09 April 2012
Received via email from Dr. Pat Porter, DHHS consultant to the NC General Assembly:
Hello
Crystal, I followed up on your question regarding the rates of pay for
direct care workers per the changes in approved service definitions.
While this seems to be resolved for now, there were a couple of issues
that caused some confusion with the transition of ECBH to the B-C
Innovations Waiver.
The
CAP IDD waiver is not a perfect crosswalk to the Innovations waiver.
In the CAP Waiver, recipients have had access to Home and Community
Support (HCS), which is primarily a habilitative service with a very
small amount of personal care (PCS) blended in. (CAP IDD also has the
basic PCS). So, HCS in CAP cross-walks to In-home Skill Building and
PCS in the Innovations waiver. In-Home Skill Building (a hab service)
pays more than PCS.
As ECBH was cross-walking the services during
transition, they cross-walked much of the HCS to PCS, rather than
In-Home Skill Bldg. Again, HCS/In-Home Skill Bldg. pays a higher rate
than PCS. But, there was a reason for this. ECBH could find very few
habilitation goals on the plans being reviewed and, unfortunately,
they found little or no evidence of assessments supporting the
recipient's ability to benefit from habilitation. Based on the
assessment information they found, it appeared that most recipients were
actually receiving more PCS than hab. As you know, the Managed Care
sites must pay for the actual services needed and rendered.
With
further review and technical assistance from the Division of Medical
Assistance, ECBH elected that the wisest course of action on behalf of
their consumers would be to cross-walk HCS directly to In-Home Skill
Bldg for ease of transition. I am told that these cross-walked plans
will last for the remainder of the plan year. This is the action that
had already been taken by Western Highlands and PBH as they made these
transitions. I am told that ECBH alerted the providers in a March 22
Communication and in a town-hall meeting in Greenville but, apparently,
not everyone has gotten the word yet.
At
some point soon, ECBH will be compelled to address the
habilitation/PCS issue. Perhaps this will occur in Annual Revisions.
Care Coordinators have been alerted to pay attention to additional
assessments that may be needed to support habilitation goals. Be
assured that the Care Coordinators will develop plans based on what the
recipient needs and wants ( that’s the rule). Utilization Management
may, however, deny a habilitation service if there is not demonstrated
medical necessity per CMS rules. Certainly, if that should occur, ECBH
will offer review and appeal rights. The DHHS will be monitoring the
process to assure due process.
This is a long reply but I hope it is helpful to you
