BAY AREA RITE
8/19/16
MEETING NOTES
Welcome and Introductions—Chris Mathiasa. Review Meeting objectives
Bay Area working on developing implementation plans for CCR
Jennie Pettet reviewed the CCR Implementation Rollout document that was handed out—likely timeline that varies depending on size of county. Document is an evolving guide. This is a CWDA document; CPOC and CBHDA are working on their own, parallel documents. There is no required plan for submission for CCR; clarified that there is a required plan for RFA to be signed by CWS and Probation.
Is the Implementation Guide that was issued by CDSS helpful to counties in guiding the various departments?
Sylvia Deporto: SF has been having multi-agency meetings using the Implementation Guide; will be meeting with providers.
Today’s agenda based on priorities set by the Regional members
2. Bay Area Regional Implementation Plan—Sylvia Deporto
1. Rationale and objectives
Bay Area has been working Regionally in parallel with the county implementation process acknowledging that they share children and families and they use the same providers. The Implementation Guide for counties has helped guide this process. CWS has tried to reach out and engage Mental Health and Probation in the process. The Regional process will help simplify the way that they work with the providers.
CDSS noted that they will be doing Regional FFA and STRTP provider convenings. Child Welfare and Mental Health Directors will be invited to those convenings. CPOC would like to make sure that they are able to make sure that their providers are invited.
3. Therapeutic Foster Care
a. DHCS presentation—Teresa Castillo & Kimberly Mayer
Developing TFC service model; received questions from the Region and will address those in the presentation. See powerpoint for details and accompanying documents
Note: still developing the model so all questions may not be answered.
What is meant by short term? Depends on medical necessity. Average length in other states is 18 months.
Is it a placement of a service? It is a service that can be provided by foster parents who will be providing specialty mental health services.
Purpose and intention: children and youth to receive mental health support in a home based setting as alternative to high level/institutional care; step-down from STRTP.
Stand alone services? No, in combination with other specialty mental health services; only three services that the resource families can provide.
Origin of TFC is Katie A. Building on ITFC and ICC. Looking at other models such as MTFC. Fitting in with the unique environment of California.
Evidence informed? So far they have developed structural aspects—infrastructure. Practices that will be delivered haven’t been described/delivered but there is no prescription for specific evidence based models (or any specific model).
Vision is that the 24/7 care provider is delivering the service---not someone coming into the home to provide specific services. There are other services that are provided that will supplement and support the foster parent.
Helpful to understand the difference between TFC and therapeutic foster care---TFC is a specific Medi-Cal service that is distinguished between what has been going on for years where therapeutic services are brought into a home to support the parents.
This will be a day rate (vs. minute-by-minute billing)—a milieu approach. This will enable families to learn therapeutic interventions throughout the day. There are disallowance concerns from Mental Health.
Eligibility criteria: Under 21 who meet medical necessity.
Service components: Plan Development, Rehabilitation, Collateral. Does not include therapy and additional clinical services that others will provide. Parents will be trained in these specific components.
Does not include room and board, adoption services, etc.
Service lockouts: when child is in psych hospital or psych nursing facility
Service provided under direction of licensed mental health professional. Need to receive training in order to considered a TFC parent—handout describes the training requirements.
TFC Program Model Service Agency; envision in the context of the county mental health plan, who contracts with organizations. Looking at FFA’s, who will be licensed by CCL and have contracts with county mental health. FFA will need site certification as specialty mental health service providers. FFA will need to meet requirements of RFA and TFC requirements, including training. Parents are working under the auspices of the FFA agency, who will have the licensed clinician overseeing the family. Site certification is the FFA, ,not the individual home. FFA will recruit and train the home, participate in the CFT, etc. FFA will provide and arrange for non-mental health services.
Parents will need to write and sign progress notes, licensed professional from FFA will review and sign the progress notes.
Reimbursement methodology: per diem rate depending on whether FFA is county operated or under contract with county mental health plan.
Parent qualifications:
Program effective 1/1/17
Meet RFA requirements
Over 21
Trained in documentation requirements (charting)
Meet HIPP requirements
Not require site certification
Not employees of the FFA
DHCS developing FAQ
Over and above RFA training---40 hours of specialized training; FFA is responsible for providing the training. County mental health will ensure training of the FFA.
Oversight and support
Parents are providing services under direction of licensed mental health professional who is an employee of the provider agency.
Parent evaluations—specific input from home visit, CFT,and self-evaluation
Next steps: DHCS will release documents about TFC Model, Parent Qualifications and FAQ’s; will update the Medi-Cal manual, ,develop training requirements, looking at service delivery models include EBP’s.
Materials will all be on CIBHS website.
Question: What happens when child no longer needs TFC service but should remain with the foster parent?
Answer: Nothing that says that the child cannot stay at the home when they no longer meet medical necessity but of course the parent won’t be receiving the payment for services.
4. Medi-Cal Certification and Capacity Building
1. DHCS—Lanette Castleman
DHCS has delegated to MHP’s the certification of RCL 13, 14 homes. They had been working on regs to make a more formal process before CCR. Since CCR they have drafted regs for this purpose. With STRTP’s coming on board, Mental Health Program approval will be a component of program approval. DHCS trying to reduce duplication of effort---combining Mental Health Program Approval process (was called certification) with Medi-Cal Certification to have one protocol, one site visit. Also working with CDSS to look at licensing regs to identify any duplication that can be eliminated by one department or the other doing it (vs. both).
