WHO IS ACCREDITED?

Private Organization Accreditation

Catholic Charities alleviates human suffering and improves the quality of life of 100,000 people annually, regardless of religious background. A staff of 600 provides support and services related to housing, food, mental health, children's services, addiction treatment, and domestic violence services.
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ORGANIZATION TESTIMONIAL

Children's Foundation of Mid America

James W. Thurman, President/CEO

Children’s Foundation of Mid America has been accredited through COA since 1983. The process of accreditation ensures that we meet or exceed the highest standards in the industry.
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Purpose

A stable, qualified workforce contributes effectively and efficiently to consumer satisfaction and positive service delivery results.

FOC
HR 8: Independent Contractors

The organization:

  1. exercises due diligence when contracting with independent contractors; and
  2. routinely monitors compliance with contract requirements.

Update:

  • Added Standard - 08/31/17
    A new core concept standard was added to address the use of independent contractors. 
Rating Indicators
1
The organization's practices fully meet the standard, as indicated by full implementation of the practices outlined in the HR 8 Practice standards.
2
Practices are basically sound but there is room for improvement, as noted in the ratings for the HR 8 Practice standards.
3
Practice requires significant improvement as noted in the ratings for the HR 8 Practice standards; and/or
  • At least one of the HR 8 fundamental practice standards has been rated 3 or 4; or
  • Two of the HR 8 practice standards have been rated 3 or 4.
4
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the HR 8 Practice standards. 

Table of Evidence

Self-Study Evidence On-Site Evidence On-Site Activities
    • Procedures for hiring and contracting with independent contractors (HR 8.01, HR 8.02, HR 8.03, HR 8.04)
    • Procedures for maintaining contractor client records (HR 8.05)
    • Procedures for collecting quality data from contractors (HR 8.06)
    • Procedures for monitoring contracts with independent contractors (HR 8.06)
    • Procedures for maintaining independent contractor records (HR 8.07)
     
    • Review a sample of contracts with independent contractor (HR 8.01, HR 8.02, HR 8.03, HR 8.04)
    • Review independent contractor client files (HR 8.05)
    • Review independent contractor records (HR 8.06)
    • Review documentation of contract compliance (HR 8.06)
    • Interview:
      1. Relevant staff
      2. Sample of independent contractors

  • HR 8.01

    Written contracts with independent contractors:

    1. are time-limited with a specified end date;
    2. define scope-of-work, expectations, and deliverables with specific timeframes;
    3. describe protocols for routine communication of relevant information and data, including confidential information;
    4. include requirements for maintaining client records, documentation of services, and organization access to client records; 
    5. describe expectations for contractor involvement in the organization’s quality improvement process; and
    6. include under what circumstances the contract can be terminated.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Procedures need greater clarity; or 
    • One of the standard's elements is not fully addressed.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or 
    • Two elements are not fully addressed or one of the elements is not addressed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.

  • HR 8.02

    Written contracts with independent contractors who provide direct services include criteria for:

    1. service quality;
    2. client satisfaction; and 
    3. outcomes that accord with the organization’s expectations.

    NA The organization does not use independent contractors to provide direct services to clients.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Procedures need greater clarity; or 
    • One of the standard's elements is not fully addressed.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or 
    • Two elements are not fully addressed or one of the elements is not addressed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.

  • HR 8.03

    Written contracts with independent contractors specify necessary qualifications, including:

    1. education;
    2. training;
    3. experience;
    4. degree requirements, certifications, licenses, etc.; and
    5. as required, the expectation that contractors maintain licensure, etc. including pursuit of CEUs as applicable.

    Interpretation: Contractor qualifications  for independent contractors providing direct services must include the qualifications listed in the relevant COA Service Standards. For example, if the organization is using contractors to deliver mental health services, then contracts must include the qualifications listed in the Personnel section of COA’s Services for Mental Health and/or Substance Use Disorders (MHSU) standards.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g.,
    • Procedures need greater clarity; or
    • One of the standard's elements is not fully addressed.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or 
    • Two elements are not fully addressed or one of the elements is not addressed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.
    • Contractor qualifications do not include qualifications per relevant service standards.

  • FP
    HR 8.04

    Prior to entering into a contract, the organization verifies in writing that each contractor:

    1. possesses the necessary qualifications;
    2. is licensed and/or has certification, where applicable; 
    3. has relevant experience; 
    4. has experience delivering services to the service population, if providing direct services; and
    5. carries professional liability insurance, as required by law or generally accepted business practices.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Procedures need greater clarity; or 
    • One of the standard's elements is not fully addressed.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or 
    • Two elements are not fully addressed or one of the elements is not addressed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.

  • FP
    HR 8.05

    The organization establishes procedures for how client records are maintained by independent contractors that address:

    1. ownership of records;
    2. information that must be recorded in client records;
    3. organization access to client records for internal and external quality oversight, including review by Medicaid and/or other external funders or regulators, and accrediting bodies;
    4. secure storage;
    5. destruction of records;
    6. whether copies of records may be retained by the contractor; and 
    7. maintaining client confidentiality.

    NA The organization does not use independent contractors to provide direct services to clients.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Procedures need greater clarity; or 
    • One of the standard's elements is not fully addressed.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or 
    • Two elements are not fully addressed or one of the elements is not addressed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.

  • HR 8.06

    The organization routinely monitors and documents contractor progress toward fulfilling the terms of the contract.

    Interpretation: Monitoring timeframes and documentation expectations should be established in written procedures.

    Interpretation: For standards that will be implemented by independent contractors (e.g., CR, BSM, and ASE), the organization must:

    1. provide contractors with a comprehensive policy and procedure manual or include copies of relevant policies and procedures in contracts with independent contractors; 
    2. include contract language regarding a contractor’s obligation to adhere to organization policies and procedures; and 
    3. routinely monitor and document compliance with organization policies and procedures (see HR 8.07).

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Procedures need greater clarity.
    3
    Practice requires significant improvement; e.g., 
    • Procedures are very general and/or do not provide useful guidance; or
    • Monitoring is sporadic; or
    • Documentation is incomplete or poorly maintained.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all.

  • FP
    HR 8.07

    The organization maintains a record for each independent contractor that contains:

    1. identifying and contact information;
    2. application, resume, and documentation of qualifications;
    3. IRS Form SS-8 or an internal assessment that the individual was properly classified as an independent contractor per Internal Revenue Service guidelines; 
    4. a completed IRS W-9 form;
    5. documentation of reference checks;
    6. documentation of qualifications per HR 8.04; 
    7. a background check, as appropriate; 
    8. a copy of the contract; 
    9. a signed statement that the contractor will adhere to the organization’s conflict of interest policies; 
    10. a signed confidentiality agreement; and
    11. documentation of quality monitoring of contractor performance.

    Interpretation: Background checks should be conducted for contractors who:

    1. work in residential programs;
    2. provide direct services to, or be alone with, children, the elderly, or other persons determined by the organization to be vulnerable or at risk; or
    3. work with sensitive or confidential information such as personnel files and case records.
    The organization is not required to conduct background checks for licensed contractors if the organization has verified that background checks are conducted as part of the licensing process.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • With few exceptions, the organization complies with the standard, but a few records reviewed on newly hired contractors have not yet been completed; or 
    • Documentation in a few records need updating.
    3
    Practice requires significant improvement; e.g.,
    • Documents in several files are outdated or missing.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • Contractor files are consistently incomplete or missing required documentation.
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