RFP 26-87928 Comprehensive Rehabilitative Management Needs Facility (CRMNF)

EXHIBIT A

STATEMENT OF WORK Comment by Huntley, Hayley: Note: This Statement of Work would benefit from some structural and organizational refinements to help improve clarity and consistency. In several places, information is repeated, placed in sections where it may not belong, or presented without timelines, acceptance criteria, or clearly identified responsible parties.

I. EXECUTIVE SUMMARY

These facilities play a critical role in ensuring that individuals experiencing acute or high‑risk needs receive timely, structured, and clinically informed services that promote stabilization and prepare them for successful transition back to a less restrictive community setting. CRMNFs operate under federal and state requirements, including Center for Medicare and Medicaid Services (CMS), ICF/IID regulations, relevant Indiana Administrative Code (IAC), and IDOH certification standards as outlined in CMS 42 CFR part 483.450.

If the Contractor’s proposal involves the use of State-managed systems or requires access to State data, all applicable Statewide IT Policies & Standards shall apply. If no State systems or data are used, only basic confidentiality and data handling requirements apply.

CRMNF providers will be responsible for delivering a full continuum of services including active treatment, behavioral and psychiatric support, nursing and medical oversight, habilitation programming, crisis intervention, and comprehensive discharge planning. Services must reflect person‑centered practices, trauma‑informed care, and the principles of least‑restrictive support. Providers are expected to maintain collaboration with FSSA, BDS, IDOH, guardians, and community partners to ensure coordinated, transparent, and effective service delivery.

This Scope of Work outlines operational expectations, staffing requirements, physical environment standards, documentation and communication obligations, quality improvement processes, incident management protocols, as well as financial and Medicaid responsibilities. The selected provider will play a vital role in strengthening Indiana’s service system by ensuring timely responsiveness, accountability, and high‑quality care for individuals with the most significant and complex support needs.

II. BACKGROUND AND CURRENT STATE

This facility replaces a prior CRMNF that closed in 2024 and expands statewide capacity by establishing a second operational site. Establishing this replacement facility represents a strategic step in strengthening Indiana’s continuum of care by ensuring that individuals with the most complex needs receive timely, person‑centered, and clinically appropriate stabilization services before transitioning back into the community.

III. SCOPE OF WORK

A. OBJECTIVES OF ENGAGEMENT Comment by Huntley, Hayley: Comment (Recommendation):

Consider grouping objectives under common section titles (ex: Compliance, Clinical, Staffing, Behavioral, Health, Documentation...etc.) Makes intent easier for Respondents to follow and respond to. Additionally, as it stands, the current bulleted list feels like it needs more context consider further explaining these objective in a paragraph format.

The following objectives define the core functions required of the CRMNF provider.

1. GENERAL EXPECTATIONS

· The provider must demonstrate the operational capacity to scale staffing, resources, and facility supports to serve up to twenty (20) individuals as needed.

· The provider must be able to support a diverse population of individuals with varying levels of ability, behavioral needs, and support requirements.

· The provider must demonstrate adherence to person‑centered planning principles and a commitment to supporting individuals in the least restrictive environment appropriate to their needs.

· The provider must maintain contingency plans for staffing shortages, emergency situations, technology outages, and other operational disruptions to ensure continuity of care.

· The provider must maintain the ability to collect, track, analyze, and report required data such as incidents, outcomes, staffing metrics, discharge progress in formats required by BDS or IDOH. Comment by Deidrick, Derrick: Rationale: “Formats required” lacks security/PII redaction guidance and DLP controls.

Recommendation: Add: “Apply data minimization and PII redaction as required, implement DLP scanning for exports, prohibit external email of Confidential‑Sensitive data unless encrypted (TLS 1.2+).” Comment by Kimmel, Kira D: Get clarification

· The provider must possess foundational knowledge in the following areas:

a. IDOH survey expectations including Life Safety Code requirements and emergency preparedness.

b. Applicable state codes and policies, including IAC 405, 410, and 460

c. CMS regulations related to ICF/IID certification and service delivery

d. Myers & Stauffer rate methodologies and cost‑reporting requirements

2. STAFFING, SUPERVISION & TRAINING

· The provider must implement a structured onboarding and ongoing training program that ensures staff competency in behavioral supports, medical needs, crisis intervention, documentation, trauma informed practice, and CRMNF specific expectations.

