Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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6/30/21  11:31 am
Commenter: Shirley Lyons

Concur with comments from VACSB and VA ACCSES
 

I firmly agree with the following two organizations recommendations: 

VA ACCSES 

HCBS 10% FMAP ARPA Funds (approx. $273.2M available):

  • Supplemental provider rate increase to sustain and build capacity for an established period of time - preferably through March 2022 - at a minimun. The DD Waiver system is in a workforce crises - exacerbated by the COVID pandemic. Programs are reducing capacity and even closing. Others are not reopening specific services. Low rates result in low wages. Low wages result in high vacancy rates. Without staff, service capacity can not be maintained or built. Individuals that receive waiver slots can not be served without providers. The DD waiver community-based system is in crisis.
  • Will help serve as a "bridge" to current rate rebase underway.
  • Retention and survival of providers
  • $2M for one-time adjustment to align Supportive Living rate to current Group Home Rate. Change would increase provider interest in providing this service vs other residential options for individuals. Rates should not dictate options or the choice of individuals between living in a congregate setting versus one's own home. (Increase utilization of service option.)

 

ARPA State General Relief ($4.3B availble)

  • DD Waiver Infrastructure Support - Economic Recovery - Provider Capacity Payments - 2% of FY19 DD Waiver billing in lump sum. (pre-COVID) Sustainability and “build back” infrastructure funding for use over the next several months while programs reopen and build capacity. On-boarding new staff and smaller staff to waiver member ratios while reopening in phases will be more expensive. Funding, similar to retainer payments or federal Medicaid provider relief payment structure. Lump sum payment. Needs to be simple and flexible to allow providers to spend based on their individualized needs - workforce, program capacity sustainability and capacity building, and COVID mitigation. Based on provider authorizations pre-COVID. There has been significant attrition of authorizations because of COVID and DBHDS policy. (Capacity building - Build Back Better)
  • COVID expense reimbursement - Reinstate full Phase 2 reimbursement through December 2021. Expand to additional DD Waiver Services and Providers other than Day Services and Residential. Recommend elimination of cap per person calculation or adjust calculations for per person cap. Reimburse previous certified expenses from Phase 1 that were not reimbursed because of previous arbitrary per person cap. (Additional pandemic expenses not covered by current rates)

·      and VACSB:

 

VACSB Proposals for Use of Enhanced FMAP under ARPA
 

The Virginia Association of Community Services Boards strongly believes that DMAS should use the enhanced FMAP funds available as a result of the ARPA to serve as a stop-gap measure until a full rebase of the rates for DD Waiver services is completed and fully funded by the General Assembly.

This approach will:

  • Ease the incredible burden providers face as a result of the increase in the minimum wage as Medicaid providers are reimbursed at the Medicaid rate regardless of whether that is enough to cover the cost to deliver the service.
  • Help with the recruitment and retention of a workforce to support Waiver service delivery.

This approach should be implemented as follows:

  • The state should not place any more restrictive requirements on accessing the funds than what the federal government requires and the state should interpret the CMS guidance on these funds as broadly as possible.
  • Providers should receive payments for their portion of the funds, based on claims billed, on a quarterly basis.  For example, on 01 AUG 2021, a payment would be made based on billing for any eligible services over the period of time between 01 APR 2021 and 30 JUN 2021.
  • Documentation and accountability for the appropriate use of the funds should be confirmed in conjunction with an existing auditing/review process and cycle.  For example, appropriate use could be determined at an upcoming QMR review for the provider as opposed to requiring a separate process for these funds.

As the state begins to interpret CMS guidance in this area, the VACSB asks that it consider funding for the existing Individual and Family Support Program (IFSP).  The VACSB believes this could fall under the category of enhancing HCBS services, or perhaps, while not strictly “reducing the wait list” per the CMS guidance, at least it could serve as a bridge for families while they are waiting for a DD Waiver slot.

CommentID: 99320