Many LMHAs contract with independent physicians who function as staff. Should these physicians be identified and treated as External Providers? If an LMHA contracts with a doctor, and they work within the LMHA’s mental health clinic providing services, does the LMHA treat them as an external provider and list what they provided as services?
Under the new rule, a physician working under contract is considered an external provider. As the template indicates, the LMHA should use the definition of the term, External Provider (rather than the CAM definition).
Whether services provided by a physician are listed as services provided by an External Provider depends on the context. On page 3 of the template (Current Services and Providers), the table follows the same format used in previous years, with all discrete services listed individually. In this table, if a service is provided by a physician, a contracted physician working in an LMHA clinic would be considered an External Provider.
In the next section of the template (Provider Network Development), the table lists service packages and certain discrete services. In this context, the physician’s services are generally part of a comprehensive service package. So, if the LMHA provides and/or plans to contract the entire service package as an integrated unit, the dollars used to contract with the physician would NOT be broken out separately. If, however, the LMHA plans to procure physician services separately from the rest of the service package, the physician services would be listed as an independent entry in one of the blank rows. A physician providing services under the contract(s) that results from the procurement would be considered an External Provider.
On the first page of the template, we list the organizations participating in our planning efforts, and also state how many individuals participated according to category (consumers, family, other). Some individuals participate in more than one role. How do we determine how to classify them, and how can we accurately reflect the full level of participation within each category? For example, if a consumer attends as a representative of an advocacy organization, and we list the advocacy organization on the table, it may appear that we did not have adequate consumer input.
The table should reflect an unduplicated count of participants. Participants should be counted in the role that they themselves identify. If a consumer signs in as the representative of an organization, the organization should be listed; do not count a second time as a consumer. If an individual identifies multiple roles, use the primary role for classification. Also, please note that the column “Interested Individuals” should be used for people who are not consumers or family members. You may include footnotes to the table to give a more complete picture of the representation when individuals identify multiple roles (e.g., “three organization representatives are also consumers”).
On page 3, where we list the name and address of external providers, how do we handle multiple addresses/locations?
Will addresses or other contact information from external providers be used for any other purpose?
Is there any methodology or definitive instruction on how we to reflect the costs identified on the service procurement page?
DSHS is not prescribing a specific cost allocation methodology. The service cost should include administrative and indirect costs that support the service, but exclude administrative expenses associated with authority functions. The Texas Council and related consortia may be interested in developing a recommended methodology that provides some consistency among LMHAs.
Item (2) on the first page asks for information on individuals and organizations who have participated in planning efforts since the last planning cycle. Does this mean meetings and input reflected in our last local service area plan should be carried forward into this plan?
Page 5 asks for information for the past two (2) years relating to inquiries from external providers. Given that this is a new requirement, how are we expected to have a complete record of all inquiries?
The plan asks only for written inquiries. For this first plan, LMHAs should review their records to compile as complete a response as possible. In preparation for the next planning cycle, it would be advisable to develop a system to maintain a file of all written inquiries.
If a provider contacts us and asks to be included in the mailing list for any future RFP, and we did not issue an RFP, would that inquiry be listed?
Can you be more specific about what is expected for item (7) on page 10, in reference to diversity?
First, the response should describe what the LMHA is doing to ensure staff are culturally competent and services are delivered in a way that is appropriate for the diverse populations in the local service area and responsive to their needs. Second, the LMHA must state how it plans to ensure that external providers will appropriately address cultural diversity; which may include related contract requirements and monitoring.
In the table on page 3, do we need to identify the dollars spent on a service if we do not plan to procure the service?
Is it necessary for the cost information listed in the table on page 3 to exactly match the information in the RFP or RFA that we release?
This table should provide an accurate picture of the capacity and current funding allocated for each service. If you decide to procure a service, you will probably do a more detailed cost analysis to further refine the data. While the costs used during procurement may not be an exact match to those identified in the plan, they should not differ substantially.
In the table on Page 6, where it addresses the Service Packages and procurement, two columns ask whether or not the LMHA will procure the service and, if so, the capacity to be procured. If a service will be procured based on the availability and viability of bidders, how can we know for sure whether we can procure and how much we will be able to procure? That information won’t be available until after we put out the RFP.
On page 11 (Item 11) we are asked to explain what conditions must be present in order to attract external providers to the local service area. How does this differ from Item 10, which asks us to describe and address barriers? Is Item 11 “pie in the sky,” or should we only address issues that can realistically be addressed?
In Item 10, list specific barriers that you may be able to influence, even if only indirectly. For example, if external providers will need to provide services in remote areas on a part-time basis, the cost of leasing offices full-time might present a barrier. If the LMHA has a site-sharing arrangement with a local agency, or might be able to identify potential partners for such an arrangement, the LMHA could work with these local partners to see if they would be willing to consider site-sharing with a potential external provider.
Item 11 is intended to portray the full context of your local situation that might limit your ability to develop an external provider network, and identify what conditions would be needed to attract external providers. This may include some of the broader issues identified in Item 10 that represent long-term constraints, but it can also include local circumstances that the LMHA has no control over, such as large, sparsely populated counties.
Item 11 also provides an opportunity to describe some of the more positive aspects of the local area that are already present and might offset some of the challenges identified. Examples might include less traffic, good schools; cheap real estate, telemedicine infrastructure, favorable tax structure, etc.
Some of the information requested in the planning template may change over time. For example, current capacity is based on historical data, and that may change as new reporting periods are factored in. If we are sending out plan out for comment in May, but will not submit it to DSHS until August, the capacity in the draft and final plan will be different. Should I asterisk the figure in the draft plan?
The table on page 6 asks for current and projected capacity. If the two numbers are different, do we need to provide justification?