Subtitle
Title
1
Professional Development & Training Series:
Behavioral Health Quality Assurance (BHQA) Staff
Workshop #5:
San Francisco Citywide Contract Boilerplate (P-600)
June 2017
San Francisco Department of Public Health
Behavioral Health Services
Quality Management
Clinical Documentation Improvement Program (CDIP)
Staff contact: Joseph A Turner, PhD ([email protected])
Handouts
Build a binder for workshop materials:
Powerpoint: steal these slides for your training!
CDIP Version of Contract, Appendices, etc.: a must-
have reference for a true QA professional
Bonus Info: Reflection on the CQI prompt from
Appendix A
Staff Contact: Joseph A Turner, PhD ([email protected]) 2
Recap on the Series
Problem: People Do Not Understand…
Quality assurance…
Managed care…
BHQA staff deserve education, training &
support:
Workshop 1: don’t have to memorize CCR Title 9, but…
Workshop 2: don’t have to our Medicaid State Plan, but …
Workshop 3: don’t have to memorize MHP Boilerplate, but…
Workshop 4: don’t have to memorize SDMC 1993 Manual, but…
Workshop 5: don’t have to memorize SF City Boilerplate, but…
Staff Contact: Joseph A Turner, PhD ([email protected]) 3
Jargon Check: Quality Assurance
4
…retrospective
comparison against
a standard
…real-time
investigation of
processes
…organized
system to monitor
& improve quality
Staff Contact: Joseph A Turner, PhD ([email protected])
5
Recap on the Series
Federal
State
County
Provider
Workshop #1 Workshop #2 Workshop #3 Workshop #4 Workshop #5
State Plan
CCR Title 9Boilerplate
Contract
1994
SDMC
Manual
SF City
Boilerplate
Contract
Staff Contact: Joseph A Turner, PhD ([email protected])
Recitals* provide background (“whereas”)
Context recitals: description of the circumstances leading up
to the parties entering into a contract
Purpose recitals: indicate (in broad/brief terms) what the parties wish to accomplish
Articles** identify the terms/rules
Groups of paragraphs which state the terms/conditions of
the agreement
The agreed upon “rules” between DPH and the contractor
6
JARGON of the San Francisco
Citywide Contract Boilerplate (P-600)
*Adams, K.A. (2013). A Manual of Style for Contract Drafting (3rd ed.). Washington: American Bar Association
**J. Hale, personal communication, 07/17/2017
Appendix A: 9 Sections
1. Program Identifiers
2. Nature/Type of Document
3. Goal Statement
4. Target Population
5. Modality/Intervention:
6. Methodology
7. Objectives & Measurements
8. Continuous Quality Improvement
Staff Contact: Joseph A Turner, PhD ([email protected]) 7
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Section Title
1 Recitals
2
(Articles)
Articles
Definitions
Terms of Agreement
Financial Matters
Services & Resources
Insurance & Indemnity
Liability of the Parties
Payment of Taxes
Terminations & Defaults
Rights in Deliverables
Additional Requirements Incorporated by Reference
General Provisions
MacBride & SignatureProtected Health Information
Additional Terms
3
(Appendices)
AppendicesA-CBHS Services to be Provided by Contractor
B-Calculation of Charges
C-Insurance Waiver
D-Additional Terms
F-Invoice
G-Dispute Resolution ProcedureH-Privacy Policy Compliance Standard
I-Declaration of Compliance
Other-FMP
Other-MHSA; SUD
Appendix B: 7 Budget Forms
1. Contract Budget Summary
2. Cost Reporting/Data Collection (CRDC)
3. Salaries & Benefits Detail
4. Operating Expenses
5. Capital Expenditures
6. Contract-Wide Indirect Expenses
7. BHS Budget Justification
Items in bold font = QM!!
