OPWDD is sharing the FAQs from the December Webinars. Please see the Questions and Answers attached. Thank you to OPWDD for sharing the information!
FAQs from the December Transition Plan Webinars Now Available
On December 12, 2017 and December 14, 2017, the Office for People With Developmental Disabilities (OPWDD) in collaboration with the Department of Health (DOH) hosted two webinar sessions to provide stakeholders with an overview of the recently announced 1115 Waiver Transition Plan. This Transition Plan is open for public comment until January 5, 2018 prior to its submission to the federal Centers for Medicare and Medicaid Services (CMS). The Transition Plan describes how the services for people with developmental disabilities will move to New York State’s 1115 Waiver and the timelines and steps for initiating Care Coordination Organization/Health Home (CCO/HH) Services. The goal of the activities laid out in the Transition Plan is to help our system become more flexible and responsive to the needs of individuals and families.
This document provides responses to questions raised during the webinar sessions and is organized by topic area.
A copy of the draft Transition Plan is available for your reference at: https://www.health.ny.gov/health_care/medicaid/program/medicaid_health_homes/idd/draft_idd_1115_waiver.htm.
Response to Webinar Questions & Answers
Review of Application
1. During the webinar, references were made to attachments to the Transition Plan. Where can these attachments be found?
The attachments can be found at the end of the Draft Transition Plan document on pages 41-57. (See the link referenced above.)
2. Is the Draft Transition Plan available in Spanish?
The Draft Transition Plan is now being translated into Spanish, and an announcement will be sent when the translation is available.
3. Are self-advocates and parents of individuals with disabilities members of the advisory committees identified in the Transition Plan?
Yes, self-advocates and parents of individuals with disabilities are members and active participants of the advisory committees identified in the Transition Plan. These committees are listed on page 6 of the Draft Transition Plan. The link to the Joint Advisory Council (JAC), which is the main advisory body for OPWDD’s managed care development activities, can be found here: https://opwdd.ny.gov/opwdd_services_supports/people_first_waiver/opwdd-joint-advisory-council-managed-care.
4. What are the dates for the Medicaid Service Coordination (MSC) Information Sessions referenced in Attachment “C”?
The first session took place on December 13, 2017 and the second is scheduled for December 27, 2017 at 12 noon. Additional dates through January are scheduled; and registration for these sessions are available at: https://opwdd.ny.gov/opwdd_services_supports/care_coordination_organizations/msc_webinars. Following each session, the PowerPoints and recordings will be available at this link.
5. What is the federal authority for the two services, CCO/HH Care Management and the opt-out service, Home and Community Based Services (HCBS) Care Management?
CCO/HH Care Management will be authorized as a Medicaid State Plan Service. HCBS Care Management, the opt-out service, will be authorized under the 1115 Waiver for individuals who do not want comprehensive care management.
6. Will all approved CCO/HHs offer HCBS Care Management?
Yes, all approved CCOs will offer HCBS Care Management. The Transition Plan describes the process for individuals and families to learn about and select their preferred care management option in advance of the July 1, 2018 start date for CCO/HH operations.
7. Will the requirements of HCBS Care Management be the same as the current Plan of Care Support Services (PCSS) requirements?
The requirements of HCBS Care Management are similar to the current requirements for PCSS, including the four payments per year to the HCBS Care Management provider. The attachments in the Transition Plan outline the similarities and differences between CCO/HH services and HCBS Care Management.
8. How long will HCBS Care Management be available?
There is no established end date for the provision of HCBS Care Management.
9. If an individual chooses to receive HCBS Care Management, how will this affect the HCBS waiver services that the person self-directs?
Individuals who self-direct their HCBS Waiver services typically have extensive contact with their service coordinators to support the on-going function of the circle of support and the management of self-directed services. The HCBS Care Management option does not provide for the level of care management activity typically needed to effectively assist individuals who self-direct their services. The CCO/HH payment methodology recognizes this Care Manager workload by including self-direction in the weighting that establishes eligibility for CCO/HH payment tiers.
