Kyle L. Janek M.D., Executive Commissioner
VENDOR CONFERENCE
Nonemergency Medical Transportation Services
(NEMT) Request for Proposal (RFP)
No. 529-15-0002
December 10, 2013 (10:00 AM – 1:00 PM)
Welcome

Introductions:
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Chris Traylor, Chief Deputy Executive
Commissioner
Wayne Wilson, Deputy Executive
Commissioner, Richard Blincoe, Procurement
Project Manager, PCS
Robert Hall, Director for Client Services
Procurement/HHS HUB Coordinator, PCS
Dimitria Pope, Director, Medical
Transportation Program (MTP)
Shannon Pickett, Associate Director MTP
Rich Stebbins, Director of Finance,
2
Medicaid/CHIP
Welcome

Introductions (cont.):


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
Rachel Butler, Chief Actuary, Financial
Services
PJ Fritsche, Director of Health Services
System, Information Technology
Sherice Williams, HUB Coordinator
/Administrator, Procurement and Contract
Services (PCS)
Kent Hardin, Assistant General Counsel, Office
of General Counsel
Housekeeping Items
3
Vendor Conference Overview

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Procurement Activities
Program/RFP Overview
Financial Overview
Capitation Rate Methodology Overview
Information Technology and Telecom
Overview
HUB Overview
Legal Overview
Question Submittal
Break
4
PCS Procurement Activities

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Sole Point of Contact
Source for Questions & Answers
Procurement Schedule
Solicitation Access
http://www.hhsc.state.tx.us/contract/5
29150002/rfp/announcements.shtml
Submission Requirements
Solicitation Amendments
Oversees Screening & Evaluation Process
Award Information
5
Procurement Schedule

RFP Release Date
November 25, 2013

Vendor Conference
December 10, 2013

Vendor Questions Due (COB)
December 13, 2013

Response to Questions Posted

Proposals Due (2:00 PM Central Time)
January 15, 2014

Tentative Award Posting
March 1, 2014

Anticipated Contract Start Date
(est.)
(est.)
December 19, 2013
July 31, 2014
6
PROGRAM/PROJECT OVERVIEW
RFP #529-15-0002
Dimitria D. Pope, Director MTP
7
RFP Mission
HHSC’s mission for this procurement is to
establish a statewide network of qualified,
Managed Transportation Organization
(MTO) that will offer quality, safe, timely
and economical transportation services to
eligible clients that have no other means
of transportation to obtain medical care or
other health care services.
8
RFP Goals and Objectives



Comply with requirements of Senate Bill 8.
Establish a qualified MTO in each MTO
Region to provide transportation services
to eligible clients that have no other means
of transportation to obtain medical care or
other health care services.
Ensure that eligible MTP clients have safe
and timely access to transportation
services to covered medical care or other
health care services.
9
RFP Goals and Objectives (Cont.)



Offer quality service that is appropriate
and economically feasible based on client
health care needs.
Increase program efficiencies through the
establishment of a regional network of
transportation providers.
Eliminate potential for fraud, waste and
abuse.
10
RFP Goals and Objectives (Cont.)



Reduce the cost of medical transportation
by utilizing a capitation rate methodology.
Increase efficiencies through data
analytics collected and reported by
providers and analyzed by HHSC.
Comply with obligations of the Frew
lawsuit.
11
Contract Terms


HHSC will award multiple contracts
across the State, selecting one vendor per
MTO Region.
Initial contract period will be for a term
of three (3) years with option to extend
the term of the contract for up to two (2)
additional (1) year terms or as necessary
to complete mission of procurement.
12
Contract Terms (Cont.)


Vendors may apply for, and may be
awarded contracts for, multiple MTO
Regions.
Vendors must submit separate proposal
responses for each MTO Region in which
they wish to be considered.
13
Scope of Work


Provide a statewide network of qualified
regional providers for transportation
services that offers quality, safe, timely
and economically feasible medical
transportation services to eligible clients.
Administer and operate the program
ensuring vendor and subcontractor
compliance and accountability to HHSC
for effective and efficient performance.
14
FINANCIAL OVERVIEW
Rich Stebbins
HHSC-MCD Finance Director
15
Financial Overview



Fundamentals of a Capitated, Full Risk
contract
Financial evaluation of RFP submissions
and prospective Vendors
Post-award financial performance
monitoring & reporting requirements
16
Fundamentals of a Capitated,
Full Risk contract

