Report Type: Evaluation Infrastructure Recommendations

Behavioral Health Services Internal Audit

YEAR
2022

AUTHOR / ORGANIZATION
BernCo & REDW

TOPIC AREA(S): Legislation & Policy Senate Bill 3 Systems & Planning

What is this?

This is an internal audit report conducted by REDW LLC for Bernalillo County, examining the operational compliance and administrative processes of two behavioral health departments: the Department of Behavioral Health Services (DBHS) and the Behavioral Health Initiative (BHI). The audit was performed in accordance with Consulting Standards issued by the American Institute of Certified Public Accountants. The audit methodology included interviews with leadership and staff from both departments, review of policy documents and meeting minutes, and testing of contract invoices, grant expenditures, and budget allocations. Fieldwork began in October 2022, with exit conferences held in January 2023. The audit focused on evaluating strategic planning processes, grant and contract administration, Behavioral Health Gross Receipts Tax allocations, and committee communications following the January 2022 organizational split of the two departments.

Summary

This internal audit reveals significant infrastructure gaps in Bernalillo County’s behavioral health system administration that directly impact systems change capacity. The most critical finding is the absence of a strategic plan for the Behavioral Health Initiative, which oversees housing, community supports, prevention, intervention, and harm reduction programs funded by Gross Receipts Tax revenues. Without formalized policies, procedures, and training manuals, operational consistency and staff accountability are compromised. The audit found that advisory committees lack annual work plans aligned with strategic goals, potentially leading to unfocused efforts across the four subcommittees (Crisis, Prevention/Intervention/Harm Reduction, Housing, and Community Supports). Contract administration issues, including late invoice submissions and routing inconsistencies, could delay payments to service providers. Management responses indicate commitment to developing a strategic plan by December 2023 using “Wise Planning” methodology, aligning with County/City Joint Strategic Plan, DBHS strategic plan, and Criminal Justice Coordinating Council strategic plan. The establishment of a Bernalillo County Behavioral Health Systems of Care Working Group in January 2023 provides an opportunity to address these gaps while incorporating community and stakeholder input. These findings are essential for systems planners to understand the administrative infrastructure needed to support effective behavioral health service delivery.

BH Systems Change Recommendations

Explicit Audit Recommendations: 1. Annual Work Plans: Each committee should develop annual work plans in collaboration with County leadership and DBHS/BHI staff, based on strategic plan goals with defined benchmarks and milestones. 2. BHI Strategic Plan: Collaborate with Operations Excellence Office and County Manager's Office to develop a strategic plan for fiscal year 2024, including: - Policy, procedure, and process development - Workforce development and education - Contract and template standardization - Coordination with providers to spend down and leverage available funding - Evaluation of services to improve outcomes - Outcomes analyses to identify trends - Community education and outreach - Improved reporting communications 3. Policies and Procedures: Develop and implement formalized policies over critical areas: - Provider Identification, Eligibility, Credentialing, and Reporting Requirements - Monthly Provider Billing Reviews and Approvals - Budget Development, Adjustments, and Monthly Reviews - Training and Continuing Education - Internal Reporting and Communication - Contract Administration, Compliance, and Management 4. Contract Administration: Update contracts to require invoice submission directly to BHI by the 15th of each month; identify and work with habitually late contractors. 5. Meeting Minutes: Implement process to post agendas and minutes 72 hours before meetings per guidelines. 6. Standardize Committee Minutes: Evaluate meeting minute templates for standardization including standing items, action items, budget-to-actual figures, and clear advisory recommendations.

How to Use for Systems Planning

What this report IS useful for: - Understanding the administrative infrastructure gaps that may impede effective behavioral health service delivery in Bernalillo County - Identifying specific areas where policy development and process standardization are needed - Learning about the organizational structure of BHI subcommittees (Crisis, Prevention/Intervention/Harm Reduction, Housing, Community Supports) - Understanding the timeline and commitments for strategic plan development (December 2023 target) - Recognizing contract administration challenges that may affect provider payment timelines What this report DOES NOT provide: - Service delivery outcomes or quality metrics for behavioral health programs - Community needs assessment data or gap analysis - Specific recommendations for expanding or improving clinical services - Information about service utilization, population served, or treatment outcomes - Budget figures or funding allocations across specific programs - Clinical or programmatic recommendations for behavioral health interventions

Key Facts & Data Points

- Audit period: January 1, 2022 through September 20, 2022 - BHI was split from DBHS effective January 2022 - Four subcommittees operate under BHI: Crisis, Prevention/Intervention/Harm Reduction, Housing, and Community Supports - 40 BHI contractor invoices tested; 14 (35%) were not submitted by the 15th of the month deadline - Invoice submission delays ranged from 1 to 136 days late - 10 grants identified for DBHS Substance Misuse services; 2 selected for detailed testing (DFA Distribution and DFA Detoxification) - 40 DBHS expenditures tested across the two selected grants - Administrative Resolution 2023-2 approved January 10, 2023 establishing Behavioral Health Systems of Care Working Group - BHI strategic plan target completion: December 2023 - BHI policy and procedure manual target completion: Fall 2023 - Contract with Pivot Evaluation initiated March 2, 2022 for program evaluation and technical assistance

Priority Services & Findings

**SUD Organizations** - DBHS oversees substance misuse services through DFA Distribution and DFA Detoxification grants - 10 grants identified supporting Substance Misuse services under DBHS - Grant expenditure tracking and coding processes were evaluated for compliance **Mental Health / Crisis Care** - DBHS maintains oversight of crisis initiatives including Mobile Crisis Teams, Resource Reentry, and Crisis Stabilization Unit - Crisis Subcommittee operates as one of four advisory subcommittees **Integrated Primary Care** - No specific findings related to **Integrated Primary Care** in this report **School-Based / Youth Services** - No specific findings related to school-based or youth services in this report

Immediate Actions for Systems Planners

-Review the Behavioral Health Systems of Care Working Group outcomes (established January 2023) to understand how administrative improvements align with broader systems change efforts. -Track BHI's progress toward December 2023 strategic plan completion and ensure alignment with County/City Joint Strategic Plan and DBHS strategic plan. -Monitor implementation of the automated invoice reminder system (implemented January 2023) and track improvement in provider invoice submission compliance. -Request copies of completed BHI policies and procedures (target: Fall 2023) to understand standardized processes for contract administration and provider oversight. -Engage with the four subcommittees (Crisis, Housing, Prevention/Intervention/Harm Reduction, Community Supports) once annual work plans are established to align systems planning efforts. -Review the Pivot Evaluation final report (expected January 2023) for additional recommendations on BHI programming and performance metrics. -Assess whether contract administration improvements have addressed the 35% late invoice submission rate to ensure service providers are being paid timely.

Key Contacts

**/BernCo Behavioral Health Initiative = - Julie Morgas Baca, Manager = - Pamela Acosta, CJBHI Programs Senior Manager = - Amber Salazar, Special Projects Coordinator = - Elena Rodriguez, Senior Accountant = **/Dept of Behavioral Health Services = - Margarita Chavez, DBHS Director = - Marcia Harris, DBHS Clinical Services Senior Manager = - Fran Martinez-Romero, DBHS Fiscal Manager = - Nancy Sanchez, DBHS Grant Administrator = - Reina Martinez, DBHS Community Program Manager = - Jessica Jaramillo, DBHS Operations Manager **/Resources = - Pivot Evaluation = - United Design Consultants = - REDW LLC = - BHI Reports -+ bhireports@bernco.gov

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