1915(c) HCBS ADvantage Waiver Amendment
The Oklahoma Department of Human Services (OHS) is seeking an amendment to the ADvantage waiver. The proposed waiver amendment includes:
- An updated estimated cost for waiver years two (2) through five (5) occurring as a result of legislatively mandated rate increases,
- The addition of Assistive Technology services, and
- The addition of Remote Supports services.
Assistive Technology services include devices, controls and appliances specified in the member's person-centered service plan which enables them to increase their abilities to perform activities of daily living or to perceive, control or communicate with the environment in which they live. Devices may include communication technology that allows members to communicate with their providers via video or audio chat to ensure ongoing maintenance of health and welfare.
Remote Supports involves monitoring of a waiver member by remote staff using audio or video equipment, allowing for live, two-way communication with them in their residence. Remote Supports is not a system to provide surveillance, and HIPAA privacy and security rules apply to all covered service providers. Remote Supports allow for a member to choose the method of service delivery which best suits their needs. This service is less intrusive than requiring the physical presence of another person to meet the needs of the member. Remote supports will promote and enhance the independence and self-reliance of the member.
Please view the waiver amendment here: 1915(c) HCBS Advantage Waiver Amendment.
Please submit all comments by close of business, June 13, 2022, via the comment box below. Written comments will also be accepted and can be sent to the Oklahoma Health Care Authority, 4345 N. Lincoln Blvd. Oklahoma City, Oklahoma 73105. Attention: Health Policy 1915(c) Waivers.
To request a hard copy of the waiver please call 1-888-287-2443 or send your request to the Oklahoma Health Care Authority, 4345 N. Lincoln Blvd. Oklahoma City, Oklahoma 73105. Attention: Health Policy 1915(c) Waivers.
Comments
Jared Hendricks:
We at SafeinHome are excited to see the proposed changes to add remote supports and assistive technology to the ADvantage waiver. We have see how these options create learning opportunities and provide individuals with a least-restrictive option that promotes their independence and self-determination.
Nathan Jensen:
PurFoods, LLC d/b/a Mom’s Meals (“Mom’s Meals”), a provider of home-delivered meals, appreciates the opportunity to provide comments concerning the ADvantage Waiver amendment. Mom’s Meals encourages the Department of Human Services (the “Department”) to make additional changes regarding home-delivered meals to support Oklahomans, ensure resiliency of the service, and align service requirements with national standards.
Mom’s Meals currently serves more than 4,000 clients in Oklahoma. In addition to our participation in home-delivered meal programs, Mom’s Meals is currently building a new production facility in Oklahoma City where more than five hundred people will eventually work. We welcome the opportunity to collaborate with the Department to shape the future of home-delivered meal service in Oklahoma.
Additional Meal:
Mom’s Meals suggests the Department allow up to two meals per day instead of one meal per day. Most states currently permit up to two meals per day. Delaware is also currently in the process of adding a second meal per day to its 1115 Demonstration Waiver. Adding a second meal would be particularly helpful for rural and remote areas as the limitation to one meal per day makes it less economically feasible to service individuals in these areas. If providers are not able to provide consistent meal delivery in all areas of the state, including hard to serve areas, the state risks negatively impacting waiver participants living in the community, possibly leading to costly institutional placement sooner than necessary.
Delivery Standards:
Mom’s Meals further encourages the Department to align delivery requirements with national standards. Mom’s Meals has seen delivery success rates over 99% in regions where driver attestation and common carriers are utilized in lieu of signature requirements. Not requiring someone to be home also frees the client and their caregivers to attend doctor appointments, visit with family, or run errands without the fear of missing a delivery.
Adding the below provisions to the waiver would align the delivery requirements to other states.
Proposed Language:
The provider shall ensure delivery provided by the provider or commercial or common carrier meets applicable federal, state and local food safety, storage and sanitation requirements. Cold, frozen, and shelf-stable meal providers may deliver meals for one or more weeks at one time without regard to when the meals were produced. The provider shall replace any item lost or stolen between the time of delivery and receipt by the individual at no cost to the individual or the Department.
The delivery driver’s attestation that delivery occurred shall be sufficient documentation of delivery. If a provider uses a common carrier to deliver meals, the provider may verify the success of the delivery by retaining the common carrier's tracking statement or returned postage-paid delivery invoice. Nothing shall prohibit the provider from using an electronic system to verify delivery.
Rate Increases:
Mom’s Meals supports the Department’s decision to update rates. Mom’s Meals also encourages the Department to continue to monitor current supply chain disruptions and inflationary pressures. So far in 2022 those pressures have not reduced from record levels in 2021.
Mom’s Meals is committed to continuing to build a strong relationship with all involved in the nutrition program and learning how to best participate in the future when the Department gathers input from providers and other stakeholders. Please let us know if you have questions or require additional information.