Main Body of the P-600-Font Colors
Red (“legal advice from the City Attorney”)
Green (“instructions for completing the agreement”)
Appendix Instructions + Forms/Templates
The CDIP document includes the Instructions &
Forms/Templates for Appendix A (Services to be
Provided) & Appendix B (Calculation of Costs)
8
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 1-Recitals: 6 Background
“Whereas” Items
Now, THEREFORE, the parties agree as follows:
9
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
…DPH wishes (to purchase services)
…an RFP was issued (on a specific date & awarded to highest qualified scorer)
…the Local Business Entity (LBE) (subcontracting participation requirement %)
…there is no Local Business Entity (LBE) (for the contract)
…Contractor represents & warrants (it is qualified to perform the services)
…approval for this agreement was obtained (the Civil Service Commission)
Section 2-Articles: Within each of the 14
Articles are sub-articles
1. Definitions:
2. Term of the Agreement:
3. Financial Matters
10
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
1.1 Agreement
1.2 City
1.3 CMD
1.4 Contractor or Consultant
1.5 Deliverables
1.6 Effective Date
1.7 Mandatory City Requirements
1.8 Party & Parties
1.9 Services
1.1 Commencement date
3.1 Certification of Funds
3.2 Guaranteed Maximum Costs
3.3 Compensation
3.4 Audit & Inspection of Records
3.5 Submitting False Claims
ARTICLE!
SUB-ARTICLE!
Section 2-Articles: continued
4. Services & Resources
5. Insurance & Indemnity
6. Liability of Parties
7. Payment of Taxes
11
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
4.1 Services Contractor Agrees to Perform
4.2 Qualified Personnel
4.3 Subcontracting
4.4 Independent Contractor (4.4.1-Independent Contractor; 4.4.2-Payment of Employment Taxes & Other Expenses
4.5 Assignment
4.6 Warranty
5.1 Insurance
5.2 Indemnification
6.1 Liability to the City
6.2 Liability for Use of Equipment
6.3 Liability for Incidental & Consequential Damages
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 2-Articles: continued
8. Terminations & Defaults
9. Rights in Deliverables
10. Additional Requirements Incorporated by Reference
12
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
8.1 Termination for Convenience
8.2 Termination for Default; Remedies
8.3 Non-Waiver of Rights
8.4 Rights & Duties Upon Termination/Expiration
9.1 Ownership of Results
9.2 Works for Hire
10.1 Laws Incorporated by Reference 10.11 Limitations on Contributions
10.2 Conflict of Interest 10.12 Reserved
10.3 Prohibition on Use of Public Funds for Political Activity 10.13 Working with Minors
10.4 Nondisclosure of Private, Proprietary or Confidential Information 10.14 Consideration of Criminal History in Hiring & Employment
10.5 Nondiscrimination Requirements 10.15 Public Access to Nonprofit Records & Meetings
10.6 Local Business Enterprise & Non-Discrimination in Contracting 10.16 Food Service Waste Reduction Requirements
10.7 Minimum Compensation Ordinance 10.17 Reserved (Sugar-Sweetened Beverage Prohibition)
10.8 Health Care Accountability Ordinance 10.18 Tropical Hardwood & Virgin Redwood Ban
10.9 First Source Hiring Program 10.19 Reserved (Preserved Treated Wood Products)
10.10 Alcohol & Drug-Free Workplace
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 2-Articles: continued
11. General Provisions
12. MacBride & Signature
13. Protected Health Information
14. Additional Terms
13
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
11.1 Notices to the Parties 11.8 Construction
11.2 Compliance with Americans with Disabilities 11.9 Entire Agreement
11.3. Reserved 11.10 Compliance with Laws
11.4 Sunshine Ordinance 11.11 Severability
11.5 Modifications of this Agreement 11.12 Cooperative Drafting
11.6. Dispute Resolution Procedure 11.13 Order of Precedence (no P-600)
11.7. Agreement Made in California; Venue 11.14 Order of Precedence (with P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
see
slide 38
Section 3-Appendix A: Services to be
Provided (text from P-600)
1. Terms
2. Description of Services (directs you to the Narrative Template)
14
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
A-Contract Administrator L-Client Fees & Third Party Revenue
B-Reports M-CHBS Electronic Health Records System
