HomeMy WebLinkAboutAgreements/Contracts - Veterans ServicesGRANT COUNTY
COMMISSIONERS AGENDA MEETING REQUEST FORM
(Must be submitted to the Clerk of the Board by 12:00pm on Thursday)
REQUESTING DEPARTMENT: Veteran Services
REQUEST SUBMITTED BY:Anthony Garcia
CONTACT PERSON ATTENDING ROUNDTABLE: Anthony Garcia
CONFIDENTIAL INFORMATION: ❑YES ®NO
SATE: 06/13/2025
PHONE: 5097542011 5255
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Due to a limited State Funding looking to see if we can pick up the last 6 months of
the year with Bates Counseling services for Mental health for veterans.
Contract amount not to exceed $27,300.4z:;
R a%�
If necessary, was this document reviewed by accounting? ❑ YES ❑ NO 0 N/A
If necessary, was this document reviewed by legal? *1 YES ❑ NO ❑ N/A
DATE OF ACTION: r,� DEFERRED OR CONTINUED TO:
APPROVE: DENIED
D 1:
D2:
D3:
ABSTAIN
WITHDRAWN:
RECEIVED
JUN 13 2025
4/23/24 GRANT COUNTY COMMISSIONERS
K25-115
GCVS Contract No. 02-2026
Page 1 of 6
Contract for Services between
Grant County Veterans Services
and
BATES COUNSELING SERVICES, PLLC
This Contract is made and entered into by and between Grant County Veterans Services,
hereinafter referred to as the "GCVS", and Bates Counseling Services, PLLC, 16271 Rd 9 NW.,
Quincy, WA 98848 hereinafter referred to as "CONTRACTOR."
I. PURPOSE
The purpose of this contract is to provide readjustment counseling to all wartime veterans,
Washington State National Guard and Reserve members and their immediate family members
and significant others. Veterans and family member clients must be residents of the State of
Washington as described under the Statement of Work.
The CONTRACTOR shall provide readjustment counseling as described in Attachment B.
11. SCOPE OF WORK
A. Attachment A, attached hereto and incorporated by reference, contains the General Terms
and Conditions governing work to be performed under this contract, the nature of the working
relationship between the GCVS and the CONTRACTOR, and specific obligations of both
parties.
B. The CONTRACTOR will provide services and staff., and otherwise do all things necessary for
or incidental to the performance of work, as set forth in Attachment B, Statement of Work.
C. Attachment C, attached hereto and incorporated by reference, contains the Business
Associate Agreement, which ensures that Protected Health Information (PHI) is appropriately
safeguarded.
111111. PERIOD OF PERFORMANCE
J
The initial period of performance under this contract will be from July 1, 2025 through-9�e
,___a1.,_-2.02-5--.-Upon the expiration of the initial term, options to renew for one-year term(s) may be
exercised by GCVS.
IV. COMPENSATION
Total compensation payable to CONTRACTOR for satisfactory performance of the work under.
this contract for the initial period of performance shall not exceed T-wrenty-Sieven-T-M-usawd 15i0cc)
-Thre-eJiund-r-ed-O-off,aTs-($27,-3", without prior consent from the contract manager. All renewal
term compensation shall be identified by amendment to this contract for each successive period
of performance and will identify the period of funding and the amount that will be provided.
CONTRACTOR's compensation for services rendered shall be based on the following rates:
GCVS Contract No. 02-2026
Page 2 of 6
A. Professional Service Rates
INDIVIDUAL' COUPLES, AND FAMILY RATE $105a00/HR
CONSULTATION/COMM UNITY EDUCATION $105w00lHR,
GROUP RATE PERCILIENT $20.00/HR
Travel time shall not be included in the tabulation of CLIENT counseling time.
The GCVS Form 066-Client Intakem.ust be- completed and submitted to the GCVS when billing
for services rendered. A copy of the GCVS Form 066 will be accomplished for every client seen
in the. program..
B. Mileage.
Mileage may be, reimbursed for attendance at required conferences and meetings designated
,by the GCVS. CONTRACTOR shall receive compensation for mileage expenses at current state
travel reimbursement. rates. These posts are included in the total compensation of the contract.
V. BILLING PROCEDURES AND PAYMENT
A. Billing and Payment
GCVS will pay CONTRACTOR upon acceptance of services provided and receipt of properly
completed invoice (Form GCVSi9-1 A), which shall be submitted to the Contract Manager riot
more often than monthly.
The CONTRACTOR 'shall submit 'Monthly invoices for services performed pursuant to this
Contract on Forms A-! 9A, which shall be accompanied by GCVS Forms 066, 047A, 04713, and
047C, as applicable (which will be sent to CONTRACTOR for use by the Contract Manager).
.Invoices shall describe and document, to the GCVS'S satisfaction, a description of the work
performed, the services provided, and fees. The 'Invoice shall include the contract reference
number GC'VS Contract No. 02-2026 CONTRACTOR shall utilize the GCVS Forms. GCVS
047A1) B, and/or C to account for hours provided, and the activity covered, (i.e., outpatient
mental health treatment, or limited professional training/consultation services").
CONTRACTOR original billings will have original signatures and supporting documents and
must be receiVed key the GCVS by the 5th working day of the month following the month end
that services were provided. Otherwise, there will be a delay in payment. Adhering to this
schedule will permit rapid payment.
Additionally, at the end of the Washington State Fiscal Year (June 30th) CONTRACTOR shall
have all billings in by the 5th working day in June or face the possibility of delayed payment.
CONTRACTOR is encouraged to bill no more than 1/1 2th / 1/24th of his or her (1.2 / 24 month)
Contract in any given month. (if billing exceeds 1112th or 11,24th of the contract then
CONTRACTOR will submit unbiiled hours.) If CONTRACTOR over -bills for service in a given
month, the GCVS reserves the right to reduce payment to the 1/1 2th of total annual Contract,
however this will be done only in consultation with the CONTRACTOR. CONTRACTOR shall
limit billings for group sessions to a maximum of two hours per group, unless special
arrangements have been made in aGCVSnce and in writing with the PTSD Program Director.
Failure to complete GCVS Form 066 Client Intake Form will result in non-payment. Intakes are
very important to accomplish and submit routinely. Billings for individual treatment will be for
one -hour sessions unless the session is an emergency.
GCVS Contract No. 02-2026
Page 3 of 6
The GCVS1 9-1 A and all accompanying documents shall be submitted directly to the GCVS's
Contract Manager identified in subsection V1, Contract Management.
Details and instructions on completion of forms and other billing aspects are in Attachment B,
Statement of Work, Section 111.
Payment shall be considered timely if made by the GCVS within thirty (39) calendar days after
receipt of properly completed invoices. Payment shall be sent to the address designated by the
CONTRACTOR.
The GCVS may, in its sold discretion, terminate the contract or withhold payments claimed by
the CONTRACTOR for services rendered if the CONTRACTOR fails to satisfactorily comply
with any term or condition tion of this contract.
No payments in a'G.CVSnce or in anticipation of services or supplies to be provided. under this
contract shall be made by the GCVS.
B. Alternative Resources. Expenditures under this Contract shall not supplant federal, state, or
private resources. Every effort shall be made to obtain U.S. Department of Veterans Affairs
funding where available (i.e.,, Vet Center: [RCS] contracts., VA service -connected, Mental Health
Fee Basis funding, and private insurance resources, etc.) Efforts to access. these alternativ
e
funding resources shall be considered routinely. Assistance and suggestions in accessing these
alternative resources for CONTRACTOR are part of the GCVSS effort to help with s ources of
treatment support.
