APD’s iConnect Contract Warrants Closer Scrutiny
The Agency for Persons with Disabilities (APD) is responsible for iBudget Florida (iBudget). iBudget provides home and community-based services (HCBS) through a federally approved Medicaid waiver to Floridians with intellectual and developmental disabilities (I/DD). Waiver Support Coordinators (WSCs) and service providers work with the APD clients to ensure they are receiving the services they need.
To enhance recordkeeping, increase security, and maintain compliance with the expectations of the Centers for Medicaid and Medicare Services (CMS), the APD pursued a procurement contract to develop a client data management system with capabilities to perform electronic visit verification (EVV), a safeguard against fraud. After an Invitation to Negotiate (ITN), the procurement contract was awarded to Harmony Information Systems, Inc. (which was later acquired by Mediware Information Systems and then by Wellsky, Inc.), and the resulting product is a software system known as iConnect.
The iConnect contract was a standard two-party agreement by statute, set to be active February 1, 2015, through June 30, 2018. Based upon negotiations, the deliverables were expected to be met by the end of the original term, and a renewal was expected to operate and maintain the system. The total cost was expected to be $7.4 million and the contract established a cost cap of $9.6 million.
During the timeframe that iConnect has been implemented, the APD has undergone two operational audits by the Auditor General. Both the first audit (performed in 2017) and the second audit (performed in 2021) found that the APD neglected to conduct required contract monitoring activities. As one of the APD’s largest contracts, the execution of iConnect without required contract monitoring activities should concern Florida taxpayers.
Upon reviewing the procurement and contract of iConnect, as well as relevant materials within the APD’s long-range program plans and legislative budget requests, Florida TaxWatch found several aspects of iConnect in need of greater scrutiny. Most in need of attention is the prolonged duration of the iConnect contract. Florida statute only allows one extension of a procurement contract, but iConnect has been extended three times. While the latest extension expires at the end of December 2022, the latest implementation plan suggests that the project will not end until April 2024.
Although the vendor’s proposal suggested that all deliverables would be met before the first renewal, the APD still awaits the fulfillment of seven deliverables. Most of the deliverables are related to the deployment of a consumer portal, allowing APD clients and their caregivers access to their records. This is an especially important feature for empowering APD clients and providing a sense of self-determination.
In September 2022, the APD dropped one of the deliverables of the iConnect project. Originally, iConnect was intended to provide a claims module to process the billing of iBudget services. Although dropping this deliverable was deemed to be in the best interest of the project—the service providers already use a billing platform that works—proper procedures should be maintained. The APD should amend its contract with the vendor, and the Florida Legislature should amend § 393.066, Fla. Stat. (2020), which requires service providers to use iConnect for billing.
iConnect was not only intended to benefit the APD but also to enhance the recordkeeping of service providers and WSCs. For it to do so, it should have interface capabilities with secondary data systems maintained by each party. Within its best and final offer, the vendor stated that it would create interfacing with such systems, specifically listing the software provided by Therap Services, LLC (Therap) as an example. The intention to interface with Therap was reiterated upon renewal of the contract; however, to date, there have been no developments for deploying an update to make such an interface possible.
As iConnect continues to be implemented, the onboarding of service providers and WSCs deserve special attention. As parties using the software daily, and liable for recoupments upon misuse or error, the functionality of iConnect is especially important. Required training is time consuming and is often delivered several months before users begin using the system, which limits the training’s effectiveness. Currently, WSCs and service providers face difficulties accessing their portal, uploading documents, maintaining records, and participating in EVV. Help desk support is largely inaccessible and ineffective as personnel that staff the help desk often do not appear to possess the expertise necessary to effectively solve user problems. When WSCs and service providers cannot resolve their difficulties, they may be unable to provide the proof of service needed to pass their quality assurance reviews conducted by Qlarant.
The iConnect procurement is the latest of many IT projects that demonstrate the need to overhaul Florida’s procurement system. In regard to this procurement process, the iConnect project highlights the need for better contract monitoring. APD should revise its internal contract management processes to hold vendors accountable for the timely provision of contract deliverables and to comply with chapter 287, Florida Statutes. Compliance with chapter 287 is particularly important given that the iConnect contract is scheduled to expire on December 31, 2022 (reference Amendment 8).
Similarly, agencies should provide consistent documentation when establishing new deliverables and project schedules. Throughout the conduct of the iConnect contract, amendments were often posted late. When the timeline was altered, some deliverables failed to be accompanied by new delivery dates.
When a contract is changed, such as was done with the abandoned claims module, an agency should create an amendment when foregoing a provision of the contract. Since the APD’s claims module was listed as a requirement not only in the contract but also within Florida statute, the Florida Legislature should amend Florida Statute 393.066 to eliminate the requirement of a claims module. As it reviews Florida Statute 393.066, the Florida Legislature should also consider adding language that allows providers to provide data to the iConnect system electronically and require APD to finalize implementation of the required interface.
Since iConnect is a recordkeeping system for a network of stakeholders and not solely the Agency, the APD should ensure the needs of stakeholders are met. To do so, the APD should provide alternative procedures when technical issues occur within the presence of a client and host a debrief with stakeholders and enhance supports for stakeholders. To determine the potential value of conducting a debrief, Florida TaxWatch interviewed WSCs and service providers (Appendix: Stakeholder Interviews). Florida TaxWatch looks forward to engaging with the APD and supporting their efforts to improve iConnect.