services on a voluntary basis. The key principles of providing quality, client-centered counseling include: 1) establish and maintain rapport with the client, 2) assess the client’s needs and personalize discussions accordingly, 3) work with the client interactively to establish a plan, 4) provide information that can be understood and retained by the client, and 5) confirm client understanding. These principles are useful when developing counseling protocols that ensure voluntary participation. (See Appendix C for additional detail). Quality Assessment: 1. Observation of counseling process, including I&E material provided, at service demonstrates that the five principles of quality counseling are utilized when providing family planning services. A client’s acceptance of family planning services must not be a prerequisite to eligibility for, or receipt of, any other services, assistance from, or participation in any other program that is offered by the grantee or sub-recipient (Section 1007, PHS Act; 42 CFR 59.5 (a)(2)). Delegate should institutionalize administrative procedures (e.g., training, clinical protocols, and consent forms) to ensure clients’ receipt of family planning services is not used as a prerequisite to receipt of other services from the service site. Evidence that this requirement has been met includes: The delegate has a written policy that prohibits their service sites, and any sub-vendor service sites from making the acceptance of family planning services a prerequisite to the receipt of any other services. Documentation (e.g., staff circulars, training curriculum) indicates staff has been informed at least once during their period of employment that a client’s receipt of family planning services may not be used as a prerequisite to 1. Delegate Policies 2. Staff Training 3. Service Site Policies
requirements (45 CFR parts 74 and 92). 8.3.2 If a sub-recipient wishes to subcontract any of its responsibilities or services, a written agreement that is consistent with Title X Program Requirements and approved by the grantee must be maintained by the sub-recipient (45 CFR parts 74 and 92). Evidence that this requirement has been met includes: Delegate has a signed agreement with any who subcontracts for responsibilities or services, requiring the sub-vendor to include compliance with Title X requirements in their subcontracts. Documentation shows the Grantee has approved Delegates’ sub-vendor subcontracts. Review of Delegate and sub-vendor monitoring reports demonstrates that the delegate ensures that the sub-vendor is monitoring the entity for compliance with Title X requirements. 1.Delegate Documentation-signed agreements 2.Delegate 3. Delegate Monitoring 8.3.3 The grantee must ensure that all services purchased for project participants will be authorized by the project director or his designee on the project staff (42 CFR 59.5(b)(7)). Evidence that this requirement has been met includes: Policies clearly indicate the approval process for any services that are purchased for participants. Documentation of purchases demonstrates that the delegate’s established policies and procedures are followed. 1. Delegate Policies 2. Review of Purchases Documentation-
8.3.4 The grantee must ensure that services provided through a contract or other similar arrangement are paid for under agreements that include a schedule of rates and payment procedures maintained by the grantee. The grantee must be prepared to substantiate that these rates are reasonable and necessary (42 CFR 59.5(b)(9)). Evidence that this requirement has been met includes: Delegate contracts clearly indicate the schedule of rates and payment procedures for services. Delegate can substantiate that the rates are reasonable and necessary. This includes demonstrating the process and/or rationale used to determine payments, examples of financial records, applicable internal controls. 1. Delegate contracts 2. Process for determining rates 8.3.5 Sub-recipient agencies must be given an opportunity to participate in the establishment of ongoing grantee policies and guidelines (42 CFR 59.5 (a)(10)). Evidence that this requirement has been met includes: Delegate policies identify the mechanism(s) used to be involved and involve sub-vendor agencies in the development of policies and guidelines. Documentation exists and may include meeting minutes, conference calls, and webinars that demonstrates that delegates and sub-vendors participate in this process as indicated in the delegate policy. 1. Delegate Policies 2. Documentation
8.3.6 The grantee and each must maintain a financial management system that meets Federal standards, as applicable, as well as any other requirements imposed by the Notice of Award, and which complies with Federal standards that will support effective control and accountability of funds. as required (45 CFR parts 74.20 and 92.20). Evidence that this requirement has been met includes: Delegate financial policies and procedures can be referenced back to federal regulations as applicable. Delegate financial records and oversight documentation demonstrates that the financial management practices within all project sites are aligned with Title X and other applicable regulations and grants requirements. 1. Delegate Policies 2. Documentation-Oversight
