HomeMy WebLinkAbout20051111.tiff RESOLUTION
RE: APPROVE CHILD PROTECTION AGREEMENT FOR SERVICES AND AUTHORIZE
CHAIR TO SIGN - CHILDSAFE
WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to
Colorado statute and the Weld County Home Rule Charter, is vested with the authority of
administering the affairs of Weld County, Colorado, and
WHEREAS,the Board has been presented with a Child Protection Agreement for Services
between the County of Weld, State of Colorado, by and through the Board of County
Commissioners of Weld County, on behalf of the Department of Social Services, and ChildSafe,
commencing January 1,2005, and ending May 31,2005,with further terms and conditions being
as stated in said agreement, and
WHEREAS,after review,the Board deems it advisable to approve said agreement,a copy
of which is attached hereto and incorporated herein by reference.
NOW,THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County, Colorado, ex-officio Board of Social Services, that the Child Protection Agreement for
Services between the County of Weld, State of Colorado, by and through the Board of County
Commissioners of Weld County,on behalf of the Department of Social Services,and ChildSafe be,
and hereby is, approved.
BE IT FURTHER RESOLVED by the Board that the Chair be,and hereby is,authorized to
sign said agreement.
The above and foregoing Resolution was,on motion duly made and seconded,adopted by
the following vote on the 4th day of April, A.D., 2005, nunc pro tunc January 1, 2005.
BOARD OF COUNTY COMMISSIONERS
��� WELD COUNTY, COLORADO
� A '; >/' `�, ) /�� EXCUSED
William H. e, Chair
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, M. J. Geile, Pro-Tem
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Date of signature: 'yi-/LS--
2005-1111
SS0032
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DEPARTMENT OF SOCIAL SERVICES
P.O. BOX A
GREELEY, CO. 80632
Website:www.co.weld.co.us
Administration and Public Assistance(970)352-1551
Child Support(970)352-6933
VIIDc
COLORADO MEMORANDUM
TO: William H. Jerke, Chair Date: March 31, 2005
Board of County Commissioners
FR: Judy A. Griego, Director, Social Services rtt3 Ol-QGN
RE: Child Protection Agreement for Services Between the
Weld County Department of Social Services and
ChildSafe
Enclosed for Board approval is a Child Protection Agreement for Services between the Weld
County Department of Social Services (Department) and ChildSafe. This Amendment was
reviewed at the Board's Work Session of March 9, 2005.
The major provisions of the Agreement are as follows:
1. The term of the Agreement is January 1, 2005 through May 31, 2005.
2. The source of funding is Core Services funding.
3. ChildSafe will provide evaluation and outpatient therapy for sexual abuse victims and
their family members who are involved with the child welfare system.
4. The Department agrees to reimburse ChildSafe according to the fee schedule provided in
the Agreement with a provision that any evaluation cannot exceed$1,000 in total per
individual.
If you have any questions,please feel free to ask me.
-j
2005-1111
Contract No: 05-CORE-48 4f
CHILD PROTECTION AGREEMENT FOR SERVICES ��"j
BETWEEN THE WELD COUNTY DEPARTMENT OF SOCIAL SERVIdS AND CHILDSAFE Fj,11
This Agreement,made and entered into the day of March 2005,by and between the Board of Weld
County Commissioners, sitting as the Board of Social Services, on behalf of the Weld County Department of Social
Services,hereinafter referred to as"Social Services,"and CHILDSAFE,hereinafter referred to as"PROVIDER".
WITNESSETH
WHEREAS, required approval, clearance,and coordination have been accomplished from and with
appropriate agencies;and
WHEREAS,the Colorado Department of Human Services has provided Core Services funding to Social
Services for outpatient therapy for sexual abuse victims and their family members.
NOW THEREFORE,in consideration of the premises,the parties hereto covenant and agree as follows:
Tema
This Agreement shall become effective on January 1,2005 upon proper execution of this Agreement and
shall expire May 31,2005,unless sooner terminated as provided herein.
2. Scope of Services
Services shall be provided by the PROVIDER to any person(s)eligible for child protection services in
compliance with Exhibit A"Scope of Services,"a copy of which is attached by reference.
3. Payment
a. Payment shall be made on the basis of Exhibit B,"Payment Schedule." of which are attached
hereto and incorporated herein by reference.
