2018-2019 Waiver Renewal Children s Habilitation Residential - - PowerPoint PPT Presentation

2018 2019 waiver renewal
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2018-2019 Waiver Renewal Children s Habilitation Residential - - PowerPoint PPT Presentation

2018-2019 Waiver Renewal Children s Habilitation Residential Program (CHRP) Presented by: Sarah Hoerle December 2018 1 Our Mission Improving health care access and outcomes for the people we serve while demonstrating sound stewardship of


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1

December 2018

Presented by: Sarah Hoerle

Children’ s Habilitation Residential Program (CHRP)

2018-2019 Waiver Renewal

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SLIDE 2

Our Mission

Improving health care access and

  • utcomes for the people we serve

while demonstrating sound stewardship of financial resources

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SLIDE 3

Housekeeping

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SLIDE 4

Ground Rules

During the meeting:

  • We have a lot to cover, so please hold questions

until breaks in the presentation.

  • Please do not speak over the presenter, or other

participants. During the engagement process:

  • Questions about this stakeholder engagement

process can be sent to: hcbswaivers@ state.co.us

  • If you have a formal comment/ suggestion on the

waiver(s), please submit them to: ltss.publiccomment@ state.co.us

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SLIDE 5

Meeting Purpose

  • Inform S

takeholders of the Waiver Renewal Process

  • Explain the content of

the CHRP waiver application

  • Discuss updates to the

CHRP waiver for this renewal

  • S

takeholder feedback

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SLIDE 6

Major Changes to the CHRP Waiver

  • Removal of requirement that the child be in foster care.
  • Transfer of administration of the CHRP waiver from the CDHS to

the Department.

  • Transfer of case management from child welfare agencies to Case

Management Agencies (specifically Community Centered Boards- CCBs).

  • Addition of two services to the waiver to mitigate the need for an
  • ut of home placement and facilitate returns to the home once

stabilized.

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SLIDE 7

Home and Community- Based Services Overview

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SLIDE 8

HCBS waiver authority permits the state to

  • ffer home and community-based services

to individuals on the CHRP waiver who:

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  • Are under the age of 20
  • In out-of-home care who have been

determined to have a developmental disability

  • The waiver serves as an alternative to

placement in an Intermediate Care Facility of Individuals with Intellectual Disabilities

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SLIDE 9

Waiver Application Process

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  • S

tates must submit initial waiver application to the Centers for Medicare and Medicaid

  • Initial approval period is 3 years
  • After initial period renewal occurs

every 5 years

  • The CHRP waiver requires a renewal

by June 30, 2019

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SLIDE 10

Renewal Process

  • The Children’ s Habilitation

residential Program (CHRP) Waiver expires on June 30, 2019

  • The S

tate must respond to Evidentiary Reports and

  • ther CMS

Guidance

  • Waiver Application must be

submitted at least 90 days in advance of expiration

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SLIDE 11

S cope

Things that can change:

  • Correct grammatical or

technical language errors

  • Legislative updates

Things we cannot change:

  • Changes or additions not

authorized by legislation

  • Changes that would

cause a fiscal impact

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SLIDE 12

Intended Timeline

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Important Dates:

  • Public Comment Period from 1/ 28/ 2019 through

2/ 28/ 2019

  • The Department will submit the renewal to CMS

before 3/ 31/ 2019

  • Renewal will go into effect on 7/ 1/ 2019
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The Centers for Medicare and Medicaid Services (CMS) has several requirements States must meet when administering a waiver

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Centers for Medicare and Medicaid Services

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CMS Requirements

Appendix A: Waiver Administration & Operation Appendix B: Participant Access and Eligibility Appendix C: Participant Services

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CMS Requirements

Appendix D: Participant-Centered Planning and Service Delivery Appendix E: Participant Direction

  • f Services

Appendix F: Participant Rights

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CMS Requirements

Appendix J: Cost Neutrality Demonstration

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Appendix I: Financial Accountability Appendix H: Systems Improvement Appendix G: Participant Safeguards

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A:

“What entities are involved in the

  • peration of

the waiver?”

