Attachment A4c.docx

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Attached to
Behavioral Health Treatment Facility Continuum of Care
Solicitation number
RFSQ-BHS-FY23-0225
Issued by
California

About this file

This is a Scope of Work document issued by Santa Clara County's Behavioral Health Services Department (BHSD) for residential care services for adults and older adults with severe mental illness (SMI) and traumatic brain injury (TBI). The County seeks qualified offerors to provide supplemental residential care facilities offering structured, supervised, and individualized treatment programs designed to maximize client functioning and facilitate transition to less restrictive community settings. The target population includes County residents aged 18 and older diagnosed with SMI and cognitive or traumatic brain injuries causing severe functional impairments, including those with behavioral challenges, nursing complexities, dual diagnoses, or conditions that preclude admission to regular residential care facilities. Offerors must operate facilities 24 hours a day, seven days a week, provide one-to-one supervision for clients with self-harm or aggressive behaviors, maintain appropriate staffing levels reflective of the County's diversity, and implement a comprehensive array of services including daily living assistance, medical care, behavioral management, therapy referrals, and skill development training. The contract establishes a six-month initial authorization with potential six-month extensions subject to updated discharge planning and demonstrates client progress toward community integration, with performance outcomes reviewed every six months.

The document does not specify pricing terms, contract amounts, award dates, or response deadlines. However, it establishes detailed operational and service delivery requirements including mandatory monthly and quarterly meetings with County staff, unannounced yearly facility reviews, 24-hour reporting of admits and discharges, and a bed hold policy of seven days for clients requiring acute medical or psychiatric services. Offerors must comply with all Community Care Licensing requirements plus provide additional staffing beyond regulatory minimums for clients with specialized behavioral needs. The scope mandates cultural competency training of at least eight hours annually, recruitment strategies reflecting Santa Clara County's seven threshold languages (Spanish, Vietnamese, Mandarin, Cantonese, Tagalog, Farsi, and Russian), and continuous quality improvement efforts targeting a 70 percent reduction in recidivism to acute psychiatric and medical settings and transitioning at least 10 percent of census to less restrictive community settings within 9-12 months. Offerors must maintain emergency and disaster preparedness plans and comply with all County COVID-19 health requirements.

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Appendix I.docx DOCX document
Attachment A3a.docx DOCX document
Attachment A3b.doc DOC document
Appendix B4a.docx DOCX document
Addendum 6.pdf PDF
Addendum 9.pdf PDF
Appendix B4b.docx DOCX document
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Attachment C1.pdf PDF
Attachment F.pdf PDF
Attachment C4.pdf PDF
Appendix B1.docx DOCX document
Appendix D.docx DOCX document
Appendix G.docx DOCX document
Attachment C5.pdf PDF
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Addendum 4.pdf PDF
Attachment A2b.docx DOCX document
Solicitation_Document_1.pdf PDF
Addendum 5.pdf PDF
Attachment B.pdf PDF
Appendix B3b.docx DOCX document
Attachment A3d.pdf PDF
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Appendix B4c.docx DOCX document
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Addendum 1.pdf PDF
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Addendum 2.pdf PDF
Attachment A4a.docx DOCX document
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Appendix B3a.docx DOCX document
Addendum 8.pdf PDF
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ATTACHMENT A4c CATEGORY 4: Supplemental Residential Care Facilities

CATEGORY 4: SUPPLEMENTAL RESIDENTIAL CARE FACILITIES

RESIDENTIAL CARE SERVICES FOR CLIENTS WITH SEVERE MENTAL ILLNESS (SMI) AND TRAUMATIC BRAIN INJURY (TBI)

Scope of Work

Purpose The County of Santa Clara (County) Behavioral Health Services Department (BHSD) is seeking statements of qualifications from qualified Offerors interested in providing a supportive environment, such as residential board and care facilities with a specialized treatment program with a goal of rehabilitation that focuses on maximizing the client’s level of functioning. Clients are expected to progress from intensive psychiatric behavior interventions to functioning independently in the least restrictive setting.

The program shall serve adults and older adults residing in Santa Clara County who are diagnosed with a Severe Mental Illness (SMI) and traumatic brain injury (TBI), anoxia (absence of oxygen in the brain), stroke, or seizure disorders. These clients may also be vulnerable or at risk of victimization that precludes them from being placed in a regular Residential Care Facility (RCF).