"Payment Schedule"shall establish the maximum reimbursement,which will be paid from Core
Service funding during the duration of this Agreement.
b. The PROVIDER shall submit an itemized monthly bill to Social Services for all costs incurred and
services provided pursuant to Exhibit A of this Agreement in accordance with criteria established
by Social Services. The PROVIDER shall submit all itemized monthly billings to Social Services
no later than the twenty-fifth(25)day of the month following the month the cost was incurred.
c. Payments of costs incurred pursuant to this Agreement is expressly contingent upon the availability
of Core Service funds to Social Services.
d. Social Services shall not be billed for,and reimbursement shall not be made for time involved in
activities outside of those defined in Exhibit A. Work performed prior to the execution of this
Contract shall not be reimbursed or considered part of this Agreement.
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Contract No: 05-CORE-48
4. Financial Management
At all times from the effective date of this Contract until completion of this Contract, PROVIDER shall
comply with the administrative requirements,cost principles and other requirements set forth in the
Financial Management Manual adopted by the State of Colorado. The required annual audit of all funds
expended under Core Service funding must conform to the Single Audit Act of 1984 and OMB Circular A-
133.
5. Payment Method
Unless otherwise provided in the Scope of Services and Payment Schedule:
a. PROVIDER shall provide proper monthly invoices and itemization of services performed for costs
incurred in the performance of the agreement.
b. Social Services may withhold any payment if the PROVIDER has failed to comply with the
Financial Management Requirements,program objectives, contractual terms,or reporting
requirements. In the event of a forfeiture of reimbursements,PROVIDER may appeal such
circumstance to the Director of Social Services. The decision of the Director of Social Services
shall be final.
6. Assurances
PROVIDER shall abide by all assurances as set forth in the attached Exhibit C,which is attached hereto and
incorporated herein by reference.
7. Compliance with Applicable laws
At all times during the performance of this contract, PROVIDER shall strictly adhere to all applicable
federal and state laws, orders, and all applicable standards,regulations, interpretations or guidelines issued
pursuant thereto. This includes the protection of the confidentiality of all applicant/recipient records,
papers,documents,tapes and any other materials that have been or may hereafter be established which
relate to the Contract. PROVIDER acknowledges that the following laws are included:
Title VI of the Civil Rights Act of 1964,42 U.S.C. Sections 2000d—1 et seq and its implementing
regulation,45 C.F.R.Part 80 et seq• and
Section 504 of the Rehabilitation Act of 1973,29 U.S.C. Section 794,and
its implementing regulations,45 C.F.R.Part 84;and
the Age Discrimination Act of 1975,42 U.S.C. Sections 6101 et seq. and
its implementation regulations,45 C.F.R.Part 91;and
Title VII of the Civil Rights Act of 1964;and
the Age Discrimination in Employment Act of 1967;and
the Equal Pay Act of 1963;and
the Education Amendments of 1972;and
Immigration Reform and Control Act of 1986,P.L.99-603;
42 C.F.R.Part 2
and all regulations applicable to these laws prohibiting discrimination because of race,color,
National origin, and sex,religion and handicap, including Acquired Immune Deficiency Syndrome(AIDS)
or AIDS related conditions,covered under Section 504 of the Rehabilitation Act of 1973, as amended,cited
above. If necessary,PROVIDER and Social Services will resist in judicial proceedings any efforts to
obtain access to client records except as permitted by 42 CFR Part 2.
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Contract No: 05-CORE-48
Included is 45 C.F.R.Part 74 Appendix G 9, which requires that affirmative steps be taken to assure that
small and minority businesses are utilized,when possible, as sources of supplies, equipment, construction
and services. This assurance is given in consideration of and for the purpose of obtaining any and all
federal and/or state financial assistance.
Any person who feels that s/he has been discriminated against has the right to file a complaint either with
the Colorado Department of Human Services or with the U.S.Department of Health and Human Services,
Office for Civil Rights.
8. Certifications
PROVIDER certifies that, at the time of entering into this Contract, it has currently in effect all necessary
licenses, approvals,insurance,etc.required to properly provide the services and/or supplies covered by this
contract.
9. Monitoring and Evaluation
PROVIDER and Social Services agree that monitoring and evaluation of the performance of this Agreement
shall be conducted by PROVIDER and Social Services. The results of the monitoring and evaluation shall
be provided to the Board of Weld County Commissioners and PROVIDER.
