HIV/STD Prevention Corrective Action Plan Cleveland Department of Public Health Written: December 21, 2018 Initial Meeting Held: February 27, 2019 Expenditure Reporting • A corrective action plan to address the historical pattern of late expenditure report submissions (documented late submissions in 2018, 2017, 2016, 2015, etc.). The agency has demonstrated late submissions for at least the last four grant years, despite multiple notifications of late reports. Period Start Period End Due Date Date Submitted # Days Late HP/ST 1/1/2018 1/31/2018 2/10/2018 2/22/18 12 HP/ST 5/1/2018 5/31/2018 6/10/2018 6/11/18 1 HP 10/1/2018 10/31/2018 11/10/2018 11/28/18 18 ST 10/1/2018 10/31/2018 11/10/2018 12/11/18 31 HP 11/1/2018 11/30/2018 12/10/2018 12/19/18 9 ST 11/1/2018 11/30/2018 12/10/2018 12/21/18 11 o o o Agency must submit all expenditure reports by the due date. If they are not received by the due date, payments may be held. If a pattern of late submissions continues, agency could be de-funded. Agency is on automatic payment with each monthly expense report. If any expense report is submitted past the due date (the 10th of each month), automatic payments will be stopped. Payments will then be issued after all expense report details have been reviewed and approved. Agency will utilize the Grants Management Information Systems (GMIS) Training Resources located at: https://odh.ohio.gov/wps/portal/gov/odh/about-us/fundingopportunities/ODH-Grants/ODH-Grants. Agency must send statement to zach.reau@odh.ohio.gov indicating completion of review of the training resources no later than March 15, 2019. At a minimum, Agency must review: 1. Special Condition Submission, Budget Revision Submission, Expenditure Report Submission and Final Report Submission. Review of the training resources will ensure understanding of submission processes before due dates go into effect. Special Conditions • A corrective action plan to address late responses to special conditions within the designated timeframe. Per the Ohio Department of Health Grants Administration Policies and Procedures (OGAPP), on the 2nd day of the grant period, a Special Conditions link within GMIS is available. If Special Conditions are given, the subrecipient must respond to all Special Conditions within 30 days via GMIS. If a subrecipient does not respond to the Special Conditions within 30 days, future payments may be delayed Your agency received special conditions (total of 2) on January 2, 2018. Your agency responded on February 21, 2018. o Special conditions must be resolved within 30 days after they are viewable in GMIS. If the special conditions are not resolved, payments may be held until they are resolved. Executing Contracts • A corrective action plan to address failure to execute contracts in a timely manner. Nearly $250,000 in HIV and $85,106.52 in STD was unspent as of Nov 2018 due to position vacancies, contract mismanagement or failure to execute contracts. One, the Cleveland Clinic Foundation, was a longstanding contract of ODH and was provided to CDPH to accelerate the process. Additional funds were allocated to the agency to support this work, yet it went unfinished, despite ODH intervention and facilitation. GMIS Contracts: Budgeted Item Category Net Amount AIDS Taskforce of Greater Cleveland (Total CCA Amount: $62000.00) Personnel $16,558.78 Other Direct Costs $18,101.66 Cleveland Treatment Center (Total CCA Amount: $100000.00) Personnel $63,100.05 Circle Health Services (Total CCA Amount: $65000.00) Personnel NEON (Total CCA Amount: $50000.00) Personnel Metro Health Medical Center (Total CCA Amount: $132000.00) Personnel Planned Parenthood of Greater Ohio (Total CCA Amount: $75000.00) Personnel Center for Community Solutions (Total CCA Amount: $30000.00) Personnel Other Direct Costs Other Direct Costs Other Direct Costs Other Direct Costs Other Direct Costs Other Direct Costs Personnel Budgeted Amount Difference $62,000.00 $27,339.56 $100,000.00 $30,750.89 $65,000.00 $23,027.44 $50,000.00 $18,442.06 $132,000.00 $24,492.30 $75,000.00 $20,363.26 $30,000.00 $3,194 $30,000.00 30,000 $6,149.06 $38,825.73 $3,146.83 $31,557.94 $0.00 $103,527.29 $3,980.41 $54,013.53 $623.21 $0.00 $26,806.00 $0.00 Commuter ADS (Total CCA Amount: $30000.00) Other Direct Costs Totals: $30,000.00 $396,390.49 $544,000.00 A required special condition of ODH. Despite ODH intervention, contract dispute was not resolved. Several complaints were filed about CDPH’s customer service, clarity, and dedication. $60,000 Commuter Ads In the original budget, $70,000 was set aside for this contract. $40,000 MedSearch Staffing Cited in IPR as method for filling staffing gaps but never submitted in GMIS. As a result, many funds were lapsed due to staff vacancies. Unexecuted Contracts Cleveland Clinic Foundation $147,609.51 Notes ? STD Contracts: Budgeted Item Personnel Other Direct Costs Contracts Totals: o Net Amount $41,591.66 $10,473.82 $0.00 $52,065.48 Budgeted Amount $101,058.01 $36,113.99 $0.00 $137,172.00 Difference $59,466.354 $25,640.17 $0.00 $85,106.52 Agency must execute all contracts by March 15. Original Notification of Award was on Nov 16, 2018. Failure to execute contracts may result in a reduction or termination of funds. Staff Vacancies • A corrective action plan to address staff vacancies. Per the grant workplan, budget narrative and IPR, CDPH agreed to complete DIS activities within their region with five FTE DIS. In 2018, one DIS was terminated and, per the IPR, was expected to be filled in July. Additionally, a Health Educator position and a Lab Technician remained unfilled. This not only resulted in a significant lapse in funding but hampered the agency’s ability to carry out the work for which they are funded. o o Agency must fill all existing staff vacancies by March 15, 2019. Any new staff vacancies must be filled or be offered to a candidate within three months. Failure to fill positions that have been vacant for over three months by June 30, 2019 may result in a reduction or termination of funds. DIS Performance • A corrective action plan to address poor DIS performance. The Centers for Disease Control and Prevention set national DIS performance measures. As of November 2018, these performance measures have not been met. For performance data see attachment #1 o o o o o By June 30, 2019, the agency must meet the following measures: ▪ 75% of newly diagnosed persons are interviewed for partner services within 30 days of the confirmed HIV-positive test date. ▪ 90% of newly HIV-diagnosed persons receive their test results. ▪ 75% of named partners are notified of potential HIV exposure by partner services. ▪ 85% of named partners are notified of potential HIV exposure by partner services. ▪ 90% of newly identified, confirmed HIV-positive test results are returned to partners. ▪ 75% of newly diagnosed persons are screened for syphilis within 30 days of the confirmed HIV- positive test date. ▪ 80% of newly diagnosed persons receive risk-reduction counseling. ▪ 90% of newly identified, confirmed HIV-positive clients are referred to medical care. ▪ 75% of newly identified, confirmed HIV-positive clients are referred to medical care. ▪ 75% of all syphilis cases are interviewed within 14 calendar days from the date of field record assignment. ▪ 85% of all syphilis cases are started on treatment within 14 calendar days from the date of field record assignment. ▪ 75% of Early Syphilis (P, S, EL) contacts are prophylactically treated (Dispo A) within 30 calendar days from the date of interview of index case. ▪ 75% of Early Syphilis (P, S, EL) infected contacts will be treated (Dispo C) within 30 calendar days from date of interview of the index case. ▪ Achieve a partner index of at least 0.7 for early syphilis (P,S,EL) cases interviewed. ▪ Achieve a partner index of at least 0.7 for newly identified HIV-positive cases interviewed. ▪ 90% of all syphilis cases are closed within 45 calendar days from the date of original interview. ▪ 90% of newly identified HIV cases are closed within 45 calendar days from the date of original interview. ▪ 85% of syphilis records under the age of 10 years old will be dispositioned within 7 calendar days from the date of field record assignment. If, by June 1, 2019, the above measures are not on track to be met, the agency must request technical assistance from the assigned Disease Intervention Consultant. (Data will be pulled from 1/1/19-4/16/19 to account for the 45 day case closure window.) DIS and DIS Supervisor must complete an ODRS training, provided by ODH, by May 1, 2019. Agency must adhere to ODH