· Supervision must be maintained through adequate, qualified staffing levels that reflect the number of individuals served, their behavioral and medical needs, requirements for active treatment, and community engagement.

· Staff must receive training that prepares them to meet CRMNF‑level needs.

· Staff must remain awake and attentive to the needs of the facility on a 24‑hour basis.

· An emergency preparedness plan must be in place for instances in which adequate staffing is not available, and such occurrences must be reported to BDS.

· Staff must receive adequate, appropriate, and ongoing training related to medical and behavioral needs, crisis intervention, individual support plans, behavioral plans, and other relevant requirements.

· Staff must demonstrate competency in all required training areas.

· Staff must be supervised and routinely assessed to ensure they are functioning effectively and appropriately in supporting individuals in their care.

· Performance issues must be identified and addressed promptly.

· Supervisory staff must remain knowledgeable about and engaged in day‑to‑day activities and incidents within the facility.

· Staff must work collaboratively and communicate effectively with one another, supervisors, families/guardians, individuals, and other team members as appropriate.

· Each individual’s active treatment program must be integrated, coordinated, and monitored by a QIDP.

3. COMMUNICATION REQUIREMENTS

· The provider must develop and maintain a clear, effective, and accessible communication process for individuals, guardians (when applicable), family members, employees, service coordinators and case managers.

· The Provider must ensure that an accessible phone system is available at the facility.

· Communication regarding each individual must include all members of the Interdisciplinary Team (IDT).

· The Provider must promptly notify parents, legal guardians, and/or other authorized persons of any significant incidents or changes in an individual’s condition, including but not limited to serious illness, accident, death, abuse, or unauthorized absence.

· Communication regarding discharge goals and planning must begin at admission and continue at regular intervals throughout the individual’s placement at the CRMNF.

4. ABUSE, NEGLECT, & INCIDENT MANAGEMENT

· The Provider must develop and implement written policies and procedures that prohibit the mistreatment, neglect, abuse, or exploitation of individuals.

· The Provider must ensure that all allegations of mistreatment, neglect, abuse, and injuries of unknown origin are reported immediately to the administrator and to all required officials in accordance with State law and established procedures.

· An incident must be reported within twenty-four (24) hours by a provider or an employee or agent of a provider who is providing services to the individual at the time of the incident or becomes aware of or receives information about an incident.

· The person discovering or witnessing the incident must: ensure immediate safety measures, including calling 911 when indicated and notifying required contacts.

· The provider providing services at the time of the incident is responsible for taking appropriate and effective measures to secure the individual’s immediate safety, implementing preventative measures, and investigating reported incidents.

· Investigations must be initiated within 24 hours of the incident (or first knowledge). The provider’s investigation must include all the mandatory components as outlined in the Mandatory Components on an Investigation Policy. The investigations should be completed within thirty (30) calendar days and should include corrective action plans.

· All Abuse, Neglect, or Exploitation (ANE) or death reports must be reported to APS within 24 hours.

· For critical events (as determined by BDS), follow-up reports are required every seventy-two (72) hours until protective measures are implemented.

· The results of all investigations must be reported to the administrator or designated representative, and to any required officials in accordance with State law and policies. If an allegation is substantiated, appropriate corrective action must be implemented.

· The Provider must comply with the Bureau of Disabilities Services (BDS) incident reporting and management policy to ensure the ongoing health and welfare of individuals receiving services, including completion of all required follow up.

5. ACTIVE TREATMENT & HABILITATION

· The facility must ensure that active treatment and habilitation services are designed to prepare individuals for discharge to a less restrictive community setting.

· An Activities Director must be responsible for creating and maintaining both facility‑based and community‑based opportunities.

· Active treatment must be individualized and aligned with each person’s preferences.

· The facility must provide opportunities for socialization and participation in community activities that promote inclusion.

· An active treatment and/or activity calendar must be posted and accessible to both individuals and staff.

· In developing the ISP, the Provider must coordinate with the individual and their support team to create a plan that meets social, health, and emotional needs.

· Sufficient support staff be available to ensure that qualified and trained personnel are able to assist with activities of daily living, self-help skills, and social skill development according to each individual’s needs.

· Each individual’s active treatment program must be integrated, coordinated, and monitored by a QIDP.

6. BEHAVIORAL SERVICES

· BSPs must be developed and written by a qualified BC. BSPs must be completed within thirty (30) days of admission and must be based on an FBA.

