2023-2026 Plan 07/19/2023 Kevin Madok, cpA
ty Clerk of the Circuit Court& Comptroller Monroe Coun , Florida
DATE: August 3, 2023
TO: Tina Bowl, Sr. Director
Budget & Finance
FROM: l'anicla G
SUBJECT: July 19" BOCC Meeting
Attached is Dui electronic copy ol'the 1'()Ilo%%Iiig item for your limidling:
D9 Monroe County Designated Receiving System Plan for 2023-2026 as presented by
South Florida Behavioral Health Network, d/b/a Thriving Mind South Florida, the designated
Managing Entity for Monroe County and Miami/Dade County, for a centralized receiving system
for Monroe County as required by Senate Bill 12 (Chapter 2016-241).
Should you have wiv questions please Feel free to contact nic at (305) 292-3550.
cc: County Attorney
FinwiCe
File
KEY WEST MARATHON PLANTATION KEY
500 Whitehead Street 3117 Overseas Highway 88770 Overseas Highway
Key West, Florida 3300 Marathon, Florida 3300 Plantation Key, Florida 33070
Monroe County
Designated Receiving System Plan
In accordance with
Florida Statute 394, Florida Mental Health Act
Florida Statute 397, Hal S. Marchman Alcohol and
Other Drug Services Act
2023-2026
Monroe County DRS Plan Updated May 2023 Page 1 of 27
Contents
I. Background/Purpose:.............................................................................................................. 3
IL Monroe County's Designated Receiving System (DRS).................................................... 4
III. Inventory of Participating Service Providers....................................................................... 6
IV. Designated Receiving System (DRS) Agreements.............................................................. 8
Attachment A—Process Flow for Centralized Receiving System Monroe.................................... 9
Attachment B —Transportation Plan Monroe............................................................................... 11
Attachment C —Agreements Template......................................................................................... 19
Attachment D—Sign In Sheet Monroe County Public Meeting .................................................. 27
Monroe County DRS Plan Updated May 2023 Page 2 of 27
I. Background/Purpose:
In accordance with the changes promulgated by Senate Bill 12 to Florida Statute 394 (Florida
Mental Health Act, commonly referred to as the"Baker Act"), and Florida Statute 397 (commonly
referred to as the Marchman Act), Monroe County in collaboration with South Florida Behavioral
Health Network, Inc. dba Thriving Mind South Florida (Thriving Mind), the Managing Entity,
have completed this Designated Receiving System (DRS) Plan. Implementation of this plan
assures the coordinated provision of emergency services for people in need of help for behavioral
health disorders and supports a comprehensive behavioral system of care.
This DRS Plan describes how the community shall ensure the provision of the "No Wrong Door
Model" defined in FS 394.4573. This description includes the organization of the DRS and how it
responds to individual needs and integrates services among various providers.
The designated receiving system may be organized in any manner which functions as a no-wrong-
door model. Such models include, but are not limited to:
A central receiving system is identified as a system that consists of a designated central
receiving facility that serves as a single-entry point for persons with mental health or
substance use disorders, or co-occurring disorders. The central receiving facility shall be
capable of assessment, evaluation, and triage or treatment or stabilization of persons with
mental health or substance use disorders, or co-occurring disorders.
A coordinated receiving system as a system that consists of multiple entry points that are
linked by shared data systems, formal referral agreements, and cooperative arrangements
for care coordination and case management. Each entry point shall be a designated
receiving facility and shall, within existing resources, provide or arrange for necessary
services following an initial assessment and evaluation.
A tiered receiving system consists of multiple entry points, some of which offer only
specialized or limited services. Each service provider shall be classified according to its
capabilities as either a designated receiving facility or another type of service provider,
such as a triage center, a licensed detoxification facility, or an access center. All
participating service providers shall, within existing resources, be linked by methods to
share data, formal referral agreements, and cooperative arrangements for care coordination
and case management.
OR
The DRS may be organized in any manner that functions as a No-Wrong-Door Model that
responds to individual needs and integrates the services of various providers.
Monroe County DRS Plan Updated May 2023 Page 3 of 27
The County and the Managing Entity shall review and update, as necessary, the designated
receiving system at least once every 3 years. An accurate inventory of the participating service
providers shall be maintained and made available at all times to all first responders in the service
area.
IL Monroe County's Designated Receiving System (DRS)
Monroe County's Designated Receiving System is best described as a centralized receiving
system.
In Monroe County, there are 2 designated receiving facilities which are both publicly funded
(Guidance Care Center, Inc. and Lower Keys Medical Center). Thriving Mind currently funds
a total of 17.79 beds at these public receiving facilities — 9.79 are CSU beds and 8 are DETOX
beds. The following are the number of funded beds at each facility, by type:
• Guidance Care Center, Inc. —7.50 Adult CSU beds
8 DETOX beds
• Lower Keys Medical Center—2.29 Adult CSU beds
*Note: Contract bed totals are subject to change due to rate enhancements.
