what the consolidated and p/fds waiver renewals mean for …...11/2/2016 1 >> what the...

11/2/2016

1

>www.dpw.state.pa.us >www.dhs.pa.gov

What the Consolidated and P/FDS Waiver Renewals Mean for SCs

Proposed Changes to the Consolidated and P/FDS Waivers

November 2016

111/2/2016

July ‘17

Residential rate simulation begins

Feb‐Mar ‘17Dec ‘16 – Jan ‘17

PA Bulletin notice I & J public comment period

Review App I and J comments and revise

Nov ‘16Aug –Sept ‘16July – ‘16

Waiver app finalized Appendix A ‐ H

WAIVER RENEWAL

6100 REGSRATES SETTING

6100 regsPromulgationin PA Bulletin.

KEY DATES

Servicedefinitions finalized

Nov‘17 Jan ‘18

Implement Residential Rates

Internal DHS review of A‐H

ODP Research and internal work on application

ProviderMeetings on Waiver changes

6100 regs Proposedin PA Bulletin. 45 day comment period

PA Bulletin notice A‐HWaiver 45 day public comment period

Rate development

Develop App. I & J

Waivers Effective

Waivers Submitted to CMS

P/FDS and Consolidated Waiver Renewal Development Time Line

Internal DHS review of A‐H

Webinars on Waivers for Stakeholders

ProviderMeetings on Waiver changes

Oct ‘16

Review App A through H comments and revise

11/2/2016

2


Timelines

• Appendices A-H Include Program Design, Eligibility and Service Definitions - Released for Public Comment on November 12th or 19th

• Comment period 45 days

• Appendices I&J which include the rates will be released for public comment in December 2016

3


ADA

HCBS Rule

WIOA

Gov’s Exec. Order Employ-

ment 1st

Everyday Lives

Advocacy

Drivers of Change

4

11/2/2016

3

>www.dpw.state.pa.us >www.dhs.pa.gov11/2/2016 5

Draft Waiver Renewals

EDL Values Statements

ISAC Recommend

ations

Data• Demographics• IM4Q

QoL/Outcomes

ODP Futures Planning

•Public Forums•Webinars

Inputs

5


Stakeholder Involvement

• 2013 ODP Futures Planning begins - 265 stakeholders

• Everyday Lives 2016 – vision and values published

• ISAC 13 recommendations for system change based on values

• Ten in-person public forums and two

webinars in the fall of 2015 to solicit

public input on the waivers

6

11/2/2016

4


Summary of Major Changes

• Expand eligibility to people with autism regardless of a co-occurring ID diagnosis

• Expand eligibility to children age birth to seven with a developmental delay

• Implement a new Community Participation Supports service

• Enhance support for families

• Expand residential options

• Align residential service payment with individuals’ needs

• Streamline monitoring of AEs, SCOs, and providers

7


Expanding Eligibility

811/2/2016

11/2/2016

5


Basis for Expanded Eligibility

Proposed: Expanding Eligibility to People with Autism

• ODP waivers have long served people with ASD & co-occurring ID: – 30% of the 32,000 people in the Consolidated & P/FDS waivers have

autism

– 25% of the 570 people in the Adult Autism Waiver have ID

• Standardize and equalize access to all options for all ODP participants.

• Expand autism expertise to all ODP waiver programs

• Prepare for the future - the number of children in education with autism is increasing as the number with ID is decreasing.


Basis for Expanded Eligibility

Proposed: Expand Eligibility - Lower Age from 3 to Birth

• Provide children with developmental disabilities currently in ICF/ID facilities or at risk of admission the option to live at home with family

• Provide services and supports not covered by Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) such as family and caregiver training and support, respite care, home adaptations

10

11/2/2016

6


Proposed Expanded Eligibility

• Waiting list management policies that prioritize people with the most urgent needs will not change; these priorities will now apply regardless of whether a person has an intellectual disability or autism.