· The BC must maintain 24‑hour availability and provide a minimum of fifteen (15) hours per week of behavioral services within the facility, including direct monitoring, assessment, intervention, and staff training. – objective of engagement

· All aspects of implementation, documentation, communication, reporting, and required timelines must follow established policies and procedures.

· Changes to the BSP should be made with participation from the individual and the interdisciplinary team whenever possible.

· Staff must be trained on any revisions or updates to a plan prior to working with the individual.

7. HEALTH SERVICES & MEDICAL MANAGEMENT

· Coordinating and attending medical appointments as necessary.

· Ensuring physician recommendations are implemented, monitored, and tracked.

· Following and routinely updating dining plans and food restrictions as required.

· Ensuring the availability and proper use of adaptive equipment.

· Managing and administering medications, including all responsibilities related to delivery, storage, packaging, documentation, and regimen review

· Ensuring the availability of prescribed and over‑the‑counter medications, including timely management and tracking of refills.

· Communicating appointment information, results, changes in condition, and medical incidents to families/guardians and/or physicians, as appropriate.

· Ensuring the availability of qualified nursing staff.

8. DISCHARGE PLANNING & TRANSITIONS

· A transitional discharge plan must be developed within the first 90 days of admission and reviewed at each quarterly meeting to assess progress. Goals must be attainable, relevant to the reason for admission, and clearly understood by all team members, including the individual.

· The individual and the interdisciplinary team (IDT) must review and update the discharge plan quarterly, or more frequently if needed, based on the individual’s changing needs.

· The discharge plan must be person‑centered and include behavioral and medical criteria for discharge, documentation of restrictions, identification of barriers, and progress notes.

· Upon meeting discharge criteria, or upon determination that the individual is no longer appropriate for the CRMNF level of care, the individual is expected to transition from the facility within six months.

· Once discharge criteria are met, planning meetings must occur at least monthly to monitor progress and address any barriers, delays, or concerns. Meetings should include the Case Management Organization (CMO) when applicable.

· The discharge planning process must include preparation of both the individual and the receiving provider/staff to ensure a smooth and successful transition.

· Any delays or barriers to discharge caused by guardians must be documented and addressed with the BDS to allow for the use of placement authority when deemed appropriate by BDS.

9. ADMISSIONS

· The Provider must review the referral packet within five (5) business days and provide a recommendation or decision within ten (10) business days.

· BDS expects the Provider to be able to accept all referrals submitted. If the Provider has concerns that may lead to a potential denial, a meeting with BDS staff is required prior to any denial to review the individual’s needs and the Provider’s concerns.

· A transition meeting must be held and include the individual, guardian (if applicable), family (if applicable), BDS staff, the previous provider team (if applicable), and the CRMNF team.

· All requested documents must be submitted to BDS prior to admission.

· The Provider must provide a staffing schedule demonstrating the capacity to appropriately meet the needs of the individual.

· Prior to admission, all staff must be trained on applicable materials, including high‑risk plans (medical and behavioral), the behavior plan, and individual‑specific training.

· Admission must be formally approved by BDS before the individual may be admitted.

10. ENVIRONMENTAL SAFETY & FACILITY MAINTENANCE

· Maintaining a facility that is in good repair, clean, sanitary, and free from odors.

· Ensuring that kitchen areas remain clean and sanitary, with all food properly stored and dated.

· Providing sleeping accommodations that comply with applicable CMS certification standards.

· Supplying appropriate furnishings that support comfort, safety, and dignity

· Implementing environmental adaptations as needed to support individuals with intensive needs.

· Ensuring all fire and safety systems meet current Life Safety Code requirements (IDOH)

· Providing routine housekeeping services

· Maintaining the building to ensure ongoing safety and functionality.

· Maintaining exterior grounds to promote safety and accessibility.

· Developing and maintaining an emergency preparedness plan, including procedures for relocation when necessary.

11. QUALITY IMPROVEMENT

The provider must implement and maintain strong internal quality assurance and performance improvement processes. These processes must include routine internal audits, corrective action planning, and ongoing monitoring to ensure high-quality, complaint service delivery. At a minimum, the provider must review and analyze the following areas on a regular basis:

· Incident Reports

· Service and outcome trends

· Admissions and discharges

· Staffing levels, patterns, and gaps

· Facility improvements, including maintenance and repairs

· Oversight processes that ensure regulatory compliance and continuous improvement.