The County's approach to develop the designated receiving system for Monroe County is one that
attempts to maintain the current process for Baker Acts for law enforcement, so that they are
transporting Baker Acts to the nearest receiving facility (as is the case currently). This is consistent
with the requirement in Senate Bill 12 to ensure that there is a"no wrong door"approach for acute
care services. Thriving Mind held a public meeting in Monroe County for input and will continue
to receive feedback from the stakeholders on the continued implementation of the Designated
Receiving System through its community needs process. The sign in sheet for the public meeting
can be found in Attachment D.
Thriving Mind has identified the Guidance/Care Center as the provider that will be designated as
the centralized receiving facility for the centralized receiving system, described above.
Individual is taken by Law Enforcement to the appropriate receiving facility, which is the
centralized receiving system:
The individual can be referred to the centralized receiving system through multiple entry points:
as a transfer from other facilities (such as jails/prisons, courts or hospitals), as a self-referral, as a
individual that is picked up by law enforcement for a Baker Act/Marchman Act, etc. If the
individual is referred to the centralized receiving system because he/she is picked up by law
enforcement as a result of a Baker Act, then he/she is taken to the appropriate receiving facility
(public/private). If the appropriate receiving facility is a public receiving facility, then the
individual will be screened for both behavioral health and financial eligibility (indigent vs.private
pay). If that individual meets acute care criteria and there is capacity at that public receiving
facility, then he/she will be accepted, stabilized and treated. Once the person is stabilized, if the
individual is determined to be indigent, then the designated receiving facility will create a
discharge plan,which includes a recommended level of care. The individual will also be screened
Monroe County DRS Plan Updated May 2023 Page 4 of 27
for care coordination through Thriving Mind. If that individual meets criteria for care coordination,
then a referral will be made to Thriving Mind's Care Coordination Department. If the person does
not meet criteria for care coordination, then a referral will be made to a Thriving Mind provider
that has the recommended level of care within their treatment continuum.
If it is determined that the individual meets acute care criteria, but the public receiving facility
doesn't have capacity, then the public receiving facility will coordinate a transfer to another
receiving facility that has capacity. It is important to note that if the individual is a Baker Act,then
the law allows for the receiving facility to keep that individual as long as they do not go over 10%
of their licensed bed capacity. However, if the individual is a Marchman Act,which does not allow
for that flexibility and the Addiction Receiving Facility (ARF) is at licensed capacity, then the
facility must provide a basic screening or triage sufficient to refer the person to the appropriate
services and coordinate the transfer of that individual to another facility or hospital that has
capacity.
If it is determined (through the screening process) that the individual does not meet criteria for
acute care,then the public receiving facility will determine the recommended level of care for that
individual. If the recommended level of care is one that is actively managed by Thriving Mind
(Short-term Residential Treatment (SRT), Residential treatment), then Thriving Mind's Adult
System of Care Department will be contacted in order to coordinate that referral. If the
recommended level of care for that indigent individual is not actively managed by Thriving Mind,
then the receiving facility will contact the Thriving Mind provider directly. Referrals will be made
to best match the individuals with their needs and geographic preference. If no preference or
specific needs are noted,then referrals are made on a rotating basis. All referrals that come through
the centralized receiving system will be well documented and available for review at Thriving
Mind.
Individual is taken by Law Enforcement to the appropriate receiving facility, which is a
private receiving facility:
If the individual is referred to the centralized receiving system because he/she is picked up by law
enforcement as a result of a Baker Act, then he/she is taken to the appropriate receiving facility
(public/private). If the facility is a private receiving facility, then he/she will be screened to
determine if he/she meets acute care criteria. If he/she meets criteria, then the individual will
remain at the private receiving facility and will be stabilized and treated. A discharge plan will be
made by the private receiving facility, which includes a recommended level of care. If it is
determined that the individual is an indigent individual and meets acute care criteria, then a
individual may be transferred to the centralized receiving system for continued acute care services
and/or referral to lower level of care services.
Individual is self-referred for any publicly funded service:
If the individual is seeking publicly funded services, the individual can access care through the
centralized receiving facility. The centralized receiving facility has satellite offices throughout
Monroe County which allows for screening and level of care assessment. Based on the individuals
Monroe County DRS Plan Updated May 2023 Page 5 of 27
identified needs, the facility will make referrals accordingly including for acute care services if
necessary.
A Process Flow of the Centralized Receiving System is found in Attachment A. The
Transportation plan that outlines how individuals needing acute care are transported can be found
in Attachment B.
III. Inventory of Participating Service Providers
Voluntary Assessment and Evaluation Facilities
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients? Disorders/Co-
Occurring?
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
Lower Keys CSU Only No Yes
Medical Center
Involuntary Assessment and Evaluation Facilities
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients? Disorders/Co-
Occurring?
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
Lower Keys CSU Only No Yes
Medical Center
Triage Centers for Mental Health
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients?
Monroe County DRS Plan Updated May 2023 Page 6 of 27
Disorders/Co-
Occurring?
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
Lower Keys CSU Only No Yes
Medical Center
Triage Centers for Substance Use Disorders
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients? Disorders/Co-
Occurring?
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
Involuntary Treatment for Mental Health Disorders
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients? Disorders/Co-
Occurring?