Mental Health Program approval: annual requirement, annual site visit. MediCal certification requirements will be an add on every third year. Option of MHP to do the process for the STRTP providers; if they don’t opt in then DHCS will do the process. Likely that the counties will do it but DHCA is fall back if they do not. County MHP will still need to do the Medi-Cal certification part of the process and will need to coordinate with DHCS.
Hoping to have something out by mid-September for review and stakeholder input; major elements: Application, Written Program Plan (same as for other requirements), notification of changes in Plan, records retention, documentation, control of psych meds, training for staff, staff hiring process, due process, etc. Medi-Cal components that are added on are: availability of beneficiary informing requirements, specific policies and procedures including HIPPA, disaster plan, documentation requirements specific to Medi-Cal, fire clearance, head of service requirements. Medi-Cal certification depends on the services that the provider wants to deliver---basic services and specialized services that have additional requirements.
Will start training for providers in October—Medi-Cal 101, Medi-Cal documentation requirements.
1/1/17 implementation, with authority to issue instructions through ACL pending finalization of regulations.
Provisional Medi-Cal program approval will be available in first year due to anticipated volume; provisional pending the ability to make a site visit. On-site date is determinant of annual review date.
CDSS Program Statement and licensing process will address the integrity of the STRTPs’ programs.
Question: if agency has sites in many counties, who does the process? Answer: It is a site-specific process. What about FFA that has homes in more than one county? Is it where the headquarters of the agency is? Every county that has kids receiving services in the program needs a mental health contract with the provider; counties can piggy back on one another’s certification.
Same EPSDT certification and contracting has not changed.
Q: Does Juvenile Sex Offender treatment fall under medical necessity? A: Depends on the diagnosis and how you word it. If you only cite the criminal findings then it won’t qualify but if you describe the behaviors in a specific way you can justify medical necessity.
Lunch
5. Rates
1. CDSS— Foster Care Audit and Rates Branch –Greg Rose and John Sanfilipo
Talking about care and supervision rates. Key changes in new rate structure---moving from age-based rate to one that is based on assessment/screening for child’s level of needs, which correlates to a level of care. 4 levels of care in new structure. Equalizes rates for all foster parents irrespective of placement type—now licensed FFH’s and certified homes in FFAs have different rates. Working on new screening assessment tool to determine level of care to help determine rate for each child.
Also developed rates for STRTPs. Going away from RCL—all will receive the new rate when convert from GH to STRTP. Group homes can get an extension with oversight by CDSS and the county.
ITFC rates are also set by CDSS and are between the Levels 1-4 and the STRTP rate.
CDSS will do more to help inform Probation about the new rates structure.
Q: How does this affect AAP rates? A: What the child would have otherwise received if they were in foster care.
Q: What about Therapeutic Foster Care and the child’s need for permanency? A: Need to think about how you deliver intensive services to a family –ICC, ITFC, Wraparound---then can address the permanency issue in relative homes and other permanency-oriented families. There is also a rate to purchase services for the family that can add to the resources available to these families as an alternative to TFC.
Q; Wraparound rates were tied to RCL structure? Now what? A: Rate still exists based on old rates costs—Wrap rate will continue with some cost of living increase. May revisit how it evolves in the future.
Q: What rate is paid to group homes that have extensions? A: They get the RCL rate until they become an STRTP. If the provider gets all of their documentation in they will get a provisional license and STRTP rate.
Programs have to put in for an extension even if they don’t think that they will qualify to be an STRTP since there will be no way to pay them after 1/1/17 unless they have an extension approval.
CDSS will have to look at how to deal with providers that deal with special populations who do not meet medical necessity criteria and may have to think about creating additional congregate care options for these youth.
Rates for out of state placements are what the facility charges, up to the STRTP rate. They will need to meet the STRTP criteria---e.g. accreditation. CDSS is talking to out of state providers, who understand what they need to do in order to qualify and the transition process. Can waive Medi-Cal certification requirement for out of state placements.
Automation solution—CDSS meeting with SAWS consortia to make sure that they are finding a solution to this issue.
Q: Will CDSS process the applications for STRTP’s---licensing and rates—in time for 1/1/17? A: Yes.
STRTP’s and FFA’s need to be accredited by one of three—JACO, CARF, COA. Group home or FFA can submit for reimbursement of some of the costs.
6. Performance and Outcomes
1. CDSS—Sara Rogers
2 years to work out the oversight requirements but wanting to start the process of thinking about this, especially with a county lens. Want to know is it working, how can it be better. Want a technical assistance, quality improvement process that takes into account the various points of view, including counties and providers.
Program Statement allows the provider to articulate what they intend to do. The oversight system will enable counties to say whether the providers are meeting these objectives. Also linking to Rates and Accountability
AB 388---Dept. to establish a methodology using # of law enforcement calls and visits to help determine quality of the program.
AB 484—Looking a provider rates of prescribing psych meds in order to look at high rates and the development of alternative approaches.
These bills begin to offer a way of looking at provider performance.
Is there a logic model? CDSS can develop a visual that shows where oversight exists and where oversight might enhance these. A number of inputs are identified; also are required to survey youth? Matched data sets between CWS/CMS and Health. Want to know what else should be measured.
Could we develop a dashboard of performance indicators by providers that would enable counties to know how providers are doing.
Other useful measurements that could be included in the performance and oversight process?