12. BENEFITS MANAGEMENT & FINANCIAL RESPONSIBILITIES

The provider must maintain and manage Medicaid and Social Security benefits when designated as responsible for doing so. Responsibilities include:

· Demonstrating proficient knowledge of Social Security benefit processes, including applying for and maintaining benefits and serving as Representative Payee when required.

· Demonstrating proficient knowledge of Medicaid eligibility requirements, maintaining benefits, serving as an authorized representative when necessary, and ensuring individuals receive the correct Medicaid category.

· Understanding the differences between Supplemental Security Income (SSI) and Social Security Disability (SSD), including how benefits and additional income may impact financial liability.

· Managing individual funds in accordance with all Medicaid, Social Security, and applicable state and federal rules.

B. DELIVERABLES AND DEADLINES

The Contractor shall provide, at a minimum, the following deliverables according to a mutually agreed upon schedule. Each deliverable must include the required compliance evidence and will be subject to formal review and approval by the State. Deliverables should be submitted in both editable and PDF formats and stored in a state-owned repository.

1. PRE-IMPLEMENTATION DELIVERABLES

· Facility implementation plan that outlines renovation, preparation, security, staffing, and development activities.

· Implementation timeline to include key milestones, dependencies, critical dates, and anticipated operation start.

· Identification of key staff and qualifications that lists leadership and essential personnel with required credentials.

· Operational readiness plan that demonstrates clinical, environmental, staffing, and policy preparation for launch.

· Readiness review documentation that includes results of IDOH life safety survey, staffing verification, and required state forms.

2. MONTHLY DELIVERABLES (due on the 10th calendar date of the following month)

· Behavioral data trend report

· Restriction review summary

· Active treatment summary

· Incident Report (IR) trend review

· Staffing trend review

3. QUARTERLY DELIVERABLES – due by the 10th calendar day of the month following the quarter end date

· Incident Activity

· Summary of incident types, frequency, severity, timeliness of reporting, investigations, and follow-up actions. Identified trends, including corrective actions taken.

· Admissions and Discharge

· Accounting of referral decisions, admission timeliness, discharge planning timelines, and barriers to transition.

· Compliance with expectations related to stabilizing individuals and progressing toward discharge.

· Staffing

· Evaluation of staffing adequacy, turnover, training completion, and competency demonstration.

· Trends and Data Analysis

· Review of behavioral data, medication errors, health events, staffing ratios, and other quality metrics.

· Trend identification to support early intervention and risk mitigation

· Environmental

· Documentation of repairs, maintenance, environmental risks, and life safety code compliance.

4. ANNUAL DELIVERABLES - due by January 31st of new calendar year

· Year-End Quality Review – Major trends, corrective actions, and outcomes

· Staffing Summary – Turnover, recruitment/retention efforts, and training compliance

· Program Outcomes – Length of stay data, discharge outcomes, and system-level barriers

· Facility Review – Summary of maintenance, safety improvements, and emergency preparedness updates.

5. CONTINUOUS DOCUMENTATION DELLIVERABLES - certain documentation must be kept current and submitted or shared upon request:

· Updated plans – ISP, BSP, HRPs, Medication Administration Records (MARs)

· Daily progress notes

· Medication documentation – appointment notes, physician orders, updates, etc.

· IRs and Investigation reports – submitted per BDS policy

· Staff schedules and training records

· Emergency Preparedness Documentation

Readiness Review During the Transition Phase, the State will conduct a readiness review process to ensure the Provider is ready to assume responsibility for contract services upon the Operational Effective date. FSSA will distribute any readiness review instructions, tool(s), timelines, and related documentation at or before the time of contract award. Any and all readiness review activities will be conducted at the sole discretion of the state.

C. PAYMENT

Payment is facilitated by Medicaid as a daily per diem rate per person.

PER DIEM / DAILY RATE (405 IAC 5-13-3)

The all-inclusive per-dem rate covers all services and support required for individuals served in the facility, including:

1. Room and Board - Housing, all dietary services, and personal laundry.

PROPOSED PAYMENT STRUCTURE BASED ON MILESTONE COMPLETION Comment by Kimmel, Kira D: Need help with formatting The $2,000,000 start-up payment may be used only for allowable, non-Medicaid expenses such as facility renovations, security updates, equipment, and initial staff onboarding. Each milestone payment requires State verification of completion through submitted documentation, inspection results, or certification as applicable.

1. Procurement & Contracting Phase

* Contract Award – An initial disbursement (e.g. ~20%) issued upon formal contract award.

