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Compliance Review Plan (September 2000)

I. Program Background

The Comprehensive Services Act for At-Risk Youth and Families was enacted in 1993 with the intent of creating a collaborative system of services and funding to address the needs of at-risk youth and families in Virginia that is child-centered, family-focused and community-based. Purposes of the law included:

• Ensure preservation of families and provide appropriate services in the least restrictive environment;

• Intervene early with young children and their families who are at-risk of developing emotional or behavioral problems;

• Provide and design services in response to the unique needs of youths and families and

• Increase interagency collaboration and family involvement in service delivery and management.

An essential feature of the CSA provided communities flexibility in the use of funds as well as authority for program and fiscal decision making. Communities in turn were deemed accountable for providing services in concert with the above goals.

The CSA established a single state pool of funds by consolidating eight categorical funding streams from four child-serving agencies. The funds are used to purchase residential and non-residential public or private services for troubled youth and families. The funding streams were consolidated into a single pool to place decision-making authority at the community level and provide greater flexibility in the use of the funds. In addition, it was anticipated that a single funding pool would reduce disparity in accessing services, the provision of overlapping services by multiple agencies and the inadvertent fiscal incentives for serving children according to differing matching rates.

II. Population Served

Children who would have been served by one of the funding streams placed in the pool before the CSA are targeted for CSA-purchased services. Within this group, those children who would have been served with education and/or foster care funds before the creation of the pool are considered mandatory. Funding for children considered mandatory is sum-sufficient based on federal and Code of Virginia regulation. Communities have the option of serving other children with emotional or behavioral problems by preserving a portion of their pool allocation to serve children not meeting the mandate criteria.

III. State Management

State-level oversight of the CSA consists of a two-tiered, multi-agency system. The first tier, the State Executive Council (SEC), includes the Commissioners of Health, Social Services and Mental Health, Mental Retardation and Substance Abuse Services; the Superintendent of Public Instruction; the Executive Secretary of the Virginia Supreme Court and the Directors of the Department of Juvenile Justice and Department of Medical Assistance Services. Membership also includes two local government representatives, a private provider, and a parent representative. State Executive Council responsibilities include but are not limited to the following:

• Hire and supervise a director of the Office of Comprehensive Services;

• Appoint members of the State and Local Advisory Team;

• Provide for establishment of interagency programmatic and fiscal policies;

• Provide for public participation for programmatic and fiscal guidelines;

• Oversee the use, distribution and monitoring of pool funds;

• Advise the Governor and appropriate Cabinet Secretaries on proposed policy and operational changes;

• Provide administrative support and fiscal incentives for the establishment and operation of local comprehensive service delivery systems and

• Oversee the coordination of early intervention programs to promote comprehensive coordinated service delivery, local interagency program management and collocation of programs and services in communities (Code of Virginia §2.1-746).

The Office of Comprehensive Services (OCS) is the administrative entity of the SEC and ensures that SEC decisions are carried out. Duties of OCS include but are not limited to:

• Develop and recommend to SEC program and fiscal policies.
  
• Develop and recommend to SEC interagency policies governing the use, distribution and monitoring of pool funds.
  
• Develop and provide for consistent oversight for program administration and compliance with state policies and procedures (Code of Virginia §2.1-746.1).

The second tier of state level oversight is the State and Local Advisory Team (SLAT) which includes staff from the Departments of Social Services, Juvenile Justice, Health, Education and Mental Health, Mental Retardation and Substance Abuse Services. Also included are a parent representative, private provider, family court judge, local CSA Coordinator and one representative from each of five different geographical areas of the Commonwealth who serve on Community Policy and Management Teams. (Code of Virginia section 2.1-747).

State and Local Advisory Team responsibilities include but are not limited to the following:

• Advise SEC on state policies which promote and support collaboration in the provision of services to at-risk youth at the state and local levels;

• Advise SEC on state interagency fiscal policies that promote collaboration in the provision of services

• Advise state agencies and localities on training and technical assistance necessary of provision of services responsive to the needs of at-risk youth and their families (Code of Virginia §2.1-748).

IV. Local Management

The CSA extends considerable flexibility to local governments to design and implement community-based service delivery systems within the broad framework of the legislation. Code of Virginia section 2.1-750 mandates a two-tiered, multi-agency local delivery system. The first tier is the Community Policy and Management Team (CPMT) and includes agency heads from community child-serving agencies, a private service provider, a parent representative and at least one appointed or elected official from the governing body. The local governing body appoints CPMT members. The CPMT is accountable for CSA implementation and oversight in its community and responsibilities include but are not limited to:

• Develop interagency policies and procedures governing the provision of CSA-funded services in its community, including utilization management procedures;

• Develop interagency fiscal policies governing access to CSA pool funds;

• Coordinate long-range, community wide planning which ensures resource development;

• Establish quality assurance and accountability procedures for program utilization and funds management;

• Authorize and monitor expenditure of funds by the Family Assessment and Planning Team (FAPT);

• Establish policies governing referrals of children to the FAPT and

• Provide oversight to the FAPT (Code of Virginia §2.1-752).