PROVIDER shall permit Social Services,and any other duly authorized agent or governmental agency,to
monitor all activities conducted by PROVIDER pursuant to the terms of this Agreement. As the monitoring
agency may in its sole discretion deem necessary or appropriate,such program data, special analyses,on-
site checking, formal audit examinations,or any other reasonable procedures. All such monitoring shall be
performed in a manner that will not unduly interfere with agreement work.
10. Modification of Agreement
All modifications to this agreement shall be in writing and signed by both parties.
11. Remedies
The Director of Social Services or designee may exercise the following remedial actions should s/he find
PROVIDER substantially failed to satisfy the scope of work found in this Agreement. Substantial failure to
satisfy the scope of work shall be defined to mean incorrect or improper activities or inaction by
PROVIDER. These remedial actions are as follows:
a. Withhold payment to PROVIDER until the necessary services or corrections in performance are
satisfactorily completed;
b. Deny payment or recover reimbursement for those services or deliverables, which have not been
performed and which due to circumstances caused by PROVIDER cannot be performed or if
performed would be of no value to the Social Services. Denial of the amount of payment shall be
reasonably related to the amount of work or deliverables lost to Social Services;
c. Incorrect payment to PROVIDER due to omission,error,fraud,and/or defalcation shall be recovered
from PROVIDER by deduction from subsequent payments under this Agreement or other agreements
between Social Services and PROVIDER,or by Social Services as a debt due to Social Services or
otherwise as provided by law.
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Contract No: 05-CORE-48
12. Representatives
For the purpose of this Agreement,the individuals identified below are hereby designated representatives of
the respective parties. Either party may from time to time designate in writing a new or substitute
representative(s):
For Social Services:
Gloria Romansik Social Services Administrator
Name Title
For CHILDSAFE:
Kandy C Moore MS,LMFT Executive Director
Name Title
13. Notice
All notices required to be given by the parties hereunder shall be given by certified or registered mail to the
individuals at the addresses set forth below. Either party may from time to time designate in writing a
substitute person(s)or address to whom such notices shall be sent:
To: Social Services To: CHILDSAFE
Judy A Griego.Dirertor 1017 Robertson Street
P O Rox A Fort Collins,CO 80524
Greeley,CO 80692
14. I itig.tion
PROVIDER shall promptly notify Social Services in the event that PROVIDER learns of any actual
litigation in which it is a party defendant in a case that involves services provided under this Agreement.
PROVIDER,within five(5)calendar days after being served with a summons,complaint, or other pleading
which has been filed in any federal or state court or administrative agency, shall deliver copies of such
document(s)to the Social Services Director. The term"litigation" includes an assignment for the benefit of
creditors, and filings in bankruptcy,reorganization and/or foreclosure.
15. Termination
This Agreement may be terminated at any time by either party given thirty(30)days written notice and is
subject to the availability of funding. PROVIDER reserves the right to suspend services to clients if funding is
no longer available.
16. Entire Agreement
This Agreement,together with all attachments hereto, constitutes the entire understanding between the
parties with respect to the subject matter hereof, and may not be changed or modified except as stated in
Paragraph 10 herein.
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Contract No: 05-CORE-48
IN WITNESS WHEREOF,the parties hereto have duly executed the Agreement as of the day,month,and year first
above written.
, LiSaAit
'.. a f ,'p WELD COUNTY BOARD OF COUNTY
CLERK TO THE BOARD COMMISSIONERS W D
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O 1y: By: -�.6
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ep Clerk M. S. Geile, Chair ProAFR
pfl 4 2005.
D AS T . CHILDSAFE: (BY t / (t Ci(y:wiN/- CV----247-
C Attom y dy C.Mode,MS,L
Executive D ctor
WELD COUNTY DEPARTMENT
OF SOCIAL SERVICES
By:
Direct
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(065—fit/
Contract No: 05-CORE-48
EXHIBIT A
SCOPE OF SERVICES
The provider will provide the following services when requested in writing by the caseworker:
A. Referrals.
I. Referrals are made to Provider from Various community agencies including the Department of
Human Services,Larimer County Child Advocacy Center, Law Enforcement, Medical
Community, School Personnel,Mental Health Community,and through self-referral.