C. The GCVS Contract Manager shall develop and maintain a pa ent process to ensure
accurate and timely disbursements under this Contract All contractors must coMP lete the
required registration under this process before submitting any reques -ts for payment, and no
payment shall be issued until such registration is finalized
V1. CONTRACT MANAGEMENT
The Contract Manager for each of the parties shall be the
contact person for all communications and billings regarding
the performance of this contract.
CONTRACTORICONTRACT MANAGER INFORMATION
BCS Contractor
GCVS Contract Manager
Name: Robert Bates
Anthony Garcia
Address: 16271 RD 9 NW
Grant County Veterans Services
Quincy, WA 98848
1008 W Ivy Ave.
Phone.- (425) 477-9383
Moses Lake, WA 98837
E-mail: rob@batescounselingservices.com
Phone." (509) 885-4097
E-mail: agarcia@grantcountywa.gov
GCVS Contract No. 02-2026
ATTACHMENT B
STATEMENT OF WORK
The. CONTRACTOR will provide service's and staff, ff, and otherwise 'do all things necessary
or incidental to the performance of work, as set forth below:
I. DEFINITIONS
As used throughout this. Contract the following terms are given the listed meaning:
A. WARTIME OR PEA, CEKEEPING'OPERATION VETERANS
An 'individual who served in any branch of the armed forces of the United States during one or
more of the following war periods:
World War 1: April 6,1916 through July 1, 1920
World War 11: December 7,1941 through December $1, 1946
Korean Conflict: June 27, 1950 through January 31, 19515
Vietnam Era: February 28, 196*1 through May 7, 1975
Lebanon: August 25, 1982 through February 26, 1984
Grenada: October 23, 1983through November 23, 1983
Panama (Operation Just Cause): December 20, 1989 through January 31, 1990
Persian Gulf War (Operation Desert Storm): August 2, 1990 through (time to be 'established).
Somalia (Operation. Restore Hope): December 5, 1992 through (time to be
established).
Haiti (Operation Uphold Democracy) September 16, 1994 through (time, to be
established).
Bosnia Peacekeeping Mission (Operation Joint Endeavor): December 5,1995 through (time to
be est.aOshed).
Global War on Terror (GWOT) including all war theaters., 0. IF (Operation Iraqi Freedom), OEF
,(Operation Enduring Freedom), ONE (Operation Noble Eagle) and conflicts around the world
associated with GWOT. CONTRACTOR should be especially attuned to deployment locations
since highly stressful deployments mIghtrinclude duties under ONE, even .though the veteran did
not leave CON US (Continental United States), September 11, 2001 through "Indeterminate date.
Other operations/conflicts/covert actions as designated by the President and Congress.
B. SIGNIFICANT OTHER
Individual with whom the veteran lives or certifies intent to live, or a person having a significant
.relationship With the veteran.
C. READJUSTMENT COUNSELING
Counseling and Wellness Programs Counseling directed at social, psychological, or behavioral
problems presented by CLIENTS, which bear a distinct relationship to the
GCVS Contract No. 02-2026
Page 2 of 15
process of readjustment from military duty during wartime or military sexual trauma (MST).
Counseling directed at social, psychological, or behavioral problems, which bear a distinct
relationship to the process of readjustment from military duty during wartime and social,
psychological, or behavioral problems which bear a distinct relationship to the process of
readjustment from military duty due to Military Sexual Trauma (MST) including sexual
harassment,, while serving on active duty.
Telemental Health Counseling — CONTRACTOR has the freedom to choose whether to use
distance counseling and/or technology within the counseling process to clients who are
residents within the. state. Technology used will be HIPAA comp . liant and CONTRACTOR will
esi
adhere to the profession's Ethical Guidelines. Upon request, CONTRACTOR will provide
evidence of training on delivering te'lemental health services. CONTRACTOR will notify program
director they begin engaging in . telemental health services.
D. COMMUNITY EDUCATION SERVICES
CONTRACTOR may provide on an event by event approved basis by the Program Director,
Counseling and Wellness Programs, education to the larger community, academic communi I t
Y,
social service agency, or workplace settings that will enhance the delivery of important
awareness of the features of war trauma, and PTSD, and methods of management and referral
and referral information. Education may 'Include meeting with students in educational settings,
workers, organizational management staff, or in .any of several possible settings wherein the
knowledge of war trauma, and PTSD will act to improve the veteran's life and functioning as a
direct or indirect result of the educational event. Community education services may include
offering classroom or program support in the training of new clinicians who have, a strong
commitment for the treatment of war trauma and PTSD in veterans and/or their families. A
maximum of four hours can be dedicated to one training. A registration form will be used to
I I g s
collect participant names, and an evaluation (contact the Program Director for an example) will
be administered to each participant and collected at the conclusion of the training. Once
completed, the registration form., evaluations and a paragraph summarizing the evert will be
submitted to the Counseling and Wellness, Programs Program Director. Billing will be at the
current rate as is established for individuals, couples and families.
E. PROFESSIONAL CONSULTATION SERVICES
Consultation services refer to those professional treatment support and enhancement efforts
provided to other CONTRACTOR PTSD Providers or to providers in the larger community within
the CONTRAOTOR's catchment area, or those who are seeking treatment consultation or
assessment skills regarding a veteran client or family member. Consultation service may occur
in places such as a local mental health center, the veteran's place of employment, social service
agencies, counseling and other health providers offering treatment to the veteran and family,
higher education faculty, staff and administration, school counselors who work with school aged
children of Veterans or other organizations that serve veterans and their families Once
consultation has been provided, a brief summary will be provided to include name of
organization (s), participants, and description of the consultation.
GCVS Contract No. 02--2026
Page 3 of 15,
F. READJUSTMENT PROBLEMS
This term includes military, war l or homecoming related experiences which:
Interfere with a veteran's job performance;
Produce difficulties associated, with a veteran's pursu.it of education;
Create interpersonal relationship diffi.culties; and
Produce an inability to cope with problems encountered in daily life.
G. WASHINGTON STATE ARMY NATIONAL GUARD (WAANG) OR MILITARY RESERVE
The CONTRACTOR is permitted to provide counseling services to members of the State
National Guard or Military Reserves who were activated for service during the Persian Gulf War,
GWOT, COIF, OEF, ONE, other military deployments,. and their family members and/or significant
others.
H. PTSD PROGRAM CONSULTATION AND ADVISORY TEAM MEMBERS
Program and clinical consultation is provided by WDVA Counseling and Wellness Program
Director. The Program Director is available to assist in professional -development- quality
assurance, case consultation, referrals to the VA Medical Center, issues related to VA Regional
Office, and other clinical and administrative assistance,. A PTSD Program Consultation Team is
available for specialized consultation, especially to providers and other mental health providers
treating veterans and trauma. These team members include Clark Ashworth, Ph.D. and Adrian
Magnusson -White, Ph.D. Their contact information can be found on the GCVS providers list.
Advisory team member services are used on an "as needed basis to help formulate specific
directions taken by the, Counseling and Wellness Program, as well as for the purpose of
selecting new CONTRACTORs, o I r the creation of conference agendas and other events.
1I. DUTIES OF CONTRACTOR:.
X COUNSELING RESPONSIBILITIES
1. Basic Service Provision CONTRACTOR shall provide Readjustment Counseling to all
Wartime or Peace Keeping Operation Veterans or other authorized military deployments who
experienced social, psychological, or behavioral readjustment problems from m ilitary duty
during wartime or MST, and/or the immediate family members and significant others of
veterans. Veterans and family member CLIENTs must be residents of Grant County.
GCVS Contract No. 02*2026
Page 4 of 15
The CONTRACTOR's primary goal is to establish a therapeutic relationship and create an
environment that will permit veterans to participate in Readjustment Counseling. The central
purpose of counseling will be the process of readjustment from military wartime duty, the work
of adjustment from the complications of the homecoming experience.