The second tier of the local delivery system is the FAPT, whose members are appointed by the CPMT. Membership consists of staff from community child-serving agencies and parent and provider representatives. FAPT responsibilities include but are not limited to:

• Ensure implementation of utilization management for all CSA- funded services;

• Review referrals of youth and families to the team;

• Develop individual family services plans and refer youth and families to appropriate services;

• Monitor service delivery and progress toward fulfilling individual family service plans and

• Recommend to the CPMT expenditures of pool funds (Code of Virginia §2.1-754).

V. CSA Oversight

In addition to improving care for at-risk youth and families, the CSA was enacted to influence the increasing cost of residential treatment for this group. Even with the progress made, concerns about program costs continued and prompted the SEC to commission a 1996 study which focused on the feasibility of applying utilization management to services delivered through the CSA. Study results confirmed the need and support for applying utilization management technology to the CSA.

Under the direction of the SEC, a steering committee developed a utilization management approach for CSA. Maintaining the strong emphasis placed by the CSA on local flexibility and accountability in decision-making and funds management, the SEC chose a utilization management approach that retained local flexibility and responsibility through a decision support process. The decision support process provides pertinent information and guidance in planning, implementing and monitoring services with focus on service appropriateness and cost effectiveness. Section 2.1-746 of the Code of Virginia requires localities receiving funds for activities under CSA to have a utilization management process in place for all CSA-funded services. The Appropriation Act, Chapter 924, also includes this requirement.

VI. Compliance Review

A. Purpose of Review

In addition to the collaborative nature of the program, the Code of Virginia makes clear the operational flexibility and accountability at the local level relative to CSA. Equally clear is the responsibility of the SEC for statewide oversight of CSA, including management of the distribution, use and monitoring of pool funds. A 1997 report on the review of the CSA by the Joint Legislative Audit and Review Commission emphasized the role of state-level oversight of local CSA implementation.

Consequently, the OCS under the direction of the SEC launched a CSA compliance review initiative. The CSA compliance review is a process of examination and analysis of case and program information. The review process provides the means to determine how well the local government complies with Code of Virginia and SEC requirements.

Equally as important, the compliance review process assists in identifying local government needs for technical assistance and training. It also serves as a vehicle for identifying policy issues needing to be addressed by state and local government.

The compliance review process is intended to be proactive, supportive and positive. It should provide valuable information and assistance to local staff regarding their administration of the CSA.

B. Anticipated Review Outcomes

In order to ensure effective compliance reviews, desired outcomes and a process for achieving the outcomes were established. Review of a local government’s CSA operation should provide the Commonwealth of Virginia with reasonable assurances in the following areas:

1. The local government is adhering to the Code of Virginia, CSA policies and procedures and Appropriations Act requirements.
2. The local government is adhering to its chosen utilization management plan.
3. The local government’s needs for training and technical assistance are clearly identified during the review and addressed as appropriate.

C. Review Process

The OCS conducts both routine and special compliance reviews of local CSA operations. If a program-specific concern will be addressed during the review, staff from other state agencies (Department of Social Services, Department of Education, etc.) may be included in the review as appropriate.

1. Sources of review information

CSA compliance reviews are conducted using all available information and resources. Review information will be obtained from one or a combination of the following:

• Discussion with CSA Coordinators, CPMT and FAPT chairs and others;

• CSA and other child-specific case management documentation;

• Local CSA policies and procedures, including utilization management procedures;

• Expenditure, census and other available data and

• The most current local independent audit report when CSA-related issues are cited.

2. Review Components

Compliance reviews of local governments will include the following components (all or selected):

• Local CSA census, expenditure and other statistical information

• CPMT and FAPT structures

• Local CSA policies and procedures

• Required child-specific documentation (The SEC approved utilization review guidelines and documentation standards for all CSA services in September 1998.)
  

3. Written Follow-Up

Following the review, a summary is prepared for the attention of the CPMT Chair, with copies to others as appropriate. The summary includes all or some of the following:

• Detailed information on compliance issues identified during the review;

• Key points of discussion during the review, including the local government response to the identified compliance issues;

• When appropriate, a request that the local government submit to the OCS a plan for addressing the identified compliance issues and

• When appropriate recommendations for training and technical assistance to address the identified compliance issues.
  

D. Compliance Studies

The OCS utilizes off-site compliance reviews to learn about local implementation of a specific requirement. This provides for simultaneous review of several localities relative to a targeted issue of concern. The collected information is used to identify training and technical assistance needs, and to determine the overall level of statewide compliance with a particular requirement.

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