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. During the Legislative Session, INARF will update members on the top issues twice as often, releasing an Advocacy Update approximately every two weeks. Things move fast during the Session, and your INARF team will keep you informed every step of the way. 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. Waiver Re-Write and Residential Daily Rate Implementation: There is no new information on the status of the Family Supports and Community Integration & Habilitation Waiver submissions for CMS approval. Both were submitted at the end of December, 2014, and are under review by CMS. The RHS Daily Implementation Work Group has met several times with and without DDRS staff. Below is a comprehensive update of key decisions, on-going discussions, and related activities. At this time, the Division is moving forward with plans to begin converting to daily rates on April 1st, pending CMS approval. As we work through implementation, it is evident that there are a few key issues that may serve to complicate conversion. The first issue is ensuring accurate data relative to current living situation and number of individuals sharing staff. To address this concern, the Division has asked CMCOs to update / verify the living situation for all individuals on the CIHW within the next week. Once complete, the Division will analyze the impact of these verifications and make any necessary adjustments. As these adjustments are made, providers can anticipate the following: Prior to April 1, new Notice of Actions (NOAs) may be generated reflecting a change in allocation for individual’s whose allocation adjusts due to entering their accurate living situation. After April 1, new Notice of Actions (NOAs) will be issued that may reflect an OBA change for either RHS20 or the RHS Daily Rate. Those who met the criteria for the Daily Rate will have that service reflected on their NOA and those who did not may have an adjustment to their RH20 hours due to the recalculation of the OBA based on the living arrangement changes The second issue is the number of individuals in the Daily Rate eligible group who are currently utilizing days and BMAN at a level above the standard reserve amount based on their Algo, age, or other relevant factors. Because this group represents a more complicated set of issues and considerations, the Division is addressing this issue through a phased-in approach to implementation. What this means is that on April 1 (assuming CMS approval), the Division plans to auto-convert individuals who fall within the following criteria. Based on current estimates the Phase One group would include about 2,300 individuals as follows: • All individuals assessed as an Algo 3, 4, and 5s • Who Live with One or more Housemates and share RHS staff and who are not classified as living with family • Whose DAYS Reserve is at or below $10,500 for Algo 3 & 4 or $18,000 for Algo 5 • Whose BMAN Reserve is at or below 72 hours/year for Algo 3, 108 hours/year for Algo 4, or 144 hours/year for Algo 5 • And who are not attending school. The second phase of implementation would occur over the following three months (i.e. from April through June) and would involve all other individuals assessed as an Algo 3, 4, and 5s who live with one or more housemate and share RHS staff. As part of that implementation group, the Division intends to resolve those issues related to shifting resources from residential services and into DAYS or BMAN, as well as accommodating for extraordinary support needs. The daily rate is derived from two factors – the number of hours indicated by the individual’s Algo Level and Living Situation multiplied by the current hourly RHS20 rate. The full grid is listed below: RHS Daily Rates for the CIH Waiver and MFP-CIH Grant Service Description Nat'l Code Mod 1 Mod 2 Mod 3 Mod 4 Rate Unit Size ALGO Level People in Setting INsite Sub_Code RHS Daily Level 1 T2016 U7 U5 UN UA $155.29 1 Day 3 2 RD32 RHS Daily Level 2 T2016 U7 U5 UN UB $219.00 1 Day 4 2 RD42 RHS Daily Level 3 T2016 U7 U5 UN UC $238.92 1 Day 5 2 RD52 RHS Daily Level 4 T2016 U7 U5 UP UA $155.29 1 Day 3 3 RD33 RHS Daily Level 5 T2016 U7 U5 UP UB $201.09 1 Day 4 3 RD43 RHS Daily Level 6 T2016 U7 U5 UP UC $219.01 1 Day 5 3 RD53 RHS Daily Level 7 T2016 U7 U5 UQ UA $145.34 1 Day 3 4 RD34 RHS Daily Level 8 T2016 U7 U5 UQ UB $187.15 1 Day 4 4 RD44 RHS Daily Level 9 T2016 U7 U5 UQ UC $199.10 1 Day 5 4 RD54 In terms of other implementation issues, the current status is listed below: • Extraordinary Support Needs – the Division is still working on a process and methodology for providing additional fiscal support for temporary, extraordinary support needs (i.e. medical, behavioral, other factors). The current BMR process is based on adding additional hours in to the plan. With the switch to daily rate, another approach is needed. The Division requested feedback from Work Group members on what is needed to manage these periods, how existing services can be used in meeting this need, and when would additional resources be needed. • Loss of Housemate – the Division intends to publish a process that prescribes timelines and responsibilities for notifying, entering, and verifying changes in housemates/living situations by the provider and case manager(s). When entered timely, the individual’s plans will automatically adjust based on the above grid on the effective date of the vacancy. Individuals who move from a 2 person to a 1 person site will move to RHS20 at the default allocation. If more resources are needed, the team can seek a Budget Modification Review accompanied with a schedule of all non-RHS hours the individual is receiving and a plan for securing a new housemate. These procedures have not yet been vetted through the States process, once that process is complete the Division will publish these guidelines through the DDRS list serve and other mechanisms typically used for communication. As this strategy still relies heavily on the Budget Modification Process, INARF is proposing an alternative methodology using a standardized, supplemental rate based on the ALGO level of the person creating the vacancy. DDRS indicated they would review/consider the proposal and whether it would comport with the currently submitted CMS Waiver Amendment. • Individuals with an Other (i.e. Residential) Allocation that significantly exceeds the OBA Allocation will not be a part of the target daily rate group. • Existing BMRs – For individuals with a current BMR that convert on April 1, the