From CARE DESIGN NY: HCBS Waiver Amendment Call: June 4, 2020

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CARE DESIGN NY

HCBS Waiver Amendment Call: June 4, 2020

  • This amendment to the HCBS waiver will be considered “Amendment 03”
  • OPWDD/DOH will make revisions to the authorities CMS has granted due to COVID 19 which will be considered Amendment 02
  • Proposed waiver amendment effective date Oct 1st, 2020
  • Appendix B: proposes that CM and DDRO signatures not required on Documentation of Choices form
  • Appendix C: Comm Hab Authorization – clarifies that all authorizations for Comm Hab are authorized by Regional Office
  • Removal of CCO consent form from LifePlan review
    • OPWDD proposing to remove this from the list of documents required for annual review
    • The form will continue to be required but won’t be included as part of the annual LP review documentation list
  • EMOD/VMOD: Appendix C and Addendum A
    • Clarification that service limits are per calendar year
  • 2% across the board cuts were proposed initially
  • Based on feedback, trying to pinpoint and target certain waiver rates to reduce rather than across the board
  • Targeted areas where services aren’t being directly provided including:
    • Occupancy factor
      • True vacant units that did not have a service associated with them over the course of time
    • Retainer day
      • A day in which someone is outside the residence but receiving inpatient Medicaid service
    • Therapeutic leave day
    • Not changing any unit calculations for retainer days but looking to propose a limit on the number of therapeutic leave days
    • Proposed waiver limits retainer and therapeutic to 50%
  • Occupancy adjustment for IRA
    • Individuals are not in the home
    • Bed is vacant
    • Appendix I and Addendum A of the waiver
  • Retainer days for IRAs
    • Reimbursed at 50% of provider’s established rate
    • Individuals are not in the home
    • Specific to times when individuals are in another Medicaid setting
    • Addendum A
  • Therapy Days
    • Originally had monthly unit of service which was equal to 22 days, allowing indiv to go home on the weekends, vacation etc.
    • This would go back to original intent and limit them to 96 days
    • Addendum A
  • Vacancy
    • Vacant days through the occupancy adjustment will cease on 9/30
    • Beds that do not belong to a specific individual
  • Last year tried to align OPWDD regions with DOH regions
    • Prevoc still had not been aligned
    • This proposes alignment
    • Appendix C and Addendum A
  • Self-Direction
    • Change to the IDGS grid on page 395
    • Clarification that service related transportation costs are included in the methodology cost of the service
    • Not an operational change, just making sure the waiver addresses current policy in this area
  • Provider Cost Report Deadline
    • Proposing more flexibility for the instances in which the Commissioner can determine when/where the provider may have issues meeting the CFR deadline
    • Appendix I Addendum A
  • Questions/Answers
    • Will the DDROs continue to conduct service auth for Comm Hab?
      • Yes
    • Is this review going to apply to all Comm Hab services or only those for self-direction?
      • At this point, guidance to DDRO is for services outside SD
    • Will providers get the occupancy adjustment for vacancy days through sept 30 2020?
      • Yes, survey for this sent out recently
    • Are retainer days still limited by certified capacity or be limited by per person basis?
      • Retainer day definition change that took place last July  – changed to capacity times 14 per rate year  – is still in effect
      • The definition change from last year does not change with this current amendment
    • Will the rate year continue to be July 1 through June 30 or will it change to Oct through Sept?
      • Two rate periods currently:
        • Jan-Dec
        • July-June
        • This will stay in effect
    • Will property reimbursements will be calculated different?
      • No, no change at this time
    • Therapy days  – will they be reimbursed at 50% of the rate for all therapy days or once the 96 day cap has been hit?
      • 2 step:
        • Right now they’re unlimited – high utilization
        • Two step process:
          • 96 day per person cap
          • All 96 per person per rate year will be reimbursed at 50% of the DOH calculated rate
    • What is the limit for retainer days?
      • Varies by provider
      • Used to be 14 pp per rate year
      • OPWDD wanted more flexibility – Donna was successful in getting federal approval for this
    • Will any of the changes discussed today affect SD re: self-hired staff?
      • No
    • Comm Hab review – will this be retro actively applied?
      • No – this is for new requests only
    • Is the transportation change only in relation to IDTS?
      • Yes
    • COVID-19 flexibilities will not be addressed today in this webinar – additional guidance will be released on the OPWDD webpage related to this
      • Because of the pandemic, there are emergency actions that affect the waiver but those are time limited
    • Changes for res hab/rate changes – what will be the base year for those rates?
      • Last amendment – redefined the base year to be a year in the four-year period of the State’s choosing (wasn’t prescribed)
      • The construct of what will be set as the base year is still undetermined
      • Two issues at play:
        • Higher costs for 2020 related to COVID
        • Could disproportionally impact providers due to staffing issues, loss in productivity, etc.
        • Don’t want to permanently memorialize based on pandemic challenges
        • Extended submission of costs reports via the Appendix K
    • Will the proposed changes to Comm Hab affect service deliver or service provision?
      • Don’t believe so; the changes are to make sure that the request coming into the DDRO are made consistently across the State
      • Ensure OPWDD has consistent decision-making process