ARTICLE
As part of INARF’s continuing commitment to ensuring members are informed, we have compiled updates on key issues and activities in which the INARF Board of Directors, Governmental Affairs Committee, and Staff have been engaged in on your behalf (Members Only). Have a question or want to share your perspective on the issues below? Please contact either Christiaan Campbell or Keith Digman for assistance. Have an issue or concern that is impacting your business that is not listed in this update? Please let us know by clicking here. Healthy Indiana Plan 2.0: There is still no approval from CMS on the HIP 2.0 Waiver. Governor Pence recently stated that he is now in direct discussion with the Secretary of Health and Human Services. A recent article outlining the progress of negotiations cites the main concern for CMS is the requirement that HIP 2.0 members pay into the system. As a backup strategy, FSSA submitted a renewal request extending HIP 1.0 through 2015, which CMS approved in mid-November. Waiver Re-Write and Rate Reform Activities: Last month, two waiver renewals, Transition plans for the Family Supports and Community Integration and Habilitation Waivers, and the Statewide Transition Plan were released for public comment. INARF has provided comments on each, with the following highlights: Community Integration and Habilitation Waiver – A key item in the CIHW is the addition of a proposed Daily Rate for Residential Services. INARF has been actively involved in the development of this service over the past year, and completed discussions with DDRS over the past two weeks. The Daily Rate, if adopted, is anticipated to significantly reduce administrative burden for providers while adding more flexibility to residential service provision. There is some concern regarding a provision that limits recipients of the daily rate to ten hours of Community-Based Individual Habilitation (CHIO) to ten hours or less. While this may be acceptable in many cases, INARF recommends that this limitation should be exempted at times, in light of an individual’s unique circumstances. Examples of these exemptions may include, but are not limited to, situations where the same entity provides both day and residential services to the same individual, and when Community Habilitation – Individual is the primary service component of a day services program. A copy of INARF’s comments may be downloaded here. Family Supports Waiver - A new service definition, Extended Services, was proposed with the FSW, replacing Supported Employment Follow Along. A change in the scope of approved activities to allow for a much broader range in services will be beneficial to members. Of great concern, however, is that the draft service definition prohibits its use in tandem with Pre-Vocational Services. INARF recommended that this prohibition be eliminated from the service definition, or at the very least, allowing a “grandfather clause” for those individuals currently utilizing both services. Also of note are changes to medication error reporting that narrows the range of reportable incidents to those deemed harmful to the health and welfare of the individual, as determined by a physician. INARF endorsed this change, but asked that language throughout the waiver document be changed to be consistent with this new policy. A copy of INARF’s comments may be downloaded here. Transition Plans – Transition Plans to bring the state into compliance with the CMS Final Rule on Home and Community-Based Services were released for all waivers and for the State as a whole. INARF responded to the Transition Plans for both the CIHW and FSW in a single document, as the key elements in both were consistent. The Division focused its assessment process on the perceptions of individuals served instead of a direct service-by-service analysis using National Core Indicators (NCI) as a basis. INARF expressed support for this approach, and encouraged its continuation throughout the full assessment process. Of note is that in the first phase of assessment, the NCI results and a review of 90 Day Checklists were inconsistent in their determination of compliance. The Division also reviewed policies, the Indiana Administrative Code, and other internal documents to identify areas of non-compliance with the CMS Final Rule. The Indiana Institute on Disability and Community was engaged to perform the next stage of assessment through a consumer survey process. INARF endorsed this decision. A copy of INARF’s comments may be downloaded here. The State-Wide Transition Plan incorporated main points from all waiver transition plans. As these Plans will change over time as assessments determine levels of compliance, INARF recommended that the association and other stakeholders continue be an active part of the planning and execution of any changes to service delivery. A copy of INARF’s comments may be downloaded here. Representatives from the Shared Living Work Group met with DDRS to present their proposal for an updated service definition. The