PLAN FOR THE DEVELOPMENT OF THE

MANAGING ENTITY/SYSTEM OF CARE

IN CIRCUIT 4 AND BAKER COUNTY

TABLE OF CONTENTS

I.      EXECUTIVE SUMMARY

II.    CIRCUIT GOALS

A.   Legislative Intent

B.   Community Consensus

C.   Model Recommended

D.   Purpose of Circuit Plan

III.   TEN BASELINE FUNCTIONS

IV.  HUMAN RESOURCES PLAN

A.   Functional Alignment of Roles and Responsibilities

B.   Staff Analysis

V.   FINANCIAL ANALYSIS

A.   SAMH Funding/Streams

B.   Administrative Costs

1.    ME

2.    Providers

VI.  SIX STAGES OF ME IMPLEMENTATION

A.   Community Education and Planning

1.    Community Meetings – Formal and Informal               

2.    Consensus and how achieved

B.   Model Development

1.    Recommended Model

2.    Use Data

C.   Procurement

1.    Competitive vs. Non-Competitive

2.    Gantt/Pert Chart

D.   Contract Negotiation

1.    Timeline

E.   Transition/Readiness Assessment

1.    Gantt/Pert Chart for Transition Plan

F.    Implementation

1.    Governing Board Composition

2.    Quarterly Reports

3.    Goals and Objectives for Implementation

I.      EXECUTIVE SUMMARY

History

Northeast Florida has a long history of community collaboration to improve behavioral health services for persons in need, with various stakeholders and advocacy groups working through separate entities. In response to the Department of Children and Families (Department) introduction of a new service system management structure, and with the requirements for community planning to select a model, these separate groups have come together to form an umbrella organization which is proposed to serve as the Managing Entity (ME) for Circuit 4 and Baker County. This proposal is for the integrated organization, Northeast Florida Behavioral Health Solutions (NEFBHS), to obtain designation as the ME for the Department’s purchased services in Baker, Duval, Clay, and Nassau counties. 

Community of Interest

The proposed geographic area includes community based behavioral prevention and treatment services and facilities that together offer a continuum of care. There are long standing business ties between the principal providers and referral agreements with stakeholders including child welfare, juvenile and criminal justice, and the schools. Due to service patterns, geography, culture and business alliances, the other circuits in the Northeast region have their own “communities of interest” and have chosen to engage in a separate planning process to establish managing entities. 

Circuit 4 providers have struggled with the mandate to implement Managing Entities because of the potential to reduce service dollars on an ongoing basis. Additionally, two factors negatively impact on the financial resources in Circuit 4.

§  The implementation of the Medicaid Reform Pilot Program in the State of Florida has significantly reduced the resources available for mental health services. With the inclusion of Baker County, 4 of the 5 reform counties in the State are in Circuit 4.

§  Circuit 4 has one of the lowest per capita allocations for mental health and substance abuse treatment services in Florida.

Thus, a key priority for Circuit 4 is to preserve service capacity in the development, implementation and ongoing operation of a Managing Entity.

Model Selected

Community stakeholders in Circuit 4 and Baker County propose as their ME model a new 501 (c)(3 ) with a governing board representing providers of direct and non-direct services, consumers and their families, advocacy and referral agencies, community leaders, and other stakeholders, with 51% of the board being non-providers. Board members will be chosen from the broad consortium that has come together to engage in system of care planning, and there are plans to create a Community Advisory Committee as well. With regard to the required ten core management functions, some may be performed by staff employed by the Board and others may be outsourced by the Board and/or or performed by community providers at the request of the Board.

Alternative to an ITN for selection of the ME

Given the broad and representative consortium that has come together to plan the ME, with the assistance of the Department’s Circuit and Regional staff, we request that the proposed organization, Northeast Florida Behavioral Health Services (NEFBHS), is designated as the ME.  If the organization continues to perform; has the capacity to carry out the ten required functions in a timely fashion; demonstrates continued broad community participation; and has successfully completed the readiness assessment, the Department will transfer current Department SAMH contracts to the ME.  If there are equally qualified vendors seeking to perform any function which is outsourced, then a competitive procurement can be initiated by the Board for that contract.   

Community goals

NEFBHS has the commitment and capacity to fulfill the spirit and expected outcomes of the Legislature’s goals in creating Behavioral Health Managing Entities.  It is our goal to develop, manage and sustain a system of care for behavioral health services that:

§  Provides quality services with proven outcomes,

§  Is family driven, youth guided, culturally and linguistically competent and

§  Is accessible to individuals and family members with mental health, substance abuse and/or co-occurring illnesses residing in Northeast Florida.   

As this process proceeds through implementation, the Board will ensure the ME continues to obtain input from the community in the development of the final plan and operating procedures for the ME.