Title X Program Requirement 8.4 Charges, Billing, and Collections Clients whose documented income is at or below 100% of the Federal Poverty Level (FPL) must not be charged, although projects must bill all third parties authorized or legally obligated to pay for services (Section 1006(c)(2), PHS Act; 42 CFR 59.5(a)(7)). Although not required to do so, grantees that have lawful access to valid means of income verification because of the client’s participation in another program may use those data rather than re-verify income or rely solely on the client’s self-report. Evidence that this requirement has been met includes: Delegate has policies and procedures assuring that clients whose documented income is at or below 100% FPL are not charged for services and that third party payers are billed. Financial documentation at the service site indicates clients whose documented income is at or below 100% FPL are not charged for services. Financial documentation at the service site indicates that if a third party is authorized or legally obligated to pay for services, the project has billed accordingly. Service follow a written policy and procedure for verifying client income that is aligned with Title X requirements. Service site policy and procedures for verifying client income does not present a barrier to receipt of services. 1. Delegate Policies 2. Financial charges 3. Financial Documentation- Third Party Billing 4. Delegate Policies for Verifying Income 5. Delegate Policy and Procedures 8.4.2 A schedule of discounts, on ability to pay, is required for individuals with family incomes between 101% and 250% of the Federal Poverty Level Evidence that this requirement has been met includes: Delegate has policies and procedures requiring that a schedule of discounts be developed for services provided in the project and updated periodically to be in line with the FPL. 1. Delegate Policies and Procedures 2. Documentation at Service Site
8.4.9 Voluntary donations from clients are permissible; however, clients must not be pressured to make donations, and donations must not be a prerequisite to the provision of services or supplies. Evidence that this requirement has been met includes: Delegate policies and procedures indicate if the project service sites may request and/or accept donations. Onsite documentation and observation demonstrates that clients are not pressured to make donations and that donations are not a prerequisite to the provision of services or supplies. Observation may include signage, financial counseling scripts, or other evidence. 1. Delegate Policies and Procedures 2. Documentation at Service Site Title X Program Requirement Implementation Strategy Assessment 8.5 Project Personnel 8.5.1 Grantees and sub-recipients are obligated to establish and maintain personnel policies that comply with applicable Federal and State requirements, including Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act of 1973, Title I of the Americans with Disabilities Act, and the annual appropriations language. Evidence that this requirement has been met includes: Delegate has written policies and procedures in place that provide evidence that there is no discrimination in personnel administration at its organizations and within its sub-vendor network. These policies should include, but are not to be limited to, staff recruitment, selection, performance evaluation, promotion, termination, compensation, benefits, and grievance procedures. is evidence that the delegate monitors to ensure compliance with this requirement. 1. Delegate Policies and Procedures 2. Delegate Oversight Documentation
8.7 Planning and Evaluation Grantees must ensure that the project is competently and efficiently administered (42 CFR 59.5 (b) (6) and (7)). Evidence that this requirement has been met includes: Delegate records demonstrate that the results of at least one needs assessment were used to develop the competing grant application. Delegate has a written plan for monitoring the delivery of all services described in approved grant application including monitoring of Delegate records document periodic assessment of work plan progress, including work plan revisions when needed. Delegate collects and submits data for the Family Planning Annual Report (FPAR) in a timely, complete and accurate manner. LINK TO QFP: When designing evaluations, projects should follow the Recommendations for Providing Quality Family Planning Services, which defines what services to provide and how to do so and thereby provides a framework by which program evaluations can be developed. Projects should also follow the QFP that defines ‘quality’ care and describes how to conduct quality improvement processes so that performance is monitored and improved on an ongoing basis. QI activities should be overseen by the delegate and occur at both the delegate and levels. Quality Assessment: Delegate demonstrates use of FPAR data to calculate for delegate level the percentage of adolescent and adult women at risk of 1. Delegate Documentation 2. Delegate Monitoring Plan 3. Data Submission
Written clinical protocols include the full scope of family planning services as defined in QFP including contraception, pregnancy testing and counseling, achieving pregnancy, basic infertility, STD, and preconception health services. Service sites have current clinical protocols (i.e., revised within the past 12 months) that reflect the most current version of Federal and professional medical associations’ recommendations for each type of service, as cited in QFP. Documentation that clinical staff has participated in training on QFP (e.g., training available from the Title X National Training Centers). A review of medical records and/or observational assessment confirms that the recommended services are provided in a manner consistent with QFP including those identified in Tables 2 and 3 on pages 22-23. 9.7 All projects must provide for medical services related to family planning and the effective usage of contraceptive devices and practices (including physician’s consultation, examination, prescription, and continuing supervision, laboratory examination, contraceptive supplies) as well as necessary referrals Evidence that this requirement has been met includes: The delegate has written policies and procedures requiring service sites and sub-vendors to provide medical services related to family planning as indicated in this section. This should also be included in sub-vendor contracts. Current written (i.e., updated within the past 12 months) clinical protocols clearly indicate that the following services will be offered to female, male and adolescent clients as appropriate: a broad range of contraceptives, pregnancy testing and 1. Delegate Policies and Procedures & Contracts 2. Clinical Protocols 3. Clinical Protocols