2. Start of Work

* Notice to Proceed (NTP) – Release of the next milestone payment (e.g. ~20%) once the provider begins authorized pre-development activities such as site assessments or pre-construction planning.

3. Construction or Facility Readiness

* 50% Construction/Renovation completion and IDOH life safety survey: following verification of progress through inspection or provider reporting, an additional milestone payment (e.g. ~20%) may be released.

4. Final Stages

* Contract Completion: Upon full completion of required construction or renovation activities and achievement of IDOH life safety certification, another milestone payment (e.g. ~20%) is released.

5. Project Close-Out

* Project completion – After all final inspections, required documentation, and close-out reporting are received and approved, the remaining funds (e.g. ~20%) are disbursed.

The State will not guarantee coverage for cost overruns related to construction or facility readiness. If the provider fails to meet any of the expectations listed above further payments could be withheld and previously distributed payments may be subject to recoupment.

IV. PROJECT MANAGEMENT

A. PROJECT MANAGEMENT PLAN

The State’s relationship with the Provider shall be governed by three agreements: 1) the Medicaid Provider Agreement, 2) the Division of Disability and Rehabilitative Services Service Provider Agreement (State Form 55006), and 3) Contract resulting from RFS 26-87928 which will govern the provision of Services by the Contractor to Individuals.

The Contractor shall actively engage with the State and maintain up-to-date knowledge of all updates, changes, and additions to BDS services, supports, policies, guidance, and procedures. This includes, but is not limited to, participating in webinars, public meetings, and provider-specific sessions, as well as regularly reviewing BDS/DDRS/IHCP announcements, website updates, and other official communications and public releases.

B. KEY PERSONS

The provider shall maintain several positions vital to the success of this contract. Key positions shall include, at a minimum:

1. Qualified organization leadership that is responsible for the guiding, managing, and strategic decision making within the organization.

2. Medical or Nursing Director (minimum of IN-licensed RN)

3. Activities Director

4. Qualified Intellectual Disabilities Professionals (QIDPs)

5. Qualified Direct Support Professionals (DSPs)

6. Psychiatric Provider

7. Behavioral Clinician/Director

C. OTHER PROJECT STAFF

Administrative and ancillary staff as deemed appropriate and necessary.

D. DOCUMENT MANAGEMENT

1. The Provider must maintain all required documentation and make it available for review upon request. The Contractor shall submit documents in editable and PDF formats, apply State-approved naming conventions, and maintain version control with an audit trail.

2. All relevant documentation must be shared with all members of the Interdisciplinary Team (IDT), including but not limited to the individual, guardian (as applicable), family members, and BDS staff.

3. Documentation must include copies of completed and current staff training records.

4. Staff schedules must be maintained and made available as requested.

5. Incident Reports (IRs) and related investigations must be documented and accessible.

6. Current plans must be maintained, including but not limited to the Individualized Support Plan (ISP), Behavioral Support Plan (BSP), High Risk Plans (HRPs), discharge planning documentation, medication administration reports/tracking, medical notes, daily progress notes, restriction tracking, and any additional documents required to support service delivery.

V. COMPLIANCE REQUIREMENTS

This section outlines all regulatory expectations the Provider must comply with, including CMS rules, IDOH standards, BDS requirements, and State policies related to CRMNF operations.

REGULATORY COMPLIANCE

· The Provider must be able to obtain and maintain Medicaid certification in accordance with all applicable CMS regulations.

· The Provider must be able to successfully complete and respond to IDOH surveys, including annual surveys and complaint investigations.

· The Provider must be able to complete and implement corrective actions for all citations, including submission and execution of Plans of Correction required by IDOH, the BDS, and any other applicable regulatory agencies.

· The provider must maintain knowledge of and adhere to all relevant federal and state policies, rules, and regulations.

STATEWIDE IT POLICIES, PROCEDURES, AND STANDARDS Comment by Kimmel, Kira D: Were we leaving this?

· The State has robust and comprehensive security standards that permeate all levels of the organization. The Indiana Office of Technology (IOT) has been tasked with establishing and maintaining these security standards. The security standards include assessing security risks, developing, and implementing effective security procedures, and monitoring the effectiveness of those procedures. If the proposed solution involves information technology-related products or services, all such products or services are to be compatible with any of the technology standards found in the Statewide IT Policies, Procedures, & Standards (https://www.in.gov/iot/policies-procedures-and-standards/) that are applicable, including the assistive technology standard. The Contractor will be required to sign a Non-Disclosure Agreement (NDA) to access the more sensitive standards and policies. The Contractor should review the Statewide IT Policies, Procedures, & Standards and ensure their proposed solution meets all standards therein.

