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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. Have a question or want to share your perspective on the issues below? Please contact Kim Opsahl 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. Rate Restoration Implementation: As members are aware, the recently based State Budget included resources to restore key waiver rates and supervised group living rates that were reduced in 2010. On July 1st, it is anticipated that the following waiver services will be restored by 2.5%: • Facility Habilitation Individual • Community Habilitation Individual • Respite • Residential Habilitation and Support, Level 1 • Residential Habilitation and Support, Level 2 The remaining 2.5% restoration for these waiver services is slated to take place on July 1st, 2016. Initial notice for the July 1, 2015 waiver rate restoration was sent to providers and case managers, in advance of a planned conversion for the new rates. In addition, Supervised Group Living rates are anticipated to be restored by 1% on July 1, 2015. The Office of Medicaid Policy and Planning is working with Myers and Stauffer to update the rates to reflect the restoration. Waiver Re-Write and Residential Daily Rate Implementation: The Division of Disability and Rehabilitative Services continue to work on with the Centers for Medicare and Medicaid Services (CMS) on questions related to the Family Supports Waiver renewal, the Community Integration & Habilitation Waiver amendment, and their associated HCBS Settings Transition Plans. The Division responded to questions related to the RHS Daily Rate, Extended Services, Electronic Monitoring, and Pre-Vocational Services. While many of the responses have been submitted, the Division is waiting for additional clarification before finalizing their response. The RHS Daily Implementation Work Group presented a comprehensive status update on the RHS Daily Implementation activities. The presentation included suggestions on what providers and teams can be doing now to prepare. One key activity is checking the Advocare Provider Portal and ensuring the Algo and living arrangement is accurate and if not working with case managers to make corrections. The full presentation is located on the Member’s only website. Related to the HCBS Transition Plan, the Division hosted a presentation entitled “Planning for Indiana’s Future,” on April 28, 2015. At the presentation, DDRS along with their partners at the National Association of State Directors of Developmental Disabilities Services (NASDDDS) provided national perspectives for stakeholders of state service systems for people with intellectual and developmental disabilities. Following the presentation, the Division met with family, self-advocate, and provider representatives to identify perceived system strengths and challenges, as well as to discuss what type of system Indiana wants to be known as. Using this feedback, the Division has continued to work with NASDDDS to consider ways Indiana may need to change to improve service opportunities and access, while coming into compliance with the settings rule. These discussions helped form the basis of a statewide DDRS Provider Meeting, which focused on small group discussion around Residential Services and the HCBS Rule, Crisis, Family Supports, and Person-Centered Planning. Notes from these sessions will be published on the Division’s website and additional feedback will sought. Facility and Community-Based Employment Services: State wide training opportunities related to the Hybrid Model are underway and will continue through June. Dates and registration details were for this training were announced in late March. Please Note: Training participants are required to view an Overview: Employment Service Revisions available on IIDC’s website, prior to attending the training. Also, the Bureau of Rehabilitation Services recently posted its proposed Vocational Rehabilitation Services rule (460 IAC 14) and Notice of Public Hearing. Working with members, INARF developed comments in response to the rule. It appears the Bureau received a fair amount of constructive feedback, which is currently under review. The Bureau is also seeking comment on the newly developed Employment Services Manual. This manual is referenced in the written provider agreements that go into effect on July 1st. Comments are due by Friday, May 22nd. Working with members, INARF developed comments in response to the draft manual. Lastly, in partnership with the Indiana Institute on Disability and Community, the Bureau recently published video on Working with Vocational Rehabilitation. The video is a great tool to support individuals who may be interested and/or eligible for services in learning more about the program. The Division recently released a Request for Funding announcement seeking creative proposals from providers interested in exploring ways to support transition from facility to community based employment. Presentation slides, sign-in sheets, and questions/answers from the April 15th Pre-Proposal