';
Tags Posts tagged with "Consolidated Waiver"

Consolidated Waiver

ODP Announcement 19-066 serves as notice of the opportunity for public comment on proposed changes to the Consolidated, P/FDS, and Community Living Waivers. These changes (referred to as waiver amendments) are anticipated to be effective on October 1, 2019. As part of this process, ODP is seeking your valuable feedback and comments on the proposed waiver amendments. There is a 30-day public comment period that began on June 8, 2019 and ends on July 8, 2019.

Whenever substantive changes are made to an approved waiver, ODP must submit an amendment to the Centers for Medicare and Medicaid Services (CMS) for approval. ODP proposes to amend the Consolidated, P/FDS, and Community Living Waivers as follows:

  • Increase the number of individuals served in the Consolidated and Community Living waivers as provided for in the Governor’s proposed budget to support more people in the community.
  • Add planning requirements for Administrative Entities to address access to needed waiver services upon graduation to individuals who will graduate from special education and who are not eligible to continue their education through the next year.
  • Provide for support of children with medical needs who transition from a facility that does not meet waiver home and community-based settings requirements to live with their families or, if living with their family is not possible, in the home of another nurturing caregiver.
  • Increase community participation of waiver participants through changes in service definitions, such as the addition of an on-call and remote support component to the Community Participation Support service and clarification as to where newly enrolled licensed facilities can be located.
  • Increase competitive integrated employment of waiver participants by allowing Supported Employment services to be provided when a waiver participant has received an offer of competitive integrated employment and the Office of Vocational Rehabilitation (OVR) has not made an eligibility determination at that time and by clarifying where Advanced Supported Employment services can be provided.
  • Develop and support qualified staff by extending the timeframe by which requirements for employment credentials or certificates must be obtained to July 1, 2019 for Supported Employment, Small Group Employment, and the prevocational component of the Community Participation Support service.
  • Promote health, wellness, and safety by clarifying that Supports Coordinators should review information in health risk screening tools when applicable and determine whether there have been any changes in orders, plans, or medical interventions prescribed or recommended by medical or behavioral professionals when Supports Coordinators monitor a waiver participant’s health and safety, and develop Individual Support Plans (ISPs).
  • Clarify the role direct service professionals perform through Communication Specialist services.

The proposed amendments to the Consolidated, P/FDS, and Community Living Waivers effective October 1, 2019 are available here.

Information regarding the proposed waiver amendment changes, including how to provide comments, can be found in the Pennsylvania Bulletin, Volume 49, Number 23, published on Saturday, June 8, 2019.

Comments received by 11:59 pm on July 8, 2019 will be reviewed and considered for revisions to the waiver amendments submitted to CMS.

Comments should be addressed to Julie Mochon, Department of Human Services, Office of Developmental Programs, 625 Forster Street, Room 510, Harrisburg, PA 17120. Comments may also be submitted to ODP at this email.

ODP will also hold two webinars to receive comments on the proposed waiver amendments. Dates, times, and links for registration to attend these webinars are as follows:

  • Thursday, June 20, 2019, 1:00 pm to 3:00 pm
  • Monday, June 24, 2019, 10:00 am to 12:00 pm

Register for webinars using this link. Questions about this communication should be submitted via email.

The Office of Developmental Programs issued ODP Communication Number 102-18 announcing delays in two areas that were scheduled to go into effect for ODP Waiver programs. Amendments to the Consolidated, P/FDS, and Community Living Waivers were recently approved by the Centers for Medicare and Medicaid Services (CMS) effective November 1, 2018. This communication is regarding the following two changes in the amendments that were scheduled to take effect on January 1, 2019:

  1. Transportation Trip was to transition from a cost-based rate to a fee schedule rate

Implementation of the changes to Transportation Trip will be delayed until July 1, 2019. This delay includes all of the following changes associated with transitioning Transportation Trip from a cost-based service to a fee schedule service:

  • Changes to the number of miles covered in each zone designation;
  • Expanding the service to be provided by relatives, legal guardians, and Organized Health Care Delivery Systems; and
  • Expanding the service to be self-directed through the Agency With Choice or Vendor  Fiscal/Employer Agent participant-directed services models.

These changes are not to be included in a person’s Individual Support Plan effective January 1, 2019. ODP has submitted an amendment to CMS to maintain the Transportation Trip service definition and cost-based rate methodology in its current approved state with no changes effective January 1, 2019.

  1. As part of qualification requirements, staff were to complete the Certified Employment Support Professional (CESP) credential, Basic Employment Services Certificate of Achievement or a Professional Certificate of Achievement in Employment Services certification for certain employment services and components of Community Participation Support.

ODP has received feedback that providers are struggling to have all required staff complete the Basic Employment Services Certificate of Achievement or Professional Certificate of Achievement in Employment Services prior to the pending January 1, 2019 deadline. As a result, the requirement for staff to have one of those qualifications will be delayed until July 1, 2019.

It is imperative that all impacted providers and common law employers that have staff who are required to have one of these employment credentials or certificates start the process now if they have not already done so. There will be no further delays granted in implementation of this qualification criteria.

ODP is drafting another set of amendments to the Consolidated, P/FDS, and Community Living Waivers that will be effective July 1, 2019. Both the changes to transition Transportation Trip to a fee schedule rate and the delay of the qualification criteria regarding employment credentials and certificates discussed in this communication will be included in those amendments with other proposed changes. ODP anticipates that the proposed amendments will be released for public comment in February or March of 2019.

All other changes contained in the waiver amendments effective November 1, 2018 remain effective and must be followed. The current approved waivers can be accessed here.

Contact RCPA IDD Division Director Carol Ferenz with questions.