• Supports Everyday Lives’ recommendations to:– expand the ability to support people with complex needs;

– support families throughout the life span; and

– provide community services to everyone.

11


You Might Hear:

“How is ODP going to serve all these new people when it can’t even serve the people on the waiting list now?”

ODP’s Response:ODP has a waiting list for people with ID and an interest list for people with autism. These are not new people.

This is one way ODP is responding to changes in demographics and preparing for the future. The percent of students in special education with an autism diagnosis is growing while the percent with an ID diagnosis is decreasing.

We currently serve people with Autism and ID in all ODP Waivers: About 30% of people in the ID waivers also have Autism and about 25% of people in the Autism waiver have ID. The only thing new will be opening up the waiver to people who have Autism but do not have ID.

11/2/2016

7


Community Participation Supports

1311/2/2016


PROPOSED NEW SERVICE

COMMUNITY PARTICIPATION SUPPORTS(REPLACES PREVOCATIONAL AND DAY HABILITATION SERVICES)

• Flexibly wrap around and support community life secondary to employment, as a primary goal.

• This service involves participation in integrated community settings, in activities that involve persons without disabilities who are not paid or unpaid caregivers.

14

11/2/2016

8


Approach

Build system capacity over time/phase in

Promote opportunities for provider

transformation

Provide flexibility

between and among service components

Fluid service to meet a

person's needs while

minimizing need for ISP

changes

15


COMMUNITY PARTICIPATION SUPPORTS

• Prevocational skill development;

• Participation in community activities, groups, associations, or clubs to develop and maintain relationships and social networks with community organizations and clubs;

• Opportunities related to the development of hobbies or leisure/cultural interests or to promote personal health and wellness (e.g. yoga class, hiking group, walking group, etc.);

• Selecting and participating in in volunteer opportunities;

• Opportunitis focused on training and education for self-determination and self-advocacy;

• Learning to navigate the local community, including using transportation options available in the local area;

• Assisting individuals and family caregivers with providing mutual support to one another (through service/support exchange) and contributing to others in the community.

16

11/2/2016

9


Service Settings

Community Locations

Community Hubs

Prevocational Facilities

Day Habilitation

Facilities

17


Phase-in of Standards

25%+ time in Community locations and hubs

50%+ time in Community locations and hubs

75%+ time in Community locations and hubsJan 1, 2018

July 1, 2018

Jan 1, 2019

Percentages based on weekly averages.

11/2/2016

10


DRAFT EXCEPTIONS AND LIMITATIONS

• Exception process when medical, mental health or behavioral needs or condition affects their ability to participate at the standards specified.

• In Consolidated Waiver, limit of 14 hours per day of In-Home and Community Support, Companion and Community Participation Supports (whether utilized alone or in combination with one another).

o Exception process when medical, mental health or behavioral needs or condition affects their ability to maintain health and safety.

19


You Might Hear:

“ODP is closing workshops.”

ODP Response: ODP is not closing workshops. ODP is expanding options for people to get support in community settings. All changes are phased in over time and will provide people more opportunities to be engaged in their communities.

11/2/2016

11


You Might Hear:

“ODP is making everyone get a job.”

ODP Response:

ODP is not making everyone get a job. Pennsylvania is an Employment First state which means we are removing barriers and increasing the opportunity for people to work. For publicly funded programs, employment in competitive integrated settings is the preferred outcome. ODP is doing many things to better support people to get jobs in the community at minimum wage or better.


You Might Hear:

“ODP is taking away choice. My son/daughter chooses to be in the day program/workshop.”

ODP Response:

Starting in 2019, Medicaid waivers can only pay for services in integrated community settings. We are not closing options but are expanding and broadening options to give people more time in the community. ODP is changing the service definitions to better support providers to provide integrated activities and to offer individuals more choice.

