Local Planning and Network Development Questions and Answers

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Questions and Answers

2010 Planning Cycle: Questions from Local Mental Health Authorities (LMHAs)


2009 Planning Cycle: Questions from Local Mental Health Authorities (LMHAs)


Planning

  1. Suppose we determine that it is not economically feasible to have two ACT providers, and we enter into a contract with an external provider to provide ACT services. In order to preserve the safety net, wouldn’t we still have to retain an ACT team in case the external provider shut down?

    • The LPND rule uses “critical infrastructure” to capture the concept of a “safety net.” It does have an exception that allows the LPND to continue providing services during a transition period to preserve critical infrastructure. This does not, however, imply that the LMHA needs to retain a redundant service structure. The critical infrastructure is protected when the network has the reliability and resiliency to provide services on a continuous basis without significant interruption. The LMHA can determine the reliability of the external network by looking at things such as the provider’s organizational history, capacity, financial resources, and past performance. The depth of the external market is another factor to consider. When there is only one provider for a service, it is particularly important to determine how long it would take to replace lost service capacity and build that into the contract as a minimum termination notice.

  2. In our community we do not have an external provider with the experience or qualifications to provide certain specialized services. Do we therefore have to look for an external provider outside of our community to ensure that the service delivery is competitive?

    • Yes. The LMHA should not restrict its potential provider base to local providers. The DSHS website and outreach efforts might help identify other qualified providers who are willing to establish services in the LMHA’s local service area. However, if the LMHA is unable to find two or more qualified and willing external providers, it may continue to provide that service to the extent needed to ensure minimum consumer choice and sufficient service capacity.

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Procurement and Contracting

  1. We have a combination of Rural and Urban Counties in our community’s service area. How can we prevent private provides from choosing to serve just the urban areas?

    • This should be addressed through your planning and procurement process. The LMHA specifies the geographic areas in which services will be provided, and it can require providers to service both rural and urban areas. Similarly, it can choose to procure a service only in specific areas. These issues would be initially addressed at the planning stage, allowing stakeholder an opportunity to provide comment. A second opportunity for public input comes when the LMHA publishes the draft RFP or RFA, which must clearly identify geographic requirements.

  2. How can we be expected to complete all of the detailed analysis necessary to conduct a procurement in six months?

    • The information in the plan will give stakeholders a good understanding of what services you will be purchasing, and what capacity will be offered. You will publish a draft of your RFP or RFA in advance of an actual procurement, after the plan has been approved.

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Implementation Issues

  1. I have questions about maintaining RDM fidelity, financial risks and core liabilities, rate management, risks for managed care, and issues involved with performance bonding. Where would I pose those questions?

    • LMHAs may have questions about how to modify their operations under the new rule. These questions are best directed to the Texas Council. LMHAs with experience contracting for services have addressed some of these issues, and the various consortia (Quality Management, Utilization Management, Chief Financial Officers, Executive Directors, etc.) are working to provide information and guidance on implementation issues.

  2. I am the central contact person for the LPND at our Center, but we also have a team of persons who are assisting with the planning and implementation. Does each person need to register or just one contact person who shares info as needed with others?

    • One goal of the LPND training modules is to ensure that everyone receives consistent and accurate information, and the web-based format is provided to make it easily accessible to all of an LMHA’s staff. Although your internal training should be based on the module, it can be done in a variety of ways. Staff can view modules individually or as a group, followed by an opportunity for discussion and questions. The website also provides a transcript and handouts for the module (six slides per page or three slides per page). If you receive questions that are not covered in the material, submit them to the LPND mailbox.

  3. If the LMHA is not responsible for actually training external providers, how does the rule address the issue of training and how does DSHS anticipate that training will take place?

    • LMHAs are responsible for providing contractors with the information they need to comply with DSHS requirements, and for ensuring that appropriate training is provided. The RFP should specify required training and how the training is to occur (or the acceptable options), with final provisions determined during the contract negotiation process. LMHAs may choose to provide this training—for example, by allowing staff of external providers to attend LMHA staff training sessions. Some external providers have training capacity within their own organizational structures and can provide the training internally. The key is to address training issues at the beginning of the procurement process and state the specific requirements in the contract.

      It is anticipated that training would center on state mandated requirements applicable to the LMHA and any contractors. It might include reporting requirements, billing instructions, types of documentation needed, etc. Training on actual services is not seen as training for an LMHA to provide.

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Other LPND Issues

  1. Module I (Slide 14) states that LPND applies to all DSHS funding (such as the Mental Health Block Grant and other grants administered by DSHS as well as State General Revenue). What other grants are there, besides the PATH grant? Are Medicaid funds included?

    • LMHAs may also receive funding through discretionary grants that are not awarded statewide. LPND does apply to Medicaid, but does not apply to substance abuse grants or funding. The rule does apply to Medicaid funding since State General Revenue funds, administered through DSHS, serve as match.

  2. In one presentation on LPND, I heard comments that contracting out Case Management was not an option. Some service packages, however, integrate case management and skills training. For example, in Service Package 3, there are components of rehabilitation where case management and service coordination are combined. I am not sure how you contract out the service package without contracting out the case management component.

    • TAC 412 I states that routine and intensive case management must be provided by a local mental health authority. According to Medicaid rules, only the local authority can provide targeted case management, which is a separate billable service. This restriction does not apply to care coordination functions associated with Psychosocial Rehabilitative Services (sometimes referred to as Rehabilitative Case Management) that are billed as part of the Psychosocial Rehabilitative Services.

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Plan Template

  1. 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.

  2. 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”).

  3. On page 3, where we list the name and address of external providers, how do we handle multiple addresses/locations?

    • Use the main or headquarter address.

  4. Will addresses or other contact information from external providers be used for any other purpose?

    • All of the information contained in the Local Service Area Plan is a public record. It is not the intent of the state to gather email or contact information for any other purpose.

  5. 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.

  6. 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?

    • No. Include only those meetings or activities that you have conducted for the purpose of planning after the submission of your last plan.

  7. 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.

  8. 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?

    • Yes. In the “Response” column, note that you maintained the contact information but did not issue an RFP.

  9. 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.

  10. 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?

    • Yes. List the costs for all services.

  11. 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.

  12. 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.

    • It is recognized that you won't know how successful an attempt to procure services will be in advance. This section identifies what you plan or intend to procure based on the information available at the time you complete the plan, including your assessment of external provider availability.

  13. 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.

  14. 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?

    • Enter the most current information available at the time you publish your plan for public comment. Please asterisk the number with a footnote indicating the date. It is not necessary to update the number before submitting to DSHS.

  15. The table on page 6 asks for current and projected capacity. If the two numbers are different, do we need to provide justification?

    • The template does not specifically require an explanation, but it would be best to include an explanatory footnote. This will help stakeholders (and DSHS) understand your rationale and probably prevent some questions.

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Contact Us

For more information, please send an email to LPND@dshs.state.tx.us.

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Last updated August 30, 2010