Adult 1915(i) Annual Policy Update Indiana FSSA/DMHA Adult 1915(i) - - PowerPoint PPT Presentation
Adult 1915(i) Annual Policy Update Indiana FSSA/DMHA Adult 1915(i) State Evaluation Team October 22, 2020 Purpose This annual policy update provides us the opportunity to review policy changes that have been made throughout the year, provide
Indiana FSSA/DMHA Adult 1915(i) State Evaluation Team October 22, 2020
This annual policy update provides us the
made throughout the year, provide notification for upcoming changes and what to expect, and answer questions about 1915(i) programming.
Elaine Trepanier Garnet Holsapple Amanda Huff Alexis Pless Centerstone, Regional, Swanson, Meridian, Northeastern, Southwestern LifeSpring, Gallahue, Adult and Child, Park Center, Grant-Blackford, Hamilton Oaklawn, Edgewater, Sandra Eskenazi, CMHC, Valley Oaks, Community Howard Aspire, Bowen Center, Four County, Samaritan, Cummins, Porter-Starke
Starting May of 2019, the SET began to look a little different. By October we had a whole new crew and now finally have a full team as opposed to one person for the entire state. This shift has resulted in an increased ability for oversight and allows us all to do our jobs better and closer to the expectations of CMS. We have greatly appreciated your grace, understanding, and patience.
SFY19 SFY20 Percentage Change Reported Timely 117 189 38% Overall Reported 167 220 24% Timely Reporting Percentage 70% 86% 18%
abuse, or neglect
The following are considered critical incidents and must be reported:
*If you are unsure if a situation constitutes a critical incident, please reach out to the SET for clarification before the expiration of the timeframe requirements*
LIFE HAPPENS, especially when working with high-needs populations. We expect CIRs and they are an expectation of federal safety and well-being requirements. Continue the great work reporting these incidents and always reach out with any questions.
We have noticed a decrease in pended applications in the following areas:
Justifications
Describe the maladaptive behaviors caused by the client’s Dx-associated symptoms and how those behaviors prevent effective, independent healthcare management
Objectives
Action items that support client achievement of self-identified health goal(s)
Strategies
Describes how BPHC Case Management service activities will support client in achieving self-identified health goal(s)
NOTE: We are overseen by CMS and are liable to have records audited for accuracy, completeness, and fidelity to federal requirements. We ensure that BPHC applications properly demonstrate service need. If you are ever unsure about an application component, please email the SET.
This past year, the SET made changes to the Performance Measures evaluated during audits. These changes have made the auditing process more stringent but allow us to better ensure that high quality services are being provided. Despite these changes, we did not see a significant rise in CAPs for the SFY ‘20 audit period, with 19 CMHCs not requiring CAPs! Thank you for all the hard work you do to serve your clients to the highest possible standard and we will continue to support you in providing AMHH and BPHC services.
Putting the HOME in Home- and Community-Based Services This past year we have added six new HCB residential settings! Thank you for committing to creating safe, community-integrated spaces for
Going Virtual Due to COVID restrictions, in-person site visits have been suspended and replaced with virtual visits. We have successfully completed 5 virtual visits so far. Ahead of Schedule The deadline for the Statewide Transition Plan has been extended to March 17, 2023 – a deadline we are well able to meet due to your collaboration!
We know this public health crisis caught us all off guard, so we wanted to extend an especially huge and sincere THANK YOU to all providers for unwaveringly continuing forward to provide necessary services to clients all while incorporating new COVID-related practices into the workflow.
January 31, 2020, CMS declared a Public Health Emergency (PHE) related to the emerging outbreak of COVID-19, making certain powers available to states so long as the PHE remains in effect. Among these, CMS has temporarily disallowed activities that would result in the loss or reduction of Medicaid coverage. To this end, auto-renewals of expiring Medicaid program packages, including BPHC, have been instituted. All other relevant program policy requirements must be met
Public Health Emergency
The current PHE extension is set to expire 1/21/2021 Please be mindful that an abrupt change in coverage status for clients maintaining coverage due to the PHE is possible.
If a BPHC client is approaching the end of their package date with no renewal application submitted in DARMHA, a renewal will automatically be generated and processed through to DXC to ensure no lapse in coverage occurs.
BPHC Auto-renewals
For clients planning to continue utilizing the BPHC service, the process associated with a typical application is still required to be completed.
– Please note if completed remotely due to safety precautions
– Please note if completed remotely due to safety precautions – Confirm SuperUser review
– Please indicate verbal agreement in application and documentation
Remote Audits
For the package period being reviewed, documentation requests will include all clients for whom charts should be pulled. We will require all associated documentation for the application of the period being audited to be submitted – this documentation should be dated prior to the beginning date
Progress notes for all billed BPHC services for the package period are required. Progress notes for services delivered
Period Reviewed ANSA IICP Review Submission 10/12/2019- 4/11/2020 9/20/2019 9/30/2019 10/2/2019
EXAMPLE DATES
In the interest of safety, the SET is conducting audits remotely until further
Critical Incident Reporting Reporting Quarter Timely Reporting Agencies with No CIRs Filed SFY20 Q1 87% 10 SFY20 Q2 86% 11 SFY20 Q3 90% 9 SFY20 Q4 76% 10 SFY21 Q1 86% 5
We are consistently seeing agencies not reporting Critical Incidents and not reporting timely – we have struggled to stay above the 86% minimum standard for reporting timeliness.
Critical Incident Reporting Reporting Quarter Timely Reporting Agencies with No CIRs Filed SFY20 Q1 87% 10 SFY20 Q2 86% 11 SFY20 Q3 90% 9 SFY20 Q4 76% 10 SFY21 Q1 86% 5
a CIR with known information and Incident Resolution and/or Agency Plan of Action-Steps that will be taken to follow-up or resolve Otherwise, the report will be considered untimely.