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
Lower Keys CSU Only No Yes
Medical Center
Involuntary Treatment for Substance Use Disorders
Facility Capabilities/Limitations Does the facility Substance Use
have agreements to Disorders/Mental
accept DRS Health
Patients? Disorders/Co-
Occurring?
Monroe County DRS Plan Updated May 2023 Page 7 of 27
Guidance Care CSU,Detox, Screening & Yes Yes
Center, Inc. Assessment
MMMMMMMMMMMMMMMME=
IV. Designated Receiving System (DRS)Agreements
Through Thriving Mind's Acute Care Data System, partners can share data and be aware of
available beds in the coordinated receiving system. The system provides real-time bed availability
that is fed into the Thriving Mind web-site.
Thriving Mind has been working with Knight Software to expand the current service data system
to fully integrate Acute Care and Financial Reporting into one, cohesive application. The Knight
Integrated Solution (KIS) has been developed with the goal to improve the clinical and
psychosocial outcomes of stakeholders within the mental healthcare system by providing a system
for securely sharing clinical and psychosocial information across authorized healthcare providers
to facilitate coordination of care and improve outcomes.
A full description of the data functions can be found in Thriving Mind's Information Technology
(IT) Plan and is available at ...thri:V.�t mind.2 .
Network providers have individual contracts and executed Business Associate Agreements
(BAAs) through their main contract with Thriving Mind which allows for data sharing and
coordination of care.
BAA Template can be found in Attachment C.
Monroe County DRS Plan Updated May 2023 Page 8 of 27
Attachment A—Process Flow for Centralized Receiving System Monroe
-Page Left Intentionally Blank-
Monroe County DRS Plan Updated May 2023 Page 9 of 27
Monroe County DRS Plan Updated May 2023 Page 10 of 27
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Monroe County DRS Plan Updated May 2023 Page 11 of 27
Attachment B — Transportation Plan Monroe
Transportation Plan for Baker Act and Marchman Act Involuntary Examinations
Department of Children and Families
Circuit 16 (Monroe County)
This transportation plan shall describe methods of transport to a facility within the
designated receiving system for individuals subject to involuntary examination under the
Baker Act s. 394.463 or involuntary admission under the Marchman Act s. 397.6772, s.
397.679, s. 397.6798, or s. 397.6811.
When any law enforcement officer has custody of a person based on either noncriminal
or minor criminal behavior that meets the statutory guidelines for involuntary examination
pursuant to s. 394.463, the law enforcement officer shall transport the person to the
appropriate facility within the designated receiving system pursuant to a transportation
plan or an exception or to the nearest receiving facility if neither apply. Persons who meet
the statutory guidelines for involuntary admission pursuant to s. 397.675 may also be
transported by law enforcement officers to the extent resources are available and as
otherwise provided by law. Such persons shall be transported to an appropriate facility
within the designated receiving system pursuant to a transportation plan or an exception
or to the nearest facility if neither apply.
The Florida Mental Health Act, usually referred to as "The Baker Act," states that a person
may be taken to a receiving facility for involuntary examination if there is reason to believe
that the person has a mental illness and because of his or her mental illness:
The person has refused voluntary examination after conscientious explanation and
disclosure of the purpose of the examination; or the person is unable to determine for
himself or herself whether examination is necessary; and without care or treatment, the
person is likely to suffer from neglect or refuse to care for himself or herself; such neglect
or refusal poses a real and present threat of substantial harm to his or her well-being; and
it is not apparent that such harm may be avoided through the help of willing family
members or friends or the provision of other services; or there is a substantial likelihood
that without care or treatment the person will cause serious bodily harm to himself or
herself or others in the near future, as evidenced by recent behavior.
The Marchman Act is the Florida Substance Abuse Impairment Act which requires that a
person who meets the criteria for involuntary admission if there is good faith reason to
believe that the person is substance abuse impaired or has a co-occurring mental health
disorder and, because of such impairment or disorder:
Has lost the power of self-control with respect to substance abuse; and is in need of
substance abuse services and, by reason of substance abuse impairment, his or her
judgment has been so impaired that he or she is incapable of appreciating his or her need
for such services and of making a rational decision in that regard, although mere refusal
Monroe County DRS Plan Updated May 2023 Page 12 of 27
to receive such services does not constitute evidence of lack of judgment with respect to
his or her need for such services; or without care or treatment, is likely to suffer from
neglect or refuse to care for himself or herself; that such neglect or refusal poses a real
and present threat of substantial harm to his or her well-being; and that it is not apparent
that such harm may be avoided through the help of willing family members or friends or
the provision of other services, or there is substantial likelihood that the person has
inflicted, or threatened to or attempted to inflict, or, unless admitted, is likely to inflict,
physical harm on himself, herself, or another.
The law requires that each county shall designate a single law enforcement agency within
the county, or portions thereof, to take a person into custody upon the entry of an ex parte
order or the execution of a certificate for involuntary examination by an authorized
professional and to transport that person to the appropriate facility within the designated
receiving system pursuant to this transportation plan.
The law enforcement agency may decline to transport the person to a receiving facility
only if:
a. The jurisdiction designated by the county has contracted on an annual basis
with an emergency medical transport service or private transport company
for transportation of persons to receiving facilities pursuant to this section
at the sole cost of the county; and
b. The law enforcement agency and the emergency medical transport service
or private transport company agree that the continued presence of law
enforcement personnel is not necessary for the safety of the person or
others.