Observation and/or medical record review demonstrates counseling recommendations in accordance with the principles presented in QFP including reproductive life planning discussions. 9.11 Projects must offer pregnant women the opportunity to be provided information and counseling regarding each of the following options: prenatal care and delivery; infant care, foster care, or adoption; and pregnancy termination. If requested to provide such information and counseling, provide neutral, factual information and nondirective counseling on each of the options, and referral upon request, except with respect to any options(s) about which the pregnant woman indicates she does not wish to receive such information and counseling (42 CFR 59.5(a)(5)). Evidence that this requirement has been met includes: The delegate has written policies and procedures requiring its service and all sub-vendors to offer options counseling to pregnant women. Written clinical protocols ensure that pregnant clients are offered neutral, factual information, and non-directive counseling about all three pregnancy options except for those options that the woman does not wish to receive information, and that referrals requested by the client are provided to her. Medical records of pregnant clients document that clients were offered the opportunity to be provided with information and counseling about all three pregnancy options, except those for which the woman did not want to receive information and counseling. Medical records of pregnant clients document that referrals were made as requested. 1. Delegate Policies and Procedures 2. Documentation at Service Site 3. Medical Record & Counseling 4. Medical Record Review- Referrals 9.12 Title X grantees must comply with applicable Evidence that this requirement has been met includes: 1. Delegate Policies and Contracts Information
and approval process, by an Advisory Committee, of all informational and educational materials developed or made available under the project prior to their distribution (Section 1006 (d)(2), PHS Act; 42 CFR 59.6(a)). available to the clients that receive services within the project. If a delegate sub-contracts for services, the delegate must ensure that have a process in place that meets this requirement. Committee meeting minutes (delegate or as applicable) demonstrate the process used to review and approve materials. 2. Documentation 12.2 The committee must include individuals broadly representative (in terms of demographic factors such as race, color, national origin, handicapped condition, sex and age) of the population or community for which the materials are intended (42 CFR 59.6 (b)(2). Evidence that this requirement has been met includes: The delegate has established a project advisory board that is comprised of members who are broadly representative of the population served. If a delegate sub-contracts for services, the delegate must ensure that sub-vendors have a process in place that meets this requirement. Delegate (and/or sub-vendors) documentation (meeting minutes, of board members, etc.) demonstrates this requirement has been met. 1. Advisory Board 2. Delegate Oversight 3. Documentation 12.3 Each Title X grantee must have an Advisory Committee of five to nine members, except that the size provision may be waived by the Secretary for good cause shown (42 CFR 59.6 (b)(1)). The Advisory Committee must review Evidence that this requirement has been met includes: Delegate has policies and procedures addressing this element. Delegate maintains and updates Lists/Rosters of Advisory Committee members. Delegate maintains Advisory Committee written meeting minutes. Advisory committee minutes indicate that the committee is active. 1. Delegate Policies and Procedures 2.
and approve all informational and educational (I&E) materials developed or made available under the project prior to their distribution to assure that the materials are suitable for the population and community for which they are intended and to assure their consistency with the purposes of Title X (Section 1006(d)(1), PHS Act; 42 CFR 59.6(a)). 3. Oversight- Delegate Maintains Meeting Minutes 4. Documentation- Meeting Minutes 12.4 The grantee may delegate I&E functions for the review and approval of materials to sub-recipient agencies; however, the oversight of the I&E review process with the grantee. Evidence that this requirement has been met includes: Delegate policies and procedures indicate responsibility for this element. If the delegate chooses to delegate this activity, delegate policies indicate how the delegate will maintain oversight of the process. Delegate documentation indicates that an oversight process has been implemented by the delegate. 1. Delegate Policies and Procedures 2. Delegate Oversight 12.5 The Advisory Committee(s) may delegate responsibility for the review of the factual, technical, and clinical accuracy to appropriate project however, final responsibility for approval Evidence that this requirement has been met includes: Delegate Policies and procedures specify if the factual, technical and clinical accuracy components of the review are delegated to project staff, final responsibility for approval of the I&E materials rests with the Advisory Committee. 1. Delegate Policies 2. Records of Advisory Committee (if delegated)