How it works:
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

Not based on payment for each service
rendered
Not based on reimbursement for specific
costs incurred
HHSC establishes a monthly rate per
person, which covers each eligible person
living in the MTO’s Region
17
Fundamentals of a Capitated,
Full Risk contract

How it Works (Cont.):


This rate varies by type of person (e.g.,
under 21), and other factors (urban vs.
rural, by Region, etc.); each type is called a
rate cell
Aggregate monthly payment amount
determined by HHSC, by multiplying
monthly rate by the quantity of each
beneficiary type
18
Fundamentals of a Capitated,
Full Risk contract

How it Works (Cont.):


Aggregate monthly payment will fluctuate
depending upon the changes in number
(and types) of eligible beneficiaries living
in the Region
The MTO is then responsible to provide all
Contract-required services during the
month for that monthly amount
19
Fundamentals of a Capitated,
Full Risk contract

How it works (Cont.):
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
Some beneficiaries will use no services;
MTO is still paid.
Some beneficiaries use high degree of
services; MTO not paid any extra.
20
Fundamentals of a Capitated,
Full Risk contract

How it Works (Cont.):


Monthly amount paid is also to cover
administration, including Contract
Deliverables.
MTO is responsible for providing all
Contract-required NEMT services for every
eligible beneficiary living in the MTO’s
Region, regardless of where the
beneficiary may need to travel.
21
Fundamentals of a Capitated,
Full Risk contract

How it works (Cont.):
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
The Region defines who an MTO covers; it
does not define where an MTO is
responsible for providing transportation.
Monthly capitation is usually received by
MTO about mid-month, for the month
covered. This provides some cash-flow
advantage for the MTO.
22
Fundamentals of a Capitated,
Full Risk contract

How it works (Cont.):


Monthly cap payments fluctuate primarily
by beneficiary population, not by service
usage.
If usage goes up in a given month, costs
will go up, but revenues will not
necessarily change. Likewise, if usage
goes down in a month, costs will go down,
but revenues may not change.
23
Fundamentals of a Capitated,
Full Risk contract

Other Implications:
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MTOs may suffer losses if the capitation
does not cover all costs. HHSC does not
reimburse for any such losses.
Capitation rates include a profit
component but this is a full risk contract
and losses are borne by the contractor.
24
Fundamentals of a Capitated,
Full Risk contract

Other Implications (Cont.):
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The MTO should aggressively negotiate
provider subcontract rates, and look for
administrative efficiencies.
Generally speaking, HHSC adjusts rates
each year based in large part on a prior
period of experience and demonstrated
cost trends.
25
Fundamentals of a Capitated,
Full Risk contract

Other Implications (Cont.):
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There is a substantial amount of reporting
and administration involved.
Capable IT and financial staff will be
needed on an on-going basis.
HHSC dual goal: Vendor solvency and
lower costs for taxpayers.
26
Fundamentals of a Capitated,
Full Risk contract
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
Other Implications (Cont.):
It is in the MTO’s own best interest to
develop methods to cut costs, without
denying required services to beneficiaries:


This would increase an MTO’s profit in a given
year.
Over the long run, will bring down total costs
to HHSC.
27
Fundamentals of a Capitated,
Full Risk contract

History of capitated full-risk contracts:
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HHSC has successfully utilized capitated fullrisk contracts for 18 years.
HHSC now pays out over $14 Billion annually
under these contracts.
Many vendors are involved, and they generally
apply to sign-up again when contracts expire.
28
Fundamentals of a Capitated,
Full Risk contract

History of capitated full-risk contracts
(Cont.):
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
For NEMT, HHSC has already utilized this
approach for the state’s two largest metro
areas, which covers approximately 45% of
the state’s beneficiary population.
Undertaking such a contract is a significant
endeavor.
29
Financial evaluation of RFP
submissions and prospective
Vendors
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Financial capacity, stability, and track
record of prospective Vendors.
Negotiating financially-competitive
subcontracts with transportation
providers.

Potential in-house or Affiliate fleets.