CONTRACTOR may provide Readjustment Counseling in the following modalities*. Individual,
Couples, Family, and Group services
CONTRACTORS are also encouraged to consider ways in which they .may be able to offer
special services to their community through the "Professional Consultation and Community
Training" service segments of this program. Along with informing the Director, CONTRACTOR
may consult with the Veteran Training Support Center (VTs } in order to access the latest
content information, as well as current methods, tools, and models used for training and.
consulta
CONTRACTOR shall provide Readjustment Counseling or other services for the following
reasons when they bear a distinct and crucial relationship to the veteran's readjustment from
military duty: (Note: This list is advisory, and not all CONTRACTORs will be able to provide all
of the listed services. In those instances when the CONTRACTOR encounters CLIENTs
needing specialized help, the CONTRACTOR is encouraged to work with the Program Director
i I n order to seek and secure appropriate services through one of the other PTSD Program
providers or from a source outside the Program, such as the VA Medical Center or the Vet
Center. Examples of this might be related to those instances when specialized forensic
assessment and testimony, medical treatment, psychiatric evaluation, or psychotropic
prescriptions are needed.)
a. Psychosacial distress related to exposure to war, military duty, and humanitarian service
trauma while serving.
in the miliI tary.
b. Other traumatic aspects of duty in Southeast Asia or other war, peaceke
eping, or
humanitarian theaters.
c. Posttraumatic Stress Disorder or other psychological problems developing as a result of
military service.
d. Stressors. Unique to military duty during a time of conflict, war, peacekeeping, humanitarian
missions, or when stressors include sexual abuse, physical abuse, related stressors,
harassment, or personal injury while on active duty.
e. Psychological problems related to type of military discharge, especially when there is a
chance of upgrade of discharge.
f. Psychological distress resulting from military related physical 'Injury and service -connected
conditions, as well as those reactions related to abusive treatment while in the military due to
gender, racial, or any discrimination -based, issues
g. Substance abuse, secondary to military service experiences, war trauma, or service -related
PTSD.
GCVS Contract No. 02-2026
Page 5 of 15
h. Post-war experiences, including ng,
homecoming, social reentry experience or reunion, or life
complications related to military service.
i. Post -military stressors, which act to exacerbate the effects of traumatic military
duty-
j. Concern over possible Agent Orange, or other toxin and/or biochemical warfare agent, or
other war zone environmental exposures.
k. General alienation from society, interrupted developmental tasks and milestones, social
withdrawal, or over -dependency resulting from war related experiences
1. job and career counseling for veteran CLIENTs (but not job training, skills development or
placement services).
m. Substance abuse counseling when the underlying abuse is related to PTSD or other trauma
experiences;
n. When family members suffer from the immediate or transgenerational impact of the veteran's
war or military related behavior.
o. The special needs of veterans who were exposed to sexual trauma, harassiment or abuse-
p. Also, those instances of sexual harassment and physical and psychological abuse where
gender or race is an issue.
q. Activities related to the official Memorandum of Understanding (MOLD) between CVS, the
WAANG, and all other signatories. This includes services to returning WAANG members and
their families, as scheduled and offered by the department at National Guard Armories and
other locations around the state.
r. Community education activities including the following:
Case consultation provided to any qualified treatment professional who is licensed to practice
within Washington State in one of the mental health professions and who seeks consultation
support regarding a given veteran. This is not. to include supervision unless arranged in
aGCVSnce, and only when the CONTRACTOR is fully credentialed to offer these services.
Educational Services to community agencies, community schools, or to centers of higher
education may be offered with approval by the Grant County Director of Veterans Services.
These services must be connected to the promotion of healthier communities,. improvement of
veteran services, or be aimed at the potential of creating additional providers who will serve the
trauma needs of veterans and their families.
Professional service support is encouraged when community and state events have been
designed to promote the welfare and quality of life of veterans and their families.
s. Services to veterans who are seeking an education and would benefit from counseling
services support with respect to war trauma, homecoming, and readjustment for military service.
These services are designed to help the
GCVS Contract No. 02-2026
Page 6 of 15
veterans make the best academic adjustment possible following exposure to war.
t. Outreach to institutions such as schools when school aged children of war veterans are in
attendance. Services may include outreach, in-service training events to the school staff,
classroom observation, consultation to teachers and counselors,. assessment of a specific child,
counseling treatment of the child and parents, and other services that may be within the range
of expertise of the CONTRACTOR.
u. Consultation to employers who have identified staff or employees who are war veterans and
demonstrate difficulty adjusting to the workplace, to the dynamics of the work setting, or to -other
features of work that seem to be, at least in part, related to war exposure. Treatment service
priority is always to be given to those CLIENTS who clearly meet the diagnostic criteria for Post -
Traumatic Stress Disorder (PTSD) and Major or Mild Neurocognitive Disorder due to Traumatic
Brain Injury as defined in Diagnostic and Statistical Manual-V. However other symptoms,
developmental deficits, and other diagnoses may be observed when these problems can be
seen to emanate from, or have been exacerbated by, war and military experiences. The goal of
treatment is symptom management and improvement of overall functioning with an emphasis
toward post -traumatic. growth. This program does not espouse "cure" or imply that CLIENTs will
experience remission of all or any specific symptoms of PTS'D, Till or other psychological
problems and presenting concerns. The provision of the best treatment and/or treatment referral
available, are among the primary goals. Clients having ISM-V F Personality Disorders (645)
301.0 — 301.9 or characterological disorders and/or chroniclsevere and complex PTSD
conditions, should be helped to understand the likely persistence of these thinking, behavioral,
and emotional patterns. These clients should be assisted to address such conditions and learn
of the interactions of personality and traurna-oriented disorders. No CONTRACTOR. is
mandated to see a given CLIENT when it is apparent that the development of a treatment
relationship is not occurring. Efforts should be made to refer those CLIENTS who are not viewed
as benefiting from this program. This his includes CLIENTS who are not following treatment
recommendations, or are viewed as being inappropriate for outpatient care, or for whom no
progress can be seen or expected. To this end, each CONTRACTOR should develop a clear
definition and awareness of their professional expertise, scope of practice, and personal
professional capacity to manage CLIENTs with severe and complex issues. This freedom to
choose CLIENTS best suited to the CONTRACTOR'S ability and experience base is extended to
the treatment of sexually abused men and women. Male providers will want to be especially
aware of the circumstances of sexual abuse histories among women CLIENTS and veterans.
Special arrangements to see CLIENTs with this abuse history should be considered carefully
and arrangements made to best address the treatment setting requirements. If these cannot be
arranged, it may be best to consider other treatment settings or other provider arrangements
where both CLIENT and provider can be offered a sense of security.
While no means test is applied within this program, the CONTRACTOR is encouraged to
consider the program as one that attempts to address the needs of veterans with the fewest
resources. The CONTRACTOR should consider all reimbursement options open to the CLIENT
including VAMC-NVCC (fee service) or TriWest-Choice Programs, VA ChoiceNA Mission Act
since these programs have changed significantly over the past
GCVS Contract No. 02-2026
Page 7 of 15
few years and now offer funding support that, exceeds previous levels of care and more open
criteria of eligibility.
2. VA Medical Center
CONTRACTOR is expected to encourage veterans to access VA Medical Center facilities for
medical and psychiatric Care when this is clinically indicated. In addition, CONTRACTOR may
be able to obtain VA mental health Non -VA. Contracted Services to cover the costs of outpatient
care when the veteran has a service -connected disability. Any veteran with a service connection
for any mental health disorder should be considered for this support.
3. Medical Consultant
CONTRACTOR shall not provide medication and/or physical or psychiatric (MD or A NP
examinations as billed components of this Contract. However, CONTRACTOR shall maintain a
consulting and referral relationship with an individual or agency with admitting privileges to
emergency psychiatric hospital care .and psychotro0i c. rued i cation asses'sment/management.