These clients have symptoms that include cognitive and judgment impairments, and a disability that causes significant interference with treatment, but does not present an immediate threat to safety nor prevent independent functioning. It is important to note that psychiatric disorders after TBI are common.

Target Population A. The target population includes adults (age 18-59), and older adults (age 60 and above) who are residents of the County and are referred by the County’s behavioral health system.

B. All clients must meet the following criteria: 1) diagnosed with SMI and 2) have a cognitive or traumatic brain injury that causes severe functional impairments meeting requirements for a facility with TBI services.

C. The primary diagnosis must be a psychiatric diagnosis and clients may have underlying traumatic cognitive and/or brain injuries that require enhanced supervision and if applicable, nursing care.

D. The population to be served shall include, but may not be limited to the following:

a. Clients who have significant behavioral challenges, limited social skills, dual diagnoses, impaired or unable to attend to independent living skills, poor self- regulation skills, thought disorders, and or nursing complexities that prevent them from living in the least restrictive settings.

b. Clients who have difficulty with their thought process and functioning level, and are unable to perform basic tasks, which affects concentration, communication, speech, swallowing and vision, as well as mobility.

c. Clients who are chronically ill with behaviors that may require one-to-one supervision and rehabilitation services.

d. High risk clients or clients that continue to show that they are unable to function at the lower levels of care that are available in the community due to their medical and psychiatric conditions.

e. Clients with severe cognitive and psychiatric impairments who have been denied for admission at a regular RCF.

f. Clients at inpatient or acute hospitals with behaviors or conditions that have shown effectiveness to treatment with enhanced one-to-one staffing services. These are clients with the following conditions: self-harm, polydipsia, brittle diabetics, scavenger behavior, intrusive behavior, and aggressive/assaultive behavior, and food intake supervision.

E. Clients whose mental illness requires a sub-acute level of care, as well as clients suffering exclusively from developmental disability, mental retardation or physical illnesses alone (without a psychiatric component) shall not be considered for admission.

Program Goals and Objectives A. The program shall be aligned to achieve the following goals and objectives:

Goals shall include, but not be limited to:

Provide a structured, supervised, and individualized program with trained staff that addresses the unique and complex medical and mental health needs of this population.

Reduce the utilization of acute psychiatric or medical beds by stabilizing both behavioral and medical symptoms with the following goals:

1. Assist clients who are in the diagnostic spectrum that includes schizophrenia and other psychotic disorders including bipolar disorder, major depression, post- traumatic stress disorder, and may include a secondary diagnosis of developmental disability, or drug and alcohol related conditions.

2. Provide a homelike and therapeutic environment for clients who are experiencing medical and behavioral health challenges, with the goal of moving clients toward their physical, mental, and spiritual health potential.

3. Assist County in efficiently and effectively managing limited resources by providing an alternative to utilization of state hospital days and acute hospital administrative days.

4. Increase the client’s motivation and skills toward self-restoration.

5. Prevent or decrease the rate of decompensation, thus reducing placements at higher, more costly levels of care.

6. Provide the intensive staffing required to supervise and treat behavioral and medical conditions.

7. Prevent the need for re-hospitalization into acute psychiatric or medical facilities.

8. Assist clients to maintain or improve functioning and decrease psychiatric symptoms.

9. Empower clients by involving them in directing their own treatment programs.

10. Work collaboratively with the public behavioral health system to enable efficient utilization of this program’s specialized resources.

11. Assist clients in developing socially responsible behaviors, independent living skills and coping skills to address their mental illness and medical conditions.

12. Reduce homelessness, and increase safe and permanent housing.

13. Increase self-help, family involvement and natural networks of supportive relationships.

14. Reduce disparities in service access.

15. Reduce re-hospitalization into the psychiatric and medical emergency systems

16. Encourage each individual to work towards attaining necessary skills to foster independent living and managing his or her activities of daily living (ADL).

Facilitate rehabilitation that focuses on maximizing the client’s level of functioning in the community.

Provide a homelike and therapeutic environment for clients who are experiencing medical and behavioral health challenges. The goal is for clients to move towards their potential in their physical, mental, and spiritual health.

