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ISO Comments Submitted to OMR
July 16, 2003

The second draft of the Office of Mental Retardation (OMR) bulletin on Intermediary Service Organizations (ISOs) was published in conjunction with Guidelines for Operating a Vendor Fiscal/Employer Agent and Agency with Choice Intermediary Service Organizations (ISOs). The documents were circulated for comments and PCPA responded in July.

Some aspects of the second draft were improved over the first. In PCPA’s May 2003 comments on the first draft, the Association stated that the proposed step of conducting a readiness review after a contract was signed was not appropriate. The current draft includes the proposed use of a readiness review by counties 30 days prior to the signing of a county contract.

Another area that may have changed from the first to second draft is the deletion of a reference to the need for ISOs to be “conflict free,” inferring now that organizations providing MR services and supports could choose to be ISOs. This is in conflict, however, with language in the Guidelines, which do reference a “conflict free” requirement without defining the term.

PCPA's comments to the second draft are available from this link.

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