|Revision Date||August 1, 2019|
Contract staff must document monitoring activities in SCOR where monitoring is categorized by a review reason. Depending on the review reason, the monitoring event may only be created by COS, while others may be created by contract staff.
For the following review reasons the monitoring event will be created in SCOR by COS:
- Risk Based - when a contract is listed on the Client Services or Administrative SMP, then a monitoring event in SCOR will be created.
- Enhanced - is designated for a client services contract that meets indicators as outlined below.
For the following review reasons, the monitoring event may be created by contract staff:
- Complaint - if a complaint is brought against a contractor and it is determined that a monitoring review is necessary.
- Follow-up - any monitoring that is an additional monitoring event resulting from a risk based, enhanced, or complaint review.
Risk based monitoring is the means by which DFPS prioritizes contract monitoring as established through the Specialized Monitoring Plans (SMPs). COS is responsible for developing a client services SMPs for each contract division and an agency-wide Administrative (Admin.) SMP. The SMP is formulated using the contract manager’s assessment of risk through the completion of the applicable Risk Assessment Instrument (RAI).
Risk based monitoring is established via the SMP and is entered into SCOR by COS as a monitoring event. Once COS enters the risk based monitoring event in SCOR, contract staff are responsible for managing the event in SCOR which includes determining the monitoring type and level.
Details for the annual SMPs can be found in the following policies:
- Client Services Specialized Monitoring Plan (SMP)
- Administrative Specialized Monitoring Plan (Admin. SMP)
Enhanced monitoring is an increased level of monitoring, beyond risk based monitoring. One way enhanced monitoring can be achieved is by using a Performance Based Monitoring approach.
Enhanced monitoring is required when each of the below characteristics are met:
- Total cost or expected cost of the contract is over $10 million including all contract renewals;
- A client services contractor is responsible for decisions impacting the safety and protection of DFPS clients;
- DFPS could be negatively impacted by a contractor’s failure or delay in performance;
- Complexity of the contract (e.g. contractor responsible for managing a network of subcontractors or something similar to that level of complexity); and
- Heightened risk of loss, fraud, waste or abuse (e.g. utilization management is determined by the contractor, newly formed entity, financial weaknesses, high staff turnover, etc.).
Enhanced monitoring is not applicable for, open enrollment, interagency, or interlocal contracts.
COS initiates enhanced monitoring identification and coordinates with contract divisions to confirm all characteristics are met. For contracts where all characteristics are met, an enhanced monitoring event is created in SCOR by COS. Once this is done by COS, contract staff are responsible for managing the event in SCOR which includes reviewing the monitoring type, level and location, and adjusting as needed; as well as uploading required documentation into SCOR once the monitoring event is completed.
Complaint is a monitoring review reason that occurs in response to a complaint or concern lodged against a contractor. The complaint may come from a variety of sources such as:
- A DFPS Client
- DFPS employee
- Contractor’s employee
- Community stakeholder, or
- Another State Agency
Complaint monitoring correspondence from contract staff to the contractor is required to close out the complaint event. Correspondence should include what was reviewed and final recommendations or resolution of issue identified in complaint.
Follow-up is an additional monitoring event resulting from a risk based, enhanced, or complaint review. The risk based, enhanced, or complaint final monitoring report should indicate any required follow-up.
Follow-up monitoring correspondence from contract staff to the contractor is required to close out the follow-up event.
If findings from a follow-up monitoring event remain unresolved, contract staff should refer to Policy 4.7 Contractor Noncompliance and Contract Remedies.