C-Evaluation N-Patients Rights
D-Possession of Licenses/Permits O-Under-Utilization Reports
E-Adequate Resources P-Quality Improvement
F-Admission Policy Q-Working Trial Balance with Year-End Cost Report
G-San Francisco Residents Only R-Harm Reduction
H-Grievance Procedure S-Compliance with CHBS Policies & Procedures
I-Infection Control, Health & Safety T-Fire Clearance
J-Aerosol Transmissible Disease Program, Health & Safety U-Clinics to Remain Open to Referrals
K-Acknowledgement of Funding
Staff Contact: Joseph A Turner, PhD ([email protected])
slides
39-40
Section 3-Appendix B: Calculation of
Charges (text from P-600)
1. Method of Payment
2. Program Budgets & Final Invoice
15
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
A-Invoice Form & Due Date
B-Final Closing Invoice
C-Cost Reimbursement
D-Initial Payment to Contractor
A-Program Budgets (Budget Summary; Appendix B-1; Appendix B-2)
B-Compensation
C-Budget Compliance
D-Withholding Payment
E-No Liability for Late Charges
F-Failure to Expend Budgeted Revenues/Maximum Dollar Obligation
Staff Contact: Joseph A Turner, PhD ([email protected])
slides
25-31
Section 3-Appendix C: Insurance Waiver
(text from P-600)
Section 3-Appendix D: Additional Terms
(text from P-600)
(there is no Appendix E)
16
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
Protected Health Information & Business Associate Agreement
Third Party Beneficiaries
Section 3-Appendix F: Invoice (text from P-
600)
Section 3-Appendix G: Dispute Resolution
Procedure (text from P-600)
17
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 3-Appendix H: Privacy Policy
Compliance Standards (text from P-600)
18
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
• DPH Privacy Policy integrated into the program’s policies
• All staff who handle client health info are trained on privacy policies
• Privacy Notice is written/provided to client (in threshold language or interpreter)
• A summary of the Privacy Notice is posted/visible in common areas
• Each non-TPO disclosure of a client’s health info is documented
• Before releasing non-TPO (&/or substance abuse info), first obtain authorization.
see
slide 41
Section 3-Appendix I: Declaration of
Compliance (text from P-600)
Contractor attests with a “Declaration of Compliance”
Each program site has an Administrative Binder
All of the BHS required forms, policies, statements, &
documentation
Required site postings of public & client information, &
Chart compliance
BOCC may visit a program site @any time to ensure compliance
19
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
slides
42-43
Section 3-Appendices Specific to a
Program
1. FMP-State Funded Children’s Mental Health Services
2. Substance Abuse Programs
3. MHSA-Prop 65
4. FMP Disclosure of Ownership & Labor
20
Structure of the San Francisco
Citywide Contract Boilerplate (P-600)
Staff Contact: Joseph A Turner, PhD ([email protected])
21
Appendix A Narrative Template
Section 1-
BHS
Guidance from Instructions
Program
Identifiers
Program name, address,
Nature of
Document
New, renewal, modification
Goal
Statement
Provide a brief & general program goal statement (preferably one sentence).
Target
Population
Briefly describe the priority population & subpopulations to be served by the program (specific problem,
geographic area, group, age, etc..) Examples: women of childbearing age; youth between the ages of
thirteen & nineteen years; Asian/Pacific Islander gay & bisexual men; Monolingual Russian speakers
residing in the Tenderloin; etc..
Modalities/
Interventions
Table
All the service modalities provided with definitions must be listed in this section. The modalities listed here
must match the information in the program’s Budget Appendix B. The Units of Service (UOS) / Number of
Clients (NOC) / Unduplicated Clients (UDC) table with formulas may be needed. Please consult with your
CDTA Program Manager to determine if your program should use the following table.
Methodology A program may provide Direct Client Service (e.g. case management, treatment, prevention activities) or
Indirect Services (programs that do not provide direct client services), or both. Indirect Services (programs
that do not provide direct client services): Describe how the program will deliver the purchased services.