The Monroe County Sherriff's Department and City of Key West Police Department
provide transportation of individuals under the Baker Act and/or Marchman Act throughout
Monroe County.
Monroe County Transportation Plan guidelines for Baker Act:
If a law enforcement officer believes that a person has an emergency medical condition
as defined in s. 395.002, the person should be first transported to a hospital for
emergency medical treatment, regardless of whether the hospital is a designated
receiving facility or part of the centralized receiving system.
Law enforcement should transport individuals under the Baker Act to the appropriate
receiving facility.
A list of Monroe County designated receiving facilities that can provide medical
examination and treatment of persons for whom an involuntary examination has been
initiated under the Baker Act can be found in Appendix A.
Monroe County Transportation Plan guidelines for Marchman Act:
If a law enforcement officer believes that a person has an emergency medical condition
as defined in s. 395.002, the person should be first transported to a hospital for
Monroe County DRS Plan Updated May 2023 Page 13 of 27
emergency medical treatment, regardless of whether the hospital is a designated
receiving facility or part of the centralized receiving system.
Law enforcement should transport individuals (Adults and Minors) under the Marchman
Act to the nearest Addiction Receiving Facility (ARF).
A list of Monroe County designated ARFs that can provide medical examination and
treatment of persons for whom an involuntary examination has been initiated under the
Marchman Act can be found in Appendix A.
(Signature page follows)
Monroe County DRS Plan Updated May 2023 Page 14 of 27
Monroe r issi r
c M!
Holly Merrill Reschein, Mayor Pro rr0 ate
r
r w-r E
MONR0E COUNTY ATTORNEY
'y� "',.'. ^
7 apPR v�D ns ro psa 3 dr Z
CHRISTMELIhf®ERT-®ARROWS
ASSISTANT COUNTY ATTORNEY •°^—•°"
DATE 8f1f23
-Rest of Papae Intentionally Left la
CIO C)
-
��
Monroe County DRS Man Updated May 2023 Page 15 of 27
South Florida Behavioral Health Network dlbla Thriving Mind South Florida
07/14/2023
John W. Newcomer, President& CEO Date
-Rest of Page Intentionally Left Blank-
Monroe County DRS Plan Updated May 2023 Page 16 of 27
Department of Children and Families
_Ad' 41 r4 Lk 7/18/2023
Lourdes Dorado-Rubio, Interim Regional Director, Date
Substance Abuse & Mental Health
-Rest of Page Intentionally Left Blank-
Monroe County DRS Plan Updated May 2023 Page 16 of 26
Appendix A
Designated Receiving Facilities
The following is a list of Monroe County facilities designated by the Florida Department of
Children and Families to receive and hold persons with mental illness for involuntary examination
and short-term treatment. This list is subject to change from time to time as new facilities are
designated and others are closed or have their designations removed.
Public Receiving Facilities
Guidance Care Center
3000 41 Street Ocean, Marathon
305-434-7660
Lower Fl. Keys Health System (DePoo Hospital)
1200 Kennedy Drive
Key West, Florida 33040
(305) 294-5531
Addiction Receiving Facilities
The following is a list of Monroe County Addiction Receiving Facilities (ARFs)designated by the
Florida Department of Children and Families to receive and hold persons under a Marchman Act
for involuntary examination and short-term treatment. This list is subject to change from time
to time as new facilities are designated and others are closed or have their designations
removed.
Guidance Care Center (ARF & Inpatient Detox)
3000 41 Street Ocean, Marathon
305-434-7660
Monroe County DRS Plan Updated May 2023 Page 18 of 27
Attachment C—Agreements Template
BUSINESS ASSOCIATE AGREEMENT
This Business Associate Agreement("Agreement") is entered into by and between South
Florida Behavioral Health Network, Inc., ("SFBHN") and «Legal Company Name »
(individually each a "Parry" or "Associate" and collectively the "Parties" or the "Associates").
The Effective Date of this Agreement shall be July 1, 2016 ("Agreement Effective Date").
RECITALS
A. SFBHN and ((Legal Company Name », are each deemed to be Covered Entities under
the Health Insurance Portability and Accountability Act ("HIPAA") and may, from time to
time, each act as a Business Associate on behalf of the other to provide services in
accordance with one or more agreements (the "Underlying Agreements").
A. SFBHN is deemed to be a Business Associate under the Prime Contract with the Florida
Department of Children and Families and obligated to comply with HIPAA, the HITECH
Act, and any regulations promulgated thereunder, with respect to the PHI it creates,
maintains, receives, or transmits on behalf of((Legal Company Name ».
B. ((Legal Company Name » acknowledges that all provisions, terms and conditions, or
amendments, addendum, changes or revisions applicable to the
((Legal Company Name » made subsequent to the initial execution of the Prime
Contract, (Contract entered into between the Florida Department of Children and
Families) and SFBHN, not in conflict with this Business Associate Agreement shall be
binding upon the ((Legal Company Name », and the ((Legal Company Name »,
agrees to comply with same. The Prime Contract is incorporated by reference in this
Business Associate Agreement.