This relationship and referrals for care will not result in any expectation of payment by the
CONTRACTOR or GCVS. The requirement for Medical Consultant is one that may include an
arrangement with a mental health agency or with a private psychiatrist who has admitting
privileqes at a local or regional hospital, and/or where in VA Medical Center services 'may result.
(Note: Frequently, this requirement may be satisfied by a working relationship. with one of the
VA Medical Centers in Washington or Oregon. If the CONTRACTOR should need assistance
creating this arrangement, the Program Director may assist.)
4. Health Status Form
CONTRACTOR shall collect sufficient health status and treatment history information to permit
effective counseling, treatment or referral. Questionnaires, surveys, forms, or other methods
employed to document this activity may be of the CONTRACTOR's own design. It is
acknowledged that some providers are concerned about giving a CLIENT the wrong "impression
about, services when medical histories are taken. However, the clinician/CONTRACTOR is
expected to make it clear to the CLIENT that medical historical information may h helpful in the
psychotherapy process or if a medical emergency occurs; however, the provider is not offering
medical treatment under this contract.
5. Progress Notes, Audit Tracking, CLIENT File Storage,, Security, and related issues
As per ethical and legal guidelines CONTRACTOR shall have in place a progress notation
method that includes: presenting problem(s), purpose or diagnosis; date and service provided; a
copy of all tests and evaluative reports prepared; notation and results of formal consults
including information obtained from other persons or agencies through a release of information;
progress notes reflecting ongoing treatment and current status; immediate treatment plan or
month treatment plan; type or modality of services rendered (either by CPT Code or described
by name — individual psychotherapy, group, family therapy, telehealth session, etc.), duration of
all sessions, general session content, and treatment plans. A clinical progress note form of
one's own design, or the GCVS PTSD Progress Note (CCVS Form 048A, a hard copy is
available from the Program Director), or like assessment will be used. Progress notes become
the most
GCVS Contract No. 02-2026
Page 8 of 15
direct method of knowing that a treatment event occurred, that treatment is progressing, and are
therefore part of the clinical and audit, trail assessment process. Some clinicians may choose to
assess and document at the end of each session. CONTRACTOR will have a CLIENT sign -in
form or CLIENT signed collaborative progress note kept within the individual CLIENT file or
chart. This is a method of meeting the standards of audit, and offers clear evidence that the
veteran or family member was seen on the date indicated. Use of collaborative progress notes
involve the CLIENT and the therapist together engaging in the focus of treatment and the
completion of the progress note. This approach creates the clinical progress note, treatment
process document., specifics of therapy and intervention, and creates evidence for the auditing
process. Examples of tools for collaborative progress notes have been given to all contractors,
and further training would be offered to any therapist who requests it. If for any clinical or other
legitimate reason process notes- for a specific CLIENT are not.kept for each session, and no
other progress notes are created, CLIENTs will be required to sign a. statement that declares
that he or she attended a treatment session for which there is a billing to GCVS. The Statement
or log -in form must reflect the date, type, and duration of each service provided. This document
will be filed in the CLIENT chart by date of service, thereby allowing ease of accountability for
services offered during audits. CONTRACTOR shall maintain a separate counseling file or chart
on each CLIENT seen as the, primary CLIENT, and a progress note entry will occur and will
coincide with billings for all services. This file will hold all entry data and intake forms,, eligibility
documentation (IDD 214), releases of informationl disclosure statements, mental health
professional limits of confidentiality, clinical treatment plans, and any other documents required
by state law or HIPAA. Group progress notes may be filed in a single group therapy chart so as
to be able to offer chart notes about the nature and process of a given group, however each
group note must identify each member present by case number only. The CLIENT -number is to
be used for all progress notes and for all billings. No CLIENT names are re ever to be employed in
the billing or intake process materials sent to the GCVS. This procedure will protect from
accidental disclosure the identity of other members of a group when notes are ever required to
be disclosed for whatever reason. A sign -in roster must be kept for each group session.
Individual, couple, family and group progress notes may be stored electronically in the
CONTRACTORS computer ter system. Access to these electronic files must be readily available to
GCVS staff for purposes of audit or when treatment is transferred to another care provider. Any
computer security access codes, keys, or safe locks that the CONTRACTOR employs to secure
the computer or computer system must be formally housed and secured, yet accessible by your
designated colleague or family member, so that in the event of the CONTRACTORs (your)
death or impairment, CLIENT files may be retrieved for purposes of adequate treatment and
transfer. Use of electronic progress notes does not relieve the CONTRACTOR from maintaining
other required CLIENT folders or charts that contain all required documents.
6. Progress Notes for Professional Consultation & Community Education Services
Community Education Services, described in CONTRACTOR Duties and said services, shall be
documented in a dedicated and labeled file or chart, not unlike a CLIENT chart or file. Along
with a copy of the 047C (Professional Consultation and Community Training Service Accounting
Form) the event for which the CONTRACTOR is billing will be
CVS contract No. 02- Q26
Page 9 of 15
identified by date, location, describing the community organization, topic, audience, number of
participants, and a description of the perceived outcome of the event. Once consultation has
been provided, a brief summary will be provided to include name of organization(s), participants,
and description of the consultation. if there are copies of the agenda ar program.. These
documents will be maintained in this dedicated file far audit purposes, and are not required for
billing only the completed 047C is attached to the A-19A (invoice).
In the instance of professional Consultation Services, document your efforts in much the same
manner as Community Education Services or CLIENT charting, but in this case simply list what
you did, for whom, ham' many hours, and how many people, and any other information you wish
to include in the consultation progress metes. if possible, submit an evaluation of the event.
Since both of these activities require prior notification and approval, when the CONTRACTOR.
calls or emails the Grant County Director of Veterans Services, details about, billing and
documentation can be reviewed in order to make certain the educational or consultation
event/activity is fully documented and billed successfully.
7. After -Hours Answering service
CONTRACTOR shall have in place an answer service or telephone message directing CLIENTS
to an after-hours crisis service. This may be a referral to a local crisis line or the local 9111
number. Also, callers should be offered an expectation of hover long they might expect to wait for
a return calf Once a message is left on a telephone answering service. if the CONTRACTOR IS
not, currently accepting new referrals, it is expected that the phone message_ reveals this fact.,
HOWERVER the CONTRACTOR must also encourage the caller to leave a message so that
you might return the ,call in an effort to discuss being placed on a waiting list or to .be considered
for referral to another provider. (Note. The GCVS is dedicated to the notion that the Counseling
and wellness Programs will not contribute to barriers to cane, the creation of the impression of
being rejected for consideration, or otherwise denied services or access to services and a warm
referro%)
8. veterans Eligibility
CONTRACTOR shall obtain a copy of the veteran's Form D D214, NGF-22, and Copy of Military
ID for their files and potential review by the grant. County Director of Veterans Services. Since
this is not always readily available to the veteran, the CONTRACTOR will assist the veteran to
complete a Standard Farm (SF) 1$0 in order to obtain a certified copy of the Form DD214 In
the case of family members seeping treatment without the veteran, an attempt by the
CONTRACTOR shall be made to obtain the veteran's Form DD214. Counseling services shall
not be denied veterans or family members who do not have Form DD21 . The family member
can briefly draft a statement describing the circumstances for the inability to retrieve
documentation and then offer a signature. if the veteran or family member has a certificate
reflecting discharge and honorable military service, for example a Certificate of Honorable
Discharge, this will act as a substitute for the DD 214 initially or permanently, depending upon
circumstances. If these forms or documents are not available, the CONTRACTOR. must contact
the GCVS for assistance to verify veteran status.
QCV S Contract No. 02-2026
Page 10, of 15
Veteran status must be verified within three (3) clinical visits with the CONTRACTOR. Payment
for services may not occur without verification of veteran status, or approval from the Grant
County Director of Veterans Services.