I. Reporting and Data Collection Requirements A. Offeror shall implement an appropriate reporting system in order to evaluate and monitor contract activities. County needs to keep an accurate record of each person placed for contracted services for each day of service. All client data and services shall be maintained by County in County Billing Application. Offeror is responsible for making sure that County receives accurate information of all clients served within twenty-four (24) hours of each transaction.

B. Offeror shall allow the BHSD Director or designee to make periodic reviews of program activity and client care. Offeror shall provide all necessary information and client records as needed to complete the review, and to evaluate fiscal and clinical effectiveness, appropriateness, and timeliness of services being provided.

C. County, with input from the proposer, may develop reporting instruments to facilitate evaluation and monitoring. Previously established documents shall be used when applicable and appropriate, as judged by the County. Upon implementation of these reporting instruments, proposer shall comply with the established requirements.

D. Monthly meetings shall discuss care coordination, outcome, and client progress of each BHSD client. Additional meetings may be required or needed based on the needs of the client and the facility.

E. Quarterly meetings shall be held with the proposer to discuss contractual and operational concerns or issues. Offeror may request additional meetings with the County if needed.

F. County shall conduct unannounced yearly supplemental reviews of the facility to ensure expectations for client care are met. Site visits or facility reviews may also be sporadic pending the needs of the clients or any complaints received by the County.

G. Offeror shall be required to submit a Plan of Correction to the BHSD 24-Hour Care Unit within fourteen (14) business days of receiving the notice for citations or issues relating to the facility.

H. Bed holds are granted up to ten (10) days in the event that the client is required to leave the facility for acute medical or psychiatric services. The provider is expected to inform the BHSD 24-Hour Care Unit staff immediately if the bed hold period is beyond the ten (10) day time frame. The BHSD 24-Hour Care Unit shall not be responsible for payment beyond the ten (10) day bed hold period without prior authorization. Offeror is expected to accept the client back to the facility within the ten (10) day bed hold period if the client is deemed appropriate to return.

II. Outcomes and Measurements A. Offeror shall achieve the following outcome measurement methods:

1. County reserves the right to conduct an annual review of the program to ensure that Offeror is providing quality care to clients.

2. Offeror shall engage in a continuous quality improvement process to reduce the rate of recidivism into the acute psychiatric and medical settings by 70%.

3. Offeror shall engage in continuous quality improvement process to minimize incidences of aggression towards others and self-harm by reducing admissions into the acute psychiatric settings.

4. Offeror shall work towards transitioning at least 10% of the total census of BHSD clients to the least restrictive settings in the community within 9-12 months of residing in the facility.

5. Measurements shall be monitored and tracked through a designated tracking system.

6. Performance outcomes shall be reviewed and shared with the RCF provider every six (6) months.

III. Program Description A. Service Description

1. Offeror shall admit clients in need of supplemental residential and psychiatric services to clients with or have a history of TBI. Offeror shall also admit clients who may have a history of or who, without adequate treatment, are at risk of displaying behavioral symptoms (e.g. non-medication, non-ADL adherence, history of elopement risk, disrobing, unable to follow through with medical care, substance or alcohol abuse, and/or excessive verbal abusiveness), which preclude them from being accepted and admitted into a regular RCF.

2. Offeror shall provide clients a structured training regimen with individualized therapy to assist them to develop new skills and modify behaviors that prevents them from living in an independent and unsupervised setting.

3. When applicable, Offeror shall refer clients out for the following services to ensure clients receive the most appropriate services for their health: professional nursing care with licensed nursing staff, physical therapy, occupational therapy, speech therapy, social services, medications, supplies, equipment, and other services necessary to the health of the client.

4. Offeror shall use a variety of tools or motivational strategies (e.g., verbal prompts, one-to-one behavior management techniques, redirecting, and modeling of appropriate behavior) to prevent physical, mental, and emotional deterioration.

5. Offeror shall provide prompts and provide one-to-one supervision in assisting clients with managing their symptoms of impulsivity, anger, and other behavioral issues.

6. For clients who exhibit self-injurious behaviors (e.g., head banging, biting, etc.), Offeror shall provide one-to-one behavior management and supervision to educate redirect, and model appropriate behaviors. In addition, the Offeror shall:

a. Have one additional direct care staff on the premises at all times beyond Community Care Licensing (CCL) requirements to address client issues.

b. Provide on-going trainings to staff on how to work with clients with specialized behavioral and medical needs.

c. Document the frequency and intensity of the clients who have inappropriate behavior, and their skill development progress.