10. Will OPWDD cease to accept MSC enrollments in advance of the start of CCO/HH services?
No, for individuals wanting to enroll in MSC, OPWDD will continue to accept enrollments through June 2018. To ensure a smooth transition for individuals graduating in June, OPWDD will be working with the schools to encourage early identification of needed care management services. Part of the initiation of MSC services, beginning in spring 2018, will include the selection of the CCO/HH or HCBS Care Management for services effective July 2018.
11. Is there a caseload maximum or minimum based on tier?
Caseload levels are not linked to payment tiers except for the highest payment tier (tier 4). At tier 4, there is a limit of no more than 20 individuals per care manager. The State is generally providing Care Managers the flexibility to manage caseloads according to the individual’s needs. During the initial year of operation, the quality and individual and family satisfaction of the provision of CCO/HH services will be carefully assessed. The State will consider whether caseload requirements are necessary following year one of operation.
12. Can a Care Manager have a mixed tier caseload?
Yes, a mixed caseload is permitted; however, a Care Manager serving an individual in the highest tier (tier 4) must maintain a ratio that is no greater than 1:20.
13. Has the formula been developed to determine how individuals will fall among the tiers?
Yes, a formula was developed and is available in the CCO/HH Application: https://www.health.ny.gov/health_care/medicaid/program/medicaid_health_homes/idd/docs/hhidd_application_part_1.pdf.
An attachment to the Application explains the methodology for assigning individuals to the tiers. Assignment of the tiers is geared towards ensuring that the appropriate payment to the Care Manager is made; it does not diminish the quality of care management services that an individual receives.
14. When will the public know which CCO/HHs that MSC agencies and MSC coordinators have affiliated for that first year?
OPWDD and DOH are currently reviewing ten submitted CCO/HH applications. Each of these applicants were required to identify the MSC agencies with which they are affiliating. Based on a preliminary review, there is a high percentage of MCS agencies that have aligned with one of the ten applicants. As soon as the CCO/HH entities are designated, DOH and OPWDD will make public the MSC agencies that are affiliated with each CCO/HH.
15. What if there are not enough MSCs willing to become CCO/HH Care Managers?
There are significant investments being made in the CCO/HH fees, and OPWDD believes that the development of CCO/HH Care Management will provide advancement opportunities for today’s MSC service coordinators and attract new professionals to the field.
16. What happens if an individual cannot get in touch with his/her CCO/HH Care Manager, or is experiencing problems with his/her CCO/HH provider? Where can individuals go for assistance?
CCO/HHs are required to establish methods to assist individuals and/or family members who are concerned about the quality of service they receive. In the CCO/HH application, the potential CCO/HH was asked to describe its processes for ensuring that there is access to the Care Manager 24-hour a day, 7 days a week, if needed. Additionally, OPWDD Developmental Disabilities Regional Offices (DDROs) will continue to be available as a resource for individuals and families if they are experiencing problems with providers, as is the case today.
Phase II & III
Phase II & III are related to the transition to voluntary and mandatory managed care. As the State proceeds with the development of these phases, there will be additional opportunities for public input and comment. These opportunities include future publication of an updated Transition Plan, a Draft qualification document for I/DD Specialized Managed Care Plans, and Managed Care OPWDD Transition Policy & Related Guidance document. (See page 40 of the Transition Plan.)
17. Will there be a cap per person and, if so, how do services get decided?
Individuals, in partnership with their interdisciplinary teams, will identify the supports and services that will be received, based on individuals’ wants and needs, and included in their Life Plans (enhanced Individualized Service Plans (ISPs)). The I/DD Specialized Managed Care Plans will authorize services in accordance with State-approved policy guidance. There are no per-person expenditure limits although, as is the case today, some services may have expenditure limits (for example, environmental modifications).
18. What effect will enrollment in an I/DD Specialized Managed Care Plan have on a person’s services provided in an Individualized Residential Alternative (IRA)?