Vendor strategies for reducing costs.
30
Post-Award Financial Performance
Monitoring & Reporting Requirements

Why internal MTO costs matter to HHSC:
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Certain costs are unallowable based on
regulation or contract.
Historical vendor costs are an important
component in the rate-setting process.
31
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)
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Encounter submissions:
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“Encounters” are electronic records of
provider transactions.
Encounter data must be sent to HHSC’s
agent by the MTO.
Encounter data must be highly accurate.
32
Post-award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

Encounter submissions (Cont.):
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The MTO must have knowledgeable staff
to handle this data.
Encounters must tie to financial reports,
within close tolerances.
Encounters will be used in developing
future capitation rates.
33
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

MTO financial reporting to HHSC:
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Financial reporting is described in the RFP,
and required by the Contract.
Most reporting is quarterly and annually,
with some “as-occurs” reports.
34
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

MTO financial reporting to HHSC:
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
There are a number of different reports,
requiring some substantial administrative
efforts.
Reports include a defined income
statement, plus operating metrics, and
various disclosures.
35
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

HHSC Cost Principles:
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Financial reporting must conform to
HHSC’s Cost Principles document.
There are a number of types of costs that
are allowable by GAAP and the IRS that
are not allowable for inclusion in reports
to HHSC.
36
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

Experience Rebates:
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If an MTO earns a pre-tax income of over
5%, then the MTO must rebate back a
certain portion that is in excess of the 5%
income.
Certain offsets may apply, such as a Loss
Carry-forward.
37
Post-Award Financial Performance
Monitoring & Reporting Requirements
(Cont.)

Audits:
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
Each annual Financial Statistical Report
(FSR) is audited.
Liquidated Damages:

Potential penalties for misreporting, late
reporting or inadequate reporting.
38
CAPITATION RATE METHODOLOGY
Rachel Butler, Chief Actuary
39
Capitation Rate Process Overview


Generally, under a capitated full-risk
model, the Managed Transportation
Organization will be paid a
predetermined amount, per member per
month (PMPM) for each enrolled client in
their area.
Rates are set annually for the state fiscal
year which begins September 1.
40
Capitation Rate Process Overview
(Cont.)


Rate setting process begins well in
advance of the effective date.
HHSC in conjunction with HHSC’s
external actuarial firm calculates the
rates in advance of the effective date.
41
Capitation Rate Process Overview
(Cont.)
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MTOs will be present rates and a meeting
will be held to discuss the rate-setting
methodology used in determining those
rates.
MTO’s will be given the opportunity to
ask questions and comment on the rates.
42
Capitation Rate Process Overview
(Cont.)
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Additional time will be granted for the
MTO’s to draft responses and provide
additional information or data they deem
necessary for rating.
A final meeting will be held with the
Executive Commissioner present the
MTO’s comments and seek approval of
the rates.
43
Capitation Rate Process Overview
(Cont.)

Rates require approval from the following:

HHSC Executive Commissioner

Legislative Budget Board

Governor’s Office

Centers for Medicare and Medicaid Services
(CMS)
44
Capitation Rate Methodology

Rates are fixed for the rating period.

Rates are set by:

Geographical service area

Risk Group
45
Capitation Rate Methodology
(Cont.)

Rate Components:

Base Data

Trend

Adjustments for Policy Changes

Administrative Cost

Risk Margin
46
INFORMATION TECHNOLOGY &
TELECOM OVERVIEW
P.J. Fritsche, Director
Health Services Systems
47
Information Technology &
Telecom Overview


HHSC IT’s mission is to provide
outstanding customer service and
innovative technology solutions securely,
efficiently and effectively.
HHSC IT will support secure file transfers,
provide NEMT eligibility and rate files,
and support for the Telecom cloud.
48
Information Technology &
Telecom Overview
(Cont.)

HHSC Health Services Systems:
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
Oversees IT Readiness Review.
Provides eligibility and capitated rate files
via secure transmission.
Supports client look up through Texas
Medical Transportation System.
49
Information Technology &
Telecom Overview
(Cont.)


IT oversight for vendor and subcontractor
compliance to IT standards, including
Claims Administrator.
HHSC Infrastructure & Operations:
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Contract oversight for Telecom Cloud
implementation
On-going support of Telecom Cloud
IT oversight for telecom vendor and
subcontractor compliance to IT standards.
50
Information Technology &
Telecom Overview
(Cont.)

HHSC provided cloud telecommunications
services will include:

Toll-free number routing to MTO (IVR)

ACD functionality
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Priority call routing

Call center reporting

Audio recording
51
Information Technology &
Telecom Overview
(Cont.)

