STORAGE NAME: h0633e.HHS
DATE: 4/15/2025
1
FLORIDA HOUSE OF REPRESENTATIVES
BILL ANALYSIS
This bill analysis was prepared by nonpartisan committee staff and does not constitute an official statement of legislative intent.
BILL #: CS/CS/HB 633
TITLE: Behavioral Health Managing Entities
SPONSOR(S): Koster
COMPANION BILL: CS/SB 1354 (Trumbull)
LINKED BILLS: None
RELATED BILLS: None
Committee References
Human Services
17 Y, 0 N, As CS
Health Care Budget
14 Y, 0 N, As CS
Health & Human Services
20 Y, 0 N
SUMMARY
Effect of the Bill:
CS/CS/HB 633 requires managing entities (MEs) to submit data and information the Department of Children and
Families (DCF) in a specific electronic format to ensure interoperability and allow for analysis. The bill requires
DCF to conduct operational and financial audits addressing specific topics for each ME contract, and prepare and
submit a report of findings to the Governor and Legislature by December 1, 2025. The bill also specifies
performance measures for client outcomes that MEs must track and submit to DCF.
Fiscal or Economic Impact:
The bill will have a significant, negative, recurring and non-recurring fiscal impact on the DCF.
Contingent upon the bill’s passage, anticipated fiscal impacts incurred by DCF as a result of implementing the bill
will be addressed through the appropriations process and reflected in the General Appropriations Act.
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
ANALYSIS
EFFECT OF THE BILL:
Behavioral Health Services
Behavioral health managing entities (MEs) are contracted by the Department of Children and Families (DCF) to
plan, subcontract for, and coordinate safety-net mental health and substance use disorder services for individuals
who are uninsured or underinsured. There are seven managing entities across the state. MEs subcontract with
community providers, which serve clients directly. The bill establishes requirements for ME data submission and
its performance measures.
ME Submission of Data and Information to DCF
MEs provide data and information to facilitate DCF oversight of ME services. By contract, MEs currently must
submit this data and information electronically to DCF. CS/CS/HB 633 additionally specifies electronic reporting
formats and processes for this data and information to ensure interoperability and analysis.
When submitting information to DCF, the MEs must meet the following bill requirements:
Use of a standardized format for electronic data interchange that is used for health care claims processing.
Organization into discrete, machine-readable data elements that allow for efficient processing and
integration with other datasets;
Compliance with department-established protocols for data fields; JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
2
Compatibility with automated systems to enable the downloading, parsing, and combining of data with
other sources for analysis; and
Required validation checks to confirm adherence to the required data structure and format before
acceptance.
When submitting data DCF, the MEs must meet the following bill requirements:
A format that allows for accurate text recognition and data extraction, as specified by DCF, which may
include, Portable Document Format or machine-readable text files.
Accompanying metadata containing key information, such as:
o A descriptive and unique name for the document;
o The date the document is uploaded;
o A predefined classification indicating the nature or category of the document;
o Any relevant identifiers, such as application numbers, case numbers, or tracking codes, as
specified by DCF; and
o The name, contact information, and any other required identification number, such as a contract,
license or registration number of the person or organization submitting the document. (Section 1)
The bill does not specify any actions that DCF is to take using the data and information in this new electronic
format.
Managing Entity Audits
The bill requires DCF to contract biennially for operational and financial audits of each of the seven MEs, including:
Business practices, personnel, financial records, related parties, compensation, and other areas as
determined by DCF.
Services administered, the method of provider payment, expenditures, outcomes, and other information as
determined by DCF.
Referral patterns, including referral volume, referral assignments, services referred, length of time to
obtain services, and key referral performance measures.
Adequacy and participation in DCF’s available bed platform, the Opioid Data Management System, the
Agency for Health Care Administration Event Notification Service, and other DCF-required provider data
submissions.