Direct Client Services: Describe how services are delivered & what activities will be provided, addressing,
how, what, & where for each section below: (A) Outreach/recruitment/promotion; (B) admission/enrollment-
intake criteria/process; (C) service delivery model/modalities/phases of treatment/LOS/service frequency-
duration; (D) discharge planning/exit criteria & process/criteria of a successful program completion; (E)
program staffing.
22
Appendix A Narrative Template
Section 1-
BHS
Guidance from Instructions
Objectives &
Measurements
Objectives will not be inserted in the Appendix A narrative, rather the objectives will be referenced in
Appendix A with the following required sentence: (AOA): “All objectives, & descriptions of how objectives
will be measured, are contained in the BHS document entitled BHS CYF/AOA Performance Objectives
FY15-16."
CQI Describe your program’s CQI activities to monitor, enhance, & improve the quality of service delivered,
including how you identify areas for improvement, & your CQI meeting structure & frequency. Include in
your description how you ensure continuous monitoring of the following:
1) Achievement of contract performance objectives & productivity;
2) Quality of documentation, including a description of the frequency/scope of chart audits;
3) Cultural competency of staff & services;
4) Satisfaction with services; &
5) Timely completion & use of outcome data, including CANS &/or ANSA data (MH)/CalOMS (SUD)
Evidence of CQI activities related to 1-5 above must be maintained in your program’s Administrative
Binder. Some examples of Evidence of CQI activities are descriptions of monitoring processes or
improvement projects, copies of meeting agendas or materials addressing these items, Avatar or BHS-
generated outcome reports, etc.. You will be required to produce a complete & up-to-date Administrative
Binder for review by the DPH Business Office Contract Compliance (BOCC) staff during monitoring visits.
Required
Language
Several DPH Systems of Care (SOC) have one or more items that must appear in the Appendix A
Program Narrative. The reason for this may be due to internal DPH guidelines, a requirement of the
original RFP, State or Federal regulations, &/or a requirement from a particular funding source
see
slide 40
23
Appendix B Forms
Form
DPH#
Form Details
1
COST BUDGET SUMMARY:
designed to show total contract funding sources and expenditures for each Provider in the contract
2
COST REPORTING/DATA COLLECTION (CRDC):
The DPH 2: CRDC form consists of four sections: (1) Provider Identification and Service Descriptions; (2) Funding
Uses; (3) Funding Sources (BHS Mental Health, BHS Substance Abuse, Other DPH-Community Programs and
Non-DPH Funding Sources); (4) Units of Service and Unit Cost
3
SALARIES & BENEFITS DETAIL:
The purpose of the Salaries and Benefits Detail worksheet is to show personnel costs associated with the
provision of direct program services.
4
OPERATING EXPENSES:
The purpose of the Operating Expense Detail worksheet is to budget for operating costs by line items, which are
associated with the provisions of direct program services
24
Appendix B Forms
Form
DPH#
Form Details
5
CAPITAL EXPENDITURES:
The purpose of the Capital Expenditure Detail worksheet is to itemize purchased equipment which costs $5,000 or
more per unit and/or to show any approved remodeling costs for the proposed transaction budget which have
been negotiated and approved by the Department of Public Health
6
CONTRACT-WIDE INDIRECT EXPENSES:
The DPH 6: Contract-Wide Indirect Cost Detail form should list the indirect amounts for positions and operating
costs for the entire contract.