C. The Associates both acknowledge that they are each obligated to comply with the Privacy
Rule, the Security Rule, the Breach Notification Rule, the Health Information Technology
for Economic and Clinical Health ("HITECH") Act, s. 501.171, F.S., and other laws and
regulations pertaining to the access, use, disclosure, and management of Protected
Health Information ("PHI") without limitation, PHI in an electronic format (EPHI).
D. In the event that either Party (or both Parties) is a Program, as defined by the federal
regulations governing the Confidentiality of Alcohol and Drug Abuse Patient Records, at
42 CFR Part 2 (the "Substance Abuse Regulations"), the Underlying Agreements may also
require each of the Parties to create, receive, transmit, or maintain patient information
on behalf of the other that is subject to the Substance Abuse Regulations. As such, the
Associates further acknowledge that they are each obligated to comply with those
regulations, with respect to a Program's patient information.
E. The Associates intend to protect the privacy and provide for the security of patient
information, including PHI, pursuant to this Agreement, and all in compliance with
Applicable Law.
Monroe County DRS Plan Updated May 2023 Page 19 of 27
F. The Parties acknowledge that this Agreement supplements and amends each of the
Underlying Agreements only with respect to the creation, use, or disclosure of patient
information, including PHI. Except as so supplemented or amended, the terms of the
Underlying Agreements shall govern the matters addressed in this Agreement and in
each of the Underlying Agreements.
NOW,THEREFORE, in consideration of the mutual promises below, the Parties agree as follows:
Section 1. Definitions. Capitalized terms used in this Agreement and not otherwise defined
herein shall have the meanings set forth in the HIPAA Rules, which definitions are incorporated
in this Agreement by reference. Capitalized terms used in this Agreement are defined as follows:
a. "Applicable Law" means HIPAA, the HITECH Act, and all regulations issued thereunder, as
well as the Substance Abuse Regulations and any other applicable federal and state law.
b. "Breach" shall have the meaning given to such term under the Breach Notification Rule,
including, but not limited to, 45 CFR § 164.402.
c. "Breach Notification Rule" shall mean the Breach Notification Standards at 45 CFR Parts
160 and 164.
d. "Business Associate" shall have the same meaning as given to such term in 45 CFR §
160.103.
e. "Covered Entity" shall have the same meaning as given to such term in 45 CFR § 160.103.
f. "Electronic Protected Health Information"or"ePHI" shall have the meaning given to such
term under the HIPAA Rules, including, but not limited to, 45 CFR § 160.103, as applied
to the information that each Associate creates, maintains, receives from, or transmits on
behalf of the other Associate.
g. "Enforcement Rule" shall mean the Compliance and Enforcement Standards at 45 CFR
Part 160.
h. "HIPAA" meansthe Health Insurance Portabilityand Accountability Act of 1996("HIPAA"),
Public Law No. 104-191, and any regulations promulgated thereunder.
i. "HIPAA Rules" shall mean the Privacy, Security, Breach Notification, Enforcement, and
Transaction Rules at 45 CFR Parts 160, 162, and 164.
j. "HITECH Act" means the Health Information Technology for Economic and Clinical Health
("HITECH") Act, Public Law No. 111-005, and any regulations promulgated thereunder.
k. "Privacy Rule" shall mean the Standards for Privacy of Individually Identifiable Health
Information at 45 CFR Parts 160 and 162 and Part 164, Subparts A and E, 42 U.S.C. 1320d-
5 and 1320d-6.
I. "Program" shall have the same meaning as given to such term in 42 CFR § 2.11.
m. "Protected Health Information" or"PHI" shall have the same meaning given to such term
under the HIPAA Rules, including, but not limited to, 45 CFR § 160.103, as applied to the
information created or received by each Associate from, or on behalf of, the other
Monroe County DRS Plan Updated May 2023 Page 20 of 27
Associate.
n. "Required by Law"shall have the same meaning as given to such term in 45 CFR§ 164.103.
o. "Secretary" shall mean the Secretary of the Department of Health and Human Services or
his or her designee.
P. "Security Rule" shall mean the Security Standards at 45 CFR Parts 160 and 162 and Parts
164, Subparts A and C.
q. "Subcontractor" shall have the same meaning as given to such term in 45 CFR § 160.103.
r. "Substance Abuse Regulations" shall mean the Confidentiality of Alcohol and Drug Abuse
Patient Records regulations, at 42 CFR Part 2.
s. Transaction"shall have the same meaning given to such term under the Transaction Rule,
including, but not limited to, 45 CFR § 160.103.
t. "Transaction Rule" shall mean the Standards for Electronic Transactions at 45 CFR Parts
160 and 162.
u. "Unsecured PHI" shall have the same meaning given to such term, as "unsecured
protected health information," under the Breach Notification Rule, including but not
limited to, 45 CFR § 164.402, as applied to the information created or received by each
Associate from, or on behalf of, the other Associate.