For onsite functionality, HHSC will install
and provide the following:
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Agent phones
Cabling to agent stations
Voice gateways
Network connectivity
Remote and onsite maintenance of HHSC
provided telephony equipment and cabling
Initial training to MTO on ACD reports,
audio recording and call monitoring
52
systems
Information Technology &
Telecom Overview
(Cont.)

Claims Administrator (Texas Medicaid
Health Partnership):



Third party vendor responsible for
provider enrollment, Encounter
Processing, and central secure file transfer
via TxMed Central.
On-line provider enrollment and lookup.
Maintains Electronic Data Interface (EDI)
for Encounter submission.
53
HHSC Cloud Telecommunications (Cisco)
(877) 633-8747
Clients
Data
Center
Cloud Infrastructure
Business Reporting
Quality
Management
Application
ACD
CTI
IVR
Dialer
WFM
Routing
Applications
• IVR
MTO 1
MTO 5
• ACD
MTO 3
MTO 2
MTO 6
QM
MTO 7
MTO 8
MTO 9
MTO 4
MTO 10
MTO 11
54
Information Technology –
Encounters

What is an Encounter?
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

Historical record of a claim adjudicated by
the MTO for a covered service.
Used by HHSC to monitor MTO
performance, comply with Federal
reporting, and as a component of rate
setting.
Encounter Record: An electronically
formatted list of encounter data elements
in a HIPAA compliant transmission.
55
Information Technology –
Encounters – EDI X12 837P

What is an EDI X12 837P transaction?


EDI (Electronic Data Interchange) X12
provides standards for exchanging data
between two entities.
The 837P is the standard document format
for exchanging information about
Healthcare Claims/Encounters for
Professional services.
56
Information Technology –
Encounters – EDI X12 837P
(Cont.)

What is an EDI X12 837P transaction?
(Cont.)


HHSC uses the EDI X12 837P version 5010
X222A1 standard as its basis for
standardizing the submission of NEMT
Encounter Data.
Customizations to this standard to support
MTO service data are described in the MTO
837P Companion Guide provided by HHSC.
57
Information Technology –
Encounters Submission

How is Encounter Data submitted to
HHSC?
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
MTO IT system will generate files with a
maximum of 5000 Encounters compliant
with the EDI X12 837P standard and the
MTO 837P Companion Guide.
MTO’s will submit Encounter Data at least
monthly no later than the 30th calendar
day after the last day of the month in
which the claim was adjudicated.
58
Information Technology –
Encounters Submission
(Cont.)

How is Encounter Data submitted to
HHSC? (Cont.)

Each MTO will put Encounter files in a predefined secure folder location on TMHP’s
Secure FTP server assigned to the MTO.
59
Information Technology –
Encounters Processing

How are Encounters processed?
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
Encounter files submitted by MTO’s will
automatically be picked up for processing
and validated for X12 structure
compliance.
An EDI X12 999 Functional
Acknowledgement file will be generated
for each file processed and will indicate if
the entire file was rejected due to X12
non-compliance.
60
Information Technology –
Encounters Processing
(Cont.)

How are Encounters processed? (Cont.)


Files that pass the X12 structure
compliance validation will then be
validated for compliance with transaction
level HIPAA and Business edits.
An EDI X12 277 CA (Encounter/Claim
Acknowledgement) report will provide the
results of this second level of validation
and will identify any individual
transactions that were rejected.
61
Information Technology –
Encounters Processing (Cont.)

How are Encounters processed? (Cont.)


