Additional Questions for 15BCTS21Q00000002.pdf

Additional Questions for 15BCTS21Q00000002 (CTS in Billing, MT.)

Question 1: If a subcontractor does not have a CAGE code Number, are we excluded from subcontracting with them? We are specifically subcontracting some psychiatric services via telehealth and 52.204-24 (e) (3) requests the CAGE code for provider of these services.

Response: Subcontractors are not required to have a CAGE Code.

Question 2: DJAR-PGD-15-03 Security of Department Information Systems 18 (e), will an audit need to be perform to show compliance with this?

Response: Your compliance with DJAR-PGD-15-03 Security of Department Information Systems will be accessed at the time of quotation submission. Please provide all relevant document to demonstrate compliance at the time of quotation submission.

Question 3: Does a Local Area of Concern, ADA Compliance sheet, and photos need to be supplied for subcontractors?

Response: Yes. If you are planning to use a subcontractor’s facility to provide treatment, all of the requirements stated in Decisional Rule Criteria (DRC) 5 would apply.

Question 4: Chapter 11: Administration 11.1.1 indicates that Treatment providers shall not use audio/video monitoring or electronic recording of treatment sessions. We are wondering if a personal stipulation could be made for our agencies. Our agency is equipped with video surveillance in all group rooms. Individual therapy sessions, evaluations, etc. do not have surveillance. This system is not audio recorded. We use this system for the safety and security of our residents and staff and also use it as an accountability tool for taking counts of residents when not in the residential area of the building or checked out to employment or pass locations. The system has been reviewed and approved under all previous CTS, USPO, FBOP, and MT DOC onsite monitorings.

Response: No. Audio/video monitoring or the electronic recording of treatment sessions, to include group sessions, is not permitted.

Question 5: File Maintenance 11.3 The Files should be maintained on-site, in a locked file cabinet or secure area. If files are stored electronically per encryption and other requirements of 42.204-24, does that meet the definition of “secure area?”

Response: Yes. This requirement refers to paper files.

Question 6: 11.3.5 All Clinical documentation must be signed by the therapist who actually provided the service- If files are maintained electronically, including group notes, evaluations, individual counseling, etc. per 42.204-24 and 11.3.6, would a signature pad that records a signed signature in the database meet this requirement? If so, how does that relate to 8.1.5 where it indicates all original handwritten signatures needed for billing audits (comparing it to 11.3.6)? Additionally in 12.2.4 it indicates Electronic or stamped signatures are not acceptable. Can you clarify how this would pertain to all electronically kept files if an original signature on a signature pad and recorded to the electronic file would comply, especially if form C-1 could be duplicated in the electronic database?

Response: Electronic signatures are permitted on all clinical documentation; however, Treatment

Services and Accountability Logs (C-1) and Travel Logs (C-2) must be maintained with original signatures. Please note that sections 11.3.5 and 11.3.6 pertain to clinical documentation. Section

8.1.5 is relevant to the aforementioned log sheets, and 12.2.4 is specific to the requirements of the

Treatment Services and Accountability Log.

Question 7: Chapter 4: 4.2.4 Indicates that Sessions shall be process oriented in nature. For the response to the Cognitive Behavioral Therapy (CBT) Operational Requirement and reviewing 1.3 EBPs, many of the CBT compatible programming that is EBP approved by both the FBOP, CTS, USPO, and MT

DOC, are curriculum based. We have submitted and approved to be able to use certain curriculums as part of EBP and SUD groups. Could you clarify the FBOP’s expectation on these groups as how 1.3 and

4.2.4 may differ and be approved for use? If curriculums are approved as they stand under current CTS contracts, what is the process for changing curriculums and gaining approval? With a 10 year contract, it is very likely that EBP may change and more comprehensive or effect treatment models and curriculums will change in that time.

Response: The expectation of the Bureau is that all services are delivered based upon a cognitive behavioral model. Inmates should be processing their experiences of transitioning back into the community and providing feedback to one another regarding thoughts, feelings, behaviors, and beliefs. Peer interactions are the focus for group sessions rather than staff providing counseling or teaching. Use of a curriculum to conduct group sessions is unnecessary.

Question 8: I am currently viewing the active Solicitation for the Community Treatment Services needed in Billings, MT. After reviewing the services needed to be rendered, my company is inquiring if the services can be delivered via telepsychiatry, or must all services be performed on-site

Response: Contract Line Item Numbers (CLINS) 5030 Psychiatric Evaluation & Report and 6051

Medication Monitoring can be provided via telepsychiatry. All others services must be performed on-site.

Question 9: Is there a specific clinician that the site is recruiting for?(Psychiatrist, Nurse Practitioner, Clinical Psychologist, other mental health clinicians)

Response: Please review DRC 7 for the staffing requirements. In addition, Table 7c within the DRC details the type of licenses that are acceptable.