After enrollment in an I/DD Specialized Managed Care Plan, an IRA resident will remain eligible for Residential Habilitation (which is the service provided in an IRA), as long as he or she wants to receive the service and it is specified in his or her Life Plan.
19. How will people who have varied medical benefits types be affected by the transition to managed care? For example, many individuals with I/DD have dual Medicare/Medicaid coverage or job-based (third party) coverage for acute care services (e.g. hospitals, doctors, prescription drugs, etc.) and Medicaid that pays for their home and community based services and supports.
For individuals with Medicaid coverage only:
The I/DD Specialized Medicaid Managed Care Plan will offer a comprehensive Medicaid benefit package inclusive of acute care services and long term supports and services that includes important HCBS services.
For individuals with both Medicaid and Medicare coverage:
Individuals with I/DD who have both Medicare and Medicaid coverage will have the option to either:
Receive their Medicare acute health benefits through traditional fee-for-service Medicare, and enroll in the I/DD Specialized Managed Care Plan for coverage of Medicaid benefits inclusive of HCBS services; or
Receive their Medicare acute health benefits through a Medicare Advantage product and enroll in the I/DD Specialized Managed Care Plan for coverage of Medicaid benefits inclusive of HCBS services.
Alternatively, these individuals may enroll in a Dual Advantage product that offers all Medicare and Medicaid benefits through one plan (e.g., PACE programs or the FIDA-IDD)
For Individuals or their parents that have access to comprehensive job-based (third party) health benefits:
If individuals or their parents have access to comprehensive job-based health benefits, they may continue to keep this coverage for acute care needs. The State is developing an option for such individuals to also enroll in the Specialized Managed Care Plan for coverage of Medicaid benefits inclusive of HCBS services.
20. When is public comment for managed care guidelines and practices?
The specific timeframe for public comment about managed care has not yet been determined. OPWDD anticipates that prior to managed care implementation there will be several opportunities for public comment and engagement on these guidelines. Page 40 of the Draft Transition Plan identifies the anticipated public comment periods for key documents related to the operations of I/DD Specialized Managed Care Plans.
21. Initial eligibility for services is determined by OPWDD, often aided by agencies who send the DDROs packets for families and individuals. Will agencies continue to play this role?
DDROs will continue to determine eligibility for OPWDD services. CCO/HHs will work with the DDROs by assisting individuals with the gathering of documentation to support eligibility determination. There is a special transition fee to fund these supports for individuals who are newly receiving comprehensive Medicaid care management services.
22. Is OPWDD committed to developing best practices for achieving person-centered goals?
Yes. The Life Plan is a critical element of OPWDD’s commitment to enhancing person centered supports for individuals’ goal attainment. A draft template for the Life Plan is included in Attachment E of the Transition Plan. The Life Plan is a person-centered planning tool that will document the goals and objectives that are important to the individual. The developmental disability service system is moving into a world where information technology will both support these goals and objectives and empower the planning process. OPWDD is committed to making sure that the care planning process is dynamic and is helping people achieve the goals that they wish to attain.
23. Must addendums be done to all ISPs to discontinue MSC and add CCO/HH care management?
The State will address this in the Final Transition Plan. An addendum to the ISP will not be required because the “checklist” (Attachment A, page 41 of the Transition Plan) will address the change in services for ISP documentation purposes.
24. Who exactly will be the Division of Quality Improvement for CCO/HH services?
Designation of the CCO/HHs is a joint function of DOH and OPWDD. The CCO/HH has oversight responsibility for the quality of care management services. In addition, the Division of Quality Improvement, a division within OPWDD, will continue to complete person centered reviews and will retain oversight of the quality of services under the auspice of OPWDD.
25. How does this Transition Plan expand the availability of direct care professionals or other staffing or service shortages?
The Transition Plan does not address staffing shortages for direct care professionals. It does, however, lay the groundwork for a system of support that is efficient, and provides better access to services to address a person’s comprehensive needs. In addition, it provides a pathway toward future value based payments that will provide opportunity for more flexible service delivery and, ultimately, incentivize more timely service delivery.