This article was contributed by Kerri Erb, ASNC’s Chief Program Officer.
The North Carolina Department of Health and Human Services (DHHS) has published the draft application to renew its Home and Community Based Waiver (HCBS/Innovations, formerly known as CAP) for people with intellectual and developmental disabilities (IDD). This is known as the Innovations waiver. DHHS is seeking public comment and feedback on changes made and needed to the waiver. After processing public comments, the state will continue the steps necessary to submit the application to the federal Centers for Medicare & Medicaid Services (CMS) for approval. Once CMS approves the waiver renewal application, DHHS will begin implementing the changes.
Click here to read the draft: INNOVATIONS WAIVER AMENDMENT APPLICATION
The waiver program allows people who are eligible to receive Medicaid services through an intermediate care facility (ICF MR) to instead utilize those services in home and community settings. See ASNC’s toolkit or the DHHS website for further information on the waiver itself.
DHHS has spent the past year listening to feedback on needs in the IDD community through stakeholder groups and listening sessions. Those results can be found here, and elements of needs are showing in the renewal waiver that attempts additional flexibility, predictability, and sustainability.
ASNC and many other stakeholders, including families, participated in the advisory committees and made comments throughout the draft period. Not all have been reflected, though several have been. If you have thoughts about the waiver, please take the time to review the proposed changes and submit public comment by
midnight July 13, 2015: Comments may be submitted via email to SVC_DHHS.IDDListeningSessions@dhhs.nc.gov . (See below for explanation.)
UPDATE – ASNC received the following notice from the Division of Medical Assistance (DMA) with DHHS on July 8: It has come to our attention that some comments regarding the NC Innovations Waiver amendment may not have been transmitted to DMA. If you submitted a comment prior to July 8, please resend it to: IDDListeningSessions@dhhs.nc.gov. Comments may also be submitted by leaving a voice-mail message at 919-855-4968. To ensure adequate time is provided, the public comment period is being extended through August 7 at 12:01 a.m.
As soon as the Autism Society of North Carolina has more information about the implementation plan, we will share it with families, staff, and the public. Often implementation takes much longer than originally thought because of changes ordered by CMS or others. At present, DHHS aims to begin implementation of the new waiver in January 2016.
Below are some of the changes in the renewal waiver:
- Expands the resource allocation model statewide (currently Cardinal Innovations MCO uses this), which is a combination of the Supports Intensity Scale (SIS) and other measures to correlate needs/acuity to resources (services) to develop individual budgets. This change may result in more services for some and less for others. For more information, see Appendix C-4 in the draft (starting on page 119).
- Phases in the individual budgets based on resource allocation over two years
- Increases the flexibility of services
- Replaces the current Personal Care and In Home Skill Building services with a new waiver service: Community Supports and Living. Those separate services will be blended into one to allow for more flexibility. At this time, ASNC is concerned about the removal of the in-home intensive skill building component and a lack of intensive skill building within the waiver. However, we understand that DHHS is also working on another service for autism treatment outside of the waiver through Medicaid that may alleviate some of these concerns as long as there is no gap in those critical services. We will share further information as it comes available on that proposed service.
- Adds Supported Living as a new service that allows two adults to live in a non-licensed program and receive supports. This service allows for more flexibility and integration into the community.
- Alters respite definition to allow for respite in an adult family living (AFL) setting
Other minor changes include:
- Updates military transfer slots from out of state
- Day Supports: moves to hourly units and no longer has service start and end in the licensed day facility to allow for more flexibility
- Residential Supports: updates the levels 1, 2, 3, and 4 to be determined by the individual budgeting methodology. Allows new four-bed programs in the Appendix.
- Respite: adds language around nursing level; allows respite to occur in AFL settings
- Supported Employment: removes the requirement for staff to have three years of full-time experience to help with capacity
- Community Guide: changes to Community Navigator with more specific and increased duties within the definition to help access supports and services as well as empower
- Crisis Services: specifies the use of Consultative Services allowed as part of this service as well
- Other changes and updates to service definitions, policy, and quality measures based on feedback and data review
Please take the time to review the document and submit comments to DHHS with needed changes from your perspective. ASNC will provide updates as it learns more throughout the year. If you have questions, please do not hesitate to contact Kerri Erb, Chief Program Officer, firstname.lastname@example.org.
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