     II. CIRCUIT GOALS

1. Legislative Intent

During the 2008 legislative session, the Florida Legislature passed House Bill 1429, amending s.394.9082, F.S., authorizing the Department to implement Behavioral Health Managing Entities or similar models for the management of mental health and substance abuse services.  The Behavioral Health ME will be responsible for the management of the delivery of behavioral health services to persons who have mental health, substance abuse or co-occurring disorders; conduct strategic planning; coordinate resources; build collaborations; accomplish the ten baseline functions; and manage the day to day operational delivery of behavioral health services through an organized system of care.  

2. Activities Leading to a Community Consensus       

The discussions among stakeholders which led to this proposal has been built on the work of several collaborating groups with a history of accomplishments.  Discussions about the best methods to create improved systems of care for Department funded and other services had been ongoing for several years.      

Adult Mental Health:

§  In 2006, the Mental Health Coalition of Jacksonville (Adult Coalition) was convened to provide vision and leadership for the adult mental health system.

§  In 2009, the Adult Coalition including providers, advocacy and funding organizations, persons served, and other community stakeholders worked with the Duval County Health Department over a 10-month period on a diversion planning process which resulted in the Duval County Criminal Justice, Mental Health and Substance Abuse Diversion Strategic Plan.

Children’s Mental Health:

§  In 2006, consumers and interdisciplinary professionals representing 32 agencies convened as the Northeast Florida Children’s Mental Health Coalition (Children’s Coalition) after completing an 18-month assets and needs assessment of children’s mental health services.

§  Since its inception, the Children’s Coalition: a) has used the Assessment as a blueprint for systems change and development; b) has grown to include over 50 organizations, professionals, providers, persons served, family members and behavioral health advocates and c) is recognized as the coordinating body for children’s behavioral health services and advocacy in Northeast Florida.

Adult Mental Health and Children’s Mental Health:

§  During the summer and fall of 2009, members of the Adult and Children’s Coalitions began a series of discussions and meetings around the need to integrate the work of both coalitions and engage substance abuse providers, constituent stakeholders and additional counties in Northeast Florida. 

Substance Abuse: 

§  In 2003 Senate Bill 2404 directed the Department to work with community agencies in Districts 4 and 12 to establish a single ME that would be accountable for the delivery of Substance Abuse Services to child protective service recipients in the two Department districts. 

§  The entity established in 2004, Northeast Florida Addictions Network, managed the Department contract for Family Intervention Specialists and the TANF funding for four years, developing model tools, protocols and systems to integrate and improve the services of the participating providers.

Substance Abuse and Mental Health:

§  During 2005 through 2008, the Department, FADAA, and the Florida Council provided ongoing training and technical assistance to mental health and substance abuse providers regarding formation of provider networks and administrative organizations to support development of a system of care.

§  In 2008, the Department Provider Board in our area established a taskforce comprised of representatives from both substance abuse and mental health service providers to begin planning.

§  In June 2009, there were 3 World Café meetings that brought together substance abuse and mental health service providers, community stakeholders, advocates, family members and consumers to discuss the community’s Behavioral Health System of Care.

§  In July 2009, the Department and FADAA provided technical assistance to Northeast Florida substance abuse and mental health providers regarding the ME model and requirements.

§  In 2009, a large regional meeting was held for all 20 counties and the CEOs of three established managing entities talked about their structure and operations.

§  In late 2009, it became clear that community stakeholders throughout the region were coalescing into three separate ME planning groups.

§  In December 2009, several community meetings were held with recipients of services, providers, agencies and advocates that resulted in a consensus to proceed with the proposal to develop the NEFBHS as the ME for Circuit 4 and Baker County.

§  In December 2009, Baker County stakeholders facilitated discussions regarding which ME structure (Circuit 3/8 or Circuit 4) best met the community’s needs.  At this time, the Baker County Board of Commissioners, Baker County School Board, Baker County Health Department, Baker County Sheriff’s Office, the County Judge, Child Guidance Center, Baker Community Counseling Services and Northeast Florida State Hospital Community Behavioral Healthcare Services have confirmed that the proposed plan in Circuit 4 would better meet the needs of the community and residents of Baker County. 

§  In January 2010, the Baker County providers began participating in Circuit 4 workgroups and meetings.

NEFBHS is composed of nearly 100 organizations, professionals, providers, consumers, family members, youth, advocates and other stakeholders committed to transform the behavioral health system in Baker, Clay, Duval and Nassau Counties. Community stakeholders who are not serving on the ME Board of Directors will have the opportunity to provide input to the Department and the ME through their participation in a Community Advisory Committee.  The following organizations are participating in the formation of NEFBHS as the coordinating body tasked to establish a system of care for behavioral health services in Northeast Florida.