9. GGVS PTSD CLIENT U.st
CONTRACTOR shall maintain a complete listing of all GCVS PTSD Program CLIENTs, to
include name, address, and phone number. This list will be maintained in separate folder
a
labeled " CVS PTSD CLIENT List and kept inside the. file cabinet in the very front of the PTSD
Contract Program CLIENT charts. Provisions shall be developed for this list to become
p r
accessible to the Grant County Director of Veterans Services or a professional colleague of the
CONTRACTOR, in the event of an emergency or the CONTRACTORs death or incapacitation.
This list will be used solely for notification, crisis intervention with regard to the loss of the
provider, and timely referral of PTSD CLIENTs to alternative providers.
10. Research Requirement.
The OQ-45.2 will be administered and scored with client scores submitted to GCVS by
uploading the surveys to the War Trauma Portal. The, OQ 45.2 is administered at or near the
time of Intake, administered to all current clients on a quarterly basis (typically June, Sept,
December, March), and prior to termination, unless previously administered within four weeks
prior to termination. The general description of the research design, however, is that this study
is a, repeat-meas ures de ssessment (re -administrations
sign, and one that requires ongoing re-a
of the OQ 45.2) of the client's progress. The research paradigm requires a baseline measure,
and subsequent measures to assess changes in the client's objectively assessed condition. The
analysis of .data. can only be accomplished on clients with completed surveys at all intervals
being considered.
11. Employee, Staff, Assistants, Additional Counselor ' s
CONTRACTOR shall provide to the Program Director, the he names,, professional license,
professional liability insurance and resumes of all counselors employed by the CONTRACTOR
who will provide counseling services funded by this Contract. The CONTRACTOR will inform
the GCVS if a change of counselors occurs during the period of this Contract. The Program
Director must approve the addition of any new counselor/staff member appointed or hired by a
CONTRACTOR who will provide services under this contract. The PTSD Consultation and
advisory Team may review selections and may exercise the option of interviewing the
prospective counselor before the CONTRACTOR closes on a decision to add a provider to work
with veteran or family member CLIENTs. The purpose of this consideration is to ensure the
quality of treatment providers and services being provided under this Contract.
With respect to criminal background clearance, CONTRACTORS (Fully Licensed Providers) are
assumed to have been screened by the State Department of Health, P . rofessional License
Division.
12. Health Information Portability and Accountability Act (HIPAA)
CONTRACTOR shall comply with all applicable provisions of Public Law 104-191, the Health
Insurance Portability and Accountability Act (HIPAA). (See Exhibit C: Business Associate
Addendum.)
GCVS Contract No. 02-2026
Page 11 of 15
14. ADA
CONTRACTOR shall accommodate disabled veterans and adhere to the provisions of the
Americans with Disabilities Act (ADA).
15. Professional and Ethical Standards
CONTRACTOR and CONTRACTOR staff or assistants, providing direct service under this
Contract, must comply with all rules, guidelines, and ethics as set forth by the State of
Washington, Department of Health for fully licensed psychologist, licensed social worker,
licensed marriage & family therapist, or licensed mental health dounselor. Non -fully licensed
(unlicensed) providers will provide no services under this Contract (Cvs Policy number
5o0 oo establishes the qualifications for new CONTRACTORS}, unless the non -fully licensed
(unlicensed) staff is at a minimum registered as a counselor associate (LMHCA), and is being
supervised" by the CONTRACTOR, and explicitly covered under the CONTRACTOR's
professional liability insurance as such. It is expected that any non -fully licensed (unlicensed)
providers being supervised are working toward becoming fully licensed to provide services. A
rovi
photocopy of the license document will be uploaded annually* at the time of renewal through the
War Trauma Portal. Contracts cannot be renewed without current and up to date
documentation.
1.6. Provider and Client Surveys
Each CONTRACTOR shall complete a War Trauma Program Provider Survey on an annual
basis and must be uploaded to the War Trauma Portal.
Each CONTRACTOR shall administer to all clients on an annual basis the War Trauma
Program Client Survey. The survey shall be administered electronically or via paper and
uploaded to the WarTraum'a Portal.
B. TREATMENT PLANS
CONTRACTOR shall bomplete a Treatment Plan (OCVs Form 048A, revised) or a form of the
CONTRACTOR's design, for every CLIENT. This form shall be completed to the extent possible
within the first four sessions after intake, during treatment, and every 180 days thereafter. This
will be accomplished even if the CLIENT is seen intermittently; (Le., one visit during the six-
month period covered by the Treatment Plan). This requirement applies to all new and current
CLIENTs.
C. CULTURAL AND GENDER AWARENESS AND SENSITIVITY
CONTRACTOR shall be culturally and gender -orientation sensitive. Special attention is required
on the part of CONTRACTORs with regard to appropriate accommodation to the needs of
minority, women, cross gender, or transsexual CLIENT veterans. CONTRACTOR shall make
every effort to help CLIENTs obtain treatment that responds to the individual veteran's cultural,
gender, sexual orientation, and special trauma experience needs, such as military sexual
trauma (MST). Since sexual and physical abuses by and to members of the military are
frequently related to these issues, the special dynamics oaf these experiences should be
considered carefully. The GCVS, and the PTSD Program Consultation and Advisory Team
members are available in order to
GCVS Contract No. 02-2026
Page 12 of 15
maximize service effectiveness and to assist the CONTRACTOR in whatever way necessary in
these areas. It is important that the Program make every accommodation possible to assist, or
refer veterans having special needs related to culture and gender. If you are unable to provide
these services, as in the case of a male therapist working With a female veteran who was
sexually traumatized, the CONTRACTOR should make certain a referral is corn p*le'ted to an
appropriate provider. Again, coordinating this referral with the Program Director may be prudent.
Additionally, special funding offered through the VAIVIC MH Fee Services Department is
available for MST survivor veterans, and the CONTRACTOR should make every effort to use
these resources directly, or facilitate a referral to someone willing and able to connect through
this or other resource.
CONTRACTORs will also be assessed by means of a state developed and locally modified Risk
Management Tool. This procedure will help to consider the level of legal and practice risk that
exists for a given CONTRACTOR. While in no way perfect, the method does alert the Director
and CONTRACTOR to practice trends and will help create feedback to CONTRACTORS
regarding their practice and workload, .along with adjustments that may ac I t to reduce risk
Copies of the Risk Management Tool are distributed during training at the annual PT
Provider Conference, or will be provided upon request.
Following a site visit, the CONTRACTOR will be given feedback at the time of the visit.
If a finding requires the CONTRACTOR's attention, this will be addressed at the time of the site
visit, and a date for a follow-up site visit will be. established.
CONTRACTORs who now hold, or who obtain during the term of this Contract, a federal Vet
Center (RCS) Contract for Readjustment Counseling Services should anticipate the potential for
a jointly conducted fiscal and clinical audit by the US-GCVS RCS Vet Center and GCVS. In
anticipation of the potential of these joint audits, the CONTRACTOR will make certain the
identity of all CLIENTs and CLIENT services are clearly noted, making the audit trail, clear for
each funding resource and servicelbilling event.
CLIENTs may be shared within the GCVS PTSD Program and another funding source, (i.e.,
VAIVIC MH Non -VA Contracted Services or RCS, Vet Center Contract Program), since changes
in funding levels or clinical service restrictions in one program -or another may require the
CONTRACTOR to select one funding source over another. Duplicate billings for the same
service, however, are strictly prohibited.