Accepted Encounter transactions will be
stored for review by Texas HHSC.
Rejected Encounter files and transactions
must be corrected and resubmitted by
MTO’s within specified timelines.
62
Encounter Data
Secure FTP Folder
EDI
X12
837P
MTO
IT System
EDI
X12
999
EDI
X12
277CA
Encounter
Data
Functional
Acknowledgement
TMHP
Encounter
System
Claim/Encounter
Status
63
Historically Underutilized Business
(HUB) Requirements
Sherice Williams
HHSC HUB Coordinator/Administrator
64
Agenda Topics
I.
RFP Section 4.0 Historically Underutilized
Business Participation Requirements
II. HUB Subcontracting Plan Development
and Submission
III. HSP Quick Checklist – Handout
IV. HSP Methods – Section 4.6.3-4.6.6
V.
HSP Prime Contractor Progress
Assessment Report – Section 4.8
65
I. Historically Underutilized
Business Participation
Requirements
66
I. RFP Section 4.0 Historically
Underutilized Business
Participation Requirements
•
HUB Participation Goals – Section 4.3
•
Potential Subcontracting Opportunities – Section
4.5
•
Centralized Master Bidders List and HUB Directory –
Section 4.5
•
Vendor Intends to Subcontract – Section 4.6
67
I. RFP Section 4.0 Historically
Underutilized Business Participation
Requirements (cont.)
•
Minority or Women Trade Organizations – Section
4.6.6
•
Self Performance – Section 4.7
•
HSP Changes After Contract Award – Section 4.8
•
Reporting and Compliance with the HSP – Section
4.8
68
II. HUB Subcontracting Plan (HSP)
Development and Submission
69
If HSP is
inadequate,
response will be
rejected
HUB GOALS
Special
reminders and
instructions
HSP
Information
Page
70
III. HSP Quick Checklist
** See Checklist Handout**
71
IV. HSP Methods
72
METHOD OPTIONS
A Respondent may choose from one of the
following methods when completing the
HSP:
• Method I – if 100% of your subcontracting
opportunities will be performed using only HUB
vendors;
• Method II – if one or more of the subcontracting
opportunities identified will be performed using HUB
protégé’s;
• Method III – if a combination of HUBs and Non-HUBs
are used to perform the subcontracting work identified
AND the HUB goal identified in the solicitation is met
or exceeded;
73
METHOD OPTIONS
A Respondent may choose from one of the
following methods when completing the HSP
(cont.):
• Method IV – if a combination of HUBs and Non-HUBs
are used to perform the subcontracting work identified
AND the HUB goal identified in the solicitation is not
met or exceeded.
• Method V - if the Respondent intends to self perform
all of the work utilizing their own resources,
equipment, employees, and supplies.
74
ALL METHODS
For ALL Methods the following steps are
required to be completed on the HSP Form:
• Page 1 - Section 1 - Respondent and Requisition
Information;
• Page 2 - Company and Requisition Information
• Page 2 - Section 2(a) – Subcontracting Intentions
• Section 4 – Affirmation and Sign
75
HSP
Information
Page
Respondent and
Requisition
Information
76
Company Name
and Requisition #
Subcontracting
Intentions:
If Yes, Complete
Section 2a
If No, Complete
Section 2b
77
Section 4;
Affirmation
Signature
Affirms that
Information
Provided is
True and
Correct.
78
METHOD I
If all (100%) of your subcontracting
opportunities will be performed using only
HUB vendors, complete:
• All of the steps in Slides 76 and 77
• Section 2 b. – List all the portions of work you will
subcontract, and indicate the percentage of the
contract you expect to award to HUB vendors;
• Section 2 c. – Yes;
• HSP GFE Method A (Attachment A) – Complete
this attachment for each subcontracting
opportunity.
79
Complete Section
2-b; List all the
portions of work you
will subcontract, and
indicate the % of the
contract you expect
to award to all HUBs.
Complete Section
2-c; Yes if you will
be using only HUBs
to perform all
Subcontracting
Opportunities in 2-b.
80
HSP GFE Method A
(Attachment A)
Complete this
attachment
(Sections A-1 and
A-2) and List Line #
and Subcontracting
Opportunity.
HUB Subcontractor
Selection for this
Subcontracting
Opportunity
81
METHOD II
If any of your subcontracting opportunities
will be performed using HUB protégés,
complete:
• All of the steps in Slides 76 and 77
• Section 2 b. – List all the portions of work you
will subcontract, and indicate the percentage of
the contract you expect to award to HUB
vendors;
• HSP GFE Method B (Attachment B) – Complete
Section B-1 and Section B-2 only for each
subcontracting opportunity as applicable.
82
Complete Section