7. Propose shall have the physical layout of the building secure at all times, with security alarms in place as necessary.

8. Offeror shall provide clients daily assistance with hygiene, grooming and wound care, transportation to dialysis appointments as needed, and one-on-one assistance and supervision with medical equipment as appropriate.

9. Offeror shall teach clients how to check and monitor their blood sugar levels and administer insulin to treat their diabetic condition.

10. Offeror shall provide wander guards or additional security measures for clients who have a history of AWOL, wandering, or are currently at risk for wandering offsite without supervision.

11. Offeror shall contact the outpatient case manager, the outpatient provider’s after-hours hotline, the Behavioral Health Services Department (BHSD) 24-Hour Care Unit, and if applicable, the conservator to coordinate general care and response to crisis situations. All client crisis situations must be acted on immediately to ensure the safety of the clients and other clients in the facility.

B. Staffing Requirements

1. Qualified medical staff shall possess and maintain appropriate licenses and certificates in accordance with all statuses and regulations. Background checks, criminal records review, Department of Justice clearance, etc. shall be obtained and maintained in accordance with County rules and regulations.

2. Offerors staffing patterns shall reflect, to the extent feasible, at all levels, the cultural, linguistic, ethnic, sexual, and other social characteristics of the client base served in the program.

3. Offeror shall make every effort to hire staff reflective of the County’s diversity with particular attention to the County identified seven (7) Santa Clara County threshold languages (Spanish, Vietnamese, Mandarin, Cantonese, Tagalog, Farsi, and Russian). Offeror must be able to document recruitment and outreach strategies.

4. Offeror’s staffing levels need to be appropriate to provide necessary residential and treatment needs. Staff schedules must be available for review upon request of BHSD staff.

5. Offeror shall provide professional development and training requirements that are in accordance with the BHSD standards.

6. Offeror shall provide appropriate staff that possess the education and training to address the behaviors needs of the SMI population.

7. Offeror shall provide one-to-one staffing to the clients with the conditions stated, such as self-harm, polydipsia, brittle diabetics, scavenger behavior, intrusive behavior, and aggressive/assaultive behavior.

8. Offeror shall be in compliance with licensure and all laws governing the qualifications of personnel. Offeror agrees to submit any material changes in such duties or minimum qualifications to the County.

9. Offeror shall provide continuing education to all staff to proactively address client’s problematic behaviors and to minimize transfers to Emergency Psychiatric Services (EPS) and inpatient hospitalization.

10. Upon request, proposer shall submit to the BHSD an organizational chart, which reflects the contracted facility’s current operating structure.

11. Offeror shall provide at least eight (8) hours of cultural competence training to staff per fiscal year. Trainings may be obtained internally within the facility or through external sources.

12. Offeror’s organization shall maintain practices related to recruiting, hiring, and promoting multi-lingual staff and/or a culturally or ethnically diverse workforce. Offeror’s organization shall have training requirements related to diversity, equity, and/or inclusion (e.g., Lesbian, Gay, Bisexual, Transgender, Queer, Questioning + [LGBTQ+], cultural and linguistic capacity, racial equity).

C. Cultural Competency

1. Offeror’s organization shall be inclusive of promoting behaviors and practices towards a more equitable, diverse, and inclusive organizational mindset. Offeror shall have a leadership model inclusivity and tools and support to improve their organization’s ability to identify and mitigate bias, respect differences, build empathetic relationships, and manage conflict.

2. Offeror shall monitor and evaluate client/family satisfaction and culturally responsive services/practices to continually improve service quality. Data shall be used to improve program satisfaction.

3. Offeror’s organization shall have a plan to address barriers when they do not have staff available to meet the seven (7) Santa Clara County threshold languages (Spanish, Vietnamese, Mandarin, Cantonese, Tagalog, Farsi, and Russian) and a plan for actions and changes to ensure diversity and inclusion in service delivery.

D. Referrals and Admissions

1. Offeror or his/her designees shall work closely with County staff to facilitate the admission, transfer, and discharge of clients. Offeror shall admit clients in accordance with the following: ability, scope of practice, and adequate staffing requirements.

2. Frequency, scope, and severity of the client’s behaviors shall be a determining factor to be negotiated on an individual client basis between County and Offeror.

