Provider Update:Centers For Medicare and Medicaid Services HCBS Rules
June 10, 2014
The Center for Medicare and Medicaid Services (CMS) has recently made changes to its requirements for Home & Community Based Services (HCBS). The new Final Rule, effective March 17, 2014, addresses several sections of Medicaid law under which States may use federal Medicaid funds to pay for HCBS. The rule supports enhanced quality in HCBS programs and adds protections for individuals receiving services.
A full version of the Federal Register may be found at the following link:
PERSON CENTERED SERVICE PLANNING
Person Centered Service Planning has been a critical focus of the ADvantage 1915(c) waiver and our Members are afforded many protections under this approach. It is a process-oriented approach to empower our Members and puts focuses on their strengths and interests, as well as their needs. We have seen tremendous strides in our waiver utilizing Person Centered planning, as it allows our Members to be in charge of the direction of their care and includes them in the development of their service plan.
Per the new rules, CMS has regulated modifications to the current way we administer the ADvantage program. Under the new Rules:
• §441.301(1)(vi) Providers of HCBS for the individual, or those who have an interest in or are employed by a provider of HCBS for the individual, must not provide Case Management or develop the person-centered service plan, except when the State demonstrates that the only willing and qualified entity to provide case management and/or develop person-centered service plans in a geographic area also provides HCBS.
• §441.301(2)(vi) The Person-Centered Service Plan must reflect risk factors and measures in place to minimize them, including individualized back-up plans and strategies when needed.
CONFLICT FREE CASE MANAGEMENT
Effective October 1, 2014, all ADvantage Member Service Plans submitted to the Medicaid Services Unit – ADvantage Administration (MSU-AA) must reflect that the Member is not receiving Case Management services from the same Agency that is providing Personal Care services. As a result, ADvantage Member Service Plans may not have T1016 services and T1019 services billed by the same contracted ADvantage Provider Agency. The only exception may be when there is only one Provider choice available for either Case Management services or Personal Care services in the Member County of residence.
All New & Reassessment Service Plans received at the MSU-AA on or after October 1, 2014, that are not in compliance with the Conflict Free Case Management rules noted above, will not have Case Management or Home Care service lines authorized until the Service Plan is received meeting all compliance requirements.
BACK-UP SERVICE PLANS
Effective July 15, 2014, all Service Plans submitted to the MSU-AA must include the Services Backup Plan, form 02CB014E (ADv300). All Service Plans received at the MSU by 07/15/2014 will be required to be in compliance with this new requirement. In the event the Service Plan is submitted without the required Backup plan, the Case Management service line will not be authorized until the back-up plan has been received at the MSU-AA.
Please be advised, all New and Reassessment Service Plans that are currently in review at the MSU-AA will have the Case Management line conditionally authorized, requesting submission of the Services Backup Plan form.
HCBS SETTINGS
The rules aim to ensure that individuals have a free choice of where they live and who provides services to them, as well as ensuring that the individual rights are not restricted. While Medicaid HCBS has never been allowed in institutional settings, these new regulations clarify that HCBS will not be allowed in any setting that has qualities of an institution. The rules set the expectations for settings in which HCBS can be provided to the Member and CMS has advised that additional guidance on the rules pertaining to settings is forthcoming.
PROVIDER INFORMATIONAL MEETING
In order to assist ADvantage Providers with implementation of the CMS final rules, the DHS Medicaid Services Unit has scheduled an ADvantage Provider Meeting for:
JUNE 25, 2014 at 10:00am
OG&E TECHNOLOGY CENTER
220 EAST WILSHIRE
OKLAHOMA CITY, OK 73105
The goal of the DHS Medicaid Services Unit is for ADvantage Members to live and thrive in their homes and provide assurances to their health and safety. We will strive to make this ongoing process transparent and as least burdensome as possible. We look forward to meeting with you and if you have any additional questions, please contact the Medicaid Services Unit via Smarter Mail at aauproviderquestion@aau.okdhs.org
DRIVING DIRECTIONS TO OG&E TECHNOLOGY CENTER:
PLEASE NOTE: THERE ARE TWO OG&E ENTRY GATES. THE FIRST GATE IS LOCATED ON WILSHIRE BLVD. YOU WILL NOT BE ALLOWED TO ENTER AT THE WILSHIRE BLVD. GATE. YOU MUST ENTER AT THE GATE LOCATED ON CENTRAL AVE. APPROXIMATELY ONE BLOCK EAST).
Directions: Take the (East) Wilshire Blvd. exit off the Broadway Extension (HWY 77).
1. Head east approximately three blocks … (follow the Energy Technology Center signs located along the way) and turn right (south) on Central St.
2. Enter at the electric gate with the yellow bar (about halfway down the block). You will see the Energy Technology Center sign on the north side of the building.
3. For question call (405) 553-3746.
ACCESSIBLE PARKING DIRECTIONS:
Please call 553-3746 at least one day in advance if possible.
Take the (East) Wilshire Blvd. exit off the Broadway Extension (HWY 77).
1. Head east approximately three blocks … (follow the Energy Technology Center signs located along the way) and turn right (south) on Central St.
2. There are two open gates on Central St. You will need to drive past the first gate and continue driving until you come to the second gate located at the end of the street to your right.
3. Proceed slowly and turn right. Continue north to the back side of the technology center building. The accessible sign and parking are located on the South side of the Energy Technology Center building. Enter at the gate.
4. For questions call (405) 553-3746.
If you have any questions regarding the information provided above, please feel free to contact us via Smarter Mail at: aauproviderquestion@aau.okdhs.org