Conference were posted for reference. Proposals were due on May 7th. Ten proposals were received. June 24th is the target award date. From a National perspective, the U.S. Departments of Education and Labor released proposed rules to implement key provisions of the Workforce Investment and Opportunity Act (WIOA). The rules are available through June 15 for public comment. INARF plans to work closely with its partners at ACCSES and ANCOR to review the rule and formulate comments. We will share our proposed comments for member references before the June 15th deadline. The Proposed Rules cover the following areas: • EDUCATION: State Vocational Rehabilitation Services Program, State Supported Employment Services Program and Limitations on Use of Subminimum Wage • EDUCATION: Programs and Activities Authorized by the Adult Education and Family Literacy Act (Title II) • EDUCATION AND LABOR: Joint Rule for Unified and Combined State Plans, Performance Accountability and the One-Stop System • EDUCATION: Miscellaneous Program Changes Of interest, the Atlantic Weekly recently published an article looking at the various issues and concerns implicated in discussions of policy efforts to move away from facility based services. The article explores several aspects of the issue and its impact on individuals served, families, providers, and systems of support. Supervised Group Living: INARF recently reconvened its Supervised Group Living Advisory Work Group to review and discuss current issues. In terms of BDDS, the work group recognized that discharges and readmissions related to hospitalizations and/or rehabilitation stays have been going smoothly. They also recognized that the BDDS in general appears to be more responsive and moving in a positive direction. That being said, the Work Group identified concerns related to the following: • Ensuring transparency and collaboration on transitions to the waiver, • Clarifying the vacancy / referral process, including o Parameters for identifying a vacancy for referrals o Parameters for visits o Parameters for handling age differences o Honoring family requests / choice o Improving internal transitions o Clarifying roles and responsibilities of all parties, including instances involving multiple district offices o Clarifying frequency / need for transition checklist for physical structure o Ensuring current and accurate referral packets Overall, the group felt many of these issues could be addressed through policy development and training. To this end, the group plans to meet with BDDS Leadership to share these observations and discuss opportunities to collaborate on solutions. The group also discussed issues and concerns related to the survey process, including the impact of the recently released updated interpretative guidelines. Several similar themes were identified relative to increase consistency and common understanding of protocols and expectations. The group will work to connect with ISDH to discuss these observations, as well. Division of Disability and Rehabilitative Services HCBS Waiver Provider Manual: Earlier this month, the Division announced updates and corrections to the DDRS HCBS Waiver Provider Manual to address concerns related to updates published in February. Key changes were included in Section 6 to clarify how the residential allocation in the OBA example was developed using the current rate and the RHS hours identified in administrative code. The Division also included expanded guidance on the BMR and BRQ process, consistent with their recently published policies. INARF appreciates the Division’s efforts to clarify these matters in the re-published manual. Managed Care Notice of Public Rule Making: The Centers for Medicare and Medicaid Services recently published the pre-release of its long anticipated Notice of Public Rule Making for Managed Care. The official notice will be available on June 1st. According to the pre-release, the proposed rule is intended to: • modernize the Medicaid managed care regulations to reflect changes in the usage of managed care delivery systems. • align the rules governing Medicaid managed care with those of other major sources of coverage, including coverage through Qualified Health Plans and Medicare Advantage plans; implement statutory provisions; strengthen actuarial soundness payment provisions to promote the accountability of Medicaid managed care program rates; and promote the quality of care and strengthen efforts to reform delivery systems that serve Medicaid and CHIP beneficiaries • ensure appropriate beneficiary protections and enhance policies related to program integrity. • require states to establish comprehensive quality strategies for their Medicaid and CHIP programs regardless of how services are provided to beneficiaries. • implement provisions of the Children’s Health Insurance Program CMS-2390-P 2 Reauthorization Act of 2009 (CHIPRA) and addresses third party liability for trauma codes INARF plans to work closely with its partners at ACCSES and ANCOR to review the rule and formulate comments.