Section 2. Permitted Uses and Disclosures of PHI.
a. Uses and Disclosures of PHI. Except as otherwise limited in this Agreement, Associates
may each use or disclose PHI received from or created on behalf of the other Associate only to
perform such functions, activities, or services for, or on behalf of, each other pursuant to the
Underlying Agreements.
b. Permitted Uses of PHI by Associates. Except as otherwise limited in this Agreement,
Associates may each use the PHI received from or created on behalf of the other Associate (i) for
their respective proper management and administration, (ii) to carry out their respective legal
responsibilities; and (iii) for Data Aggregation purposes for the Health Care Operations of the
other Associate. Associates may use PHI to create de-identified health information, in
accordance with the HIPAA Rules at 45 CFR § 164.514, and may use such de-identified health
information.
C. Permitted Disclosures of PHI by Associates. Except as otherwise limited in this Agreement,
Associates may each disclose PHI (i)for their proper management and administration; (ii)to carry
out their respective legal responsibilities; (iii) as Required by Law; and (iv) for Data Aggregation
purposes for the Health Care Operations of the other Associate. If an Associate intends to
disclose PHI to a third party, prior to making any such disclosure, such Associate shall first obtain,
(i) reasonable written assurances from such third party that PHI will be held confidential in a
manner that is consistent with the terms of this Agreement and will only be used or disclosed as
Required by Law or for the purposes for which it was disclosed to such third party, and (ii) a
written agreement from such third party to notify Associate of any breaches of confidentiality of
Monroe County DRS Plan Updated May 2023 Page 21 of 27
the PHI, to the extent it has obtained knowledge of such breach, without unreasonable delay,
and in any event within sufficient time to meet any breach notification requirements under the
HIPAA Rules.
Section 3. Obligations and Activities of Associates(as Business Associates). Associates shall each
comply with all obligations and requirements for Business Associates under Applicable Law with
respect to PHI, and shall have the following obligations:
a. Appropriate Safeguards. Associates shall each implement administrative, physical, and
technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and
availability of PHI, in accordance with 45 CFR § 164.308, physical safeguards as set forth at 45
CFR § 164.310, and technical safeguards as set forth at 45 CFR § 164.312; including, policies and
procedures regarding the protection of PHI and/or ePHI set forth at 45 CFR § 164.316 and the
provisions of training on such policies and procedures to applicable employees, subcontractors,
independent contractors, and volunteers, that reasonably and appropriately protect the
confidentiality, integrity, and availability of the PHI and/or ePHI that the Provider creates,
receives, maintains or transmits.
Associates shall take immediate steps to limit or avoid recurrence of any security breach and take
any other action pertaining to such unauthorized access or disclosure required by applicable
federal and state laws and regulations regardless of any actions taken by SFBHN or The Florida
Department of Children and Families.
b. Reporting of Improper Use or Disclosure.
(i) Each Associate shall report to the other Associate, in writing, any use or
disclosure of PHI not provided for by this Agreement, including any Breach of Unsecured PHI or
any Security Incident of which it becomes aware as required at 45 CFR 164.410, and any security
incident of which it becomes aware.
(ii) ((Legal Company Name » shall provide notification to SFBHN Security
Officer, Privacy Officer and Contract Manager as soon as possible, but no later than four (4)
business days following the determination of any breach or potential breach of personal and
confidential data.
(iii) ((Legal Company Name »shall provide notification to SFBHN Privacy Officer
and Contract Manager within twenty-four (24) hours of notification by the US Department of
Health and Human Services of any investigations, compliance reviews or inquiries by the US
Department of Health and Human Services concerning violations of HIPAA (Privacy, Security
Breach).
C. Data Breach Notification. No later than four (4) business days following any breach
affecting 500 or more individual, either Associate shall provide to the other, in writing the
elements as required by s. 501.171, F.S. to permit SFBHN to comply with the HIPAA Breach
notification requirements set forth in the Prime Contract, 45 C.F.R. §§ 164.400, et seq., and in
s. 501.171, F.S. Associates, as applicable, at its own cost, shall notice affected parties no later
than thirty (30) days following the determination of any breach or potential breach of personal
or confidential data as provided in § 817.5681, Fla. Stat. Following a HIPAA Breach (Privacy,
Security Breach), each Associate will have a continuing duty to inform the other Associate of new
and material information learned regarding the HIPAA Breach.
Monroe County DRS Plan Updated May 2023 Page 22 of 27
d. Mitigation Procedures. Each Associate agrees to mitigate, to the extent practicable, any
harmful effect that is known to it of a use or disclosure of PHI by such Associate in violation of
the requirements of this Agreement, or the HIPAA Rules.
e. Subcontractors and Agents. Each Associate shall ensure that any agent, including a
Subcontractor, to whom it provides PHI, agrees (in writing) to the same restrictions and
conditions that apply through this Agreement to such Associate with respect to such PHI.
