized Residential Services (CLS in licensed setting and Personal Care) from providers who currently are directly contracted with our Core Provider Network. The RFQ does not include fiscal intermediary services.
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Please explain how/what is acceptable as proof of remedial action for substantiated rights cases for the last five (5) years? List the remedial actions for each case and attest that each has been completed. OCHN retains the right to ask for proof documents if needed.
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Can OCHN elaborate more on no more licensed settings? At this time, OCHN intends to only contract with providers and Specialized Adult Foster Care homes currently contracted within the OCHN network. The purpose of this RFQ is not to add additional licensed settings to the OCHN network. Following completion of this process, additional settings may be added, but only if needed as a result of capacity issues.
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Is there going to be a way that providers or home placements don’t get overlooked in the system. Example, Referrals from Supports Coordinators tend to stick with only certain providers. This will not be an issue, given that OCHN will manage the centralized list of all homes and vacancies.
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What is OCHN’s expertise in managing housing contracts and how many extra people did you have to hire to manage these contracts? MORC has 40 years experience. Direct contract management of services, including housing, is OCHN’s responsibility under contract with MDHHS. Additionally, OCHN helped establish and has continued to provide funding for Community Housing Network (CHN) since 2001. CHN’s mission is to provide quality, property/housing management for people with disabilities and while also ensuring them accessibility to affordable housing. (Visit CHN’s Website) As discussed during the community forum, OCHN currently plans to hire two staff members on its Service Network Team (SNT) and three staff for Quality Management.
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What is the expected outcomes of these changes? Please be specific. People will have improved choice about where they want to live and enhanced conversations about their long-term goals for independence. Choice, independence, and safe housing are areas of interest frequently identified by people served. Reduced layers of administration and improved communication between OCHN, persons served, and direct care service providers are also expected outcomes of this change.
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Does OCHN want all Recipient Rights substantiations in Oakland County such as, MORC, Easterseals, Community Living Services (CLS), etc.? Responders to the RFQ should include any violations substantiated regarding their organization specifically or any staff working for their organization for any location in which they operate. Which core provider they contract with is not relevant.
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Providers are aware that Trauma Informed Care is required for Residential providers. Is it required for CLS services as well? Can this be an “in-house” or is it required to be completed online thru MORC? OCHN’s contract with MDHHS requires that all staff, including direct care staff, are trained and has ongoing training (defined as, at minimum every three years) in Trauma Informed Care. Both MORC and TTI are available to provide this training free of charge to staff.
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Is OCHN as dedicated to Self-determination (SD) as MORC? Yes. Self-determination is identified as a priority focus under Principles and Practices in OCHN’s current Strategic Plan. OCHN also oversees the SD program and is considered the region lead of this initiative. Service providers that contract with OCHN attend regular meetings and submit quarterly SD reports to OCHN for review and discussion.
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Why was it necessary for you to buy an expensive new building when that money could have gone to increasing wages for staff and providing monies for the clients? Will you be favoring the agencies that move in your building because they are closer to you and you “see” them more regularly? No, OCHN will not favor agencies leasing space. These relationships are guided by contractual agreements.
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The decision to move OCHN’s administrative offices was impacted by several factors. Since 2014, at the state’s request to reduce layers of administration, OCHN assumed several delegated functions from its service network. These functions include Non-Emergency Access, Jail Diversion, Substance Use Disorders, Utilization Management, and Utilization Review. The Auburn Hills location simply did not meet the space needed to accommodate staffing requirements to meet these new responsibilities.
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If a setting is in the heightened scrutiny process, will the provider still be considered to provide services? Will there be more steps to take? Yes. The state requires service providers be in compliance with Home and Community Based Settings by March 2019. OCHN will still be working with providers to become compliant on October 1, 2018 when the Specialized Residential and CLS contracts go into effect.
Q&A Released 4/4/2018 (Community forum 3/26 - 3/29)
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