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W ai aiver r Adm inist rat rat ion

  • n

an and Operat rat ion

  • n
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Appendix A Identifies

The S tate agency responsibilities for day to day administration and operation of the waiver and contracted

  • r local/ regional

entities with

  • perational functions

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Waiver Administration and Operation

  • Currently, the waiver states that it is operated by

a separate state agency: The Colorado Department of Human S ervices, Division of Child Welfare S ervices

  • At renewal, the S

tate will update this to the S tate Medicaid Agency per HB 18-1328

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A:

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SLIDE 20

Contracted Entities

Currently there are no contracted entities that perform waiver operational and administrative functions on behalf

  • f the Medicaid agency and/ or the operating agency.

At renewal we will:

  • Add Case Management Agencies (CMAs) as contracted entities to

provide targeted case management services

  • Add Memorandum of Understanding (MOU) with DHS

for monitoring/ licensing of residential services

  • Add DPHE Interagency Agreement to conduct surveys of certain

services

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A:

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SLIDE 21

Roles

  • Currently, a local/ regional non-state public

agencies, the County Departments of Human/ S

  • cial services, perform waiver
  • perational and administrative functions for

clients enrolled in the CHRP waiver.

  • At renewal, local/ regional non-governmental non-

state entities, the Community Center Board’ s (CCB), will perform waiver operational and administrative functions for clients enrolled in the CHRP waiver.

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A:

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SLIDE 22

Responsibility

  • Currently, the responsibility of assessing the

performance of County Departments of Human/ S

  • cial S

ervices in conducting waiver

  • perational and administrative functions is DHS

, under the oversight of HCPF.

  • At renewal, HCPF is responsible for assessing the

performance of the Community Centered Boards (CCB) in conducting waiver operational and administrative functions.

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A:

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Assessment Methods

Currently, methods to assess performance of Contracted non-state entities include:

  • An administrative tool is used by the waiver

administrator for all enrollments

  • Oversight and monitoring of the case management

agencies is provided by the DHS waiver administrator.

  • HCPF and DHS

review all plans of correction and necessary remediations.

  • HCPF provides oversight to the DHS

waiver administrator.

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A:

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Assessment Methods

At renewal, the CHRP waiver will be updated to include:

  • An Interagency Agreement with DPHE on complaints to be

investigated

  • Annual monitoring for each CCB
  • Administrative evaluation to monitor compliance with agency

requirements

  • Programmatic evaluation that consists of a desk audit on client

files

  • Oversee the fiscal agency operating the MMIS
  • Oversight of the Quality Improvement Organization and Post

Payment Review contractor

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A:

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Operational and Administrative Functions

Currently the assessment of performance of contracted non-state entities is DHS , under the

  • versight of HCPF, for the County Departments of

Human/ S

  • cial S

ervices in conducting waiver

  • perational and administrative functions.

At renewal, HCPF will be responsible for the assessment of performance for Community Centered Boards (CCB).

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A:

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Quality Improvement

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A:

HCPF will update the Performance Measures in Appendix A to provide CMS with the assurance that HCPF retains ultimate administrative authority over the CHRP waiver through the tracking and monitoring of deliverables provided by the contracted entities.

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B: B:

“Who receives waiver services?”

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Part art icipan ant Access an and Eligibilit y

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Appendix B Identifies

Target group(s) and Medicaid eligibility groups, Level of Care (LOC) & Evaluation procedures, Freedom of Choice, and the Application Process for entrance into the waiver

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Specific Target Groups

Currently CHRP serves individuals 0 – 20 with a Developmental Disability. At renewal, we will update the definition of intellectual and developmental disability to read:

"Int ellect ual and development al disabilit y" means a disabilit y t hat manifest s before t he person reaches t went y-t wo years of age, t hat const it ut es a subst ant ial disabilit y t o t he affect ed person, and t hat is at t ribut able t o an int ellect ual and development al disabilit y or relat ed condit ions, including Prader-Willi syndrome, cerebral palsy, epilepsy, aut ism, or ot her neurological condit ions when t he condit ion or condit ions result in impairment of general int ellect ual funct ioning or adapt ive behavior similar t o t hat of a person wit h an int ellect ual and development al disabilit y. Unless

  • t herwise specifically st at ed, t he federal definit ion of "development al disabilit y"

found at C.R.S . 25.5-10-202

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B:

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Selection of Entrants into the Waiver

Children/ youth age birth (0) through twenty (20) who have a determination of developmental disability by a Community Centered Board. As well as; meet the level of care criteria for Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IID) as defined in 42 CFR §440.150, and have with extraordinary support needs as defined in 10 CCR 2505-10 8.500, and are at risk

  • f, or in need of, out of home placement.