11/2/2016

12


Enhancing Support for Individuals and Families

2311/2/2016


Support families throughout the life span and expand options for community living

• Supported Living

• Housing Tenancy and Tenancy Sustaining Services

• Family/Unpaid Caregiver Training and Consultation

Promote self-direction, choice and control

• Participant-Directed Goods and Services

Assure effective communication

• Communication Specialist

24

New Services

11/2/2016

13


Promote health, wellness, and safety and support people with complex needs

• Consultative Nutritional Services

• Art, Music and Equine-Assisted Therapy

Increase employment and increase community participation

• Community Participation Supports

• Advanced Supported Employment

• Benefits Counseling

New Services


New Service

Discovery, job development, systematic instruction for participants for whom supported employment unsuccessful. Specifically, the participant:1. Found ineligible for or closed case with OVR services and chooses not to

be re-referred, and

2. In the past 2 years, with the use of supported employment services, has not been able to secure a competitive integrated job or unable keep a competitive integrated job for more than 6 months, and

3. Meets one of the following criteria:

a) Is currently in an activity receiving a sub-minimum wage, or

b) After consulting with a credentialed provider, it is the opinion of the ISP team that the level of support provided through this service is needed to secure sustained competitive integrated employment.

Eligibility shall be determined by the ISP team.

Advanced Supported Employment

11/2/2016

14


• Work that participants perform during the provision of Transitional Work services must be paid at least minimum wage and the compensation must be similar to compensation earned by workers without disabilities performing the same work.

• Defined Affirmative Industry - a business that sells products or services where at least 51% of the employees do not have a disability.

• Transitional Work includes supporting the participant with personal care needs that cannot, or would be inappropriate to, be provided with the support from coworkers or other natural supports.

• Participant limited to 3 years of consecutive Transitional Work Service

Transitional Work


NEW service• Through accurate individualized assessment, this service provides

information to the participant regarding the full array of available work incentives for essential benefit programs including Supplemental Security Income, SSDI, Medicaid, Medicare, housing subsidies, food stamps, etc.

• Provided by Certified Work Incentive Counselor

• Limit 10 hours annually

• Available only after service sought and unavailable through PA’s Work Incentive Planning and Assistance programs (WIPAs)

Benefits Counseling

11/2/2016

15


Respite

• Expanding respite options – allowable setting, changes in rate structure

Respite Limitations:

• Self-directing - limited to $8,000 per fiscal year.

• Traditional agency – 30 units of day respite per fiscal year and

– 480 units of 15-minute unit respite per fiscal year (Consolidated) or

– 1440 units of 15-minute unit respite peer fiscal year (P/FDS).

• Participants must choose participant direction or traditional agency for Respite

11/2/2016 29

Enhance Support for Families


P/FDS ONLY - NEW service

• Equipment or supplies not otherwise provided through other services offered in this waiver, MA, or a responsible third-party and address and:– Decrease the need for other Medicaid services;

– Promote or maintain inclusion in the community;

– Promote the independence of the participant;

– Increase the participant’s health and safety;

– Develop or maintain personal, social, physical or work-related skills.

– Must be used primarily for the benefit of the participant.

• $2000 annual cap

Participant-Directed Goods and Services

11/2/2016

16


Enhance Support for Families

• These changes address the Everyday Lives participant values of Individuality and Partnerships and the family values of Mentoring, Simplicity and Flexibility, and Opportunity for Innovation.

• These changes address the ISAC recommendations to:– Support Families throughout the Life Span

– Promote Self-Direction, Choice, and Control,

– Assure effective communication

– Promote health, wellness, and safety and support people with complex needs

31


Expanding Residential Options

3211/2/2016

11/2/2016

17


• Transition residential services from cost based reimbursement to a needs-based fee schedule 1/1/2018.

• Robust service definition and rate structure will include clinical services and eliminate Additional Individualized Staffing (AIS).

• Refresh fee schedule with updated data on all service cost components.

• Include participant rights to lease, visitors, private communication, choosing a roommate, lock on bedroom door, etc.