Associates shall implement and maintain sanctions against agents and Subcontractors that
violate such restrictions and conditions, and shall attempt to mitigate the effects of any such
violation. Each Associate and their Subcontractors and Agents are directly liable under the civil
and criminal enforcement provisions set forth at Section 13404 of the HITECH Act and section 45
CFR § 164.500 and 164.502(E) of the Privacy Rule (42 U.S.C. 1320d-5 and 1320d-6), as amended,
for failure to comply with the safeguards, policies and procedures requirements and any
guidance issued by the Secretary of Health and Human Services with respect to such
requirements
f. Access to PHI. Each Associate agrees to provide access to PHI in a Designated Record Set
to the other Associate or, as directed by the other Associate, to an Individual, at the written
request of the other Associate within a reasonable time and manner,sufficient to allow the other
Associate to meet the requirements of 45 CFR § 164.524. Each Associate agrees to disclose PHI
in electronic format to the other Associate or, as directed by the other Associate,to an Individual
or an Individual's designee, as may be necessary to satisfy the other Associate's obligations under
45 CFR §§ 164.524(c)(2)(ii) and (3)(ii) regarding an individual's request for an electronic copy of
PHI.
g. Amendment of PHI. Each Associate shall make any amendment(s) to PHI in a Designated
Record Set that the other Associate directs or agrees to, pursuant to 45 CFR § 164.526, in a time
and manner reasonably designated by the other Associate.
h. Documentation of Disclosures. Each Associate agrees to document such disclosures of PHI
and information related to such disclosures as would be required for the other Associate to
respond to a request by an Individual for an accounting of disclosures of PHI in accordance with
45 CFR § 164.528.
i. Accounting of Disclosures. Each Associate agrees to provide to the other Associate, within
thirty(30) business days, information collected in accordance with Section 3(f)of this Agreement,
sufficient to permit the other Associate to respond to a request by an Individual, or on behalf of
an Individual, for an accounting of disclosures of PHI in accordance with 45 CFR § 164.528.
j. Minimum Necessary. Each Associate shall request, use, and disclose only the minimum
amount of PHI necessary to accomplish the purpose of the request, use, or disclosure to the
extent that the minimum necessary standard is applicable to the disclosure under 45 CFR §
164.502(b).
k. Governmental Access to Records. Each Associate agrees to make its internal practices,
books, and records relating to the use and disclosure of PHI received from the other Associate,
or created on behalf of the other Associate, available to the Secretary for purposes of
determining either or both Associates' compliance with the HIPAA Rules.
Monroe County DRS Plan Updated May 2023 Page 23 of 27
I. Standard Transactions. If an Associate conducts, in whole or in part, any Transactions
electronically on behalf of the other Associate, such Associate shall comply with the applicable
requirements of 45 CFR Part 162 and shall require that any agents or Subcontractors that
perform, in whole or in part, such Transactions on its behalf, agree in writing to comply with such
requirements. Such Associate will not enter into any trading partner agreement in connection
with conducting Standard Transactions on behalf of the other Associate: (i) that changes the
definition, data condition, or use of a data element or segment in a Standard Transaction; (ii)
adds any data element or segment to the maximum defined data set; (iii) uses any code or data
element that is marked as "not used" in the Standard Transaction's implementation specification
or is not in the Standard Transaction's implementation specification; or(iv) changes the meaning
or intent of the Standard Transaction's implementation specification.
m. Qualified Service Organization Agreement. In the event that either Associate (or both
Associates) is a Program, as defined by the Substance Abuse Regulations, each Associate agrees
to provide the services, as described in the Underlying Agreements, and further(i) acknowledges
that in receiving, storing, processing, or otherwise dealing with any information from a Program
about the patients in the Program, it is fully bound by the provisions of the Substance Abuse
Regulations; and (ii) agrees to resist in judicial proceedings any effort to obtain access to
information pertaining to such patients otherwise than as expressly provided for in the Substance
Abuse Regulations.
Section 4. Obligations of Associates (as Covered Entities).
a. Notice of Privacy Practices. Each Associate shall notify the other Associate of any
limitation(s) in its notice of privacy practices, under 45 CFR § 164.520 and under s. 501.171, F.S.
, to the extent that such limitation(s) may affect the other Associate's use or disclosure of PHI.
b. Notification of Changes Regarding Individual Permission. Each Associate shall notify the
other Associate of any changes in, or revocation of, permission by an Individual to use or disclose
PHI, to the extent that such changes may affect the other Associate's use or disclosure of PHI.
C. Notification of Restrictions to Use or Disclosure of PHI. Each Associate shall notify the
other Associate of any restriction(s) imposed on the use or disclosure of PHI that such Associate
has agreed to or is obligated to support in accordance with 45 CFR § 164.522, to the extent that
such restriction may affect the other Associate's use or disclosure of PHI. The other Associate
agrees to abide by such restriction to the extent applicable and provided that it is made aware of
the restriction in a reasonable and timely manner.
d. Permissible Requests by Associates. Neither Associate shall request the other Associate
to use or disclose PHI in any manner that would not be permissible under Applicable Law if done
by such Associate, except as permitted under this Agreement.
e. Marketing, Fundraising and Research. Each Associate shall follow guidance in the HIPAA
Rule regarding marketing, fundraising and research located at Sections 45 CFR § 164.501, 45 CFR
§ 164.508 and 45 CFR § 164.514.