Community Connection
As a Home and Community Based Service, the heart of BPHC is a consumer’s connection to their community. In the past year of audits, we have observed few examples of evidence of community connection in IICPs. We understand that with high-needs clients there may be barriers to regular forays into the community and that personal preferences will come into play, but HCBS philosophical tenets prioritize increasing a member’s community connection and access to resources as often as possible.
support achieving their desired changes
developed with each service progress note
supported by fostering improvement
client-identified health goal with every service provided
Strengths and Goal Progress Performance Measure SFY20 Audit Average Goal Progress Identified 85% Strength Incorporation 80%
identified goals
strengths identified in ANSA and existing natural supports Identifying Goal Progress: Incorporating Strengths:
Underutilization/Misuse
Over the last year we have seen statewide underutilization and misuse of the BPHC program due to the persistent view of BPHC as a gateway to attaining Medicaid. While a benefit of BPHC is access to Medicaid, this is not the intention
in achieving independence and stability in their healthcare management and remaining integrated in their community. When looking for ways to properly incorporate BPHC into a client’s treatment plan, please consult the Provider Reference Module for a list of eligible service activities.
In the interest of moving BPHC forward as a program and as a method of addressing underutilization, the BPHC State Plan Amendment has been updated to include the following:
Technician (IHT)
180-day package period
experience of working with individuals with SMI and/or SUD These changes were approved by CMS 9/28/2020 and went into effect 10/1/2020. The BPHC Provider Reference Module is undergoing CMS review.
Adult Mental Health Habilitation (AMHH) is a habilitative HCBS program comprised of eight distinct services intended to support and assist adults living with Serious Mental Illness (SMI) and/or substance use disorders in achieving and maintaining their functional ability.
Program Overview
necessary for those at high risk for institutionalization to remain integrated in the community
family/caretaker(s)
Implemented April 1, 2020, the following updates were made to the AMHH program to increase program accessibility, usefulness and reduce administrative burden in the application process.
Program Updates
granted as a “lump-sum.” Clients choose what services they would like to use
additional units during package period The AMHH Provider Reference Module has received CMS approval and is on the AMHH landing page.
MRO Comparison
Statewide AMHH “competes” with MRO for usage – though, the two programs are mutually exclusive and designed to address different needs. MRO is rehabilitative – focused on regaining lost abilities. AMHH is habilitative - focused of attaining and maintaining abilities necessary for community-integrated living. AMHH is designed for individuals who, due to developmental hindrances, either a) have not developed the skills necessary to live independently in the community or b) are at significant risk for deterioration and/or institutionalization without supports. AMHH is ideal for long-term consumers of rehabilitative services with little to no progress on goals.
Services Comparison
MRO AMHH
Intensive Outpatient Treatment Adult Day Services Psychosocial Rehabilitation (Clubhouse Services) Supported Community Engagement Case Management Care Coordination Adult Intensive Rehabilitation Services Respite Care Skills Training and Development HCB Habilitation and Support Behavioral Health Counseling and Therapy Therapy and Behavioral Counseling Addiction Counseling Addiction Counseling Medication Training and Support Medication Training and Support
REHABILITATION HABILITATION
Restoring a pre-existing skill to previous levels of functioning Acquiring and maintaining daily living skills that may not have developing as expected
across Levels of Need
You likely already serve individuals who may be better served on AMHH. Identifying these individuals and enrolling them in AMHH could help their treatment plan more appropriately fit their needs.
Identifying Potential Clients
For long-term BPHC clients averse to change, BPHC and AMHH can run concurrently.
Clients that have one or more of the following characteristics may be better served by AMHH:
years
institutionalization
Under the 21st Century Cures Act starting 1/1/2021, EVV will be required for Personal Care Service billing codes identified by IHCP. BPHC services will not be impacted, however, certain AMHH services will require EVV. It is the recommendation of IHCP that agencies review the list of billing codes rather than focus on service type to determine scope
Any questions regarding EVV implementation or requirements should be directed to one of the following:
Contact Best Use(s) EVV@fssa.in.gov
INXIXEVV@dxc.com
1(800)-457-4584; Option 5
Following the recommendation of CMS, the SET will be conducting a statewide training on HCBS setting eligibility. All staff who work with HCBS programming are strongly encouraged to attend, as the information provided will support their ability to provide services with fidelity to program requirements. We especially strongly encourage direct service staff as they are making the initial assessments regarding HCBS eligibility.
We have introduced Compliance Codes to QA Summary Sheets to streamline federal data reporting requirements and increase accuracy of internal recordkeeping. These points have always been tracked and this change does not impact the auditing process or requirements provider-side in any way.
Contact Name/Title Contact Information Contact For?
Garnet Holsapple 1915(i) Program Specialist and Critical Incident Reporting Coordinator Email: Garnet.Holsapple@fssa.IN.gov
Reporting
Amanda Huff 1915(i) Program Specialist Email: Amanda Huff@fssa.IN.gov
Alexis Pless 1915(i) Program Specialist Email: Alexis.Pless@fssa.IN.gov
Elaine Trepanier 1915(i) Program Specialist and HCBS Lead Email: Elaine.Trepanier@fssa.IN.gov
compliance
BPHC Inbox Email: BPHCServices-fssa@state.in.us
program HCBS Inbox Email: DMHAAdultHCBS-fssa@state.in.us
FAQs
Will EVV impact BPHC services? No. When will the three service minimum be evaluated? The SET will begin evaluating at the beginning of April 2021.