2. When a client calls into Provider,a call back will be made within 48 hours. At that point,
information and referral information will be given or an appointment will be made with either the
Executive Director or Clinical Director.
3. An intake session will take place with the parent or parents,where the client will have the
opportunity to discuss the facts of their case and any concerns they have for their child or
adolescent.
4. The Director will explain the treatment program and options for their family;paperwork will be
filled out and payment resources will be discussed.
5. A decision will be made jointly regarding how to proceed and the family will be told that Provider
therapists will contact them within a week.
6. The family will be asked to sign a Release of Information, which will enable Provider to begin a
dialogue with the other professionals involved with that case.
B. Treatment.
1. Provider is an outpatient treatment program for sexual abuse victims and their family members.
2. Services are in place to address the needs of all member so that family-the victim,non-offending
parents and/or guardians, and siblings.
3. Treatment plans are individualized depending upon the facts of the case, family composition,and
the desires of the family and system professionals.
4. Treatment of a family begins by assigning a therapist to each family member to begin individual
therapy. Individual treatment techniques used by Provider therapists include Cognitive-Behavioral
Therapy, EMDR,Play and Art Therapy,talk therapy, letter writing and journaling,confrontation,
support, criminal justice support,role playing and education. At this time we will also incorporate
group treatment for victims and non-offending parents.
5. Therapists at Provider engage in frequent case consultations in order to deliver coordinated
services for the family.
6. Families maybe involved in treatment for one to two years.
7. Frequency of sessions typically begins with weekly group and individual sessions,progressing to
less frequent individual sessions and the addition of dyad and family sessions.
8. For victims younger than age ten,individual Play Therapy is used in order to meet the needs of
young children. Play therapy sessions are typically weekly but may involve more frequent sessions
if the child's distress is extreme.
9. Parent consultation is done weekly as therapy progresses,parents often become directly involved
in their child's sessions.
C. Victim Clarification
1. When we have access to the perpetrator,we will coordinate with the sex offender
treatment provider in order to obtain a Clarification either in person or through written
correspondence. In the Clarification,the offender takes full responsibility for the victim's abuse
and outline exactly what he/she did to that child.
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• Contract No: 05-CORE-48
2. The offender then outlines the child's positive qualities and how he/she used those qualities to
coerce and manipulate the victim to comply with the abuse.
3. A typical Clarification takes many months to prepare for and complete.
4. If access to the offender is not accessible, a Victim Clarification for the child is prepared with the
help of the non-offending parents.
5. Non-offending parents are instructed in writing a Clarification letter to their child victims in whom
they take responsibility for their part in their child's abuse. The actual content of the letter will
depend upon the facts of the case and needs of the victim.
6. When families complete our program they are sent away with the assurance that we will be
available in the future to offer consultation and guidance as issues resurface months or years in the
future.
7. Provider offers a safe environment, staffed by highly qualified therapists in order to help families
navigate the often-devastating consequences of child sexual abuse.
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Contract No: 05-CORE-48
EXHIBIT B
PAYMENT SCHEDULE
1. Funding and Method of Payment
Social Services agrees to reimburse PROVIDER in consideration for the work and services performed
under Core Service funding.
Expenses incurred by PROVIDER, in association with said project prior to the term of this agreement,are
not eligible Social Services expenditures and shall not be reimbursed by Social Services.
Payment pursuant to this Contract, if Core Service funds,whether in whole or in part, is subject to and
contingent upon the continuing availability of Core Service funds for the purposes hereof. In the event that
said funds, or any part thereof,become unavailable as determined by Social Services, Social Services may
immediately terminate this Contract or amend it accordingly.
2. Fees for Services
Schedule of Fees Rate
Individual Therapy(therapeutic hour is 50 to 60 minutes) $100.00 per hour
Individual Therapy&Consultation $25.00 per 15 minutes
Offender Monthly Case Management $50.00 per 30 minutes
Group Therapy(60 to 90 minutes in length) $50.00 per group
Couples Group $50.00 per session per person
Chaperon Group $50.00 per session per person
Court Preparation&Testimony $100.00 per hour
Case Preparation,Reports,&Letters $25.00 per 15 minute period
Play Therapy Session $125.00 per hour
Child Victim Evaluation $700.00 per evaluation
Parent Child Interactional Evaluation $700.00 per evaluation
Children's Assessment $400.00 to$460.00 per evaluation
Psychological Test $100.00 per test
Parental Risk Assessment $600.00 per assessment
Psychosexual Evaluation(basic evaluation not including PPG) $600.00 to $800.00 per evaluation
PPG Assessment $200.00 per assessment
Polygraph Examination $225.00 per evaluation
Project for Healthy Adolescent Sexual Expression(PHASE) $285.00 per month
PHASE Parent Education Group $50.00 per group
All insurance statements will be billed at the rate and serviced indicated above.