3. County may grant individual exceptions to the above admission criteria. All admissions are subject to the prior authorization process as follows:

4. County’s authorization form must be completed prior to admission of any client to the facility. Failure to obtain prior authorization shall result in nonpayment for services provided by the proposer.

5. Offeror must notify the BHSD 24-Hour Care Unit of all admits and discharges within twenty-four (24) hours by using the Admit/Discharge Notification Form provided by the County.

6. Offeror reserves the right to conduct a pre-admission interview and refuse clients who are not within their scope of practice.

7. Offeror must respond to referrals from referring providers within forty eight (48) hours of receiving the referrals packets.

8. Offeror shall designate specific individuals responsible for admission authorization and admission arrangements. Offeror shall provide clinical justifications for denials of admission within two (2) working days of request for admission. Upon denial of the referrals, the proposer shall inform the

9. referring providers if there are specific expectations that must be met prior to acceptance. All denials must be based on medical necessity, scope of practice, and the ability of the facility to manage the client’s current condition(s).

10. Offeror shall assess the clients based on their current behavior and symptoms dating back to no more than thirty (30) days. Denial of referrals based on the client’s past history exceeding more than thirty (30) days must be discussed with the BHSD 24-Hour Care Unit or the referring provider prior to excluding the referral indefinitely.

E. Care Coordination

1. Monthly meetings shall be held to discuss care coordination, outcome, and client progress of each BHSD client. Additional meetings may be required or needed based on the needs of the clients and the facility.

2. Quarterly meetings shall be held with the Offeror to discuss contractual and operational concerns or issues. The Offeror may request additional meetings with the County if needed.

3. County shall conduct unannounced yearly supplemental reviews of the facility to ensure expectations for client care are met. Site visits or facility reviews may also be sporadic pending on the needs of the clients, or any complaints received by the BHSD 24-Hour Care Unit. The Offeror shall be required to submit a Plan of Correction to the BHSD 24-Hour Care Unit within fourteen (14) business days of receiving the notice for citations or issues relating to the facility.

4. Bed Holds are granted up to seven (7) days in the event that the client is required to leave the facility for acute medical or psychiatric services. Offeror must inform the BHSD 24-Hour Care Unit staff immediately if the bed hold period is beyond the seven (7) day-time frame. The BHSD 24-Hour Care Unit shall not be responsible for payment beyond the seven (7) day bed hold period without prior authorization. Offeror is expected to accept the client back to the facility within the seven (7) day bed hold period if the client is deemed appropriate to return.

F. Program Hours of Operations Offeror shall operate the program twenty-four (24) hours a day, seven (7) days a week.

G. Evaluations, Transitional Planning, and Discharge

1. Discharge Criteria and Planning:

a. At the time of admission, County designated Care Managers shall specify discharge readiness criteria for each client’s service plan.

b. Offeror shall specify whether the client is able to manage his or her medical conditions independently without the intensive supervision if transitioning to a lower level of care.

c. Offeror shall arrange care conferences with the client’s family members, conservators, outpatient case managers, and the BHSD 24-Hour Care Unit’s liaison as needed to discuss any concerns prior to discharge.

d. Offeror shall initiate a care coordination conference with the conservator, the BHSD 24-Hour Care Unit staff, family members, and if applicable, outpatient case managers in the event that there is a disagreement with the discharge plan.

e. In the event of unanticipated discharge, proposer shall give a twenty-four (24) hour notice, prior to the discharge of a client to the County’s designated staff, the conservator, and any other individuals applicable in the client’s treatment.

f. Clients who are discharging or transitioning to lower levels of care in the community must be linked with an outpatient service team for continued care coordination.

g. Assistance with discharges may be obtained from County’s public agencies, including the designated BHSD Care Managers, Public Conservator’s Office, Department of Health Care Services, and State Department of Welfare.

h. Upon a client’s AWOL from the facility, the Offeror must discharge the client within twenty-four (24) hours. A discharge notification must be sent to the BHSD 24-Hour Care Unit within the next two (2) working business days.

i. Upon discharge or death of the client, Offeror shall refund any unused funds received for the client’s bill to the payor source within thirty (30) days.

j. Any entrusted funds held in an account for the client shall be disbursed to the client (if not conserved) or conservator within three banking days.