Residential Habilitation


SIS and Needs Levels for Residential

• Residential Fee-schedule rates will be based on many different cost factors such as employee salary and benefits, training costs, supervision, the needs of each individual as measured by the SIS assessments, home size and whether person attends day services.

• SIS scores translate to 7 Needs Levels which, based on staffing needs, are condensed into 4 Needs Groups

– Bottom-up, independent process tied to an individuals’ unique needs

– Increased flexibility for providers

– Better predictability and capacity management

• Move to SIS online and addition of Supplemental Questions 1/1/17– ODP has expanded assessment capacity of ASCEND

• Outlier Process– 600 consumers identified for automatic re-assessment beginning 1/1/17

3411/2/2016

11/2/2016

18


You Might Hear:

“SIS is not a good assessment.”

Response: SIS is used in 23 states and 17 countries. It is the only assessment normed for people with developmental disabilities; it has been tested for reliability and validity and has an “excellent” score for inter-rater reliability. ODP will be adding some questions, the “Oregon Questions,” that other states have developed and tested to capture things such as the need for staff support because of involvement in the criminal justice system.


You Might Hear:

“That a specific person in residential services has a SIS that does not reflect their need.”

Response: The instrument has been applied in PA for nine years and the consistency of SIS scores for individuals who have had more than one assessment affirms its accuracy. ODP has prioritized 600 people for re-assessment. For these individuals their SIS scores did not line up well with their current residential rates. Providers will be able to request reassessments for individuals whose assessments they believe to do match the current needs or service plan.

11/2/2016

19


Design of the Residential Fee Structure

For licensed Respite -rate to be added


New stand-alone service definition• Allows participants to live in their own home, or the home of a

relative or unrelated individual and receive agency-managed services.

• Allows relatives who meet qualification standards to provide services for participants age 18 and older.

• Align rates to level of need to support people with complex needs.

• Include participant rights to visitors, private communication, choosing a roommate, lock on bedroom door, etc.

Life Sharing

11/2/2016

20


NEW service• Independent living option in participant’s private

residence.

• Provides a cost-efficient residential habilitation option for people with less intense needs.

– Paid using a daily, needs based fee schedule rate

– Daily fee schedule rate includes 24/7 on-call staff availability

– Encourages rather than displaces natural supports

– Provides participants with the option of selecting a roommate – to share living costs and staffing resources

Supported Living


• Billed as a day unit; provided at the following levels:

– 1 to 3 person private homes

– Rates structured at

• <20 hours

• 21-40 hours

• 41-60 or

• 60+ hours per week for the participant – There will only be a rate for 60+ hours per week in 2+

person home

• Remote Electronic Monitoring

Supported Living

11/2/2016

21


Expand Residential Options

• These changes address the Everyday Lives participant and family values of Choice and Control

• These changes also address the Everyday Livesrecommendation to Expand Options for Community Living

41


Other Changes

4211/2/2016

11/2/2016

22


Previously Home and Community Habilitation• Change to staffing ratios. Highest ratio is now 1:4 versus 1:6.

• Transportation that is 30 miles or less per day is included in the rate. – Anything over 30 miles should be authorized as a separate

transportation service.

• Maximum of 14 hours per day of In-Home and Community Support , Community Participation Support and/or Companion.– Exception process when medical, mental health or behavioral

needs or condition affects their ability to maintain health and safety.

In-Home and Community Support


You Might Hear:

“The 14 hours of In-Home and Community is not enough service. I need/My family member needs 24/7.”

ODP Response:

ODP is developing an exception process for the 14 hours. This process is for when medical, mental health or behavioral needs or condition affects their ability to maintain health and safety. ODP has also proposed new life sharing and supported living options to help meet this need.

11/2/2016

23


Shift Nursing

• Reminder: these services are not available to individuals under 21 as they are available through EPSDT.