Expenditures and claims, at a minimum, comparing services administered, outcomes, and expenditures for
behavioral health services for each ME and analyzing services funded by MEs rendered to individuals who
are Medicaid beneficiaries to, at a minimum, assess the extent to which MEs are funding services that are
also available as covered services under the Medicaid program. (Section 1)
DCF must prepare and submit a final report on the findings to the Governor, President of the Senate, and Speaker
of the House of Representatives by December 1, 2025. (Section 1)
Managing Entity Performance Measures
The bill requires MEs to submit data on specific performance measures to DCF regarding individual outcomes and
system functioning. The bill requires the measures to include data on individuals served by the ME, for services
funded by the ME, to the extent feasible and appropriate. The performance measures must be reported and posted
stratified by, at a minimum, whether the individual is a child or an adult and whether the individual is a Medicaid
recipient. Such measures must include, at a minimum, all of the following:
The number and percentage of high utilizers of crisis behavioral health services.
The number and percentage of individuals referred to outpatient behavioral health services after discharge
from mental receiving or treatment facilities or emergency departments or inpatient or residential licensed
service components who begin receiving services within 7 days after discharge. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
3
The average wait time for initial appointments for behavioral health services, by type of service.
The number and percentage of individuals with significant behavioral health symptoms seeking urgent but
non-crisis acute care who are scheduled to be seen within one business day of initial contact with a
provider.
The number and percentage of emergency department visits per capita for behavioral health-related
issues.
The incidence of medication errors.
The number and percentage of adverse incidents, including but not limited to, self-harm, occurring during
inpatient and outpatient behavioral health services.
The number and percentage of individuals with co-occurring conditions who receive integrated
care.
The number and percentage of individuals discharged from receiving or treatment facilities or inpatient or
residential licensed service components who successfully transition to ongoing services at the appropriate
level of care.
The rate of readmissions to emergency departments due to behavioral health issues or to crisis
stabilization units, addictions receiving facilities, or other inpatient levels of care within 30 days after
discharge from inpatient or outpatient behavioral health services.
The average length of stay for inpatient behavioral health services. (Section 1)
None are current performance measures, though similar measures to those in the bill on access timeframes are in
new ME contracts that begin July 1, 2025. Some others in the bill are tracked and reported to DCF, though not as
performance measures.
1
The bill requires MEs to report each measure using a standard methodology as determined by DCF and requires
DCF to establish a deadline for MEs to submit the required data. The bill also requires DCF to post the performance
measures on the agency’s website by the 22
nd day of each month. The measures must reflect performance for the
previous calendar month, including year-to-date totals, and annual performance trends. (Section 1)
DCF will need to amend the ME contracts and procure a vendor to assist with a redesign of its business processes
to accommodate these data submissions. DCF estimates that the estimated time to complete all these activities is
18 to 24 months.
2
The bill provides an effective date of July, 1, 2025. (Section 2)
RULEMAKING:
The bill will require DCF to revise certain administrative rules in Chapter 65E-14, F.A.C., the Office of Substance
Abuse and Mental Health Financial Rule. DCF will need to update over 20 administrative rules in total as
authorized by s. 394.9082(3), F.S.
3
Lawmaking is a legislative power; however, the Legislature may delegate a portion of such power to executive
branch agencies to create rules that have the force of law. To exercise this delegated power, an agency must
have a grant of rulemaking authority and a law to implement.
FISCAL OR ECONOMIC IMPACT:
STATE GOVERNMENT:
DCF indicates that the department will need:
1
DCF, Agency Analysis of HB 633, p. 6 (March 7, 2025), on file with the House Health Services Subcommittee.
2
Id. at 5.
3
Id. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
4
Data System Updates: $6.92 million non-recurring to replace DCF’s current data system, the Financial and
Services Accountability Management System, and meet all new data system requirements, and $3.9 million
recurring for maintenance and operation. The non-recurring cost includes:
o IT Contractors: data architects, developers, analysts, report developers) - $120/hour * 2,000 hours
each = $240,000 per FTE--$1,920,000
o Cloud Infrastructure & Security: Hosting, cloud storage, cybersecurity measures)--$800,000
o Business Advisory & Project Management: Oversight, requirement gathering, stakeholder
engagement, risk management--$1,500,000
o Training, OCM for MEs: Training managing entities on new processes, data formats, portal usage--
$700,000
o Upgrading ME Systems: Grants or funding assistance to help MEs modernize/replace legacy
systems to ensure interoperability--$1,000,000
o Additional Software, licensing: Integration with new portal, back-end application programming
interfaces, data ingestion, and partner credentialing--$1,000,000
Auditing services: $3 million to procure auditing services for the operational and financial audits of the
seven ME contracts.
