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Workshop #5: San Francisco Citywide Contract Boilerplate ... · Handouts Build a binder for...

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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])
Transcript

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

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