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Stay informed of critical changes affecting fiscal management in California's mental health sector from the CIBHS report in April 2019.
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Mental Health Financial Issues California Institute for Behavioral Health Solutions (CIBHS) Small County Fiscal Technical Assistance April 26, 2019
Mental Health Financial Issues • Quarterly Federal Financial Management Report (QFFMR) • DHCS Information Notices • Other Fiscal Issues
Quarterly Federal Financial Management Report • The reporting of costs for the Substance Abuse Block Grant (SABG) changed as of January 1, 2019 • SABG is now retrospective reimbursement rather than advance allocation • DHCS changed the QFFMR forms to reflect reimbursement • Third Quarter (1/1/19-3/31/19) Summary form and detail General Ledger form that supports information on Summary • Report unused SABG funds in top section of Summary form • Most counties received State FY Q1 payments but State does not have authority to release SFY Q2 payments yet • DHCS has proposed hosting a webinar to address county questions • https://www.dhcs.ca.gov/provgovpart/Pages/SUD_Forms.aspx
DHCS Information Notices • 19-020 – CSI Assessment Record • 19-019 – MHSA Program Review Implementation • 19-018 – DMC-ODS Provider Selection Review Process • 19-017 – MHSA Implementation of W&I Sections 5892 and 5892.1 • 19-016 – Revisions to ODS Interim Rates • 19-015 – Establishing a FY19/20 County Contract Rate in SD/MC Claiming System • 19-014 – Approval of CAADE as DMC Certifying Organization • 19-013 – ICD 10 Revisions to SD/MC Claiming System
MHSA Program Review Implementation • DHCS Information Notice 19-019 notifies counties that DHCS will conduct program reviews of performance contracts to determine compliance • Focus is on compliance with the performance contract • Not a fiscal audit • Seventeen counties chosen for calendar year 2019 • Performance contract key elements • Submission of MHSA Annual Revenue and Expenditure Report by December 31st • MHSA funds used to expand services • Non-Supplant of existing resources • Distribution of MHSA Funds
MHSA Fiscal Changes • SB 192 added W&I Code Sections 5892 and 5892.1 • Required plan to spend the funds • Prudent Reserve Limit • Allocation of Interest • Plans to spend the funds • Counties were required to submit to the OAC by January 1, 2019 a plan on how they intend to spend all reverted and reallocated funds • Counties that did not submit a plan to the OAC must remit the reverted funds to DHCS
MHSA Fiscal Changes • Prudent Reserve Funding Limit • Counties are required to establish a prudent reserve that does not exceed 33 percent of the average CSS revenue received in the local MHS Fund in the preceding five years • Five fiscal years (FY13/14 through FY17/18) • Sum of total distributions from July 2013 through June 2018 multiplied by 76 percent divided by 5 multiplied by 33 percent • Counties must complete the calculations and certify form DHCS 1819 • Counties that exceed the limit have until June 30, 2020 to move the funds from the prudent reserve to CSS and PEI (if applicable) • Include transfer(s) in FY19/20 MHSA Annual Update • Report transfer(s) on FY19/20 MHSA Annual Revenue and Expenditure Report • Allocation of Interest • Counties must allocate interest based on the amount of interest earned by each component during the fiscal year • Applies to interest earned in FY18/19 and subsequent FY
Revisions to DMC-ODS Rates • Counties have ability to request updated DMC-ODS rates • Must submit revisions to DHCS by February 1stprior to start of the fiscal year • Fiscal Plan template • Justification for the rate change • Certified Public Expenditure data • Revised projections for units of service and beneficiaries • Basically two year lag between actual data and interim rates
SD/MC Contract Rates • County Mental Health Plans (MHPs) have the ability to limit interim rates paid to contract providers using the County Contract Rate form • Only necessary if the interim rates for contractors are higher than what the MHP wants to pay the contractor • MHPs can establish one set of contract rates for all contractors • DHCS will pay the lower of the contract rate or the amount claimed • In general, MHPs claim at interims rate equal to the rates paid to contractors • Form is not necessary • Contract rates are interim rates subject to cost settlement through the normal cost report process
Other Fiscal Issues • Allocation of MHSA Revenue and Interest • CBHDA Prudent Reserve Recommendations • Co-Practitioner Claiming • CANS and PSC-35 State General Fund allocation methodology • CBHDA MEDSLITE Recommendation • DHCS auditors interpretation of indirect costs • Redirection of future MHSA funding for WET Five Year Plan • 15% of revenues in excess of $1.9 billion after accounting for NPLH, limited to $300 million in aggregate • Allocation of OIG recoupments between funding sources • 2020 Waiver
Other Fiscal Issues • AB43 – Open Meetings • Network Adequacy • Calculation of MHSA FSP Percentage • MHSA Annual Adjustment • $443.6 million to be posted 7/1/19 • DHCS Reorganization • Audit Treatment of Units of Service