F. Contractor Facilities
CONTRACTOR shall maintain the counseling office and immediate area in a high level of
repair. Charts and other material shall be filed at the end of the workday so as to maintain after
hours security and confidentiality. The office shall reflect a professional atmosphere at all times
and be clean and neat in appearance. Additionally, there must be appropriate waiting areas and
reasonable measures taken to ensure the comfort of the CLIENT and present a professional
atmosphere of the counseling setting. This includes adequate sound absorbing efforts to help
maintain CLIENT confidentiality. Exceptions to this standard are those outreach settings, which
are not typically used for ongoing or hour -by -hour CLIENT sessions, or remote, out -of -office
sites. One must always consider the CLIENT's needs and the needs required to maintain a
wholesome therapeutic relationship.
GCVS Contract No. 02-2026
Page 13 of 15
G. CONTRACTOR shall attend, at a minimum, two outreach events at one of five
incubator sites and collect name, email, phone number, zip code, branch of service, and
Mee enrolled In VA Health Care and discharge year, with everyone they have made contact
with h on a registration form. As part of an outreach event, CONTRACTOR may be asked to
provide suicide, gatekeeper and other veteran -related trainings (trainings will not exceed
90 minutes in length).
III, INVOICE AND ACCOUNTING RESPONSIBILITIES
A. Individual, Couples, and Family (GCVS 047A1) accounting forms shall specify the hours of
service to each CLIENT -by
-CLIENT number, date, hours and activity for i.ndividual or group
counseling services.
For Couples and Family Service billing using GCVS Form 047A.1 , CONTRACTOR shall
include the unique CLIENT number of the veteran served, and. theCLIENT numbers of family
members seen in the couples or family session. CONTRACTOR shall always list, all I family
members present for these types of treatment. Dates and hours of service are to be listed on
the line to the left of the first CLIENT number only. This will allow the program to account for
your services and numbers of unique individual CLIENTs seen.
B. Group (GCVS 047B) Accounting Forms, shall specify the hours of service to each CLIENT by
CLIENT number, date, hours and activity for individual or group counseling services.
CONTRACTOR shall limit billings for group sessions to a 'maximum of two hours per group,
unless special arrangements have been made in aGCVSnce with the Program-Prdgran Director.
Individual sessions are to be no more than one hour unless circumstances at intake or
emergency intervention services require more time. Couples' sessions should not exceed one
and one-half hours duration. Family sessions (those with parent(s) and children present) are to
be billed at no more than one and one-half hour duration. The exception to this guideline is
family therapy that takes place in the veteran f s residence, with family members present, which
may be billed as a two (2) hour duration session.
C. GQVS 047C (liar Trauma/PTSD Program GCVS Community Services Accounting Form)
shall be used to report Professional Consultation and Training services provided within
the community.
The 047C permits invoicing for billable professional activities. These activities must be approved
by the Program Director prior to the event or activity. CONTRACTORS providing these services
shall maintain an activity log and chart of all of these events describing the date, activity,
organization or group, and the outcome of the community event.
IV. TERMINATING A PTSD CONTRACT -
Contracting with the GCVS is not a right bestowed upon the CONTRACTOR, and is continued
only: 1) when it can be demonstrated that the services rendered are needed within a given
community; 2) when services are rendered in a professional, competent, effective, and ethical
manner; 3) when services represent the best interests of the target population(s); and 4) to the
extent that funding is available. Beyond the other provisions of this Contract regarding
Termination, Suspension, or Dismissal, the GCVS may exercise such termination options
whenever the CONTRACTOR'S work is found to be ethically impaired, professionally lacking,
be in violation of state or federal law, failed to
GCVS Contract No. 02-2026
Page 14 of 15
carry out the provisions of the Contract or whenever the Grant County Director of Veterans
Services finds that the CONTRACTOR'S services no longer meet the standards of this Contract
Program or the best interests of our veterans clientele.
Should the Contractor be terminated, in addition to the termination procedures contained within
the provisions of Attachment A, GT&Cs, and Attachment A, Statement of Work. CONTRACTOR
shall ensure the proper security, retention, referral of clientele in accordance with current
professional ethical and industry practices.
V. DUTIES OF GCVS
The GCVS shall provide the CONTRACTOR with specific forms to carry out the work under this
Contract, such as, A-1 9 invoice vouchers and GCVS Forms 047A, 047B$ 047C.
GCVS Contract No. 02-2026
ATTACHMENT C
BUSINESS ASSOCIATE AGREEMENT
THIS BUSINESS -ASSOCIATE AGREEMENT (""Agreement") is. entered into between
Grant County vet+eranrvice"'hovered Entity""), and Bates Counseling
Services, PLLC, 16271 Rd 9 NW., Quincy, WA 98848 ("Business Associate").
'i
RECITALS.
A. Covered Entity, including facilities/agencies owned and operated by Covered,
Entity, is designated as a "Covered Entity," as defined by the federal Health
Insurance Portability and Accountability Act of 1996 and its promulgating regulations,
CHIPAX), and as amended by the regulations promulgated pursuant to the Health,
Information Technology for Economic and Clinical Health Act ("HITE "").
B. Business Associate has an underlying business relationship ("Underlying
Contract"") with Covered Entity, in which Business Associate performs functions or
activities, or provides certain services, on behalf of Covered Entity.
C. In the course of providing such services, Business Associate may have access
to, receive from, maintain, transmit, create,, andlor receive on behalf of Covered
Entity, Protected Health Information (""PHI')..
D. Covered Entity and Business Associate intend to protect the privacy and provide
for the security of PHI disclosed to Business Associate pursuant to this Agreement
and in order to comply with HIPAA and its implementing regulations including the
Privacy Rule (defined below), the Security Rule (defined below) and the Breach
Notification Rule (defined below).
NOW, THEREFORE, in consideration of these recitals and the mutual promises
contained in this Agreement, and for other good and valuable consideration, the
receipt and sufficiency of which are hereby acknowledged, Covered Entity and
Business Associate, intending to be legally bound, agree as follows:
A. "Breach" shall have the meaning given to such term at 45 C.F.R. § 164-402.
B. "Breach Notification Rule"` shall mean the rule related to breach notification f o r
Unsecured Protected Health Information at 45 C.F.R. Parts 160 and 164.
C. "Electronic protected health information" or ("'EPHI"") shall have the same
meaning given to such terms under the Security Rule, including, but not limited to,
45 C.F.R. § 160.103 limited to the information created or received by Business
Associate from or on behalf of Covered Entity.
CVs Contract No. 02-2026
Page 2 of 8
D. "HIPAA Rules" shall mean the Privacy, Security, Breach Notification and
Enforcement Rules.
E. "Privacy Rule " shall mean the Standards for Privacy of Individually Identifiable
Health Information, codified at 45 C.F.R. Parts 160 and Part 164, Subparts A,andE.
F. "Protected Health Information" or "PHI'" .shall have the meaning given to such
phrase finder the Privacy and Security Rules a t 45 C.F.R. § 16 0 . 1 0 3 , limited to
the. information created or received by Business Associate from or on behalf of the
Covered Entity.
G. "Security Rule'" shall mean the Security Standards for the Protection of Electronic
Protected Health Information, codified at 45 C.F.R. § 164 Subparts A and C.
H. "Unsecured PHI" shall Piave the meaning given to such a phrase under the
Breach Notification Rule at 45 C.F.R. § 164.402.
1. Other terms used, ed, but not otherwise defined, in this Agreement shall have the
same meaning ning as those terms in the Privacy, Security or Breach Notification Rules
and the Underlying Contract. Where there is a conflict between meanings in either
this Agreement together with the Privacy, Security or Breach Notification Rules. and
the Underlying Contract, then the meanings in this Agreement together with the
Privacy, Security or Breach Notification Rules shill govern.
