Training Agenda Welcome and Introductions Presentation from KDADS - - PowerPoint PPT Presentation

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Training Agenda Welcome and Introductions Presentation from KDADS - - PowerPoint PPT Presentation

Training Agenda Welcome and Introductions Presentation from KDADS Presentation from WSU CEI Questions from You Introduction to Upcoming Provider Learning Collaboratives Breakout Room Scenarios Provi vider er R Remed


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SLIDE 1

Training Agenda

  • Welcome and Introductions
  • Presentation from KDADS
  • Presentation from WSU CEI
  • Questions from You
  • Introduction to Upcoming Provider Learning Collaboratives
  • Breakout Room Scenarios
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SLIDE 2

Provi vider er R Remed ediation

Next Steps on the Road to Compliance for Final Rule in Kansas Presenters: LaTonia Wright, KDADS Russell Bowles, KDADS

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SLIDE 3

This training w will a address…

  • The remediation process and expectations
  • Remediation strategies
  • Accessing the remediation tab and submitting a remediation plan
  • Technical supports and resources
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SLIDE 4

Rev eview w of K Key ey P Phases

  • Systemic Assessment
  • Provider Self Assessment
  • Heightened Scrutiny
  • Transition
  • Ongoing Monitoring
  • New Providers/Sites
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SLIDE 5

Tim imelin line R Revie iew

  • 03/14/2014 – CMS published HCBS Settings Final Rule
  • 09/15/2019 – Provider Self-Assessment opened in Kansas
  • 02/29/2020 – Provider Self-Assessment closed in Kansas
  • 07/01/2020 – Heightened Scrutiny Categories 1 and 2 must be

submitted to CMS

  • 10/30/2020 – Heightened Scrutiny Category 3 must be submitted to

CMS

  • 07/01/2021 – All setting(s) remediation evidence must be submitted to

community connections (KDADS)

  • 03/17/2022 – All settings must be in compliance with the Final Rule (CMS)
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SLIDE 6

Systemic c As Asse sessm ssment

  • Kansas has and continues working to modify systemic documents to

come into compliance with the Final Rule, which includes a review of statutes, regulations, policies, procedures and contracts.

  • There will be opportunities for stakeholders to review and provide

feedback on changes during public comment periods.

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SLIDE 7

Provid ider S Self lf-Ass ssessm ssment

  • This phase has been completed for those in attendance (Yes/No)!
  • KDADS continues to review assessments to determine what areas

providers need to remediate.

  • Remediation for Kansas is based on the idea that all providers and

settings willing to come into compliance - will be able to do so.

  • Remediation notifications are being processed for provider

notifications.

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SLIDE 8

Heightene ned d Scrutiny

  • HS is triggered by the provider self-assessment.
  • Heightened Scrutiny (HS) has 3 categories.
  • Category 1: Settings that are located in a building that is also a publicly or privately
  • perated facility that provides inpatient institutional treatment
  • Category 2: Settings that are in a building located on the grounds of, or immediately

adjacent to, a public institution

  • Category 3: Any other settings that have the effect of isolating individuals receiving

Medicaid home and community-based services (HCBS) from the broader community of individuals not receiving Medicaid HCBS.

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SLIDE 9

Heightene ned d Scrutiny

  • Due to triggered flags during the self-assessment regarding location

and/or physical characteristics of the setting, an on-site visit by KDADS must be completed to determine if the setting is HCBS compliant.

  • Heightened Scrutiny notifications to schedule a site visit will come

from the Heightened Scrutiny Director or team. This will be a second notification from the remediation notification.

  • A provider must have overcome HS and be willing to collaborate with

KDADS during the process in a timely manner in order to meet federal deadlines for implementation of the Final Rule.

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SLIDE 10

Transition

  • Settings choosing not to come into compliance or unable to come

into compliance with Final Rule will not receive HCBS Medicaid funding after March 17, 2022.

  • HCBS clients must transition to a compliant setting before March 18,

2022 to continue receiving HCBS funding.

  • All remediation evidence must be submitted to

communityconnectionsks.org by July 1, 2021.

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SLIDE 11

Transition

  • The July 1, 2021 date will allow time for KDADS desk review of

submitted evidence and to work with the provider to come into compliance before March 17, 2022.

  • Please note that if submitted evidence shows a setting is unable to

meet final rule requirements by March 17, 2022, it will no longer receive HCBS funding beginning March 18, 2022.

  • Transition notifications to persons served must begin no later than

October 1, 2021.

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SLIDE 12

On Ongoi

  • ing Monitor
  • ring
  • After a setting comes into full compliance with the Final Rule, ongoing

monitoring will ensure it remains in compliance.

  • The ongoing monitoring process is still being reviewed at KDADS to

determine who will complete these ongoing tasks.