policies and procedures, except in the case where they contradict local policies and procedures. In those circumstances, agency must submit local policies and procedures to ODH via email. Failure to meet the above measures may result in the termination of funds. HIV Surveillance Reporting • A corrective action plan to address poor reporting practices. In the last year, both HIV and STD Surveillance have had to follow-up for missing or incomplete reporting records. Ohio law mandates the reporting requirements, which have not been met adequately this year. CDPH HIV Surveillance Monthly Reporting - 2018 HIV Case Reporting HIV Case Reporting Adolescents/Adults Pediatric/Perinatal Exposures January February ✖ - no reports ✖ - no reports ❓ ❓ March April ✖ - no reports ✖ - no reports ✔- rec'd 5/15/18 ✖ - no reports ✖ - no reports ✔- rec'd 8/14/18 ✖ - no reports ✔- rec'd 10/3/18 ✖ - no reports ✔- rec'd 12/12/18 ❓ ❓ ❓ ❓ ❓ ❓ ❓ ❓ ❓ ❓ May June July August September October November December ODH is aware of at least two perinatal HIV exposure case reports received by CDPH from University Hospitals, one in late August and the other in early September, that were not forwarded to ODH by CDPH. • CDPH may make a copy of the HIV case report forms they receive from health care providers/facilities for their own records but should forward the original HIV case report forms, and all CD4 and viral load laboratory results within five business days, it is acceptable for CDPH to send case reports and laboratory results monthly, in an envelope marked “Confidential” to: Ohio Department of Health Attention: HIV Surveillance Program 246 North High Street Columbus, Ohio 43216-0118 • Every case of HIV infection, including AIDS and newborn infants or children born to an HIV infected mother shall report every instance of perinatal exposure to HIV and any subsequent test results on every such exposed newborn infant or child until such time that either an HIV infection or a serostatus that is negative is confirmed. Ohio Administrative Rule (OAC) 3701-3-12 and divisions (B) and (C) of section 3701.24 of the Ohio Revised Code (ORC), reporting requirements are available by clicking on the following link → HIV Reporting Rules and Forms. HIV Prevention Program Performance • A corrective action plan to address poor program reporting performance from Circle Health. Circle Health, the agency’s most productive test site, has had significant reporting issues. Per ODH protocols, negative Opscans are to be sent to ODH in batches of 50 or monthly, whichever comes first. In October, M/E received negative Circle Health Opscans for April, May, June, July, August, and September. April’s was submitted six months outside of protocol. o Agency must create a process to obtain and submit Circle Health’s Opscans so that they are received no later than one month after the earliest test performed. o Agency will request technical assistance from CTR Trainer on behalf of Circle Health to be completed within the first quarter of 2019. • A corrective action plan to address poor HIV prevention grant performance. Agency has received national and state technical assistance and capacity building efforts (table below) but has shown no improvements. The national standard for testing programs is a 1% positivity rate, which should be achieved by testing populations most impacted by HIV. These overwhelmingly include MSM (78%) within the Cleveland region. Agency has been instructed to prioritize testing these populations since 2012, yet the risk categories tested in 2018 were 73% heterosexual. Cumulative positivity for 2018: Region Total Tests New Positives Positivity Previous Positives Cleveland 9093 27 .30% 13 2017 CDPH Cumulative Positivity Rate .42% Cleveland Risk Categories for People Testing at CTR Sites Number Percentage Heterosexual 6656 73.20% IDU 324 3.56% MSM 1098 12.08% MSM/IDU 17 0.19% Other 233 2.56% Unknown 765 8.41% Total 9093 100% Training Provided Targeted Recruitment for HIV Testing Date 2016-2017 Target Population Testing Panel Discussion Passport to Partner Services 10/2017 3/2018 By: New York City Department of Health and Mental Hygiene EIIHA Panel Discussion CDC CTR Training 5/1/18 ODH Staff Testing Protocols, R/R Training, and Human 5/4/18 ODH Staff Trafficking PAPI Updates and HIV