7
BHS BUDGET JUSTIFICATION:
One Budget Justification per program must be prepared & submitted; however, if a funding source requires a
separate budget justification exclusively for its award, the contractor must prepare this document, too
Staff Contact: Joseph A Turner, PhD ([email protected])
25
Appendix B Forms
DPH1-Contract Budget Summary
“Contract Budget Summary” is designed to show total contract
FUNDING SOURCES and EXPENDITURES
26
Appendix B Forms
DPH2-Cost Report/Data Collection (CRDC)
CRDC form consists of four sections:
(1) Provider Identification and SERVICE DESCRIPTIONS;
(2) FUNDING USES;
(3) FUNDING SOURCES
(4) UNITS OF SERVICE and UNIT COST
27
Appendix B Forms
DPH3-Salaries & Benefits Detail
The purpose of the Salaries and Benefits Detail worksheet is to
show PERSONNEL COSTS ASSOCIATED WITH THE
PROVISION OF DIRECT PROGRAM SERVICES
28
Appendix B Forms
DPH4-Operating Expenses Detail
The purpose of the Operating Expense Detail worksheet is to
BUDGET FOR OPERATING COSTS BY LINE ITEMS,
which are ASSOCIATED WITH THE PROVISIONS OF
DIRECT PROGRAM SERVICES
29
Appendix B Forms
DPH5-Capital Expenses Detail
The purpose of the Capital Expenditure Detail worksheet is to ITEMIZE PURCHASED EQUIPMENT which costs $5,000
OR MORE PER UNIT and/or to SHOW ANY APPROVED
REMODELING COSTS for the proposed transaction budget
which have BEEN NEGOTIATED AND APPROVED by the
Department of Public Health
30
Appendix B Forms
DPH6-Contract-Wide Indirect Detail
Contract-Wide Indirect Cost Detail form should LIST THE
INDIRECT AMOUNTS FOR POSITIONS AND
OPERATING COSTS FOR THE ENTIRE CONTRACT.
31
Appendix B Forms
DPH7-BHS Budget Justification
ONE BUDGET JUSTIFICATION PER PROGRAM MUST
BE PREPARED & SUBMITTED; however, if a funding
source requires a separate budget justification exclusively for its
award, the contractor must prepare this document, too
Direct vs. Indirect Costs*
DIRECT = Costs which are clearly identifiable and
attributable to a specific program service, or activity.
INDIRECT = Costs that are NOT clearly identifiable
and attributable to a specific program/activity.
32
Appendix B-Other Materials
*from BHS Appendix B Budget Document Instructions
Per DPH-CDTA Policy, “Indirect Cost Rate Increase,”
12% is the expected Indirect Rate, but can be increased
to 15% with approval
Direct vs. Indirect Costs**
Direct costs are those which are clearly and easily attributable to a specific program or funding source.
Direct costs can generally be identified with a specific final cost objective (i.e., a particular award, project,
service, or other direct activity of an organization). However, a cost may not be assigned to an award as a
direct cost if any other cost incurred for the same purpose, in like circumstance, has been allocated to an
award as an indirect cost. Costs identified specifically with awards are direct costs of those awards and are
to be assigned directly to those awards. Costs identified specifically with other final cost objectives of the
organization are direct costs of those cost objectives and are not to be assigned to other awards directly or
indirectly. Any direct cost of a minor amount may be treated as an indirect cost for reasons of
practicality, where the accounting treatment for such cost is consistently applied to all final cost
objectives. The costs of activities performed primarily as a service to members, clients, or the
general public, when significant and necessary to the organization's mission, must be treated as
direct costs whether or not allowable and be allocated an equitable share of indirect costs. These
types of expenses are usually categorized as direct fundraising costs, and may include the
following types of activities:
Maintenance of membership rolls, subscriptions, publications, and related functions; Providing services
and information to members, legislative or administrative bodies, or the public; Promotion, advocacy, and
other forms of public relations; Meetings and conferences except those held to conduct the general
administration of the organization; Maintenance, protection, and investment of special funds not used in
operation of the organization; Administration of group benefits on behalf of members or clients, including
life and hospital insurance, annuity or retirement plans, financial aid, etc.; Salaries and benefits for
employees working with clients that are served through a single contract.33
Appendix B-Other Materials
**from Cost Allocation Guidelines For Nonprofits Doing Business With The City; http://sfcontroller.org/sites/default/files/FileCenter/Documents/610-CAguide.pdf
Direct vs. Indirect Costs**
Indirect costs are those which are not easily identifiable with one specific program but which are,
nonetheless, necessary to the operation of the program. Indirect costs cannot be easily attributed to
one activity or funding source and these costs benefit more than one activity and/or represent one
or more funding sources. These costs are shared among programs and, in some cases, among
functions (e.g., general fundraising). The Executive Director's salary is a common example of an
expense which benefits all programs and functions. Because of the diverse characteristics and
accounting practices of nonprofit organizations, it is not possible to specify the types of costs, which may
be classified as indirect costs in all situations. However, typical examples of indirect costs for many
nonprofit organizations may include use allowances on buildings and equipment, the costs of operating
and maintaining facilities, and general administration and general expenses, such as the salaries and
expenses of executive officers, personnel administration, and accounting. Further examples of indirect, or
shared costs, may include: rent, telephone, postage, printing and other expenses which benefit all
programs and functions of an organization. Depreciation costs may also be categorized as an indirect cost,
however these are subject to review by the granting agency and / or the Controller's Office. Usually, these
are administrative costs that benefit more than one activity and are not included in an indirect cost rate
agreement. These costs may be allocated to all benefiting activities/programs by pooling like costs and
allocating them using a reasonable methodology and basis.