4
The bill requires significant upgrades to the Financial and Services Accountability Management System. DCF will
use funding available under federal block grants in the Alcohol, Drug Abuse and Mental Health Trust Fund to cover
the $ 6.9 million non-recurring cost for data system updates. Post-implementation, DCF may submit a Legislative
Budget Request for the recurring $3.9 million for maintenance and operation of the data system in future years.
The only provision of the bill that would require a change to current business operations is the requirement of the
department to contract for biennial operational and financial audits of the seven Managing Entities. This results in
a recurring fiscal impact of $3,000,000.
5 This anticipated fiscal impact may be addressed through the
appropriations process and reflected in the General Appropriations Act. The House proposed budget for Fiscal Year
2025-2026 does not include an appropriation to fund the audits.
PRIVATE SECTOR:
MEs may experience a fiscal impact to upgrade systems and processes to collect and report required data and
information. This amount is indeterminate, but would be paid for out of the public funds DCF pays them under
their contracts.
RELEVANT INFORMATION
SUBJECT OVERVIEW:
Behavioral Health
Mental illness affects millions of people in the U.S. each year. It is estimated that more than one in five adults live
with a mental illness.
6 In 2023, approximately 22.8 percent of adults experienced mental illness.
7
4
Id at 7-9.
5
Id at 5.
6
National Institute of Mental Health (NIH), Mental Illness, https://www.nimh.nih.gov/health/statistics/mental-illness (last
visited March 31, 2025).
7
Substance Abuse and Mental Health Services Administration (SAMHSA), Key Substance Use and Mental Health Indicators in
the United States: Results from the 2023 National Survey on Drug Use and Health available at
https://www.samhsa.gov/data/sites/default/files/reports/rpt47095/National%20Report/National%20Report/2023-nsduh-
annual-national.pdf, (last visited March 31, 2025). JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
5
Approximately, 48.5 million people in the U.S. aged 12 and older had a substance use disorder in 2023.
8 The most
common substance use disorders in the U.S. are from the use of alcohol, tobacco, cannabis, stimulants,
hallucinogens, and opioids.
9
State Behavioral Health Services
Several agencies provide publicly-funded behavioral health services in Florida. For example, agencies such as the
Department of Education and the Department of Corrections provide behavioral health services ancillary to their
broader missions of education, and incarceration and rehabilitation, respectively. The Agency for Health Care
Administration provides behavioral health services as part of its primary charge to provide health care but
restricts services to those individuals who are eligible based on factors such as income, age, and disability.
However, the Department of Children and Families (DCF), responsible for safety-net behavioral health services,
serves all Floridians who are otherwise unable to obtain certain behavioral health services, based on priority
populations and the limitations of available funding. DCF administers a statewide system of safety-net services for
substance abuse and mental health (SAMH) prevention, treatment and recovery for children and adults meeting
eligibility requirements based on the nature of illness and inability to pay.
10 SAMH programs include a range of
prevention, acute interventions (e.g. crisis stabilization), residential treatment, transitional housing, outpatient
treatment, and recovery support services. Services are provided based upon state and federally-established
priority populations. DCF provides these services primarily through behavioral health managing entities (MEs).
11
Behavioral Health Managing Entities
In 2001, the Legislature authorized DCF to implement MEs as the management structure for the delivery of local
mental health and substance use disorder services.
12 The implementation of the ME system initially began on a
pilot basis and, in 2008, the Legislature authorized DCF to implement MEs statewide.
13 MEs were fully
implemented statewide in 2013, serving all geographic regions.
DCF currently contracts with seven MEs for behavioral health services throughout the state. These contracts
totaled $1.083 billion
14 in FY 2022-23, with $919 million spent on direct services.