• Individuals receiving Residential Habilitation, Life Sharing or Supported Living may not receive shift nursing (clinical services are built into the rate for the service and are to be provided by the residential provider)

• Provided by LPN or RN

• Nursing Ratio of 1:2 and 1:1 available

Shift Nursing


Behavioral Support

• Level 1: – Master’s in Human Services (or a related field) or a Bachelors’

and work under supervision of an individual with a Master’s

• Level 2: – Participants demonstrated complex needs, including regression

or lack of adequate progress with Level 1, or be high risk for decreased stability in the absence of Level 2 support.

– Providers of Level 2 must have a Master’s in Human Services (or a related field) or be a licensed psychiatrist, psychologist, professional counselor, social worker, or hold a behavior specialist license.

• Initial and ongoing service distinguished for both levels

Behavioral Support

11/2/2016

24


Behavioral Support

• Individuals receiving Residential Habilitation, Life Sharing or Supported Living may not receive Behavioral Support (clinical services are built into the rate for the service and are to be provided by the residential provider)

Behavioral Support


Transportation• Transportation Mile – Mileage will be paid per trip versus

round trip. A trip is from the point of pick-up to the destination as identified in the service plan.

• For participants under the age of 21, Transportation may only be used to travel to and from waiver services or a job that meets the definition of competitive integrated employment.

• Participants authorized to receive Residential Habilitation, Life Sharing or Supported Living may only be authorized for Transportation services as a discrete service when the participant requires transportation to or from a job that meets the definition of competitive employment.

Transportation

11/2/2016

25


• New and enhanced qualification standards– Certification standards for employment-related services

– Management standards for residential settings and supports coordination

– Orientation and training plans

Everyday Lives individual and family value statements of quality and stability.

Provider Qualification Standards


Supports Coordination• No major changes to this service definition

• Qualification Requirements– Executive Director must have 5 years of professional level

experience in the field of disability services, including 3 years of administrative, supervisory, or consultative work; and a bachelor’s degree

– Have a written conflict of interest policy for their Board of Directors and employees

– Have an orientation program that includes:• Person-centered practices

• The prevention, detection and reporting of abuse, suspected abuse and alleged abuse

• Individual rights and recognizing and reporting incidents.

Supports Coordination

11/2/2016

26


• Qualification Requirements Continued– Personnel must be employees of the SCO (extraordinary

circumstances for temporary contracts).

– SC Supervisor can supervise a maximum of 7 Supports Coordinators

– Qualification standards for SC Supervisors

• Complete 24 hours of training each year

– Qualification standards for SCs

• Complete 24 hours of training each year

Supports Coordination


Appendix C-5• Waiver funding cannot be used to provide any service in any

private home purchased for, developed for or promoted as serving people with an intellectual disability and/or autism in a manner that isolates or segregates the participant from the community of individuals not receiving waiver services.

• Further, waiver funding cannot be used to provide any service in a private home that is:– A farmstead

– A gated/secured community for people with disabilities

Home and Community-Based Settings

11/2/2016

27


Appendix C-4

• A per participant per fiscal year total limit will be established once rates have been established for all P/FDS Waiver services. ODP will set the cap to correspond with increases in the rates. All waiver services are included in the limit with the following exceptions:

– Supports Coordination and Supports Broker services excluded from the limit

– When a participant is authorized to receive Advanced Supported Employment or Supported Employment the limit established can be exceeded by $15,000 for those services.

P/FDS Limit On Amount of Services


• Consolidated Waiver capacity 18,097 people (Unduplicated)– Reserved Capacity for Age Out &Transition, Litigation,

Unanticipated Emergencies and Hospital/Rehabilitation Care

• P/FDS Waiver capacity 13,900 people (Unduplicated)– Reserved Capacity for Hospital/Rehabilitation Care

– Waiting List if granted an initiative

• Annual adjustments made upon adoption of Commonwealth budget

Waiver Capacity

11/2/2016

28


StreamliningAdministrative Entity, Supports Coordination Organization, and

Provider Monitoring

Quality Assessment & Improvement

5511/2/2016


ODP Goals for Quality Monitoring

56

• Measure progress toward implementing “Everyday Lives Values in Action”