existing BMR will end date upon conversion. If the need for the BMR persists, the team can request a new/continued BMR. • CHIO 10 hour Cap – On April 1, an edit will go into effect limiting RH Daily providers to providing no more than 10 hours/month of CHIO. The individual is not limited to this amount and may seek additional CHIO hours from other providers. That being said, INARF continues to emphasize the need to permit exceptions when the RHS and DAYS provider are the same provider and/or when CHIO is the primary component of the person’s day program. Post-conversion, the Division will have a process to make exceptions to this limitation. However, there is no systemic way to address potential exceptions as part of conversion. Healthy Indiana Plan 2.0: HIP2.0 continues its roll-out process. Earlier this week, the Family and Social Services Administration shared the following clarification about the enrollment process, especially when it comes to when HIP Plus coverage can start. “For members who automatically converted to HIP 2.0 from the former HIP program or from Hoosier Healthwise on February 1 – it is important to point out that coverage can begin for these members under HIP Plus much faster if they make their POWER account contribution. These members are currently considered “potential Plus” members. This means they are eligible to participate in the Plus program and enjoy the security of having better benefits like vision and dental coverage. They will also avoid costly and unpredictable copayments and pay only a low, predictable monthly contribution. They just need to make their first POWER account contribution, and coverage starts retroactive to the first of the month. If they don’t make their contribution, they’ll default to the HIP Basic program and will face copayments each time they receive care. For new members – HIP Plus is the pathway to immediate coverage. These Hoosiers have waited long enough for HIP 2.0 and, with your help in understanding how to enroll in HIP Plus, the best value coverage is available as soon as they are deemed eligible if they understand they should immediately start contributing to their POWER account. HIP Plus coverage is effective the first of the month in which the member’s first POWER account contribution is received and processed. This infographic found on the Helpful Tools page of our website gives a complete illustration of the entire application and enrollment process and explains how making an initial POWER account contribution provides faster access to coverage through HIP Plus. If you have any questions, please email them to HIP2.email@example.com.” Hoosier Care Connect: The Family and Social Services Administration (FSSA) will be holding multiple Hoosier Care Connect community meetings this month. The upcoming locations are in Fort Wayne and Bloomington. The FSSA plans to have the Bloomington meeting available for webcast, and will have login information coming soon. Representatives of the Indiana Family and Social Services Administration will be there, as well as representatives from Anthem, MDWise and MHS to answer questions and provide information. Hoosier Care Connect is a new coordinated care program which will serve a portion of Indiana Medicaid's aged, blind and disabled population. Enrollees will include children and adults eligible for Medicaid on the basis of age (65+), blindness or disability, who are not also enrolled in Medicare, do not reside in an institutional setting and are not enrolled in a home and community-based services (HCBS) waiver. Facility and Community-Based Employment Services: The VR Rate Reform Work Group continues to meet in preparation for the launch of the “Hybrid Model” on July 1. The Executive Briefing is set for Thursday, March 19th. The Briefing will be held at the Sheraton Hotel – Keystone at the Crossing with a webinar option for folks unable to attend in person. To register, please visit the INARF Event Calendar. Supervised Group Living: On March 26th, FSSA is holding a public hearing on their proposed rule to extend the current rate reductions for the ICFs/IDD and CRFs/DD. The hearing will be held at 9 a.m. at the Indiana Government Center South - Conference Center Room 5. INARF plans to offer public comment sharing our concerns with the proposed rule. FSSA Audit: INARF recently learned that FSSA Audit has developed its audit plan for 2015. The plan will include audits of Wellness Coordination and Behavior Management providers. Please note that while the plan indicates areas of focus for routine audits, it does not preclude audits related to complaints or other issues that might arise in the course of the year. North Willow Update: Over the past week, the Division of Disability and Rehabilitative Services made changes in the approach and staff support for this effort. As a result of these changes, providers should be seeing an increase in referrals. As you receive referrals, please be sure to respond quickly – within 24 hours if possible – with whether you are interested in considering the referral. Please note – referrals are being sent to multiple providers, so responding quickly is important. If you are not able to accept a referral, please share why – this information is helpful in better understanding your vacancy and in understanding the individual’s support needs. DDRS Staff Changes: INARF recently learned that the Bureau of Developmental Disability Services is making two key staff changes. The changes are related to the Division's overall effort to better align resources in order to support their major initiatives for the coming year. With this in mind, Julie Reynolds is moving into a new role where she will be responsible for supporting the Division’s efforts on major projects. Cathy Robinson will be moving over from First Steps to assume the BDDS Director position. The First Steps Director replacement has not yet been identified. IHCP DDRS HCBS Provider Manual: Last week, the Indiana Health Coverage Programs published an update the DDRS HCBS Provider Manual updating the sections describing the Objective Based Allocation. These changes removed the OBA service hours grid and inserted language from the Division’s OBA Assessment and Algo Development Guide (originally published in January 2014). It is our understanding that the Division will be making corrections to the manual both in terms of the incorrect rate information (as noted in Friday's bulletin) and other language included in the update. They intend to make conforming changes to the OBA Guide, as well.