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ARTICLE

Date ArticleType
11/1/2016 INCAL
Update on HCBS Waiver Program & Provider Enrollment

1. HCBS Statewide Transition Plan – On September 28th, FSSA submitted the 3rd version of the transition plan.  Specific to Assisted Living, the Division has become even more clear they intend to abandon the residential care facility license as a requirement for participation in HCBS AL services. Whether or not RCF facilities can participate beyond the minimal compliance process they discuss is unknown. Please read pages 7-9 regarding AL services. There are other relevant pages (such as the still very thin section on Heightened Scrutiny, page 12), but these give you the most direct feel for where the DA is headed.

2. October 26th Conference Call

a. Billed as a planning discussion to kick-off the next phase in designing AL services under the waiver, a group of  government, association, and providers were invited.

b. The DA indicated that a final version of the Statewide Transition Plan will be released later this week or early next week. This new draft won’t be substantively different than what is posted, at least related to statements regarding AL services or the future of RCFs being able to participate. 

c. Referenced the attached draft HCBS Settings Rule_Criteria for AL Settings (previously sent to you) as the foundation for their work going forward on AL. I’ve also attached their draft provider certification survey (excel file)

d. A series of meetings are to be scheduled to tackle individual compliance issues, as follows:

i. Nov. 10th meeting - Lease agreements. Will include discussion of: choice of available settings by participants, visitation, unit decoration, sharing of units and roommate choice

ii. Nov. 29th meeting - Remediation Plan process, leading into provider training on Dec. 13th

iii. Nov. 29th meeting - Physical characteristics – CMS rule, current Indiana requirements (accessibility, privacy, choice of daily activities, individual environment, food access at any time, doors/locks/access, memory care)

iv. Dec. 19th meeting – integration with the greater community, choice of services and how provided and coordinated for the consumer

v. Jan. 5th meeting – heightened scrutiny process, individual modifications for person centered planning (focused on memory care, ability to modify requirements when necessary for person’s benefit and care plan).

vi. Jan. 26th meeting – focus on the next HCBS program, what it looks like. Information will come out in early January on DA’s research of what other states do and outline what the next phase would look like and to be submitted to CMS

e. As to RCF ability to participate in the new HCBS program, they say not to dwell too much on the language in the Statewide Transition Plan as being a bar to RCFs ability to participate, but they have to take the law as it stands now. I don’t agree with their characterization of the language in the STP, but they did signal an openness to continue dialogue on this point.

If you have any questions, please contact Zach Cattell at zcattell@ihca.org