Attachment C Flex Funds.docx

Department of Mental Health – Division of Child, Youth, and Family Services Flexible Support Services Request For Response DMH Document Number: DMH #2019-FLEX-3066-02

Attachment C

PROCEDURES FOR THE USE OF DMH FLEXIBLE SUPPORT SERVICES FLEXIBLE FUNDS

I. Background and Purpose

DMH Flexible Funds can be used to purchase goods and services that maximize the benefit a youth derives from mental health interventions and activities delivered through DMH Services. Flexible Funds are intended to promote youth and family permanency, well-being and self-efficacy.

The “Flexible Fund Administration” fee provides reimbursement to Providers for managing Flexible Fund purchases.

The following procedures specify the requirements that Providers must follow when using Flexible Funds. Flexible Funds must be expended in accordance with these procedures.

II. Authorization for Flexible Funds

Flexible Funds are authorized at the discretion of the applicable DMH Child, Youth and Family Services Area Director (or designee). If authorized, they will be for a specified individual and/or family and purpose.

III. Allowable Purchases

Flexible Funds may be used to pay for certain contingency expenses that provide direct support to youth or their families to assist with their health, welfare, wellbeing and safety needs. Flexible Funds may be used for necessities that assist in transitioning or maintaining a youth in the community when the lack of those necessities would likely lead to the youth’s psychiatric destabilization and/or cause undue hardship on the youth or family. Flexible Fund expenditures must be consistent with the needs and Individual Community Services Plan (CSP) goals of the youth and family. Flexible Fund expenses are expected to be time limited. CSPs should reflect plans to sustain activities (where necessary) through natural supports, other funding sources, and/or other means in anticipation of Flexible Funds ending.

Providers must demonstrate reasonable efforts to obtain the needed goods or services from other sources, such as community organizations, insurance (i.e., third-party payers), faith-based organizations, philanthropic groups and other entities. Needed goods or services may be available from these entities in the form of direct payment for the good/service, scholarships, sliding scale fees, reduced/discounted prices and or fees; donations of gift certificates or clothing; etc.

Examples of Inappropriate Flexible Funds Expenses. Inappropriate uses of Flexible Funds include, but are not limited to:

· Program petty cash fund

· Program expenses

· Office supplies

· Staff training

· Cleaning of office space

· Mortgage payments

· Credit card payments

· Luxury items

· Ongoing contingency expenses beyond 3 months

· Program subscriptions to mental health journals or membership dues for program staff

· Expenses that do not support the youth/family goals and/or are not a direct benefit to them.

Gift certificates must either specify that they cannot be used for firearms, gambling/lottery tickets, and tobacco and alcohol products; or must be for stores, etc. that do not offer such goods.

IV. Required Documentation The Provider is required to maintain all original documents relative to Flexible Funds and Flexible Fund Administration for a period of seven (7) years after the applicable contract has ended. This includes but is not limited to:

A. Invoice/receipt from the vendor/service provider. The Provider must obtain a receipt or an invoice for each good or service purchased using Flexible Funds from the vendor which sold or provided the good or service. The receipt/invoice must indicate the name of the vendor, the vendor’s address, a description of the good(s)/service(s) provided, the cost of the good(s)/service(s) and the date of purchase.

B. Acknowledgement from the youth/family. For each good or service purchased for a youth/family using Flexible Funds, the Provider must obtain a signed written receipt or acknowledgement from the parent or Legally Authorized Representative (LAR) of the youth on whose behalf the good or service was purchased (or if the youth is 18 years of age with capacity, from the youth). The receipt or acknowledgement must indicate that the youth or their family received or otherwise utilized the good/service. The receipt or acknowledgement must be dated and signed.

V. Provider Monitoring and Quality Control

A. The Provider must maintain and implement written internal controls regarding the management of Flexible Funds. The controls must be designed to prevent the misuse of such Funds and to ensure compliance with these procedures.

B. Checks must be made out to and endorsed by the entity providing the goods/service that is being reimbursed.

C. Gift certificates, transportation and other types of passes/vouchers and checks written directly to staff or youth/family require stringent procedures that must be in place for their authorization and monitoring. The Provider must be able to prove that these purchases are used for authorized youth/families. To this end the following controls shall be implemented when Flexible Funds are used for (a) the purchase of gift certificates, passes and vouchers or (b) checks made directly to a staff (for reimbursement of purchase of an approved item for youth/family) or (c) checks made directly to a youth/family:

· The purchase and distribution of these items must be documented in a log, which is to be developed and maintained by the Provider.

· The log must document at a minimum, the following information:

· Identifier number for the gift certificate, pass, voucher, check

· Purchase date of certificate/pass/voucher; or if a check, date on the check

· Dollar amount of the purchase

· Name of the business from which the purchase was made

· Description of item (ie. staff reimbursement for weighted blanket, T-Pass, Mobil Gas certificate)

· Name of applicable staff, youth and parent or LAR

· Printed name and title of individual authorizing release of the certificate/pass/ voucher or check

· Date that the certificate/pass/voucher was issued to the staff, youth, or family; or if a check, date that check was issued to staff, youth or family

· Date that staff/youth/family acknowledge receipt of the certificate/pass/voucher/check

D. If Flexible Funds are paid directly to a Youth/family, the Provider must inform the Youth/family about potential tax implications.

E. The Provider is responsible to review expenditures of Flexible Funds and the process by which they were expended to ensure compliance with related DMH regulations and program procedures. At a minimum, the Provider must review and reconcile the amount of Flexible Funds used for contingency expenses on a monthly basis.

VI. DMH Monitoring and Quality Control

Given DMH’s requirement that Flexible Funds be used appropriately, DMH for good cause can mandate that:

· A Provider immediately cease making any expenditure(s) for a specific youth/family

· A Provider immediately cease making any Flexible Fund expenditures.

The mandate may be given by a DMH Area Director or Area Director of Child, Youth and Family Services Area. It may be made verbally, but then it must be followed by written notice within one business day. “Good cause” can include situations where there exists a pattern of not submitting required receipts/invoices; a violation of Regulation, Accounting Standards or other procedures. Should DMH exercise the right, a meeting will be convened with the Contractor to review the situation.

At a minimum on a quarterly basis, the applicable DMH Area Office(s) will review the distribution and amount of Flexible Funds used for contingency expenses within the Area. Additionally, at a minimum annually, the DMH Central Office will randomly review the records of Providers and DMH Area/Site Offices relating to the Flexible Funds for compliance with these procedures.

VII. Reporting

A. Monthly Expense Reporting. Every month, Providers are required to submit specific information (described below) on all Flexible Fund expenditures made during the month. This information must be submitted to the appropriate DMH Child Youth and Family Area Director in the format provided by DMH. DMH will issue the format specifications before the start of Flexible Support Services Contracts. The Monthly Expense Reporting information must be submitted at the time of invoicing and will be used to review and approve invoices. Invoices will be held until this information is received. All required information must be received before invoices will be reviewed.

The required information is as follows: For each Flexible Fund expenditure made in the month

· Identifier number for the gift certificate, pass, voucher, check

· Purchase date of certificate/pass/voucher; or if a check, date on the check

· Name of the business from which the purchase was made

· Fund amount of the purchase

· Name of applicable youth, family member, or LAR

· ID# of youth

· Description code: This code is supplied by DMH to reflect the type of purchase made.

B. DMH Maintenance of Reports. The DMH Business Bureau, Procurement Unit, will maintain copies of all Provider Monthly Expense Reports as part of Provider procurement files.