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| Revision Date | September 3, 2024 |
Policy
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 Statewide Monitoring Plan (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
Risk-based monitoring is how DFPS prioritizes contract monitoring as established through the SMPs. COS is responsible for developing a Client Services SMP for each contract division and an agency-wide Administrative (Admin) SMP. The SMP is formulated using the contract manager's assessment of risk by completing the Risk Assessment Instrument (RAI).
Risk-based monitoring is established by 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 must manage the event in SCOR which includes determining the monitoring type and level.
Details for the annual SMPs can be found in:
- Client Services Specialized Monitoring Plan (SMP)
- Administrative Specialized Monitoring Plan (Admin SMP)
Enhanced
DFPS requires SSCC/CBC contracts to conduct enhanced monitoring based on analysis of risk.
Enhanced monitoring is beyond what is driven by the RAI and SMP. Enhanced monitoring can be achieved by using a performance-based monitoring approach.
Enhanced monitoring is required when each of the characteristics listed below are met:
- The contract, including all renewals, is greater than $10 million;
- A contractor is responsible for decisions impacting the safety and protection of DFPS clients;
- The Department of Family and Protective Services (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 does not apply to open enrollment, interagency, or interlocal contracts.
COS initiates enhanced monitoring and coordinates with contract divisions to confirm all characteristics are met. For contracts where all characteristics are met, COS creates an enhanced monitoring event in SCOR. Once done, contract staff must manage the event in SCOR which includes reviewing the monitoring type, level and location, and adjusting as needed, and uploading required documentation into SCOR once the monitoring event is completed.
Additional Monitoring as Required by the State Auditor’s Office (SAO)
Within 30 days of the closeout of a contract identified as requiring enhanced contract or performance monitoring, the following information must be documented in the contract file, and provided to the State Auditor, the Comptroller, or Contract Advisory Team (CAT) upon request:
- Each of its performance expectations for the contract;
- The performance indicators it monitored during the contract;
- The methods it used to monitor performance indicators;
- Whether the contractor met its performance expectations;
- A summary of corrective action plans and corrective actions taken by the contractor;
- Any liquidated damages assessed or collected from the contractor; and
- A summary of lessons learned during management of the contract that the agency will apply to future procurements.
Complaint
Complaint is a monitoring review reason that occurs in response to a complaint or concern lodged against a contractor. The complaint may come from:
- DFPS client
- DFPS employee
- Contractor's employee
- Community stakeholder, or
- Another State Agency
Contract staff must maintain documentation with the contractor to explain and resolve the complaint. Documentation is required to close out the complaint event. Documentation must include what was reviewed and final recommendations or resolution of the issue identified in the complaint.
Follow-Up
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 follows 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.
Contract staff must maintain documentation with the contractor regarding the follow-up monitoring to close out a follow-up event.
If findings from a follow-up monitoring are unresolved, contract staff refer to policy Contractor Noncompliance and Contract Remedies.
Routine
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.
Contract staff provide documentation to the contractor of the routine monitoring event and may inform future risk assessment and monitoring events.