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# of Participants CHRP

The State does not limit the number of participants it serves at any point in time during a waiver year.

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B:

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Medicaid Eligibility Group

§1634 State with Miller Trust

Medicaid Eligibility Groups Served include: S S I recipients

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B:

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LOC & Evaluation/Reevaluation Procedures for LOC

Currently, evaluations and reevaluations are performed by County Departments of Human/ S

  • cial S

ervices. At renewal, evaluations and reevaluations will be preformed by Community Centered Boards (CCB). This section also will include the updates for:

  • Qualifications for CCB staff
  • Level of Care (LOC) criteria
  • Evaluation/ Reevaluation process

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B:

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Quality Improvement

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B:

HCPF will update the performance measures in Appendix B to provide CMS with the assurance that the correct assessment tools are being utilized appropriately by Case Managers.

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Freedom of Choice

  • Currently, the County Department of

Human/ S

  • cial S

ervices caseworker and/ or liaison provide the parent/ guardian with an explanation

  • f choice with enrollment in the waiver.
  • At renewal, the CCB case manager will provide

the feasible alternatives available under the waiver and provides the choice of institutional or community based services.

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B:

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C: C:

“What services does the waiver

  • ffer?”

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Part rt icipant Serv rvices

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Appendix C Identifies

Summarizes services provided in the waiver and describes scope, provider qualifications, coverage policies and limitations (if any)

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Services

Current S ervices:

  • Respite
  • Habilitation
  • Behavioral Assessment
  • Behavioral S

ervices

  • Professional S

ervices

  • S

upported Community Connections

Proposed S ervices:

  • Respite
  • Habilitation
  • Professional S

ervices

  • S

upported Community Connections

  • Intensive S

upport S ervices (new)

  • Transition S

upport S ervices (new)

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C:

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Services

For each service the state defines:

  • Definition
  • Specific limits on amount, frequency, and

duration

  • Delivery type
  • Provider specifications
  • Provider type

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C:

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General Service Specifications

Criminal history and/ or background investigations are required for providers This will be updated to include information for non-child welfare

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C:

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General Service Specifications

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C:

  • Currently, waiver services can be provided in
  • facilities. The following facility types include:
  • Group Home
  • Foster Home
  • Residential Child Care Facility
  • Group Center
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Quality Improvement

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C:

HCPF will updat e performance measures in Appendix C t o provide CMS wit h t he assurance t hat t he Depart ment maint ains

  • versight of service providers
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D:

How are participant needs identified and addressed during the service plan development process?

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Participant-Centered Planning and Service Delivery

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Appendix D Identifies

Participant-centered service plan development and

  • utlines the

implementations and monitoring of the service plan

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Responsibility for Service Plan Development

Currently, the CHRP waiver has Case Manager Qualifications as identified in Volume 7. At renewal, the CHRP waiver will be updated to remove the counties and include CMA requirements. These include:

  • Bachelor’ s degree in a human behavioral science or related field
  • f study; or
  • Experience working with LTS

S population, in a private or public agency may substitute for the required education on a year for year

basis

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D:

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Supporting the Participant in Service Plan Development

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D:

Each CCB is contractually obligated to provide information to participants about:

  • Potential Services
  • Supports
  • Resources
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Service Plan Development Process

  • Case Management functions include the

following responsibilities when implementing the person-centered support plan:

  • Document
  • Monitor
  • Oversee

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D:

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Risk Assessment and Mitigation

  • The waiver currently uses the ICAP but we are looking

at other options.

  • Based on stakeholder feedback, the Department is

evaluating different options for an assessment tool.

  • The Department plans to engage stakeholders in

January 2019 to discuss the determination made upon completion of evaluation.