11. OBLIGATIONS OF THE PARTIES WITH RESPECT TO PHL
A. Obligations of Business Associate. Business Associate shall:
1. Not use or disclose PHI other than as permitted or required by this Agreement or
the Underlying Contract or as required by law;
2. Not use or disclose PHI in a manner that, would violate the Privacy Rule if done by
the Covered Entity, unless expressly permitted to do so pursuant to the Privacy Rule
and this Agreement, provided that if Business Associate carries out one or more of
Covered Entity's obligations under the Privacy Rule pursuant to the Underlying
Contract, Business Associate shall fully comply with the Privacy Rule requirements
that would apply to Covered Entity in the performing those obligations:
3. Use appropriate safeguards, and comply with the Security Rule at Subpart C of
45 CFR Part 164 with respect to EPHI, to prevent use or disclosure of PHI other
than as provided for b the Agreement;
4. Report to Covered Entity promptly, and in no case later than thirty (30) calendar
days of Business Associate's discovery, any use or disclosure of
GCVS Contract No. 02-2026
Page 3 of 8
PHI not provided for by the Agreement of which it becomes aware, any Breaches of Unsecured
PHI as required at 45 C. F.R. § 1.64.410, any security incident of which it becomes aware, or any
breach as such may be defined under relevant state data breach laws ("State Law Breach"),.
Any notice of a Breach or State Law Breach referenced in this section I I.A.4 will include the
results of the risk assessment in which Business Associate determined that there is more than a
low probability that the PHI has been compromised based on the required factors set forth in 45
C.F.R. § 164.402 if the Breach is discovered on or after September 23, 2013 and to theextent
n
possible, the identification of each individual whose Unsecured PHI has been, or is reasonably
believed by Business. Associate to have been accessed, acquired, used., or disclosed during
such Breach. Notwithstanding anything set forth in this Agreement or the .Underlying Contract
Business ..Associate shall be responsible for the. cost of the risk assessment and any reasonable
breach mitigation expenses and shall indemnify, defend and hold Covered Entity and its
officers, directors, affiliates, employees, agents, successors and assigns harmless, from and
against any and all losses,, claims, actions, demands, liabilities, damages, costs and expenses
(including costs, expenses incurred urred in notifying individuals, the media or government agencies
in connection therewith) and any judgments,. settlements, court 'Costs and reasonable attorneys,
fees actually incurred (collectively, "Breach Claims") arising from or r related to: (i) the Business
Associate's or any of its subcontractors' use or disclosure of PHI in violation of the terms of this
Agreement or applicable law, and
(ii) whether in oral, paper or electronic media, any HIPAA
Breach of unsecured PHI and/or State Law Breach caused by Business Associate or any of its
subcontractors. If Business Associate assumes the defense of a Breach Claim, Covered Entity
shall have the right, at its expense, to participate in the defense of such Breach Claim. Business
Associate shall not take any final action with respect to any Breach Claim without the prior
written consent of Covered Entity. To the extent permitted by law, Business Associate shall be
fully liable to Covered Entity for any acts, failures or omissions pf its agents and subcontractors
in n furnishing the services as if they were the Business Associate's, own acts, failures, or
omissions. Notwithstanding the preceding, the parties acknowledge and agree that this section.
constitutes notice by Business Associate to Covered Entity of the ongoing existence and
occurrence of attempted but unsuccessful security Incidents (as defined below) for which no
additional notice to Covered Entity shall be retluired- "Unsuccessful Security Incidents" shall
include, but not be limited to, pings (i.e., a request -response utility used to determine whether a
specific: Internet Protocol [IP] address or host exists or is accessible) and other broadcast
attacks on Business Associate's firewall, port scans, unsuccessful log -on attempts, denials of
service and any combination of the above, so long as no such incident results in unauthorized
acquisition, access, use or disclosure of Protected Health Information;
5. Make available PHI in a designated record set to Covered Entity in the form and format as
necessary to satisfy Covered Entity's obligations under
GCVS Contract No. 02-2026
Page 4 of 8
45 C.F.R. § 164.524 within ten (10) business days of receiving a request from Covered
Entity;
6. Provide access, at the request of Covered Entity, and in no case later than ten (10)
business days after such request, to PHI in a Designated Record Set, to Covered Entity
or, as directed by Covered Entity, to an Individual or third party designated by the
Individual, in the form or format requested if it is readily producible in such for - m or
format in order for the Covered Entity to meet., the requirements under the Privacy Rule;
7. Make any PHI contained in a Designated . .Record Set available to Covered Entity (or
an Individual as directed by Covered Entity) wi thin ten (10) business days of a r eq u es
t for p u r p o s e s of amendment per 45 C. F.R. §164.526. If an Individual request an
amendment of PHI directly from Business Associate or its Subcontractors, Business
Associate shall forward the request to covered
Entity as soon as possible and within
ten (10) business days;
8. Maintain and make available the Information required to provide an accounting of
disclosures to Covered Entity as necessary to satisfy Covered Entity's obligations under
45 C.F.R. § 164.528. If an accounting, of disclosures is requested by an 'individual
directly to Business Associate, the Business Associate will forward the request to
Covered Entity as soon as possible and within ten (10) business days;
9. To the extent the Business Associate is to carry out one or more of Covered Entity's
obligation(s) under Subpart E of 45 C.F.R. Part 164, comply with the requirements of
P
Subpart E that apply to Covered Entity in the performance of such obligation(s) and to
the extent any, such obligations involve disclosures of PHI to health plans, comply, with
the requirements of 45 C.F.R. § 164.522 regarding requested restrictions on health plan
disclosures;
10. Make its internal practices , books and records , including policies and procedures,
relating to the use and disclosure of PHI available to the Secretary of HHS and to
Covered Entity for purposes of determining Covered Entity's compliance with the HIPAA
Rules;
11. Use appropriate safeguards to prevent use or disclosure of PHI other than as
provided for by this Agreement.. Implement administrative, physical, and technical
safeguards that reasonably and appropriately protect the confidentiality, integrity, and
availability of EPH as required by the Security Rule. With respect to EPH9 Business
Associate shall comply with all applicable state laws governing information security
breaches;
12. Ensure that any agents and Subcontractors that create, receive, maintain, or
transmit PHI on behalf of Business Associate agree to the same restrictions and
conditions that apply through this Agreement to Business Associate with respect to such
information. Business Associate shall ensure
CVS Contract No, 02-2026
Page 5 of 8
that any agent or Subcontractor to whom Business Associate provides EPH i agrees to
implement reasonable and appropriate safeguards to protect EPHL
13. To the extent permitted by law, cooperate with Covered Entity to ensure that legal
process conforms with the applicable requirements of the HIPAA Rules, or, if necessary
in Covered Entity's opinion., take appropriate me assured to try to obtain a qualified
protective order to limit or prevent the disclosure of PHI in the event of the receipt of a
subpoena, court or administrative order or other discovery request.
B. Permitted Uses or Disclosures by Business Associate. Business Associate may use
or disclose PHI only:
1. As necessary to perform the electronic health record software services and related
support services, set forth in the Underlying Contract, provided that Business Associate
must be specifically authorized in writing by an authorized representative of Covered
Entity to use PHI to de-ident.ify the information in -accordance with 45 C.F.R. §
I 64.514(a)-(c);
2. For its own proper management and administration
3. As required by law;
4. Issues and disclosures and requests for PHI are consistent with Covered Entity's
minimum necessary policies and procedures;
5. In a manner that would not violate Subpart E of 45 C.F.R. Part 164 if done by
Covered. Entity, except that Business Associate may use PHI to carry out the legal
responsibilities of the Business Associate only if Business Associate obtains reasonable
assurances from the r person to whom the information is disclosed that the 'Information
willremain confidential and used or further disclosed only as required by law or for the
purposes for which it was disclosed to the person, and the person agrees to notify
Business Associate of arty 'instances of which it is aware in which the confidentiality of
the information has been breached; and
6. To provide data aggregation services. relating to the health care operations of
Covered Entity only if authorized to do so in the Underlying Contract.
