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Revision 10-0; Effective June 1, 2010
15100 Quality Oversight of Home and Community-based Services Program Local Authority Responsibilities
Revision 10-0; Effective June 1, 2010
The Texas Department of Aging and Disability Services (DADS) ensures contract accountability and oversight of Local Authorities (LAs) through a variety of methods including, but not limited to, ongoing review and monitoring of CARE data, service encounter data, financial data and an annual Home and Community-based Services (HCS) on-site review.
DADS conducts ongoing monitoring reviews in several areas. These activities are part of DADS' broad oversight of LA performance and include HCS authority functions. This includes review of enrollment activity, utilization review, data verification of service encounter data, data integrity review of service encounter data and review of financial data. Detailed information regarding DADS requirements for LAs can be found in the LA Performance Contract at https://hhs.texas.gov/doing-business-hhs/provider-portals/long-term-care-providers/local-intellectual-and-developmental-disability-authority-lidda/lidda-performance-contract.
On-site Review of Requirements for Service Coordination
DADS will conduct an annual on-site review of HCS authority functions. This is an announced visit and includes the review of LA requirements for HCS service coordination. The review of HCS participants may also result in findings being cited in the DADS LA quality assurance review. This occurs if non-compliance with DADS rules or LA performance contract requirements is determined to be present, but is beyond the scope of the LA requirements for HCS service coordination.
Prior to the Review
DADS will assign a facilitator to coordinate the review activities for a given LA. The facilitator will draft an announcement letter to the LA executive director, which will also be copied to the LA board chair and the LA's designated contact person for coordinating the review. This letter is followed by direct communications between the facilitator and the LA contact person. The facilitator will randomly select the HCS sample of participants (meaning, the HCS individuals who will be participating in the review). The facilitator will send the LA contact person an authority review information and instructions packet that includes the sample of participants and forms to be completed and returned to the facilitator prior to the on-site review.
DADS staff conduct an entrance conference meeting at the beginning of the review. Occasionally some on-site activities may be scheduled to occur before the entrance conference. The entrance conference is between available review team members and key LA staff who will be involved in the on-site review. It serves as an opportunity to review the general agenda, provide information about the review and answer any questions.
Service Coordinator Qualifications and Training
Qualifications and training requirements for service coordinators assigned to HCS participants in the HCS sample are checked using the service coordination checklist.
Home and Community-based Services Participant Review
Each sample participant's record will be reviewed. DADS review team members will perform record reviews using the HCS documentation checklist. Follow-up meetings with assigned service coordinators will occur at the discretion of the review team members. Review team members may also determine whether there is a need to contact participants and their legally authorized representatives (LARs).
Throughout the review process, the review team members may point out issues, identify potential findings, ask for additional information or seek clarification on issues. After completion of the review, the HCS Authority Review Report of Findings will be drafted. A formal debriefing is held and identified items of non-compliance will be shared with the LA. The LA is then given up to one hour following the formal debriefing to provide additional information that may alter or clear findings. A cited finding may be determined to be corrected on site by the review team with no further action to be taken on that item.
At the conclusion of the HCS authority review, a final copy of the HCS Authority Review Report of Findings is provided to the LA at the exit conference. Barring a successful request for reconsideration of findings as described below, if any item is cited as "Not Met," a corrective action plan (CAP) will be required.
Reconsideration of Findings
An LA may request reconsideration of finding(s) of the HCS authority review based on the evidence originally submitted at the time of the on-site review. Instructions to the LA for requesting reconsideration are included at the bottom of the Report of Findings. This request for reconsideration must be submitted via email to the facilitator within 10 business days of receipt of the Report of Findings. Requests for reconsideration received later than 10 business days after the exit conference will not be considered. The facilitator will email a written response to the LA staff requesting reconsideration within 15 calendar days after receiving the LA's request. If a revision to the Report of Findings is necessary as a result of the reconsideration, the facilitator will ensure a written notification and copy of the revised report is emailed to the LA contact person. If changes in the CAP requirements result, the facilitator will email a revised CAP template to the LA contact person.
Amended Report of Findings
The Report of Findings is amended when the team determines that the final report shared at the exit conference contains an error. The correction is made and the corrected report becomes the Amended Report of Findings. The facilitator ensures any resulting changes in the CAP requirement will be forwarded with the amended report to the LA contact person with an amended CAP due date 30 days from the date of the amendment.
Corrective Action Plan
Submission of a CAP is required for any remaining items of non-compliance. The facilitator will provide the LA contact person with a CAP template and instructions and guidelines for completing the CAP. The CAP is due to Performance Contracts Management within 30 days after the date of the exit conference (or date of amended Report of Findings). The due date for the CAP is identified on the bottom of the final draft of the Report of Findings. The facilitator will coordinate DADS review of the CAP. If a need for revision to the CAP is identified, the facilitator will communicate that need to the LA contact person. Any revisions to the CAP are submitted by the LA to the facilitator until the review team approves the CAP.
Once the CAP is approved, the CAP acceptance letter is sent out.