15 MEs plan for and coordinate
the delivery of community mental health and substance use disorder services, improve access to care, promote
service continuity, purchase services, and support efficient and effective service delivery. MEs subcontract with
community providers to serve clients directly; this allows services to be tailored to the specific behavioral health
needs in the various regions of the state.
16
In FY 2022-23, in the aggregate, DCF reported serving 243,403 unduplicated behavioral health clients
17, including
through the MEs. Client counts for individuals served through some ME specialty programs included:
Mobile response teams (MRT): 28,394.
18
Care coordination: 4,701.
19
8
Id.
9
National Library of Medicine, Commonalities and Differences Across Substance Use Disorders: Phenomenological and
Epidemiological Aspects, available at https://pmc.ncbi.nlm.nih.gov/articles/PMC5096462/, (last visited March 31, 2025).
10
S. 394.674, F.S.
11
S. 394.9082, F.S.
12
Ch. 2001-191, Laws of Fla.
13
Ch. 2008-243, Laws of Fla.
14
DCF, A Comprehensive, Multi-Year Review of the Revenues, Expenditures, and Financial Positions of the Managing Entities
Including a System of Care Analysis, p. 5, available at https://myflfamilies.com/document/57451, (last visited March 31, 2025)
15
Id. at 11.
16
Department of Children and Families, Managing Entities, available at https://www.myflfamilies.com/services/
samh/provIders/managing-entities, (last visited March 31, 2025).
17
DCF, supra note 15, at 14.
18
Id. at 18.
19
Id. at 20. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
6
Family Intensive Teams (FIT): 1,581.
20
DCF contracts specify ME responsibilities based on requirements in Florida law. For example, MEs are responsible
for the system of care in their regions. MEs also must provide data and information to facilitate DCF oversight of
ME services.
Coordinated System of Care
MEs are required to promote the development and implementation of a coordinated system of care.
21 A
coordinated system of care means a full array of behavioral and related services in a region or community offered
by all service providers, participating either under contract with a ME or by another method of community
partnership or mutual agreement.
22 A community or region provides a coordinated system of care for those with a
mental illness or substance use disorder through a no-wrong-door model, to the extent allowed by available
resources.
There are several essential elements which comprise a coordinated system of care, including:
23
Community interventions;
Case management;
Care coordination;
Outpatient services;
Residential services;
Hospital inpatient care;
Aftercare and post-discharge services;
Medication assisted treatment and medication management; and
Recovery support.
A coordinated system of care must include, but is not limited to, the following array of services:
24
Prevention services;
Home-based services;
School-based services;
Family therapy;
Family support;
Respite services;
Outpatient treatment;
Crisis stabilization;
Therapeutic foster care;
Residential treatment;
Inpatient hospitalization;
Case management;
Services for victims of sex offenses;
Transitional services; and
Trauma-informed services for children who have suffered sexual exploitation.
Oversight and Accountability
20
Id. at 23.
21
S. 394.9082(5)(d), F.S.
22
S. 394.4573(1)(c), F.S.
23
S. 394.4573(2), F.S.
24
S. 394.495(4), F.S. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
7
DCF collects a wide variety of data and information to assess the performance of the MEs, such as about persons
served and their outcomes and costs of services provided through the contract.
25 One such document is a financial
and compliance audit, which pursuant to the contract, the MEs must submit the earlier of 180 days after the end of
the provider’s fiscal year or 30 days after the ME’s receipt of the audit report. MEs must submit these documents at
specific points and intervals. DCF specifies that documents required under contract be submitted electronically to
the DCF Contract Manager and also added to the MEs secure web-based document vault.
26
How DCF uses this data and information to assess and improve performance varies. For example, DCF negotiated
the following performance standards for MEs in the current contracts:
Monitoring of at least 20% of all network service providers each fiscal year.
Ensuring 100% of the cumulative annual network service provider expenses comply with the federal
block grant and maintenance of effort allocation standards.
Achieving 95% of the annual target levels for each of the network service provider measures, measured
across all ME providers, as listed below.