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D:

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Risk Assessment and Mitigation

  • 1. Continue use of the current assessment tool for the

HCBS

  • CHRP waiver, the Inventory for Client and Agency

Planning (ICAP), until the new Long-Term S ervices and S upports (LTS S ) standardized assessment is implemented.

  • 2. Replace the ICAP with the Child and Adolescent Needs

and S trengths (CANS ) assessment until the LTS S standardized assessment is implemented. This option would include evaluating if and how the CANS assessment could be incorporated with the new tool.

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Informed Choice of Providers

Participant is provided a statewide list of qualified providers

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D:

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Process for Making Service Plan Subject to the Approval of the Medicaid Agency

  • CM is required to utilize the BUS to enter:
  • S

ervice Plans

  • Monthly case management log notes
  • Utilization Long-Term Care assessment

(ULTC 100.2)

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D:

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Service Plan Implementation and Monitoring

CMs are responsible for monitoring the implementation of the service plan and the health and welfare of the participant.

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D:

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Monitoring Safeguards

Department is in the process of implementing Conflict Free Case Management (CFCM) by 2022

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D:

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Quality Improvement

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D:

HCPF will update performance measures in Appendix D to provide CMS with the assurance that the participant support plan are meeting their needs and services are delivered according to the support plan

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F: F:

How are participant rights protected?

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Participant Rights

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Appendix F Addresses

Participant rights to request a fair hearing

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Opportunity to Request a Fair Hearing

Participants are notified of adverse action through issuance of a written form entitled the Long Term Care Waiver Program Notice of Action (LTC 803 Form)

  • A waiver participant is notified of his/ her

right to a fair hearing upon enrollment in the waiver and when the CCB anticipates an adverse action will be taken.

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F:

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Additional Dispute Resolution Process

A waiver participant may utilize the additional process to dispute the specific actions taken by the Community Centered Board (CCB) or other qualified provider

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F:

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Additional Dispute Resolution Process

  • Notice of intended action provided to

participant at least 15 days prior in writing

  • Participant files complaint
  • Within 15 days agency provides opportunity

to participant to informally negotiate

  • If unable to resolve complaint, present to

impartial decision maker

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F:

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Department Review of the Dispute Decision

  • HCPF is responsible to review the dispute

decision

  • The Department monitors the Dispute

Resolution process at PASA agencies through its Inter Agency Agreement with the Department of Public Health and Environment (DPHE)

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F:

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Operation of Grievance/ Complaint System

The Department is responsible for

  • perating the state grievance/ complaint
  • system. Rules describing the requirements

for this process are located at 10 CCR 2505-10

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F:

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G:

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Participant Safeguards

How does the state monitor the delivery of waiver services?

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Appendix G Addresses

Safeguards to assure the health and welfare of waiver participants and describes how to respond to critical events or incidents.

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Response to Critical Events

  • r Incidents

Who is required to report critical events or incidents?

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G:

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What is considered a critical incident?

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G:

  • The following situations require reporting within the

24 hour period:

  • Death
  • Abuse, Neglect,

Exploitation

  • Inj ury/ Illness to Client
  • Damage to Consumer’s

property

  • Medication Management

Issues

  • Missing Person
  • Criminal Activity
  • Unsafe Housing or

Displacement

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Participant Training and Education

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G:

CMA provides information about mistreatment, abuse, neglect and exploitation to the participants, guardians, involved family members and Authorized Representatives at initial enrollment and annually thereafter.

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Responsibility for Review and Response

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G:

CCBs monitor services (e.g., incident reports, anecdotal data, interview, etc.) and are required to identify and report all critical incidents HCPF identifies incidents of non-compliance through Program Quality on-site surveys, stakeholder complaints and review of the critical incident reporting system

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Use of Restraints

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G:

A personal restraint is to be used only during periods of crisis or emergency for the child, when the child is a danger to him/ herself and/ or others, the child is beyond control, and when all other means to control and de-escalate the crisis or emergency has failed.

Personal restraint is an age appropriate physical intervention by a staff member of a facility in an emergency situation to limit, restrict, or control the dangerous behavior of a child by means of physically holding the child.