Program Expectations 5/21/18 ODH Staff Rapid/Rapid Training 7/26/18 Vendor Human Trafficking Training 10/2018 Regional Expertise o Agency must meet the 2018 state average positivity rate by June 30, 2019 to be considered for continued funding. The state average for 2018, excluding the Cleveland region, was .84%. o Agency must shift testing to those in highest risk categories. By June 30, 2019, 40% of tests should include MSM. o Agency must request a training on meaningful community engagement from a reputable resource by April 2019 and incorporate action steps into the Interim Progress Report submission. Attachment #1 2/27/2019 Page 1 of 1 DIS HIV Performance Measures January 1, 2018 - December 31, 2018 Performance Measure ID Performance Measurement Description HIV-1 Newly diagnosed persons are interviewed for partner services within 30 days of the confirmed HIV-positive test date. HIV-2 Newly HIV-diagnosed persons receive their test results. Formula / Result (%) Numerator Denominator Percent Numerator Denominator Percent HIV-3 Named partners are notified of potential HIV exposure by partner services. Numerator Denominator Percent HIV-4 Notified partners, not previously HIV positive, are tested for HIV. Numerator Denominator Percent HIV-5 Newly identified, confirmed HIV-positive test results are returned to partners. Numerator Denominator Percent HIV-6 Newly diagnosed persons are screened for syphilis within 30 days of the confirmed HIVpositive test date. Numerator Denominator Percent HIV-7 Newly diagnosed persons receive risk-reduction counseling. Numerator Denominator Percent HIV-8 Newly identified, confirmed HIV-positive clients are referred to medical care. HIV-9 Newly identified, confirmed HIV-positive clients attended their first medical care appointment within 90 days of the confirmed HIV-positive test date. Numerator Denominator Percent Numerator Denominator Percent 81 151 Goal 90% 53.6% 146 151 90% 96.7% 20 22 75% 90.9% 15 20 85% 75.0% 3 3 90% 100.0% 109 150 75% 72.7% 146 151 80% 96.7% 141 151 90% 93.4% 132 151 87.4% ASSIGNEE/COUNTY: Carter, Uleta Hatchett, Tiffany Hill, Karen Simpson, TaJuanna New cases include investigations with a dispositon of "2-Prev. negative, new positive" or "5-No prev. test, new positive". Calculations are restricted to investigations where the index case or partner is 13 years or older. Data reported through 2/27/2019. The HIV-6 calculation was modified to utilize a new ODRS variable to improve data accuracy beginning Jan. 2014 and will not calculate for cases prior to 2014. 75% 2/27/2019 Page 1 of 1 DIS STD Performance Measures January 1, 2018 - December 31, 2018 Performance Measure ID Performance Measurement Description STD-1 All syphilis cases are interviewed within 14 calendar days from the date of field record assignment. Formula / Result (%) Numerator Denominator Percent STD-2 All Syphilis cases are started on treatment within 14 calendar days from the date of field record assignment. Numerator Denominator Percent STD-3 Early Syphilis (P, S, EL) contacts are prophylactically treated (Dispo A) within 30 calendar days from the date of interview of index case. STD-4 Early Syphilis (P, S, EL) infected contacts will be treated (Dispo C) within 30 calendar days from date of interview of the index case. STD-5 Achieve a partner index of at least 1.0 for early Syphilis (P,S,EL) cases interviewed. Numerator Denominator Percent Numerator Denominator Percent STD-6 STD-7 Achieve a partner index of at least 1.0 for newly identified HIV-positive cases interviewed. All Syphilis cases are closed within 45 calendar days from the date of original interview. Newly identified HIV cases are closed within 45 calendar days from the date of original interview. Syphilis records under the age of 10 years old will be dispositioned within 7 calendar days from the date of field record assignment. 75% 81.8% 2 2 75% 100.0% Numerator Denominator 43 119 Index 0.4 Numerator Denominator 201 277 Percent ASSIGNEE/COUNTY OR REGION: Carter, Uleta Hatchett, Tiffany Hill, Karen Simpson, TaJuanna Data reported through 2/27/2019. 9 11 0.4 Numerator Denominator 85% 92.4% Index Percent STD-9 256 277 36 95 Numerator Denominator 85% 56.7% Numerator Denominator Percent STD-8 157 277 Goal 1.0 1.0 90% 72.6% 116 151 90% 76.8% 9 16 56.3% 95%