27
Target Population and Performance Measure Description
28 Target
Minimum
Acceptable
Performance
Adult Community Mental Health
MH003
Average annual days worked for pay for adults with severe and
persistent mental illness
40 38
MH703
Percent of adults with serious mental illness who are competitively
employed
24% 22.8%
MH742
Percent of adults with severe and persistent mental illnesses who
live in stable housing environment
90% 85.5%
MH743
Percent of adults in forensic involvement who live in stable
housing environment
67% 63.7%
MH744
Percent of adults in mental health crisis who live in stable housing
environment
86% 81.7%
Adult Substance Abuse
SA753
Percentage change in clients who are employed from admission to
discharge
10% 9.5%
SA754
Percent change in the number of adults arrested 30 days prior to
admission versus 30 days prior to discharge
15% 14.3%
SA755
Percent of adults who successfully complete substance abuse
treatment services
51% 48.5%
SA756
Percent of adults with substance abuse who live in a stable housing
environment at the time of discharge
94% 89.3%
Children’s Mental Health
MH012
Percent of school days seriously emotionally disturbed (SED)
children attended
86% 81.7%
MH377
Percent of children with emotional disturbances (ED) who
improve their level of functioning
64% 60.8%
25
Department of Children and Families, Managing Entities FY24-25 Templates, EXHIBIT C3 – ME Required Reports, Plans, and
Functional Tasks, https://www.myflfamilies.com/services/samh/providers/managing-entities/managing-entities-fy24-25-
templates (accessed March 31, 2025). Examples of required reports are the Network Service Provider Monitoring Plan,
Managing Entity Monthly Expenditure Report, and the Monthly Data Submission to SAMH Data System.
26
Id.
27
Department of Children and Families, Managing Entities FY24-25 Templates, Exhibit E,
https://www.myflfamilies.com/services/samh/providers/managing-entities/managing-entities-fy24-25-templates (accessed
March 31, 2025).
28
Id. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
8
Target Population and Performance Measure Description
28 Target
Minimum
Acceptable
Performance
MH378
Percent of children with serious emotional disturbances (SED)
who improve their level of functioning
65% 61.8%
MH778
Percent of children with emotional disturbance (ED) who live in a
stable housing environment
95% 90.3%
MH779
Percent of children with serious emotional disturbance (SED) who
live in a stable housing environment
93% 88.4%
MH780
Percent of children at risk of emotional disturbance (ED) who live
in a stable housing environment
96% 91.2%
Children’s Substance Abuse
SA725
Percent of children who successfully complete substance abuse
treatment services
48% 45.6%
SA751
Percent change in the number of children arrested 30 days prior to
admission versus 30 days prior to discharge
20% 19.0%
SA752
Percent of children with substance abuse who live in a stable
housing environment at the time of discharge
93% 88.4%
DCF has set additional performance measures for specific services, such as outcomes for participants in FIT and
Community Action Treatment (CAT) teams.
29
If the ME fails to meet the contract requirements, the contract specifies that “corrective action may be required for
noncompliance, nonperformance, or unacceptable performance under this contract. Financial consequences may
be imposed for failure to implement or to make acceptable progress on such corrective action.”
30 The contract
does not include specific dollar amounts for financial penalties.
All ME contracts expire on June 30, 2025. The contracts have been reprocured, and the same seven providers were
awarded the new ME contracts.
31 DCF reports that the new contracts include additional performance measures and
financial penalties, such as regarding timely access:
Performance Measure Description
Minimum Acceptable Performance
Effective
7/1/2025
Effective
7/1/2027
Effective
7/1/2029
Appointments for urgent services (services needed to preclude
a crisis) provided within 48 hours of a request.
70% 80% 90%
Appointments for rapid intervention for children, families, or
individuals in distress or at risk for entry into foster care,
justice systems or more intensive services within 72 hours
from the date of a referral or request for assistance.
70% 80% 90%
Appointments for outpatient follow-up services provided
within 7 days after discharge from an inpatient or residential
setting.
