We appreciate the opportunity to provide comment on the manual and are concerned that while the purpose of any manual is to provide clarification and interpretation for providers, in this manual, we have identified text that is more prescriptive than what is required in regulations.  This inconsistency spans DBHDS licensing, DD Waiver regulations and DMAS Provider Agreement requirements.  Providers need clarity and consistency in manuals.

We are also concerned that many references in this manual are directed to Support Coordinators rather than service providers.  We suggest that since support coordination is not a Waiver service that information limited to support coordinators belongs in a separate manual.

We are concerned that there are no instructions regarding the rounding of fractions of service when providers prepare and submit billing for the full amount of services provided.  We had previously been directed by DMAS to find this information in other (not DD Waiver) manuals and now suggest that this information be included within the DD Waiver manual.

We also offer the following specific comments as examples of these concerns.

Benefits Planning

Page 90: Criteria/Allowable Activities
1^st Paragraph
Comment:  DELETE “or” before “employment status” and ADD “or need for work incentives”.

Page 94:
Paragraph 1:  Indicates that this service requires face to face contact.
Comment:  Regulations do not specify that this be a face-to-face contact.  Alternative options must be available, including telehealth and virtual options. Overly prescriptive and not included in regulations.

Page 95: Mid-page - Bullet 1 -
Comment:  ADD “or is not available” after “have been explored and exhausted”.  Also, please clarify what documentation is needed to fulfill the requirement of “explored or exhausted”.

Group Day Services

Page 112 - Service Definition/Description
1^st Paragraph - Last Sentence:  DELETE “these services”.

Page 114:  Semi-Predictable Events
Paragraph 1:  States “The provider may request between 3-5 hours of additional “community engagement” per week that will allow the individual to choose additional community outings.
Comment:   Shouldn’t this read:  “The provider may request between 3-5 hours of additional “group day” services per week that will allow the individual to choose additional “group day” activities.  It is not clear.  If Community Engagement, then it should be included in the Community Engagement service section.

Supported Employment Services

Page 119: Criteria/Allowable Activities
Comment: 

• Recommend that bullets be entirely realigned AND be delineated between Individual SE and Group SE since the first sentence indicates that there is one element that is limited to ISE only. However, there are seven elements listed and are provided in GSE services.
• “For DMAS reimbursement to occur, the individual must be present, unless otherwise noted, when these activities occur:  Vocational or job-related discovery or assessment, supports to ensure the individual's health and safety during the hours of work”
  Comment: We recommend that the above allowable activities be noted that these activities can be conducted without the individual being present.  In fact, many discovery and assessment documents are reviewed in the absence of the individual.  Furthermore, the coordination and logistics of arranging health and safety supports, such as coordination with the employment site or family members, would precede the implementation and therefore occur without the individual being present.

Page 120 - Job Search Planning
Comment:  the following “conduct an analysis of benefits which may be accessed through Benefits Planning” is unclear. Benefits planning is a separate service.  What is the “analysis of benefits” that is being referred to? While most employment specialists can identify when an individual would need that service, it is the role of the support coordinator to refer for the service and coordinate services.  

Page 122: Documentation of the Individual’s Ineligibility for SE Services
5th Bullet:  States “Documentation of the individual’s ineligibility for supported employment service through DARS or IDEA, as applicable. If the individual is ineligible to receive service through IDEA, documentation is required only for lack of DARS funding. Acceptable documentation for the lack of DARS or IDEA funding would include a letter from either DARS or the local school system or a record of a telephone call, including name, date, and person contacted, documented either in the individual's file maintained by the support coordinator, on the ISP, or on the supported employment provider's supporting documentation. Unless the individual's circumstances change, for example, the individual is seeking a new job, the original verification may be forwarded into the current record or repeated on the supporting documentation on an annual basis”
Comment: We recommend that the responsibility for documenting Waiver ineligibility based on DARS or IDEA eligibility should be the responsibility of the Support Coordinator and should be indicated as a Support Coordinator responsibility instead of a provider responsibility.

CHAPTER 6

Quality Management and Utilization Reviews

Introduction

• First paragraph, 2nd sentence - who is DMAS’s “designated agent”? Recommend clarification between DMAS QMR staff and any subcontracted contractor for financial audits, etc.
• First paragraph, 4th sentence states “DMAS conducts compliance reviews on providers that are found to provide services in excess of established norms, ..."
  Comment:  Shouldn't this be just on those that do not provide services in accordance with the regulations?  What does "established norms" mean?
• Differentiate between requirements of services that are licensed and services that are not licensed such as those regarding criminal background checks and what “documentation” is required.
• Bullet 1, 4th sentence - Recognize that provider’s responsibility to identify “substantial changes” and inform the Support Coordinator. Comment:  However, it is the Support Coordinator’s role to obtain and coordinate those services that the individual requires to remain in the community and not the provider.