Stakeholders anticipate that the collaboration will ultimately address a broader array of issues and concerns than functioning as the ME for the Department, including integration of additional revenue sources including Medicaid, the revision of financing and payment systems and obtaining additional funding.

C. Model Recommended

?  NEFBHS will be organized as a new 501 (c)(3) with a governing body selected from the numerous stakeholders engaging in this collaboration, and any other community representatives especially qualified to meet the Department’s requirements for ME Board composition. NEFBHS will both employ staff and possibly outsource some of the ten core management functions in order to establish the capacities required to ensure continued designation as the managing entity.  It is possible that NEFBHS may contract with current provider organizations in our community and/or Department designated managing entities from other areas to perform certain functions; for example, Information Technology and Financial Management.

?  The ME Board will be representative of the communities served which will include representatives of adult and children’s substance abuse and mental health services, recipients of services, family members, advocacy organizations and other community stakeholders.  A 25-member board is anticipated, with 12 representatives of provider organizations and 13 non-provider representatives as outlined in the Department’s Implementation Plan.  Those stakeholders with an interest in the work of NEFBHS who are not selected to serve on the board, may participate with a larger Community Advisory Committee.  The Community Advisory Committee will hold public meetings that will include representation from Baker, Clay, Duval and Nassau Counties. The Committee will make recommendations to the ME Board based on information obtained during the public meetings. 

?  NEFBHS will employ an Executive Director, who reports to the Governing Board in order to carry out the Board’s plans and directives, manage the administrative services established by the Board and monitor the work of subcontractors.

?  NEFBHS will use system of care principles supported by existing research.  The organization will engage the consultation and support of technical experts within and outside of the community, and other communities throughout the state and the country.

?  NEFBHS will continue to engage all stakeholders in the community to ensure the system of care reflects and responds to the diversity of the population and its service needs.

During one of the organization meetings, community stakeholders adopted “Principles for a System of Care in Northeast Florida” which includes the following:

?  Ensure local control and accountability.

?  Preservation of service dollars.

?  Ensure that management services are value added.

?  Development of consumer oriented outcome measures.

?  Expansion of flexible funding strategies and an organizational structure to eliminate silo-ed services.

?  Promote the use of data management and data sharing.

?  Reduction of duplicated services and monitoring activities.

?  Implementation of evidence-based practices and culturally competent services.

?  Ensure services are accessible, seamless.

?  Implementation of creative and cost-saving strategies.

?  Ensure substance abuse is adequately and fairly addressed.

?  Promote early identification and prevention services which provide linkage between the children and adult systems.

?  Utilize workforce development tools.

D.  Purpose of the Circuit Plan

The purpose of this Circuit Plan is to:

?  Establish the framework for NEFBHS to function as the ME.

?  Meet all the Department’s requirements for an efficient, effective, comprehensive, continuous and integrated system of care for behavioral health in Circuit 4 and Baker County.

III. TEN BASELINE FUNCTIONS

IV. HUMAN RESOURCES PLAN

A. Functional Alignment of Roles and Responsibilities

The roles and responsibilities currently presented in Attachment A of the Department’s Implementation Plan (December 2009) will be used as a framework for the development of the ME Functional Roles & Responsibilities. The roles and responsibilities of the ME may evolve from the current matrix based on Department policies. It is understood that certain roles and responsibilities will remain with the Department as per state and federal statutes.

B. Staff Analysis

Circuit 4 and Baker County SAMH Program Offices will conduct a staff analysis to determine functions/funds that can be transferred to the ME.  Further, the Department and providers will review the contract provider’s administrative structure to determine functions/funds that can be transferred to support the ME.

V.  FINANCIAL ANALYSIS

1. Administrative Costs

Current funding in Circuit 4 and Baker County is $33,003,013.  This amount includes contracted and administrative dollars from Circuit 4 and contracted dollars from Baker County to support the functions of the Substance Abuse and Mental Health Program Office. The SAMH Circuit 4 and Circuit 8 Program Office will work with the Department’s Central Office to identify functions and dollars which can be transferred to the ME.  Providers will continue with current funding, minus the amounts deducted to fund the operations of the ME, for a minimum of two years.

It is NEFBHS’s initial goal to limit annual operating costs of the ME to no more than 4 percent, which includes funds from reducing the local SAMH offices and limited reduction of contracted service dollars, with the recognition that there will be additional infrastructure development costs during start-up.  The administrative rate may be affected as the organization develops more concrete plans for performance of the ten required functions, and projects the actual costs to comply with all requirements. The actual rate paid to NEFBHS for services system management will be negotiated and approved by the Department.       

Stakeholders will work with the Department to review their current organizational structure to identify opportunities to reduce internal administrative costs as the ME assumes responsibilities currently performed by the Department.  However, it is anticipated that providers with multiple revenue sources will retain most administrative capabilities within their agencies in order to comply with the requirements of contracts not managed by the Department ME. 

