Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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9/7/22  2:18 pm
Commenter: Lucy Hill Services

Telehealth for Service Facilitation

I'm writing in response to the proposed language below:

In the General Assembly budget language, the following is written:

313.DDDDDD. The Department of Medical Assistance Services, in coordination with the Department of Behavioral Health and Developmental Services, shall submit a request to the Centers for Medicare and Medicaid Services to amend its 1915(c) Home & Community-Based Services (HCBS) waivers to allow telehealth and virtual and/or distance learning as a permanent service option and accommodation for individuals on the Community Living, Family and Individual Services and Building Independence Waivers. The amendment, at a minimum, shall include all services currently authorized for telehealth and virtual options during the COVID-19 pandemic. The departments shall actively work with the established Developmental Disability Waiver Advisory Committee and other appropriate stakeholders in the development of the amendment including service elements and rated defined methodologies. The department shall have the authority to implement these changes prior to the completion of the regulatory process.

This language was passed as it is written above by the General Assembly. 

The role of the Service Facilitator is an important role to the families that we serve.  DMAS only has one billing code S5116 Mgt Training and not all 5 billing codes for telehealth. A lot of our members are AT RISK and immuno-compromised BEFORE the pandemic.  Just last week 15 of the 20 members I contacted all had COVID-19 or were recovering from it.  Telehealth allows us to reduce the risk of exposing ourselves as well as re-infecting the member again with a face-to-face visit.  With telehealth we can see the member, do our assessments and maintain safety for all involved.

There should be an option for the provider to select telehealth - even if it's reimbursed at a reduced rate. which I can feel will happen.  We are not doing monthly visits - but every 2-3 months depending on the member's needs.  The care coordinators role with the MCO has overshadowed the role that we've had prior to the CCC Plus program being implemented.  We are doing more administrative tasks and "putting out fires" that this program has created for the families that need our help.  That "help" we cannot bill for and the complaints about this program has increased tremendously.  We have to resolve the issues with authorizations, consumer enrollment, attendant pay in order to keep the member safe in their home with a paid caregiver.  Again, those are tasks that we cannot bill for the hours that it takes to resolve each week.  When we bill the MCO's we do not get all of our claims paid - denied for no prior authorization, taxonomy codes not being recognized for claims and those reimbursement issues has caused a lot of providers to quit.  The larger agencies are having a hard time retaining their facilitators and the turnover rate is happening with the care coordinators with the MCO's also. Some families have had as many as 5 care coordinators in one year but the facilitator remains the same for years. 

This program has become a nightmare for any new member who enrolls as the Fiscal Agents that we have in place - PPL, Consumer Direct and Aces$ - DO NOT GUIDE THESE MEMBERS THROUGH THE PROCESS THAT THEY ARE GETTING PAID TO DO.  CMS and DMAS needs to conduct a survey with these members to see what services are being provided properly and correct what is failing.  The facilitator is paid per assessment and not a monthly steady income.  The list of facilitators for my region has dwindled down to a handful when we used to have 20+ agencies that offered service facilitation.  



CommentID: 128524