To minimize the risk that claiming units could include unallowable costs when calculating their reimbursement claims, Health Care Services should encourage the Los Angeles County Office of Education (Los Angeles County) to revise its contracts with its claiming units to make it clear that claiming units cannot include Health Care Services' participation fee as part of their claims.
DHCS conducted a site visit in September of 2015 for LACOE. On April 29, 2016, DHCS confirmed that LACOE amended their contracts to ensure LEAs cannot claim the participation fee. In addition, DHCS issued PPL 16-007 on April 8, 2016, that detailed the prohibition of claiming reimbursement fees.
DHCS reviewed all LEC and LGA boilerplate contract language to ensure language regarding reimbursement for participation fees is accurate. Outside of LACOE LEC, DHCS did not find issues with the current contract language between all other LECs/LGAs and their LEAs. DHCS is currently working with LACOE to amend their contract and eliminate provisions that allow claiming of participation fees. DHCS will post a Policy and Procedure Letter (PPL) detailing the prohibition of claiming reimbursement for the fees that DHCS charges LECs and LGAs for participating in the program and specifying that those fees cannot be passed on to LEAs.
DHCS has requested copies of boiler plate contract language from all LEC/LGAs to ensure language regarding participation fees is accurate. DHCS received and reviewed LACOE's contract and confirmed it does include language that allows the claiming units to include DHCS' participation fee. Staff will be meeting with the LACOE LEC coordinator at the September 30, 2015 scheduled site visit, and require that the contract be amended to remove this language and be replaced with language reflecting that this is an unallowable fee.
Estimated completion date to ensure all executed LEC/LGA contracts are correct is June 30, 2016.
Agency responses received are posted verbatim.