Section 5. Term and Termination.
a. Term. The term of this Agreement shall commence as of the Agreement Effective
Date and shall terminate when all of the PHI provided by each Associate to the other Associate
is destroyed or returned, or, if it is infeasible to return or destroy the PHI, protections are
Monroe County DRS Plan Updated May 2023 Page 24 of 27
extended to such information, in accordance with Section 5(c), or when one party gives the other
fifteen (15) calendar days notification of termination in writing to the other party or such time
as mutually agreed upon by both parties.
b. Termination for Cause. A breach by either Associate of any provision set forth in Sections
2, 3 or 4 of this Agreement may, in the sole discretion of the other Associate, be deemed to
constitute a material breach of this Agreement if such breach is not cured,or a plan is not enacted
to enable a cure, within thirty (30) business days of receiving written notice from the non-
breaching Associate. Upon occurrence of such material breach,the non-breaching Associate may
immediately terminate this Agreement, notwithstanding any provision in this Agreement to the
contra ry.
C. Effect of Termination.
(i) Except as provided in paragraph (ii) of this Section 5(c), upon termination
of this Agreement for any reason, each Associate shall return or destroy all PHI received from the
other Associate, or created or received by each Associate on behalf of the other Associate, and
shall retain no copies of the PHI. Each Associate agrees to impose the same obligations to return
or destroy PHI, in writing, on each of its Subcontractors or agents to the extent they are or may
be expected to come into possession of such PHI.
(ii) In the event that an Associate determines that returning or destroying the
said PHI is infeasible, such Associate shall provide notification of the conditions that make return
or destruction infeasible to the other Associate and shall extend the protections of this
Agreement to such PHI and limit further uses and disclosures of such PHI to those purposes that
make the return or destruction infeasible, for so long as such Associate maintains such PHI.
Section 6. Indemnification. Each Associate (the "Indemnifying Associate") will indemnify,
defend, and hold harmless the other Associate (the "Indemnified Associate") from any and all
claims, losses, liabilities, damages, judgments, fees, expenses, awards, civil monetary penalties,
and costs (including reasonable attorneys' and court fees and expenses) arising out of or related
to any Breach or alleged Breach of Unsecured PHI created, received, maintained, transmitted,
or otherwise used by the Indemnifying Associate and arising from the Indemnifying Associate's
breach, or failure to perform pursuant to this Agreement (collectively, a "Claim"). This
indemnification does not cover any claims, losses, liabilities, damages, judgments, fees,
expenses, awards, civil monetary penalties, and costs resulting from the negligence or willful
misconduct of the Indemnified Associate, or any of Indemnified Associate's employees,
contractors, or agents (except Indemnifying Associate). This indemnification is contingent upon
(i) Indemnified Associate giving prompt written notice to Indemnifying Associate of any Claim
for which indemnification is sought, and (ii) Indemnified Associate giving Indemnifying Associate
sole control of the defense, including selection of counsel, and related settlement negotiations
regarding the Claim, except that Indemnifying Associate will not enter into a final settlement
involving discharge of any claims against Indemnified Associate without Indemnified Associate's
prior consent. Indemnified Associate may participate in the defense of any Claim at Indemnified
Associate's own cost. Indemnified Associate agrees that it will assist and cooperate in the
defense and related settlement of the Claim, at its expense, as the Indemnifying Associate may
reasonably request.
Section 7. Regulatory References. A reference in this Agreement to a section in the HIPAA Rules,
Monroe County DRS Plan Updated May 2023 Page 25 of 27
the Substance Abuse Regulations, or any other Applicable Law means the section as in effect or
as amended, and for which compliance is required by either or both Associates.
Section 8. Amendment. The Parties agree to take such action to amend this Agreement from
time to time as is necessary for both to comply with Applicable Law. Such amendment shall be
in writing and signed by both the Parties.
Section 9. Survival. The respective rights and obligations of the Parties under Section 5(c) and
Section 6 of this Agreement shall survive the termination of the Agreement.
Section 10. No Third Party Beneficiaries. Nothing express or implied in this Agreement is
intended to confer, nor shall anything herein confer, upon any person other than the Parties and
their respective successors or assigns, any rights, remedies, obligations or liabilities whatsoever.
Section 11. Interpretation. Any ambiguity in this Agreement shall be resolved in favor of a
meaning that permits the Parties to comply with Applicable Law.
Section 12. Waiver. No delay or omission by either Party to exercise any right or remedy under
this Agreement will be construed to be either acquiescence or the waiver of the ability to exercise
any right or remedy in the future.
Section 13. Severability. In the event any part or parts of this Agreement are held to be
unenforceable, the remainder of this Agreement shall continue in effect.
Section 14. Governing Law. This Agreement shall be governed by the laws of Florida
IN WITNESS WHEREOF, the Parties hereto have duly executed this Agreement as of the
Agreement Effective Date.
Monroe County Board of Commissioners SOUTH FLORIDA BEHAVIORAL HEALTH
NETWORK, INC.
SIGNED SIGNED
BY: BY:
NAME: Craig Cates NAME: John W. Newcomer
TITLE: Mayor TITLE: President and CEO
Date: Date:
Federal Tax ID4 (or SSN): 59-6000749
Monroe County DRS Plan Updated May 2023 Page 26 of 27
Attachment D— Sign In Sheet Monroe County Public Meeting
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Monroe County DRS Plan Updated May 2023 Page 27 of 27