  • State regulations are in the process of being updated.
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SLIDE 13

New and Cl Closed Se Settin ings

  • New settings will have an onboarding process at a later date in 2020.
  • KDADS is currently working on IT supports to enhance the database

system.

  • New Setting After 2/29/20?
  • Provider should use toolbox documents found at communityconnectionsks.org under

the “Support Tab” to assess setting(s) for HCBS compliance characteristics.

  • Use missed deadline form located at communityconnectionsks.org to notify KDADS
  • f a new setting or closed setting.
  • KDADS will follow-up with provider once onboarding process is available.
  • All HCBS settings will be tracked in the database system, including closed
  • settings. Closed settings are not deemed compliant. A new assessment will

be required for a closed setting if it reopens in the future and is seeking to utilize HCBS funding.

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SLIDE 14

Road to Com

  • mpliance

Coming into compliance -

  • Provider – review and consider each setting’s physical location,

policies, procedures and practices when identifying strategies to come into compliance with the Final Rule. The requirements are to not have institutional like characteristics in HCBS settings.

  • It is okay as a provider to have blanket policies, procedures and

practices across multiple settings if possible.

  • Most providers are not yet fully compliant, and that is okay.
  • Wyoming – 4.62% of settings in full compliance after initial assessment
  • Tennessee – 14% of settings in full compliance after initial assessment
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SLIDE 15

Remedia iatio ion: N : Notif ific icatio ion

  • Once the Self-Assessment/Validation/Desk Review Phases Concludes:
  • An email and letter is sent to the provider (for each setting)

describing what needs to be remediated.

  • If there is nothing to be remediated, the provider will get a letter
  • f compliance (for each setting).
  • The email and letter describes the remediation process and

instructs providers toward a timeline of plan submission for the setting.

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SLIDE 16

Remedi diation n Plan

  • For each self-assessment question that needs to be remediated, the

provider will select a remediation strategy and a timeframe for when the strategy will be completed. Timeframes are required as part of the remediation plan.

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SLIDE 17

What C Can Be Used ed As E Eviden ence? ce?

  • Photographs- These can be from internet map sources and/or photos taken

by the agency.

  • Policy/Procedures- These are agency documents that explain how an agency

provides guidance in different areas.

  • Handbooks- This is a document that supports or clarifies agency

policies/procedures.

  • Manuals- This is a document that supports or clarifies agency

policies/procedures.

  • Other Documentation (i.e., agency forms, agency brochures, agency

pamphlets, rental agreements, support plans etc. - If these documents are used, they should provide support or clarification to policies, procedures, handbooks or manuals. Providers, please do not submit PHI on any evidence.

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Remediation St Strategies – Guidance ce On On:

  • Writing Policy and Procedure
  • What policy should look like.
  • What procedure should like.
  • Handbooks and Manuals
  • What handbooks/manual should look like.
  • What policies support the handbook/manual?
  • Staff and Volunteer Training
  • What constitutes “good” training.
  • What policies support the training manual?
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SLIDE 19

Writ itin ing P Polic licie ies and P Procedures

  • Policies and/or procedures are the preferred documents for setting evidence.
  • Policies and/or procedures should have the following qualities at a minimum:
  • Organization Identification.
  • Policy Title and/or Policy Number (what is this policy about).
  • Policy effective date (revised date is acceptable).
  • Regularly review for updates as needed.
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SLIDE 20

Ha Handbooks

  • Handbooks should support and/or clarify a policy and/or

procedure.

  • Handbooks should have the following qualities at a minimum:
  • Organization Identification.
  • Purpose of Handbook (can be seen in the title or stated in a

purpose statement).

  • What policy and/or procedure does the handbook support?
  • Is it a handbook for persons served or staff?
  • Effective Date (can be on document or as evidenced by a

signature/date page or initials/date).

  • Does the handbook answer the question?
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SLIDE 21

Manuals

  • Manuals should support and/or clarify a policy and/or procedure.
  • Manuals should have the following qualities as a minimum:
  • Organization Identification.
  • Purpose of Manual (can be seen in the title or stated in a purpose statement).
  • What policy and/or procedure does the handbook support?
  • Is it a handbook for persons served or staff?
  • Effective Date (revised date is acceptable).
  • Does the manual answer the question?
  • Review and update as needed.
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SLIDE 22

Other Documentation

  • Other documentation submitted as evidence must support or link

back to a policy, procedure, handbook or manual (these might include; residential agreements, rental agreements, person centered plans, behavioral support plans, agency forms, etc.).

  • Keep in mind there can be exceptions and a document can be used as

stand alone evidence if it can validate and/or answer the question.

Ot Other er Documentation

  • n
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SLIDE 23

St Staff f and Volunteer Training

  • What constitutes “good” training?
  • Regularly making staff and volunteers aware of

policies, procedures and practices.