34
Appendix B-Other Materials
**from Cost Allocation Guidelines For Nonprofits Doing Business With The City; http://sfcontroller.org/sites/default/files/FileCenter/Documents/610-CAguide.pdf
SFDPH-CDTA website
35
Contract-Related Resources
& Documents
https://www.sfdph.org/dph/comupg/aboutdph/insideDept/CDTA
Staff Contact: Joseph A Turner, PhD ([email protected])
Performance Objectives:
Specific to age (CYF, AOA, TAY)
Specific to funding (SMHS; ODS; MHSA)
Specific to section (Mental Health vs. Housing)
Domains of Outpatient MH Objectives:
Section A: Mental Health Outcomes
Section D: Data Quality & Timeliness
36
Contract-Related Resources
& Documents
Staff Contact: Joseph A Turner, PhD ([email protected])
CDTA’s Annual “What’s New” Presentation
37
Contract-Related Resources
& Documents
FACTIOID:
slide 49 tells us the P-600 Boilerplate is
new as of 01/01/2016
from FY15-16 Presentation
Section 1-Recitals:
0 (none)
Section 2-Articles:
Article 13: Protected Health Information
Contractor shall comply with all federal and state laws regarding the
transmission, storage and protection of all private health information
disclosed to Contractor by City…Contractor agrees that any failure of
Contractor to comply with the requirements of federal and/or state and/or
local privacy laws shall be a material breach of the Contract.
38
QM Elements in the
SF Citywide Contract Boilerplate
QM!
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 3-Appendix A:
Narrative Template, Item #7, Objectives &
Measurements:
Standardized Objectives
Objectives will not be inserted in the Appendix A narrative, rather the objectives
will be referenced in Appendix A with the following required sentence:
“All objectives, and descriptions of how objectives will be measured, are
contained in the BHS document entitled BHS AOA/CYF Performance
Objectives FY15-16.”
39
QM Elements in the
SF Citywide Contract Boilerplate
QM!
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 3-Appendix A:
Narrative Template, Item #8, Continuous Quality
Improvement:
Describe your program’s CQI activities to monitor, enhance, and improve the quality of service delivered,
including how you identify areas for improvement, and your CQI meeting structure and frequency. Include in
your description how you ensure continuous monitoring of the following:
Achievement of contract performance objectives and productivity;
Quality of documentation, including a description of the frequency and scope of internal chart audits;
Cultural competency of staff and services;
Satisfaction with services; and
Timely completion and use of outcome data, including CANS and/or ANSA data (MH) or CalOMS
(SUD).
Evidence of CQI activities related to 1-5 above must be maintained in your program’s Administrative Binder.
Some examples of Evidence of CQI activities are descriptions of monitoring processes or improvement
projects, copies of meeting agendas or materials addressing these items, Avatar or BHS-generated outcome
reports, etc. You will be required to produce a complete and up-to-date Administrative Binder for review by the
DPH Business Office Contract Compliance (BOCC) staff during monitoring visits.