k. Any money or valuable entrusted by the client to the care of the facility shall be stored in the facility and returned to the client (if not conserved) or conservator in compliance with existing laws and regulations.

l. Offeror shall notify the BHSD 24-Hour Care Unit when a client is discharged from the facility and admitted to another proposer’s facility within twenty-four (24) hours.

m. All such discharges and admissions shall be authorized by BHSD 24-Hour Care Unit and arranged by mutual consent, with family members, County, and specified individuals involved with client’s treatment and supports

n. In the event that the client is unmanageable or in a crisis situation, the Offeror shall explore alternative treatment options to maintain the client in the facility prior to discharging the client back to the County’s acute psychiatric or medical services. Such discharge shall be coordinated with the BHSD 24-Hour Care Unit in advance.

o. Offeror shall ensure that the services provided to a specific client at a given time are cost-effective, clinically and culturally appropriate and least restrictive setting.

2. Length of Stay:

a. A client’s length of stay is time-limited. It is expected that clients shall receive active psychiatric, medical, nursing care, and rehabilitative treatment services and be supported to develop independent living skills in order to progress to a non- institutionalized setting in a timely manner.

b. Offeror shall work closely with clients, County personnel, conservators and family members, if appropriate, to ensure that clients continue to receive services at the appropriate level of care and in the least restrictive setting.

c. Median Length of Stay: The initial authorized length of stay shall be for six (6) months. If additional time is required, a six (6) month additional increment shall be authorized based on the submission of an updated discharge plan by the proposer. Extensions must be submitted in writing and send to the BHSD 24-Hour Care Unit.

d. Leave of absence: Clients are allowed to leave the facility for up to eighteen (18) days per calendar year for family visits or for other reasons that are beneficial to the client’s overall health. A leave of absence form must be submitted to the BHSD 24-Hour Care Unit for approval prior to leaving the facility. The BHSD 24-Hour Care Unit shall not be responsible for payment for days absent without prior authorization.

3. Transfer Between Contracted Facilities, If and When Applicable

a. Transfers of clients among facilities within a contracted corporation shall be arranged by mutual consent between Offeror and County and with notification to, and appropriate input from, the client’s conservator, significant family members, the BHSD 24-Hour Care Unit, and specified individuals involved in the client’s treatment and support system.

b. Offeror shall assist the BHSD 24-Hour Care Unit, and any other County designee, to ensure an orderly transfer of the client.

c. Offeror must provide County with nursing notes, client’s records, and other the documentation supporting the rationale for discharge and details of the disposition. A completed transfer form shall accompany the client to the receiving facility.

IV. Disclosure of Violations and Unusual Incidents A. Offeror shall notify County by telephone of the violation of any provision within twenty-four (24) hours of obtaining reasonable cause to believe that a violation of federal or California law or regulation, including privacy and confidentiality laws; County laws, policies, or procedures; or the requirements included in this RFSQ or the applicable agreement with the County has occurred. In addition, notice of such violation shall be confirmed by delivering a written notice to the BHSD Director within seventy-two (72) hours of obtaining reasonable cause to believe that such violation has occurred. Such notice shall describe the violation in detail as outlined in BHSD Policy AGI-003 (Attachment G).

B. Offeror shall comply with County policies, procedures, and requirements concerning the reporting of unusual occurrences and incidents.

V. Public Health Emergency or Other Emergency Disaster Plan A. Offeror shall have policies and procedures to address disaster preparedness during a Public Health Emergency or other emergency disaster. Offeror shall complete Appendix B4c, Evaluation Criteria and Qualifications and submit the following supplemental information:

1. Emergency and disaster plan to deliver services during a Public Health Emergency or other emergency disaster that includes, at a minimum, evacuation procedures, training for workforce members, and quarterly emergency drills; and

2. Emergency and disaster plan to deliver services during a pandemic such as the COVID-19 pandemic.

B. Offeror shall comply with all County requirements in effect relating to COVID-19 for persons who routinely perform services for County onsite and share airspace with or proximity to other people at a County facility as part of their services for County as set forth in a County Health Order (or similar directives).

RFSQ-BHS-FY23-0225: Behavioral Health Treatment Facility Continuum of Care Page 1 of 3 ATTACHMENT A4c: Residential Care Services for Clients with Severe Mental Illness (SMI) and Traumatic Brain Injury (TBI) Scope of Work

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