70% 80% 90%
Appointments for initial assessment are provided within 14
days of a request for treatment.
70% 80% 90%
29
Id.
30
Id.
31
My Florida Marketplace, Advertisement Number: ITN-06623, Intent to Award,
https://vendor.myfloridamarketplace.com/search/bids/detail/6623 (accessed March 31, 2025). JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
9
DCF reports on ME performance specifically, and system performance more broadly, in three statutorily-required
annual reports. These are the:
Comprehensive, Multi-Year Review of the Revenues, Expenditures, and Financial Positions of the Managing
Entities Including a System of Care Analysis,
Assessment of Behavioral Health Services, and
Triennial Plan for the Delivery of Mental Health and Substance Abuse Services and updates.
Performance Information Reported for Safety-Net Mental Health Services under Federal Block Grant
Requirements
Under the federal Substance Abuse and Mental Health Services Administration’s requirements for the Community
Mental Health Services Block Grant, which funds a portion of the safety-net mental health services administered by
DCF, state mental health agencies like DCF compile and report annual data. Below are 2023 data reported by DCF
compared to national data, for a subset of outcomes on which DCF reported, for individuals DCF served
32:
Measure Florida U.S.
Percent of adults in labor force (employed) 41.9% 52.6%
Percent of children/families with improved social
connectedness
87.7% 88.0%
Percent of adults with improved social connectedness 86.9% 76.5%
Percent of children/families reporting positively about
general satisfaction with care
82.5% 87%
Percent of adults reporting positively about general
satisfaction with care
83.7% 88.6%
RECENT LEGISLATION:
YEAR BILL # HOUSE SPONSOR(S) SENATE SPONSOR OTHER INFORMATION
2023 HB 1095 Smith, Barnaby Rouson Died in House
2022 SB 2526 Health – Senate
Appropriations Committee
Passed (LOF 2022-150)
32
Substance Abuse and Mental Health Services Administration, Florida 2023 Mental Health National Outcome Measures
(NOMS): SAMHSA Uniform Reporting System, https://www.samhsa.gov/data/report/2023-uniform-reporting-system-urs-
table-florida (accessed March 31, 2025). JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
10
BILL HISTORY
COMMITTEE REFERENCE ACTION DATE
STAFF
DIRECTOR/
POLICY CHIEF
ANALYSIS
PREPARED BY
Human Services Subcommittee 17 Y, 0 N, As CS 3/18/2025 Mitz Curry
THE CHANGES ADOPTED BY THE
COMMITTEE:
Requires DCF to contract biennially for operational and financial audits for
each ME.
Revises the information that must be analyzed during the audits to require
an analysis to assess the extent to which MEs are funding services for
Medicaid beneficiaries that are covered under the Medicaid program.
Narrows the scope of documents that MEs must submit to DCF, requiring
the submission of all documents that are required under contact for
submission on a routine basis to be submitted to DCF.
Revises the performance measures for client outcomes that MEs must track
and submit to DCF to require MEs to submit specific measures for services
funded by MEs regarding individual outcomes and functioning.
Requires DCF to post the performance measures reported by the MEs to its
website by the 15
th of each month.
Requires MEs to report the measures using the reporting methodology
determined by DCF.
Health Care Budget Subcommittee 14 Y, 0 N, As CS 4/1/2025 Clark Smith
THE CHANGES ADOPTED BY THE
COMMITTEE:
Clarifies that MEs do not pay Medicaid costs for services.
Clarifies key datapoints that must be reported related to services paid for
by MEs.
Clarifies that monthly reporting by the MEs is to identify monthly, year-to-
date, and annual performance trends.
Changes the due date of monthly reports submitted by the MEs from the
15
th day to the 22
nd day of each month.
Specifies that the bill shall be implemented to the extent of available
appropriations contained in the General Appropriations Act for such
purpose.
Health & Human Services
Committee
20 Y, 0 N 4/15/2025 Calamas Curry
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THIS BILL ANALYSIS HAS BEEN UPDATED TO INCORPORATE ALL OF THE CHANGES DESCRIBED ABOVE.
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