  • Clear correlation between staff and volunteer

training, policies, procedures and practices.

  • Regular reviews to update as needed.
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SLIDE 24

Cl Clarifi fication and Tips

  • It is possible, that questions marked as compliant by the provider on

the self-assessment, had evidence attached that did not meet validation criteria. These questions will be seen in remediation and may need clarification.

  • If a question is in bold red on a remediation plan, it needs to be

addressed first, as these relate to heightened scrutiny. The Provider should ensure that their resubmission evidence addresses what is asked in the question.

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SLIDE 25

Cl Clarifi fication and Tips continue nued… d…

  • If there are multiple sites to remediate, keep a log of what has

changed, this can make remediation for sites governed by the same policies much faster.

  • Before picking the “other” box, carefully look at the listed options.

Can what is envisioned for the setting remediation fit into one of the strategies already listed? If so, this can save time.

  • Check and double check evidence for adherence to the specific
  • question. Example - does staff training policies also extend to

volunteers? Can people come and go “whenever they please” and so

  • n?
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SLIDE 26

Remed ediation

  • n Technical G

Guidance ce

A Walk Down the Road to Compliance Presenter: Percy Turner

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SLIDE 27

Remed ediation

  • n From t

the e Top…

  • Logging back in (Communityconnectionsks.org)
  • Forgot password? (I told you to remember it…)
  • Technical Tips:
  • Do not use Internet explorer, yes - still.
  • Uploading videos will exceed the maximum file size. They are usually too big.
  • One requested change might cover multiple points of remediation. However,

evidence still must be uploaded for each remediation section.

  • Remediation plans are per site only. Approval of a plan does not mean it can

extend to all sites automatically.

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SLIDE 28

Accessing t the R Remediation T Tab

  • Once a provider receives remediation notification, they should

navigate with their internet browser (do not use Internet Explorer) to www.communityconnectionsks.org.

  • Log-in with the same information the provider used to create and

complete the self-assessment(s).

  • After logging in, the dashboard should look like this for the

remediation tab:

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SLIDE 29

The D Dashboard

The Remediation Tab

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SLIDE 30

Dashboard Part 2

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SLIDE 31

The R Remediation Tab

  • Click on the tab the red arrow pointed at.
  • Now you should see something that looks like this:
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SLIDE 32

Remedi diation n Tab:

  • Click on name of the site to be taken to the next page. This page will

have all questions in need of remediation and will look like this:

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SLIDE 33

Remedi diation n Tab

  • Click on the specific question to access the remediation strategies.

Should look like this:

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SLIDE 34

Se Selecting a strategy

  • Select (click the check box) a remediation strategy that fits the needs
  • f your site. You will be prompted to enter a date representative of

when the proposed changes will be made.

  • This date cannot be set past July 1, 2021 to allow time for

remediation activities to be reviewed by KDADS or time for transition

  • f persons served if needed.
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SLIDE 35

Remed ediation

  • n: The “

e “Ot Other” B Box

  • Each question on a provider’s remediation table for each setting will have

pre-populated suggested remediation steps.

  • A provider might or might not feel a suggestion is right for the setting.
  • A provider is able to choose not to follow the suggested action(s). There is

a field marked “other” that can be chosen.

  • If a provider marks the “other” box, KDADS will have to review and accept

the suggested remediation.

  • KDADS is advising that a provider wait for their feedback on the

submitted remediation plan listed under the “other” section of a question.

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SLIDE 36

Evi vidence ce

  • Once a remediation strategy has been selected, alongside a timeline

(before July 1, 2021) the remediation tab will accept evidence. Submission of evidence represents the provider following through on a selected strategy.

  • All evidence must be submitted by July 1, 2021.
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SLIDE 37

Remedi diation n Evidence continue nued. d...

  • Evidence must be uploaded for each item listed on a remediation

plan.

  • Evidence will be validated in the same manner as the self-assessment.

It will be first reviewed by the Validation Team and then by KDADS Desk Review Team.

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SLIDE 38

The A Activity Lo Log

  • The activity log is an active document that will show your progress

through Remediation.

  • While the system is designed to give the provider an email

notification each time the status of a question changes on a remediation plan, it is important that the provider is diligent on checking each site through the process.

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SLIDE 39

Suppor

  • rts and Resou
  • urces
  • Toolbox at https://communityconnectionsks.org
  • One-on-one support: Call 1-800-445-0116
  • There is a “Live Chat” box and “Contact” tab at https://communityconnectionsks.org
  • You can sign up for email updates at https://communityconnectionsks.org
  • Stakeholder Calls take place the 3rd Wednesday of every month from 12-1 pm and 5:30-6:30 pm
  • Phone Line: (866)620-7326
  • Code: 989 114 3937