Non-insurance bills can be discounted 5%for an individual bill paid to a"zero" balance at the time of
service.
On non-paid balances a 1'/z%per month or 18%annual fee will be assessed to your account.
Fees for any evaluation will not exceed$1,000.00 total
3. Submittal of Vouchers
PROVIDER shall prepare and submit monthly the itemized voucher and certify that the services authorized
were provided on the date indicated and the charges made were pursuant to the terms and conditions of
Exhibit A.
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Contract No: 05-CORE-48
EXHIBIT C
ASSURANCES
1. PROVIDER agrees it is an independent contractor and that its officers and employees do not become
employees of Weld County, nor are they entitled to any employee benefits as Weld County employees, as
the result of the execution of this Agreement.
2. Weld County, the Board of County Commissioners of Weld County, its officers and employees, shall not be
held liable for injuries or damages caused by any negligent acts or omissions of PROVIDER-contracted
PROVIDER's or its employees,volunteers,or agents while performing duties as described in this
Agreement. PROVIDER shall indemnify, defend,and hold harmless Weld County,the Board of County
Commissioners of Weld County, its employees,volunteers,and agents. PROVIDER shall provide adequate
liability and worker's compensation insurance for all its employees,volunteers, and agents engaged in the
performance of the Agreement upon request,PROVIDER shall provide Social Services with the acceptable
evidence that such coverage is in effect.
3. No portion of this Contract shall be deemed to constitute a waiver of any immunities the parties or their
officers or employees may possess,not shall any portion of this Agreement be deemed to have treated a
duty of care with respect to any persons not a party of this Agreement.
4. No portion of this Contract shall be deemed to create an obligation on the part of the County of Weld, State
of Colorado,to expend funds not otherwise appropriated in each succeeding year.
5. If any section, subsections,paragraph, sentence, clause, or phase of this Contract is for any reason held or
decided to be unconstitutional, such decision shall not affect the validity of the remaining portions. The
parties hereto declare that they would have entered into this Contract and each and every section,
subsection,paragraph,sentence,clause,and phrase thereof irrespective of the fact that any one or more
sections, subsections,paragraphs, sentences,clauses, or phrases might be declared to be unconstitutional or
invalid.
6. No officer,member or employee of Weld County and no member of their governing bodies shall have any
pecuniary interest,direct or indirect, in the approved Agreement or the proceeds thereof.
7. PROVIDER assures that they will comply with the Title VI of the Civil Rights Act of 1986 and that no
person shall,on the grounds of race, creed, color,sex, or national origin,be excluded from participation in,
be denied the benefits of, or be otherwise subjected to discrimination under this approved Contract.
8. PROVIDER assures that sufficient, auditable,and otherwise adequate records that will provide accurate,
current, separate, and complete disclosure of the status of the funds received under the Contract are
maintained for three(3)years or the completion and resolution of an audit. Such records shall be sufficient
to allow authorized local,Federal, and State auditors,and representatives to audit and monitor PROVIDER.
9. All such records, documents, communications,and other materials shall be the property of Social Services
and shall be maintained by PROVIDER, in a central location and custodian, in behalf of Social Services, for
a period of four(4)years from the date of final payment under this Contract,or for such further period as
may be necessary to resolve any matters which may be pending,or until an audit has been completed with
the following qualifications: If an audit by or on behalf of the federal and/or state government has begun
but is not completed at the end of the four(4)year period, or if audit findings have not been resolved after a
four(4)year period, the materials shall be retained until the resolution of the audit finding.