C. Covered Entity Privacy Practices and Restrictions..
1. Covered Entity shall notify Business Associate of any limitation(s) in the notice of
privacy practices of Covered Entity under 45 C. F. R. § 164.520, to the extent that such
limitation may affect Business Associate's use or disclosure of PHI.
2. Covered Entity shall notify Business Associate of any changes in , or revocation of,
the permission by an individual to use or disclose his or her PHI, to the extent that such
changes may affect Business Associate's use or disclosure of PHI.
GCVS Contract No. 02W2026
Page 6. of 8
3. Covered Entity shall notify Business Associate of any restriction on the use or
disclosure of PHI that Covered Entity has agreed to or is required to abide by under 45
C.F.R. § 164.52.2, to the extent that such restriction may affect Business Associate's
use or disclosure of PHI.
Ill. TERM AND TERMINATION.
A. Term. This Agreement shall be effective as of the date set forth above and shall
continue until Business Associate ceases to per -form the services defined in 'the
Underlying Contract.
B. Termination for Cause. Covered Entity mayimmediately terminate this Agreement in
the event that Business Associate materially breaches any provision of this Agreement
or the Underlying Contract.
In its sole discretion, Covered Entity may permit Business Associate the opportunity to
cure or to take substantial steps to cure such material breach to Covered Entity's
satisfaction within thirty (30) days after receipt of written notice from Covered Entity.
C. Obligations of Business Associate upon Termination. Upon the expiration or
termination of this Agreement for any reason, Business Associate, with respect to PHI
received from Covered Entity, shall:
1. Retain only that PHI which is necessary for Business Associate to continue its proper
management and administration or to carry out its legal responsibilities;
2.. Return to Covered Entity or destroy all 'PHI in any form, including such 'Information in
possession of Business Associate's Subcontractors, and retain no copies, if it is feasible
to do so;
3. If return or destruction is not feasible, extend all protections, limitations and
restrictions. contained in this Agreement to Business Associate's use and/or disclosure
of any retained PHI, and to limit further uses and/or disclosures to only those purposes
that make the return or destruction of the PHI infeasible;
4. Not use or disclose PHI retained by Business Associate other than for the purposes
for which such PHI was retained and subject to the same condition set forth above in
conditions
section B under "Permitted Uses and Disclosures by Business Associate" which applied
prior to termination.
5. Return to Covered Entity or destroy the PHI retained by Business Associate when it
is no longer needed by Business Associate for its proper management and
administration or to carry out its legal responsibilities.
GCVS Contract No. 02-2026
Page 7 of
This provision and the breach reporting provisions in Section ILAA shall survive the
termination or expiratio-n of this Agreement a.nd/or any Underlying Contract.
Iv. MISCELLANEOUS.
A. Amendment. Amendments to this Agreement may be necessary to comply with
modifications to the HIPAA Rules. Covered Entity and Business Associate agree to use
good -faith efforts to develop and execute any amendments to this Agreement as may
be required for compliance with the HIPAA Rules. This Agreement may be amended or
modified only in writing signed by Covered Entity and Business Associate.
B. Severability. In the event any provision of this Agreement. is held to be unenforceable
for any reason, the unenforceability thereof shall not affect the remainder of the
Agreement, which shall remain in full force and effect and enforceable In accordance
with its terms.
0. Independent. Contractor. For the purpose of.its obligations under this Agreement,
Business Associate is an independent contractor of Covered Entity and shall not be
considered an agent of Covered Entity.
D. Limited Liability Exclusion. To the extent that Business Associate has limited its
liability under the terms of the Underlying Contract, whether with a maximum recovery
for direct damages or a disclaimer against any consequential, indirect, or punitive
damages, or other such limitations, all limitations shall exclude any damages to
Covered Entity arising from Business Associate's breach of its obligations relating to the
use and disclosure of PHI.
E. Equitable Remedies. Business Associate stipulates that its unauthorized use or
disclosure of PHI would cause -irreparable harm to Covered Entity, and in such event,
Covered Entity shall be entitled to institute proceedings in any court of competent
jurisdiction to obtain damages and injunctive relief.
F. Ownership of PHI. lender no circumstances shall Business Associate be deemed in
any request to be the owner of any PHI used or disclosed by or to Business Associate
by Covered Entity.
G. No Third -Par t y Beneficiaries. Nothing expressed or implied in this Agreement is
intended to confer, nor shall anything herein actually confer, upon any person other than
Covered Entity, Business Associate and, to the extent specified above, their respective
parent entities, subsidiaries, affiliates, facilities, insurers, employees, directors, officers,
subcontractors, agents or other members of their respective workforces, successors or
assigns, any rights, remedies, obligations, or liabilities whatsoever.
H. Waiver. No provision of this Agreement or any breach thereof shall be deemed
waived unless such waiver is in writing and signed by the party claimed to have waived
such provision or breach. No waiver of a breach shall constitute a waiver of or excuse
any different or subsequent breach.
GCVS Contract No. 02-2026
Page 8 of 8
1. Assignment. Neither Party may assign (whether by operation of law or otherwise) any
of its rights or delegate or subcontract any of its obligations under this Agreement
without the prior written consent of the other party. Notwithstanding the foregoing,
Covered Entity shall have the right to assign its rights and obligations hereunder to any
entity that is an affiliate or successor of Covered Entity, without the prior approval of
Business Associate.
J. Counterparts. This Agreement may be executed in multiple counterparts, each of
which will be deemed an original but all of which together will constitute one and the
same instrument. Facsimile or electronic signatures shall be treated as original
signatures.
K. Construction. This Agreement shall be construed as broadly as necessary to
implement and comply with the HIPAA Rules. Any ambiguity in this Agreement shall be
interpreted to permit compliance with the HIPAA Rules.
IN WITNESS WHEREOF, Covered Entity and
Business Associate have executed this
Agreement as of the date below.
BATES COUNSELING SERVICES, PLLC
Signaturb
Printed Name
Bates Counseling Services
Managing Partner
Dates
Grant County
Veterans Services
Rob Jones, Chair
Printed Name
Grant County Veterans
Services
Date
VETERANS ADVISORY BOARD
GRANT COUNTY
FROM: Veterans Advisory Board (VAB) June 13, 2025
Grant County
PO Box 37
Ephrata, WA 98823
TO: Grant County Commissioners
PO Box 37
Ephrata, WA 98823
RE: Recommendation for Contracting with Bates Counseling Services, PLLC.
Dear Honorable Commissioners,
Your VAB unanimously recommends that Veterans Services and Grant County enter into
agreement with Bates Counseling Services, PLLC (Bates).
Bates is currently under contract/agreement for services to Grant County with the Washington
Department of Veteran Affairs (WDVA) . This contract is grant funded and will expire on June 30,
2025. Veteran Services has been informed that due to fiscal reductions, beginning at the national
level and traveling down to the WDVA and counties, the grant will not be funded after the current
expiration date.
After discussion with the Veteran Services Director, Anthony Garcia, and detailed analysis of the
current Veteran Services Budget, the VAB believes and recommends funding Bates Counseling
Services, PLLC through December 31, 2025. The cost for this counseling would not exceed
$27,300.00 and would be funded with the Veterans Services funding without the need for a budget
extension. This one-on-one counseling provided to Veterans has become a valuable asset within
Grant County Veteran Services and is considered by us a necessary service.
Once again, this is a unanimous recommendation of your VAB, and we look forward to assisting
the Grant County Commissioners and all Veterans of Grant County in any way possible. If you
have any questions, please do not hesitate to contact either myself or Anthony Garcia.
Thank you for your consideration on this matter.
tktev6
Jerry T. Gingrich, Chair
Veterans Advisory Board (VAB)
Grant County