2-b; List all the
portions of work you
will subcontract, and
indicate the % of the
contract you expect
to award to HUB
Protégés.
Skip Sections
2-c and 2-d.
83
HSP GFE Method B
(Attachment B)
Complete
Sections B-1; and
B-2 only for each
HUB Protégé
subcontracting
opportunity.
84
HSP GFE Method B
(Attachment B)
List the
HUB Protégé(s)
85
METHOD III
If you are subcontracting with HUBs and Non-HUBs,
and the aggregate percentage of subcontracting with
HUBs in which the HUB Goal identified in the
solicitation is met or exceeded , complete:
•
All of the steps in Slides 76 and 77
•
Section 2 b. – List all the portions of work you will
subcontract, and indicate the percentage of the
contract you expect to award
to HUB vendors and
Non HUB vendors;
•
Section 2 c. – No;
•
Section 2 d. – Yes;
•
HSP GFE Method A (Attachment A) – Complete this
attachment for each subcontracting opportunity.
86
Complete Section
2-b; List all the
portions of work you
will subcontract, and
indicate the % of the
contract you expect
to award to HUBs
and Non-HUBs.
Complete Section
2-c; No to using only
HUBs to perform all
Subcontracting
Opportunities in 2-b.
87
Complete Section
2-d; Yes, to the
Aggregate % of the
contract expected to
be subcontracted to
HUBs to meet or
exceed the HUB
goal, which you
have a contract
agreement in place
for five (5) years or
less.
88
HSP GFE Method A
(Attachment A)
Complete this
attachment
(Sections A-1 and
A-2) for each
subcontracting
opportunity.
Subcontractor
Selection (HUBs and
Non-HUBs)
89
METHOD IV
If you are subcontracting with HUBs and Non-HUBs,
and the aggregate percentage of subcontracting with
HUBs, holding an existing contract with HUBs for 5
years or less, does not meet or exceed the HUB Goal
identified in the solicitation, complete:
•
All of the steps in Slides 76 and 77
•
Section 2 b. – List all the portions of work you will
subcontract, and indicated the percentage of the
contract you expect to
award to HUB vendors and
Non HUB vendors;
•
Section 2 c. – No;
•
Section 2 d. – No;
•
HSP GFE Method B (Attachment B) – Complete this
attachment for each subcontracting opportunity.
90
Complete Section
2-b; List all the
portions of work
you will subcontract,
and indicated the %
of the contract you
expect to award to
HUBs and Non-HUBs.
Complete Section
2-c; No, to using
only HUBs to
perform all
Subcontracting
Opportunities in 2-b.
91
Complete Section
2-d; No, to the
Aggregate % of the
contract expected to
be subcontracted to
HUBs to meet or
exceed the HUB
goal, which you
have a contract
agreement in place
for five (5) years or
less.
92
HSP GFE Method B
(Attachment B)
Complete
Section B-1; and
Section B-2
only for each
subcontracting
opportunity.
Good Faith
Efforts to find
Texas Certified
HUB Vendors
93
HSP GFE Method B
(Attachment B)
Written
Notification
Requirements
List 3 HUBs
Contacted
for this
Subcontracting
Opportunity
94
HSP GFE Method B
(Attachment B)
Written
Notification
To Trade
Organizations
95
HSP GFE Method B
(Attachment B)
List Trade
Organizations
Notified with
Dates
Sent/Accepted.
96
HSP GFE Method B
(Attachment B)
Provide written
justification why
a HUB was not
selected for this
Subcontracting
Opportunity
97
METHOD V
If you are not subcontracting any portion of
the contract and will be fulfilling the entire
contract with your own resources (i.e.,
equipment, supplies, materials, and/or
employees), complete:
•
All of the steps in Slides 76 and 77
•
Section 3 – Self Performing Justification
98
Section 3; Self
Performing
Justification
List the specific
page(s)/section(s)
of your proposal
response, OR in the
space provided,
which explains how
your company will
perform the entire
contract with its
own equipment,
supplies, materials
and/or employees.
99
HUB Subcontracting Opportunity
Notification Form
100
Sample for
Respondent’s
Use.
101
V. HSP Prime Contractor Progress
Assessment Report
102
HSP Prime
Contractor
Progress
Assessment
Report
• Required with
ALL Pay Requests
• List ALL Sub
payments
(HUBs & Non-HUBs)
• Required even if
not subcontracting
103
Legal Overview
Kent Hardin, J.D.
HHSC Office of General Counsel
104
Legal Overview

Statutes and Rules

Collusion

Apparent or Actual Conflicts of Interest

Revolving Door

Don’t Skip Details
105
Texas Health and Human Services
Commission
Question Submittal
Texas Health and Human Services
Commission
Break
Texas Health and Human
Services Commission
Closing Comments
108
Texas Health and Human
Services Commission
Thank You!
109