ODP Announcement 098-18 announces availability of the recording of the webinar regarding the Consolidated, Community Living, and P/FDS Waiver amendments effective November 1, 2018. The Office of Developmental Programs (ODP) held two webinars to discuss the changes made to the waiver amendments as a result of public comment and ODP review. These webinars were held on October 17 and October 23, 2018. The session on October 23 was recorded and is now available online along with the PowerPoint presentation used at the sessions.

The waiver amendments are also accessible online. An online document containing a side-by-side comparison of the waiver in its previous and amended form is available. Contact Carol Ferenz, RCPA IDD Division Director, with questions.

The Office of Developmental Programs (ODP) released ODP Bulletin 00-18-04 today with long awaited guidance for claim documentation and service documentation. In anticipation of new regulatory provisions being promulgated, and in order to respond to providers’ requests for guidance until the final rulemaking is effective, ODP is providing interim guidance to providers of Consolidated, Community Living, and P/FDS Waiver services, as well as Targeted Support Management.

The CMS State Medicaid Manual (2497.2) requires accounting records to be supported by appropriate source documentation and be readily available for audit. There are federal and state requirements that documentation is to be available at the time of claim submission. Providers must maintain the documentation used to generate a claim. If the provider does not have this documentation, the claim is not eligible for Federal Financial Participation (FFP) The required documentation must demonstrate that the service is:

  • Provided to a Medicaid-eligible individual (Medicaid eligibility can be verified by checking the Eligibility Verification System (EVS));
  • Provided by a qualified provider of that service meeting licensing standards;
  • Authorized based on assessed need;
  • Rendered as authorized in the Individual Support Plan (ISP); and
  • Compliant with the Centers for Medicare and Medicaid Services (CMS) State Medicaid Manual, which states that each claim for service must include the following:
  1. Date the service was rendered;
  2. Name of the recipient;
  3. Medicaid identification number, if applicable;
  4. Name of the provider agency and person providing the service;
  5. Nature, extent, or units of service; and
  6. The place(s) the service was rendered.

Pennsylvania requirements in 55 Pa. Code Chapter 1101 specify the documentation requirements for clinical services for the treatment of a medical diagnosis. These requirements must be followed as home and community-based services are covered under the scope of Chapter 1101.

One major component of a claim record is service notes. The provider or common law employer is responsible for ensuring that service notes are completed for each service delivered to an individual. Service notes include information related to the provision of home and community-based services. Service documentation is completed by the person providing the service and is used to record information related to service delivery. The completion of this documentation is typically done during or immediately after the provision of a service.

A service note is to be completed on the day the service is delivered. The provider may choose to enter multiple service notes for multiple services for one individual in the same document or form if all required information is included.

For services that are billed in 15 minute or hour units, a service note is to be completed when services are provided by the same staff person(s) for a continuous span of 15 minute or hour billing units. A continuous span of 15 minute or hour billing units is defined as the uninterrupted provision of a service by the same staff person(s) that is not stopped or discontinued. A new service note must be completed when there is an interruption of service or a change in staff person(s) providing the service within the calendar day.

For services that are billed in day units, a service note must be completed for each day unit that documents the provision of direct or indirect services (such as staff on-call or the use of remote monitoring) for the minimum number of hours required to bill for the day unit. For residential services (Residential Habilitation, Life Sharing and Supported Living) and respite provided in licensed or unlicensed residential settings or other licensed settings (private ICFs/ID, or nursing homes), a service note must be completed for each day unit that documents the provision of at least 8 hours of direct or indirect services. For Respite services provided in private homes that are billed as a day unit, a service note must be completed for each day unit that documents the provision of more than 16 hours of service. When the provider is not rendering direct services to the individual, (the individual is at work, visiting friends, etc.) a new service note is not required to be completed. When there is a change in staff providing a service billed in day units, a new service note is not required when there is a change in the staff providing the service.

The service notes describe service activities and are intended to be an information source to be used by provider staff, the provider, the common law employer or managing employer, and the Supports Coordinator. This information is used to document that the service is being delivered as required in the ISP.

When an individual is self-directing services through the Vendor Fiscal/Employer Agent model, the common law employer is responsible to ensure service notes are completed. The service notes shall be maintained in the individual’s record by the common law employer. When an individual is self-directing services through the Agency with Choice model, the managing employer or the Agency with Choice organization will ensure that service notes are completed. The service notes shall be maintained in the individual’s and Agency with Choice organization’s records.

Supports Coordinators and Targeted Support Managers document service activities that occur with or on behalf of individuals within one business day of the activity. ODP is aware that various methods are used to document these activities such as logs, electronic notes, and recorded documentation completed during service provision and that this documentation is used to complete the Home and Community Services Information System (HCSIS) service notes. Supports Coordination Organizations and TSM providers will continue to complete HCSIS service notes in accordance with ODP guidance and training. Supports Coordinators and Targeted Support Managers have 7 days from the date of contact to enter their service notes into HCSIS.

Some services require progress notes to be completed periodically. Current ODP regulations, 55 Pa. Code § 51.16 (relating to progress notes) describe progress note requirements. Progress notes are typically an assessment written by a program specialist or other provider staff who conduct routine reviews or oversight of staff or during service monitoring. The documentation will indicate whether there has been progress or lack of progress toward the individual’s desired outcomes as stated in the ISP and documentation of restrictive intervention usage as part of the progress notes are to be completed by provider staff. Because a progress note is completed after the provision of services and submission of billing, it is not a requirement for the submission of a claim.

The bulletin provides detailed information regarding the required information necessary for progress notes. The attachment to the bulletin provides interim technical guidance for Claim and Service Documentation by service type and W code.