From Nora Bishop, Department of Rehabilitation Services CT:
I am the Community Rehabilitation Provider Liaison for the VR Agency in Ct. We have contract language for invoicing parameters. I am attaching the contract template and have highlighted the areas you mention in Section A and Section E. If you would like to discuss further, please email me and we can set up a time for a conference call. (No attachment provided; nora.bishop@ct.gov)
Attachments: None
From Barbara Boese, State of Delaware VR:
In the attachment is our Purchase of Service Agreement, Attachment 1 which identifies if the work product is late (there are time limits) or of poor quality= incomplete; then payment may be reduced. The clause is in the contract however the standard or how we go about applying this is far too subjective from my perspective as the DVR Contracts Administrator. The contract boiler plate has dispute resolution terms that solve payment reduction and other issues. In response to the quality we have modified our monthly report to be reflective of the Placement Agreement that is consistent with Individual Plan for Employment. Therefore reports reflect back to the documents in which goals and objectives are identified with who is responsible to complete. As for timely reporting; “Houston we have a problem”. We require a monthly report due within 14 days of the end of the month during the Job Development Phase. Upon placement into a job the start date triggers a report. We require a Placement report based on the first day of employment and every month thereafter until 90 days are achieved. This is the introduction of 2 time schedules which hasn’t worked. The first schedule is monthly and second is the anniversary date of the first day on the job. And like Pavlov’s dogs reinforcement of payment for a report is the situation. Although Contractor’s are contractually required to send a 30 and 60 day job retention report, these far too often come with the 90 day retention report when the Contractor is paid the final point per our payment schedule. I have recommended to the VR counselors that we have one schedule; the end of the month, because the end of the month always comes at the same time. It makes for an easier tickler system to generate and track reports for both VR and Contractors. Counselors in one county have embraced the monthly report method versus the monthly, then placement anniversary date schedule. Contractors less positive, based upon reports are tied to money. No one wants to have a payment point for 30 day & 60 day retention report to get those reports timely. So my question is; are those intermediate retention reports essential. This is the question I am about to put to the VR Counselors and the Contractor Community.
I have quarterly Contractor Community meetings where we discuss report writing-skills training, payment and reports, policy changes and upcoming Request for Proposals and new business whatever that might be. I manage to keep those meetings productive and constructive. Every VR Counselor is welcome to attend and I invite via Outlook invitation for Contractors and VR District Administrators to attend. I am working towards identification of standards that are defined where their application is prescribed and embedded in provider contracts. These contracts are available on an intranet for all VR counselors to see the terms that they may apply to a Contractor they are working with on behalf of a client.
The Contract attached is a Summer PETS Pilot Program DVR ran in 2015. We did an informal RFP among existing providers and the contract writing took a direction toward accountability, with a quantified service deliverable and an emphasis on impact of service delivery, since the outcome was not a job placement retention goal of 90 days. However the “boiler plate”; the pages proceeding the signature page is standard and is based upon Delaware Legal Code, Title 29, Chapter 69.
It is all a work in progress for me to establish the rules of compliance; get compliance and then begin to monitor for quality assurance in VR services. I have come to VR from a different Department in State Government in which rules were well established, compliance was not an issue as rule and sophisticated quality assurance monitor of services were completed. I am not convinced that the marriage of invoices/authorizations, reporting and payment in a decentralized state agency system serves us well.
One of the first things I did when I arrived in January 2014 was to complete a billing audit. I found a systems problem. Contractors reported employment of consumers that were not specifically verified. There was no evidence of malice on the part of Contractors. I instituted a fidelity measure to verify employment through the collection of paystubs within 30 days of employment start date, or use of another counter fidelity measure, e.g. Department of Labor Employment Verification Letter to be signed by the consumer’s supervisor. This has reduced our overpayment of placements that did not occur, but I need to go back and query again to statistically know how well the remedy has worked. As for quality of service among the providers we are rolling out some standardized training for their participation which is currently a term of their contract. We have selected to utilize Elsevier College of Direct Support, Employment Services. 50 different lessons are available. We require 18 hours of ongoing training annually to be documented in an annual report. Yes, you guessed low compliance in the submission of annual reports. But I have instituted Outcome Performance Measures to be reported in order to receive final payment in some of our contracts (Summer PETS Pilot Programs 2015). This next evolution of crafting placement services that marry the concepts of WIOA and Career Pathways will weave those terms into contracts. Currently for our resource manual known as the CHOICES Booklet the “DVR Report Card” is an inclusion on each contractor in the resource manual. The providers have been given the formula to calculate their own report card to be included in the annual updated CHOICES. We are updating that annually which is my tickler to get annual reports at the conclusion of the contract year or close referrals to that provider. Money is a motivator. It has been my experience as a Contracts Administrator for more than 10 years that cash flow and compliance are related. I trust I have answered your questions, provided examples and offered insight along with my own editorial comments.
From Kathy Lowry, Oklahoma Department of Rehabilitation Services:
We will honor the invoice after the due date but will not pay interest if charged. The vendor cannot bill for interest until 45-days after receipt of a proper invoice.
If a vendor submits invoice for goods or services they provided after the funds have lapsed, a Ratification Agreement would be required in order to pay the vendor. Funding lapses 18 months after the end of fiscal year.
From Jennifer Beilke, MN State Services for the Blind:
I would be happy to talk with you about this subject. We are actually going through this process right now as well. I can tell you that we’ve recently added a clause to our contracts so that invoices received 90 days past the authorized period will not be paid. (Jennifer.Beilke@state.mn.us)
Posted in: Vendor Evaluation