|Revision Date||September 26, 2022|
Contract staff must document monitoring activities in the System of Contract Operation and Reporting (SCOR) where monitoring is categorized by a review reason. Depending on the review reason, the monitoring event may only be created by Contract Oversight and Support (COS), while others may be created by contract staff.
For the following review reasons the monitoring event will be created in SCOR by COS:
- Risk-Based - when a contract is listed on the Client Services or Administrative SMP, then a monitoring event will be created in SCOR.
- Enhanced - is designated for client services contracts that meet the indicators outlined below.
For the following review reasons, the monitoring event may be created by contract staff to document additional monitoring events:
- Routine - a monitoring event initiated by contract staff to support or facilitate contractor compliance or best practice, and not driven by the results from completing a formal risk assessment tool.
- Complaint - if a complaint is brought against a contractor and it is determined that a monitoring review is necessary.
- Follow-up - any monitoring that is an additional monitoring event resulting from a risk based, enhanced, or complaint review.
Risk-based monitoring is the means by which DFPS prioritizes contract monitoring as established through the Specialized Monitoring Plans (SMPs). COS is responsible for developing a Client Services SMPs for each contract division and an agency-wide Administrative (Admin) SMP. The SMP is formulated using the contract manager’s assessment of risk through the completion of the applicable Risk Assessment Instrument (RAI).
Risk-based monitoring is established via the SMP and is entered into SCOR by COS as a monitoring event. Once COS enters the risk-based monitoring event in SCOR, contract staff are responsible for managing the event in SCOR which includes determining the monitoring type and level.
Details for the annual SMPs can be found in:
DFPS has designated the SSCC/CBC contract model to require enhanced monitoring based on analysis of risk.
Enhanced monitoring intensity is beyond what is driven by the Risk Assessment Instrument (RAI) and the SMP. One way enhanced monitoring can be achieved is by using a performance-based monitoring approach.
Enhanced monitoring is required when each of the characteristics listed below are met:
- Total cost or expected cost of the contract is over $10 million including all contract renewals;
- A client services contractor is responsible for decisions impacting the safety and protection of DFPS clients;
- DFPS could be negatively impacted by a contractor’s failure or delay in performance;
- Complexity of the contract (e.g., contractor is responsible for managing a network of subcontractors that provide client services, case management, and statutorily mandated child welfare outcomes ; and
- Heightened risk of loss, fraud, waste or abuse (e.g. utilization management is determined by the contractor, newly formed entity, financial weaknesses, high staff turnover, etc.).
Exception: Enhanced monitoring is not applicable for, open enrollment, interagency, or interlocal contracts.
COS initiates enhanced monitoring identification and coordinates with contract divisions to confirm all characteristics are met. For contracts where all characteristics are met, an enhanced monitoring event is created in SCOR by COS. Once this is done by COS, contract staff are responsible for managing the event in SCOR which includes reviewing the monitoring type, level and location, and adjusting as needed; as well as uploading required documentation into SCOR once the monitoring event is completed.
Complaint is a monitoring review reason that occurs in response to a complaint or concern lodged against a contractor. The complaint may come from a variety of sources such as:
- A DFPS Client
- DFPS employee
- Contractor’s employee
- Community stakeholder, or
- Another State Agency
Complaint monitoring correspondence from contract staff to the contractor is required to close out the complaint event. Correspondence should include what was reviewed and final recommendations or resolution of the issue identified in the complaint.
Follow-up is an additional monitoring event resulting from a risk based, enhanced, or complaint review. The risk based, enhanced, or complaint final monitoring report should indicate any required follow-up. The goal of a follow-up is to ensure the contractor is in compliance with the corrective action identified to remedy the finding. For Follow-up monitoring events, document all follow-up activities to inform future monitoring events. The event and results entered in SCOR should reflect the fiscal year in which the original monitoring event occurred.
Follow-up monitoring correspondence from contract staff to the contractor is required to close out a follow-up event.
If findings from a follow-up monitoring event remain unresolved, contract staff should refer to policy Contractor Noncompliance and Contract Remedies.
Routine is a monitoring event resulting from contract staff determination that monitoring protocol (sampling methodology, monitoring tools, report) should be used to promote, strengthen, or facilitate contractor compliance or best practice. The purpose of a routine monitoring is to provide feedback to the contractor through review of records and sharing of best practices.
Correspondence from contract staff to the contractor is provided to document the routine monitoring event and may inform future risk assessment and monitoring events.