State oversight is the responsibility of the Department of Health Care Policy and Financing.

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Use of Restrictive Interventions

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G:

State oversight is the responsibility of the Department of Health Care Policy and Financing. Whenever possible, positive behavioral interventions such as a calming tool (e.g. blankets, brushes) are used to avoid restraints.

The use of a mechanical restraint, including, but not limited to, the use of handcuffs, shackles, straight j ackets, posey vests, ankle and wrist restraints, craig beds, vail beds, hospital cribs, and chest restraints is prohibited, except as otherwise allowed under Article 27-10, C.R.S .

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Use of Seclusion

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G:

Seclusion

S tate Law Title 27-10.5-115 (5) C.R.S . prohibits the use of seclusion.

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Medication Management and Administration

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G:

State oversight is the responsibility of the Department of Health Care Policy and Financing.

Service Providers are responsible for

  • ngoing medication

management and follow-up

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Quality Improvement

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G:

HCPF will update performance measures in Appendix G to provide CMS with the assurance that the State is monitoring the Health and Welfare of the DD and SLS waiver participants

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H:

What is the Quality Improvement Strategy (QIS)?

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Systems Improvement

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CMS Technical Guide States:

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“ Quality Improvement is a critical operational feature that an organization employs to continually determine whether it operates in accordance with the approved design of its program, meets statutory and regulatory assurances and requirements, achieves desired

  • utcomes, and identifies opportunities for

improvement”

H:

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QI S Discovery & Rem ediation

Appendices:

A B C D G I

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Systems Improvement

System Improvements & System Design Changes

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H:

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I : I :

How does the state maintain financial accountability in the waiver?

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Financial Accountability

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Appendix I Addresses

Financial elements of waiver operations such as payment methods, rates, billings and claims.

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Financial Integrity

  • Claims are submitted in the Medical Management

Information S ystem (MMIS )

  • Post Payment Reviews will be conducted by the

Post Payment review (PPR) contractor

  • Data Unit conducts data analysis of claims data
  • Claims Investigative Unit conducts both desk

reviews and medical record reviews

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I:

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Rates Claims & Billing

S

  • me services are reimbursed on a fee-for-service basis

and do not vary based upon tier levels such as professional services and supported community connection. Other services are reimbursed on a tiered fee-for-service rate.

  • Individuals are grouped into 6 tiers based on data compiled

from the Inventory for Client and Agency Planning (ICAP).

Payments to providers are made through the MMIS

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I:

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Quality Improvement

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I:

HCPF will update the performance measures in Appendix I to provide CMS with the assurance that the State is monitoring waiver finances.

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J:

Does the waiver meet statutory cost-neutrality requirements?

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Cost Neutrality Demonstration

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Cost Neutrality Explanation

Home & Community Based S ervices Factors:

  • Unduplicated Count – Number of individuals who

will receive services through a waiver within a year

  • Average Length of S

tay – Average span, in days, that an individual utilizes waiver services

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Cost Neutrality Explanation

Home & Community Based S ervices Factors:

  • Factor D:The estimated annual average per capita

Medicaid cost for HCBS services for individuals in the waiver program

  • Factor D’ : The estimated annual average per capita

Medicaid cost for all other services provided to individuals in the waiver program

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Cost Neutrality Explanation

Institutional S ervices Factors:

  • Factor G:The estimated annual average per capita

Medicaid cost for hospital, NF, or ICF care that would be incurred for individuals served in the waiver, were the waiver not granted.

  • Factor G’ : The estimated annual average per capita

Medicaid cost for all services other than those included in factor G for individuals served in the waiver, were the waiver not granted.

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Cost Neutrality Demonstration

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D+D’ ≤ G+G’

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Demonstration of Cost- Neutrality Formula

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J:

D+D’ ≤ G+G’ $7,720 + $54,087 ≤ $210,753 + $15,778

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Questions or Concerns?

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S ubmit any public comments to: ltss.publiccomment@ state.co.us

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Contact Information

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Justine Miracle 303-866-5919 Justine.Miracle@ state.co.us Michele Craig 303-866-5147 Michele.Craig@ state.co.us

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Thank You!