10. PROVIDER assures that authorized local, federal, and state auditors and representatives shall,during
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• Contract No: 05-CORE-48
business hours,have access to inspect any copy records,and shall be allowed to monitor and review
through on-site visits,all contract activities,supported with funds under this Contract to ensure compliance
with the terms of this Agreement. Contracting parties agree that monitoring and evaluation of the
performance of the Agreement shall be conducted by appropriate funding sources. The results of the
monitoring and evaluation activities shall be provided to the appropriate and interested parties.
11. This Contract shall be binding upon the parties hereto,their successors,heirs, legal representatives, and
assigns. PROVIDER or Social Services may not assign any of its rights or obligations hereunder without
the prior written consent of both parties.
12. PROVIDER certifies that federal appropriated funds have not been paid or will be paid,by or on behalf of
PROVIDER, to any person for influencing or attempting to influence an officer or employee of an agency,a
Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in
connection with the awarding of any Federal contract, the making of any federal grant,the making of any
federal loan,the entering into of any cooperative agreement,and the extension, continuation,renewal,
amendment,or modification of any Federal contract,loan, grant, or cooperative agreement.
13. PROVIDER assures that it will fully comply with all other applicable federal and state laws. PROVIDER
understands that the source of funds to be used under this Contract is Core Service funds.
14. PROVIDER assures and certifies that it and its principals:
a. Are not presently debarred, suspended,proposed for debarment, declared ineligible,or voluntarily
excluded from covered transaction by a federal department of agency.
b. Have not, within a three-year period of preceding this Agreement,been convicted of or had a civil
judgment rendered against them for commission of fraud or a criminal offense in connection with
obtaining,attempting to obtain,or performing a public(federal,state, or local)transaction or
contract under a public transaction;violation of federal or state antitrust statutes or commission of
embezzlement, theft,forgery,bribery,falsification or destruction of records, making false
statements,or receiving stolen property;
c. Are not presently indicted for or otherwise criminally or civilly charged by a government entity
(federal, state, or local)with commission of any of the offenses enumerated in paragraph 11(b)of
this certification; and
d. Have not,within a three-year period preceding this Contract,had one or more public transactions
(federal,state, and local)terminated for cause or default.
15. The Appearance of Conflict of Interest applies to the relationship of a contractor with Social Services when
the contractor also maintains a relationship with a third party and the two relationships are in opposition. In
order to create the appearance of a conflict of interest, it is not necessary for the contractor to gain from
knowledge of these opposing interests. It is only necessary that the contractor know that the two
relationships are in opposition.During the term of the Contract,PROVIDER shall not enter any third party
relationship that gives the appearance of creating a conflict of interest. Upon learning of an existing
appearance of a conflict of interest situation,PROVIDER shall submit to Social Services,a full disclosure
statement setting forth the details that create the appearance of a conflict of interest. Failure to promptly
submit a disclosure statement required by this paragraph shall constitute grounds for Social Services'
termination, for cause, of its contract with PROVIDER.
16. PROVIDER shall protect the confidentiality of all applicant records and other materials that are maintained
in accordance with this Contract. Except for purposes directly connected with the
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Contract No: 05-CORE-48
administration of Child Protection,no information about or obtained from any applicant/recipient in
possession of PROVIDER shall be disclosed in a form identifiable with the applicant/recipient or a
minor's parent or guardian unless in accordance with PROVIDER written policies governing access to,
duplication and dissemination of, all such information. PROVIDER shall advise its employees,agents,and
subcontractor, if any,that they are subject to these confidentiality requirements. PROVIDER shall provide
its employees,agents, and subcontractors, if any,with a copy or written explanation of these confidentiality
requirements before access to confidential data is permitted.
17. Proprietary information for the purposes of this contract is information relating to a party's research,
development,trade secrets,business affairs, internal operations and management procedures and those of its
customers, clients or affiliates,but does not include information(1) lawfully obtained from third parties, (2)
that which is in the public domain,or(3)that which is developed independently. Neither party shall use or
disclose directly or indirectly without prior written authorization any proprietary information concerning the
other party obtained as a result of this Contract. Any proprietary information removed from the State's site
by PROVIDER in the course of providing services under this Contract will be accorded at least the same
precautions as are employed by PROVIDER for similar information in the course of its own business.
18. PROVIDER certifies it will abide by Colorado Revised Statue(C.R.S.)26-6-104, requiring criminal
background record checks for all employees, contractors, and sub-contractors.
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