Administrative costs will continuously be reviewed in order to maintain cost effectiveness and to reduce the impact to direct service dollars. As the ME continues to function, other funding streams will be researched in order to expand services and reduce the administrative rate.  Special attention will be focused on achieving efficiencies and reinvesting dollars to continuously improve services and maximize system capacity. 

                                                Circuit 4 Contracted & Administrative Funds

Baker County Funds (Contracted Only)

Included in the SAMH dollars are funding streams with specialized requirements, such as federal block grant dollars.  Substance abuse and mental health funds will be tracked separately in order to maintain compliance.  NEFBHS will comply with all regulations governing administrative costs.

VI. SIX STAGES OF ME IMPLEMENTATION

 A.   Community Education and Planning

        1. Community Meetings – Formal and Informal

§  Both the Mental Health and Substance Abuse groups have been discussing and educating stakeholders about the implementation of managing entities. In July 2009, the Department brought together mental health and substance abuse providers and interested community partners to train them on the legislation and experiences of other groups in the state.  This began the formal process of our community planning for a ME in Northeast Florida. From July through the present, workgroups have planned and coordinated efforts to gain input and direction from people throughout the community.  All minutes are kept on file with Mental Health America and area providers.  The Department and the NEFBHS will schedule community meetings (day and evening, in different locations throughout the counties) to further discuss the planning and implementation of the ME and the larger system of care.  Meetings will be posted pursuant to Department procedures.

2. Consensus and How Achieved

§  During the summer and fall of 2009, members of the Adult and Children’s Coalitions began a series of discussions and meetings around the need to integrate the work of both coalitions and engage substance abuse providers, constituent stakeholders and additional counties in Northeast Florida.  Though meeting separately for several years, on January 6, 2010, the Department provider network met and unanimously voted to join the combined Adult and Children’s Mental Health Consortium to establish the NEFBHS.  Baker County providers began participating in workgroups and meetings with the SAMH Program Office, providers, family members, recipients of services and community stakeholders.

B.     Model Development

1.    Recommended Model

?  The Model being proposed by NEFBHS, detailed in Section II, is that of a ME representing Baker, Clay, Duval and Nassau counties.  The proposed model reflects the consensus of the diverse and representative group of persons served, providers, and stakeholders who have come together as NEFBHS.  

2.    Data Use

?  Over the years, local providers, coalitions and the Department have collected data relating to community needs, service utilization and outcomes of the services provided.  This information has been used to validate the need for change and to drive the direction for the change.  NEFBHS and the Administrative Service Organization (ASO), if one is needed, contracted by the Board will design processes for system wide data collection, analysis and reporting on client demographics, services, and outcomes, utilization management, performance indicators and cost reporting.  In addition, we will continue to review data related to the location of services to ensure services are being provided in the geographic areas accessed by recipients of services.  Information will be collated and analyzed regularly to provide the Governing Board information for the quality improvement process. After the preliminary plan is approved for NEFBHS, data will be examined to ensure planning takes into account the factors identified above.

C.  Procurement Mechanism

Circuit 4 is proposing to utilize a process to noncompetitively negotiate directly with NEFBHS as the ME.  A noncompetitively negotiated contract will afford the best opportunity to obtain the terms and conditions most favorable and advantageous to the Department and the clients and communities that we serve.  This recommendation assumes that the development of the ME during 2010-2011 continues to meet the expectation of the community and that a Regulated Exemption allowed under Florida Statutes is documented for the ME services. 

The direct contracting approach would avoid the very costly and potentially divisive process, for both the Department and competing organizations, of a competitive procurement of these services. Hopefully, it would also avoid administrative protests from non community-based entities, which could be very costly to all parties involved.

Justification: Florida Statutes permits the Department to contract for substance abuse and mental health services without a competitive procurement (Ch.287 F.S., Part 1, section 287.057, (2) (f) 6&7.)  Florida Statues 394.9082  “Behavioral health managing entities” states that the legislative intent is to put in  place a management structure for the current network of safety net services, already privatized, which state and local governments have invested in for over 30 years. The ME law does not require a competitive procurement to select a management structure. 

The law emphasizes community led services planning, a representative governance and provides for a developmental process for a ME to put in place the required capacities, with the Department adding responsibilities to the NEFBHS contract as the entity is reviewed and approved for additional functions.

The ME intends to subcontract certain business functions to an ASO (Administrative Service Organization) as needed.  In the process of procuring these functions the NEFBHS will use an effective and ethical method of procurement.  The procurement process will be fair with open competition and uniform requirements in compliance with regulations contained in Federal cost principles and other administrative requirements.

Refer to the transition/readiness assessment (VI.E) for the specific timeline relative to procurement.