"When should we submit our MHSA application?" I have been asked this question several times recently, so thought I would give you some advice here.
Keep in mind that the LACDMH MHSA application and contracting process has several steps and you want to move through them in a way that minimizes your revisions, avoids risk of contract amendments, and maximizes your chance of approval.
I recommend that providers do not submit an initial MHSA application to LACDMH until ...
- you have at least narrowed down the EHR-S product you want to license down to 2 products that are in the same pricing ballpark,
- AND you have a complete overall project budget (like the one I reviewed in the ACHSA seminars and workshops - not simply an EHR-S price given to you by a vendor),
- AND you have a fairly accurate schedule that you have collaborated on with the top 1-2 vendors (which WILL have the final start date as a speculation and need to be revised when you sign the EHR-S license agreement with your final vendor).
- AND preferably you have selected a project manager or consultant to work with you and your final vendor.
So, if you are only beginning to review products, or you have only narrowed it down to vendors in different pricing brackets, and/or you have not found a product / vendor that you are confident can meet your needs, ... you are not ready to draft your initial MHSA project application.
If, however, you have been working as a committee with a fairly structured selection process and narrowed down the products to the one or two that best meet your needs, and your project manager has worked out a draft of a schedule and a comprehensive budget, then you may want to proceed through the Level I & II evaluation steps with LACDMH. And yes, your vendor should / can help you complete the application, but they should not be relied on to do it all. You are the one that will be audited against it. (I can also help if need be, particularly on strategies for your project and reimbursement).
Also, if you have already licensed a product and are implementing it now, it's a good time to submit your first MHSA project application. As long as you base it on costs you will incur after the project is approved.
You should expect to be asked to make several revisions to your project plans and application during these steps, which may take a month or so. It is possible to successfully pass through both Levels of application review without a final product selection, although you will have to submit updates to LACDMH and possibly jump through some more hoops and process if you need a modification to your TNFA, see below.
Once you have successfully passed through Level I & II, the final step is to attend an Orientation meeting (held monthly) and then execute / sign the TNFA, which may also be possible without a final product selection, pricing, and schedule ……….. but not wise!
I advise providers to attend an Orientation meeting, but avoid executing their TNFA until you have a final product selection, pricing, and schedule from your vendor of choice.
Once you have a final project / product plan, then you can submit an update to your MHSA application with final schedule and budget, as well as any sections that relate specifically to the product and vendor. (As long as this update is not wildly different from the one approved, you will likely be able to move ahead. E.g. don't submit an update for a mid-range product, when your initial application was approved for a basic product, when these are not comparable projects on any level.) And then proceed to the TNFA stage.
If you did proceed with the TNFA before this, you will also need to submit the change to your TNFA using another process as well, to be reviewed in the Orientation sessions. But, if your final project differs in cost beyond the budget change thresholds LACDMH set (thresholds were discussed in a previous CPTT meeting, see minutes) in any one cost category or overall, you will be required to file an amendment to your TNFA (which could take months!). Good to avoid this process.
Ok, hope that helps a bit.
Here are some ideal steps to follow:
- Select an expert to facilitate your selection process and pricing negotiations, or at least form a committee and use a structured process, (as taught in the ACHSA seminars and workgroups).
- Narrow down options to 1-2 products, and develop a budget and schedule that has validation from your work with these vendors.
- Submit an initial MHSA application for “EHR-S purchase and implementation”. Including budget and schedule.
- Once approved through Level I & II , attend Orientation and HOLD
- Select product and get final pricing.
- Update a complete project budget with final pricing.
- Submit an Update to your MHSA application.
- Sign TNFA.
- Obtain <=20% of project costs up front from MHSA $, sign the EHR-S vendor agreement.
- Begin the implementation process, and submitting invoices for cost reimbursement.
- If MHSA funds remaining, Submit 2nd MHSA application for “EHR-S ongoing costs”, (paying annually up front makes sense if vendor gives a discount) - or include these costs in initial application and avoid the 2nd, if you have sufficient MHSA dollars.
Of course there are many variations on this theme, for example, projects for certain one-time implementation costs can be used, like Tx Library development / purchase, hardware/network costs, etc. Or other ongoing incremental costs, like Internet access and internal project labor costs. Don't forget, you can submit as many project as you like, so you may want to submit several small cost projects rather than one big one.
If you cannot afford the costs of a comprehensive selection process and need some MHSA funds for that phase first, or simply need help getting to the final product selection and project budget & schedule, try this for your initial project application. You will need to sign a TNFA to start the reimbursement process:
- Select an expert to facilitate your selection process and pricing negotiations, or at least as a committee using a structured process. (as taught in the ACHSA seminars and workgroups)
- Submit an MHSA application for a “EHR-S Selection process” only. Including selection budget and schedule. Your costs for consulting, internal staff time, and 3rd party assessments can be included.
- Once approved, attend Orientation & Sign TNFA contract.
- Obtain <=20% of project costs up front from MHSA $, begin / complete your Selection process, and begin submitting invoices for cost reimbursement.
- Proceed with # 5 above.
Hope this helps. Send in your questions to Keely@4Sahara.com .
No comments:
Post a Comment