40
QM Elements in the
SF Citywide Contract Boilerplate
QM!
Staff Contact: Joseph A Turner, PhD ([email protected])
Section 3-Appendix H:
Privacy Policy Compliance Standard:
41
QM Elements in the
SF Citywide Contract Boilerplate
Compliance Standard As Measured By…
#1: DPH Privacy Policy is integrated in the program's governing policies
and procedures regarding patient privacy and confidentiality
Existence of adopted/approved policy and procedure that
abides by the rules outlined in the DPH Privacy Policy
#2: All staff who handle patient health information are oriented (new hires)
and trained in the program's privacy/confidentiality policies & proceduresDocumentation showing individual was trained exists
#3: A Privacy Notice that meets the requirements of the Federal Privacy
Rule (HIPAA) is written and provided to all patients/clients served in their
threshold and other languages. If document is not available in the
patient’s/client’s relevant language, verbal translation is provided
Evidence in patient's/client’s chart or electronic file that
patient was "noticed."
#4: A Summary of the above Privacy Notice is posted and visible in
registration & .01common areas of treatment facilityPresence and visibility of posting in said areas
#5: Each disclosure of a patient's/client’s health information for purposes
other than treatment, payment, or operations is documentedDocumentation exists
#6: Authorization for disclosure of a patient's/client’s health information is
obtained prior to release (1) to non-treatment providers or (2) from a
substance abuse program
An authorization form that meets the requirements of the
Federal Privacy Rule (HIPAA) is available to program staff
&, when randomly asked, staff are aware of circumstances
when authorization form is needed.
QM!
Section 3-Appendix H:
Three Buckets of the “Declaration of Compliance”
ADMINISTRATIVE BINDER: with forms, policies, etc.
PREMISES: displaying posters, notices, etc.
CLINICAL CHART CHECKLIST OF CLIENT SIGNATURES:
client/staff signatures appear on forms
42
QM Elements in the
SF Citywide Contract Boilerplate
QM!
Staff Contact: Joseph A Turner, PhD ([email protected])
Clinical Chart ChecklistPremisesAdministrative Binder
Section 3-Appendix H: Declaration of
Compliance
43
QM Elements in the
SF Citywide Contract Boilerplate
QM!
• Americans with Disabilities (ADA) Form
• BHS Policy and Procedures Table of
Contents
• Client Satisfaction Survey and Analysis
Documentation
• Compliance, Privacy & Data Security
• Copies of Staff Clinical Licenses or Licensure
Waivers
• Cultural Competency Staff Report
• Emergency Response Plan
• Fire Clearance
• Harm Reduction Policy
• Infection Control, Health & Safety
• Latest Program Monitoring & Plan of Action
• Quality Assurance Plan & Activities
• Separation Notification of Staff &/or Interns
• Site/Facility Licenses
• Timely Access Documentation
• Transgender Training
• 12N Ordinance (LGBTQ Youth Sensitivity)
Training
• Trauma Informed Systems Initiative &
Workforce Training
• Wavier Requested
• Availability of Interpretation Signage
• Grievance/Appeal Information/Procedures
• HIPAA Posters
• Hours of Operation Posted
• Monitoring & Invoice Backup Documentation
• Payment Sign
• Program Utilization Review Quality
Committee
• Vocational Training Opportunities
• Accounting of Disclosures Log
• Acknowledgement of Receipt of Materials
Form
• OTHER CHART REQUIREMENTS
REQUIRING CLIENT SIGNATURE
44
Parting Thoughts…
The SF Citywide Contract
Boilerplate (P-600) is your friend!
Staff Contact: Joseph A Turner, PhD ([email protected])
SFDPH-BHS-CDIP Website:
Not a “buffet” (i.e., take what you want)
Is “pre fixe” (i.e., the chef gives you)
https://www.sfdph.org/dph/comupg/oservices/mentalHlth/CBHS/CBHSQualityMgmt.asp
Staff Contact: Joseph A Turner, PhD ([email protected]) 45
Our Resources