VI. KEY PERFORMANCE INDICATORS

The State will use Key Performance Indicators (KPIs) to measure performance and outcomes of the Contract. The specific KPIs and their targets will be defined and agreed upon by the State and the Contractor during the initial phases of the requirements under the Contract. At a minimum, on time delivery at quality standards of the scope provided within the budget set forth in the Contract will each be measured. Additionally, the State will collect a modified Net Promoter Score from customers to this Contract in its discretion. Low ratings on the modified Net Promoter Score or failure to meet any other KPIs may be deemed, at the discretion of the State, to constitute default under the Contract.

Regulatory Compliance

· Successful completion of IDOH annual and complaint surveys

· Timely, corrective action plans submitted and accepted

· No repeated or recurring condition level citation violations in the same regulatory areas

Incident Management and Quality Improvement

· Timeliness and completeness of IRs

· Investigations completed within 5 business days

· Accuracy and comprehensiveness of documentation

· Reduction in preventable incidents over time

· Completion of internal audits

· Submission of trend reports

· Development and follow through with corrective action plans

Discharge Planning and Transition Timeliness

· Discharge plan completed within 90 days of admission

· Quarterly review of discharge plans

· Monthly transition meetings once discharge criteria is met

· Timely transitions to less restrictive settings

Referral Acceptance/Admission

· Referral review within 5 business days

· Admission recommendation within 10 business days

· Completion of pre-transition meeting within 30 days prior to admission

· Required pre-admission documents completed and submitted on time

· Admission rate – provider will accept 100% of referrals received for individuals who meet LOC for CRMNF.

Environmental Safety and Facility Maintenance

· Compliance with life safety and emergency preparedness expectations

· Prompt completion of building repairs and corrective maintenance

· Clean, odor-free environment maintained consistently

· Evidence of routine housekeeping and safety inspections

VII. END OF CONTRACT TRANSITION AND TURNOVER

The Provider shall ensure continuous Services are delivered for the entire Contract term as contemplated by this Scope of Work. During transition periods, as initiated by the State, the Provider shall participate in all transition activities as outlined by the State and shall cooperate fully with the State and the succeeding CRMNF provider to ensure an orderly, timely, and complete transfer of responsibilities.

The Provider shall continue to provide and bill for Services until all Individuals are successfully transitioned to a succeeding provider. The Provider shall provide required notices to Individuals and ensure all Individual cases are current before transition, including:

· ISP

· BSP, BSP tracking, HRPs

· Incident Report (IR) follow-ups

· Demographic information

· Medical documentation (MARs, physician reports, etc…) In addition, the Provider shall complete all required transition and turnover activities, including but not limited to the following:

A. Transfer of Individuals The Provider shall actively support the transfer of individuals to the succeeding provider if applicable by:

· Coordinating with individuals, families, guardians, and providers to ensure clear communication of timelines and expectations.

· Providing all required notices and documentation in accordance with Indiana Code and State policy.

· Ensuring no disruption in authorized services during the transition period.

B. Record Handoff The Provider shall prepare and transfer all individual records and case materials to the succeeding provider, including:

· Complete electronic and physical case files.

· Any personal possessions or legal documents belonging to the individual

· All assessments, plans, notes, authorizations, monitoring tools, and historical documentation.

· A formal handoff summary for each individual , noting current status, outstanding actions, risk factors, and continuity-critical information.

The Provider shall use formats and transmission methods approved by the State to safeguard confidentiality and ensure timely receipt.

C. Data Retention and Access The Provider shall comply with all State and federal requirements regarding data retention, including:

· Retaining records for the period required by FSSA.

· Ensuring the State has access to retained data upon request.

· Maintaining secure storage of all retained data and preventing unauthorized access, use, or disclosure.

D. Continuity of Care Planning The Provider shall collaborate with the State and the succeeding provider to ensure continuity of care for all the individuals, including:

· Completing continuity of care planning documents as required.

· Preparing updated summaries of each individual’s service needs, risk mitigation strategies, and active supports.

· Participating in joint transition meetings when requested by the State.

· Ensuring no lapse in medically or behaviorally necessary supports throughout the transition.