SCRBH ASO tells contracted agencies to prepare for 2027 document-based monitoring; attestations due Aug. 31

Kate Kennedy, the Spokane Regional Behavioral Health Administrative Services Organization (SCRBH ASO) health care compliance analyst, led a training webinar laying out contract compliance requirements for agencies that receive SCRBH ASO funds and announced that monitoring will shift in 2027 from desk attestations to document review.

Kennedy said agencies should be prepared to provide supporting documentation on request and that "this year ... we're actually gonna be doing some monitoring where we have you send in some documents for us to review, not just attestations." She warned that the change makes it more important than ever that agencies submit accurate attestations now.

Why it matters: The SCRBH ASO provides regional oversight for contracted behavioral health services in Spokane County; changes to monitoring practice and the requirement to produce records on request could expose agencies to additional review, findings and, in some cases, repayment or corrective actions.

Kennedy summarized the seven fundamentals of a standard compliance program as described in the agency's QM-10 compliance plan: written policies and procedures; designated compliance professionals who report outside operations; required training and documented attestations; clear communication channels for reporting compliance issues; enforcement and corrective actions; internal monitoring and data validation; and prompt investigation and remediation of incidents. She said QM-10 is the department's primary compliance policy and that agencies should align their procedures to it.

On training and records, Kennedy said agencies must maintain training documentation and attestations (for example, HIPAA and general compliance trainings) and retain compliance training and documentation records for 10 years. She emphasized that attestations may be kept electronically if the system reliably records individual completion.

Kennedy walked through the monitoring-tool and two attestation options required this year. Under Option 1, an authorized representative signs the program attestation to affirm the agency fully meets monitoring requirements and may submit a blank monitoring tool. Under Option 2, an agency that does not meet all requirements must complete the monitoring tool, document gaps and mitigation steps in the results and agency response columns, and sign the second attestation box. SCRBH ASO reserves the right to request supporting documents at any time.

Kennedy also noted that federal CMS general compliance and fraud/abuse trainings are available online but do not cover Washington State false claims statutes, so agencies must separately document training covering state-level rules. She said agencies contracting for Medicaid with MCOs should follow MCO training requirements where applicable.

Deadlines and follow-up: Agencies must submit three documents—the monitoring tool, a program attestation, and a training attestation—on or before Aug. 31. SCRBH ASO staff will compile results and provide notifications to agencies by Sept. 30. Kennedy confirmed e-signatures (Adobe) are acceptable if documents arrive by the due date.

Kennedy reminded agencies that if a compliance incident involves SCRBH ASO funds they should report it to SCRBH ASO first so staff can determine whether further reporting (for example, to MCOs or the state) is required. She said responses to incidents could involve executive leadership, HR, legal counsel or law enforcement, depending on severity, and that corrective action plans or repayment may be required.

The webinar concluded with logistics for accessing the recorded presentation and handouts; Kennedy said county technical staff will upload the recording and slides and that contract staff Jamie Gadd and Michelle Jarellman will assist in distributing monitoring-notification results.

The SCRBH ASO webinar provided practical steps and deadlines for contracted agencies preparing for a move to document-request monitoring in 2027 and reiterated the need for documented policies, designated compliance staff and retained training records.