proposal was well received, and is under review by BDDS. INARF Staff is working with member agencies to develop and analyze rates to propose to the State, including their potential impact on provider revenue and State spending. The group anticipates that the revised service definition will be included in a future Waiver Amendment submission. INARF member CMCOs have developed recommendations around the 90 day checklist and its process, as well as a case management service definition. These were reviewed with BDDS. The Work Group will continue efforts to draft a case management model proposal that, while being sustainable and person-centered, alleviates the administrative burden that is present in the current system. Finally, the Centers for Medicare and Medicaid Services (CMS) released two final documents as a part of its HCBS Settings Toolkit. These documents, “Exploratory Questions to Assist States in Assessment of Non-Residential Home and Community-Based Service (HCBS)/Settings” and ”HCBS Final Regulations 42 CRF Part 441: Questions and Answers Regarding Home and Community-Based Settings,” provide much-anticipated guidance on how to apply the Final Rule’s definition of Home and Community-Based Services to non-residential services. INARF has conducted a preliminary review, and it appears that, like Indiana’s approach to assessing HCBS settings, CMS has based compliance upon the individual served and their personal experience as it relates to service settings. Person-Centered Planning will be a primary mechanism to ensure consumer choice and the availability of community-based opportunities. INARF will continue to analyze these documents and will relay any pertinent information to the Membership. Facility and Community-Based Employment Services: INARF and several member agencies submitted comments on the proposed Hybrid Model in November. Most recommendations surrounded the need for an adequate reimbursement for hourly services to ensure sustainability. Many comments also emphasized the use of a single Employment Specialist throughout the service delivery process as critical to the model’s success. In a VR advisory council meeting early in December, several unresolved issues were identified by BRS that must be addressed prior to the anticipated July 1 roll-out of the model. A meeting between the VR Rate Reform Work Group and BRS is scheduled for December 18 to review stakeholder comments and to begin addressing the identified issues. A copy of INARF’s comments may be downloaded here. Indiana Protection and Advocacy Services (IPAS) is continuing to conduct surveys on facility-based employment programs. Two surveys have been scheduled for this month. Cathy Wingard, Assistant Director, has offered to meet with INARF regarding the overall findings. It is unclear whether this will complete the survey process or if another round will be scheduled for 2015 or beyond. Supervised Group Living Work Group: Since the last Industry Update, there have been no SGL Work Group Meetings. The ESN Work Group continues to meet with the Division to improve processes for transitioning in and out of the program. During the last meeting, the group reviewed feedback on policies and procedures for BDDS staff and reviewed proposed training components for BDDS and Case Management staff. Managed Care Study: Hoosier Care Connect, Indiana’s replacement for the Care Select Program, is anticipated to launch in the spring. Anthem, MDWise, and MHS were selected as vendors for the new managed care product. Although FSSA anticipates enrollment of approximately 84,000 individuals in the first year of the program, most individuals served by INARF members will not be impacted, as HCBS Recipients and ICFIDD Residents are specifically excluded. Gap Analysis Project: FSSA held a meeting with key legislators to review the findings and recommendations from the gap analysis. As shared earlier, the recommendations include a focus on training for all system stakeholders to increase competencies in serving this population. The recommendations also include developing a pilot-based on a systems point-of-entry concept that includes a mix of crisis response, system navigation, and other coordination activities. If the pilot moves forward it would be done through a competitive RFP process. Wellness Coordination: Wellness Coordination was selected by the INARF Membership Support and Development Committee (MSDC) as a primary area of need. A Work Group, which will include BDDS staff, is being developed to address inconsistencies in service provision and to provide clarity in service guidelines. Quality Improvement Initiative: INARF’s “System of Excellence” Program has been identified as a primary area of member need by the MSDC. With the dissolution of the Industry Infrastructure and the Innovation/Systems Change Committees, all activities for the project have been shifted to a Work Group that is in development. A follow-up meeting in January will determine deliverables and recommendations for Work Group volunteers.