• Gather timely & useable data to manage system performance

• Use data to manage the service delivery system with a continuous quality approach

• Demonstrate Administrative Entity (AE) outcomes in the operating agreement

• Collect data for waiver performance measures

• Verify that providers and Supports Coordination Organizations (SCO) comply with 55 Pennsylvania Code 6100 regulations

56

11/2/2016

29


Reasons to Streamline Quality Assessment & Improvement

11/2/2016 57

• Create more time to focus on quality improvement and the experience of individuals

• Eliminate multi-layered process and unnecessary duplication

• Desire to move away from top-down compliance and remediation toward collaborative partnerships that foster technical assistance and shared learning

• Improve methods for collecting and using data in a timely way

Quality of the

Individual’s Experience

Compliance

57


Examples of Streamlining Changes

ODP is considering modifications in the following areas:

• Sampling approach

• Individual record review

• Frequency of monitoring AEs, SCOs and providers

• Use of self-assessment

• Corrective action plan process

11/2/2016 58

58

11/2/2016

30

>www.dpw.state.pa.us >www.dhs.pa.gov 59

For 7/1/17 Fiscal Year ISP Renewals

All Consolidated and P/FDS ISPs will be auto authorized for FY2017 renewal unless:

• Contain Residential Habilitation, Day Habilitation or Prevocational

• Change in the total plan units for Consolidated or exceeds P/FDS cap

• Contain new services

Auto-Authorization Policy DRAFT

>www.dpw.state.pa.us >www.dhs.pa.gov 60

Consolidated

• Initial ISPs will be manually authorized

• For subsequent FY renewals, Consolidated ISPs auto-authorized if no new services and no change in units.

• For annual reviews, Consolidated ISPs auto-authorized if no new services and no change in units.

Starting 7/1/2017 for P/FDS

• Initial ISPs will be manually authorized.

• Annual and FY renewals auto-authorized if no new services and budget is below cap

• Critical Revisions auto-authorized if no new services and the budget is below the cap

Please remember, like everything in the waiver renewals, this is DRAFT policy and is subject to change!

Auto-Authorization Policy DRAFT

11/2/2016

31


Sept 2016

January 2018

• EDL Conference• 3 EDL Principles

Webinars -1 HrSEP 2016

OCT 2016• LifeCourse Tools

Web – 2 hrs with Assignment ”[Req]

• Sexual Assault –PCAR [Oct-Nov]

DEC 16• Follow-up on

LifeCourseAssignment –Web/Tele 2 hrs –2 per region [Req]

• Community Participation Supports (changes in day services)

• “The Really Tough Employment Conversations” Web – 2 hours – SELN

• SC Supervisors LifeCourseLeadership Statewide Session (1)

JAN 2017

FEB 2017 April-May 2017Webinar Series on FY Renewals with

Changes• Auto-Auth• CPS Service

cross walk• Res Hab

Crosswalk• New Procedure

Codes

ODP Supports Coordination Training Plan Through Jan 2018• SCO Webinars:

“What the waiver renewal means for SCs”[Req] - 2 hrs

• Employment Experience Connection (June-Nov)

• SIS On-line

NOV 2016

• Residential Rates

• SELN Discovery & Customized Employment Face-to-FaceMarch-Apr 2017

Other Possible TopicsHealthy SexualityPersonal Safety for

SCs in Private Homes (Dubble)Family Dynamics

JUNE 2017


Timelines

• Appendices A-H Released for Public Comment on November 12 or 19, 2016

• Comment period ends 45 calendar days after publication

• Julie Mochon, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 501, Harrisburg, PA 17120. Comments may also be submitted to the Department at [email protected].

• Appendices I & J will be released in December

62

what the consolidated and p/fds waiver renewals mean for …...11/2/2016 1 >> what the...

Documents