14 comments
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.
It is my understanding that Service Facilitation has been included in the draft amendment from DMAS with only 1 of our 5 services - Management Training (MT). MT is only formally provided at the request of an EOR and is normally completed during a Routine Review or Reassessment. From our experience, MT is 99.9% of the time, never a stand-alone service.
The actuality of the amendment, the way it is written, DMAS has not included Service Facilitation at all in their request to continue to allow telehealth as a delivery method after the PHE has ended.
The budget language states that “……ALL SERVICES CURRENTLY AUTHORIZED FOR TELEHEALTH AND VIRTUAL OPTIONS ……” should be included in the amendment.
We submit that all of our services should be included in the amendment and submitted to CMS for their decision.
Services: T1028 – 6 Month Reassessment
99509 – Routine Assessment
S5116 – Management Training
H2000 - Initial Comprehensive Visit
S5019 – Comprehensive Training
Thank you.
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.
OT; PT, SLT, school, social, case management, care coordination… so much to keep up with!
We have been grateful for the opportunity to have a break, comply with services, but in a way that doesn’t take negotiating a million things, to accomplish.
Parent as provider and telehealth have been tremendous! Please keep it up!
Please allow permanent telehealth/virtual visits for parents that are receiving services. This will help members stay safe. COVID-19, MonkeyPox, and other diseases are still out there. Allowing parents to stay virtual/telehealth allows them to keep their family safe in their homes. Virtual/Telehealth allows us to do everything we can do in a person. Please let's keep this going forward.
Thank you for the opportunity to write to you all under open comments. First, I want to say I am humbly grateful that we have been able to service our clients through Telehealth means. This has been a life line for so many clients during a time where confusion, sickness and anxiety has taken over their lives. Our team works very hard to assist the families of the Long Term Care Waivers with their Consumer Direction. I remember a time ( before SF companies ) when DMAS themselves worked individually, helping consumers and guiding them through the processes. There were several caring individuals at DMAS who were striving to bring to these folks a program that would help reshape their lives and provide security to them. When I first started my journey as a Service Facilitator I wanted to share with clients the possibility of a new program; that would still help assist them and they have that continuity in care they were missing. My business wasn't about rules or regulations, at the heart it was about the people. Though we do have rules and regulations that we should follow, I still placed people first. I have heard from several clients as I am still functioning ( more now that ever ) as a working Service Facilitator within my own company. The stories they tell me range from having Covid-19 and being so sick they thought they were not going to make it home again. Some still carry residual Long Covid-19 ( as I am being told ) which several symptoms have stayed with them after the initial Covid-19 diagnosis on their already frail and weak bodies. Though they are scared and have fears, my team and I are very happy to still be able to help assist them with their issues and or problems related to their Long Term Care Services and Consumer Direction through Telehealth. I recognized Telehealth as an essential tool in ensuring clients are able to access the healthcare services they need in as safe a manner as possible . Then in DMAS amendment, you all are stating that only 1 of our 5 services can be considered as telehealth??? Especially after the General Assembly stated that ALL SERVICES currently authorized for telehealth and virtual options during the Covid-19 pandemic should be included at minimum!!! DMAS - I have watched several YOU TUBE videos that DMAS creates from time to time. I want to bring your attention to " What Is Telehealth? A Message from Virginia Medicaid and Our Partners " It currently has 895 views and was dated August 18, 2020. Segment where as Karen S. Rheuban, MD. Professor of Pediatrics, Univ. Of Virginia states ( Quoting ). " Telehealth medicine is NOT A Clinical Specialty in and of itself. It's simply the use of technology to connect a patient to a provider when they are physically separated from one another." What Is Telehealth? A Message from Virginia Medicaid and Our Partners
The telehealth has kept my patient safe as well as my family..also has kept the workers safe from covid and from spreading from house to house on visits
I’m fine either way but I like Telehealth system because it helps us to be safe from flu and COVID-19
I prefer telehealth for safety health reasons-it’s a great program & very easy to comply with
I like the phone/telehealth option.i would like to see it become permanent.
I like to keep telehealth permanent for several reasons
Firstly the fact that its safer for my parents to not get any covide or flu or anyother viruses that might be going on .
Secondly, it would make my mom happy as she gets scared every time someone comes home.
The pandemic has taught us that there is a huge problem with access to health care. Telehealth has been a great tool and should continue.
Telehealth is GREATLY NEEDED. IT COULD SAVE LIVES…..INFLATION IS UP.. GAS IS UP..but moreover We are not out of this PANDEMIC. THE FACILITATORS ARE IN/OUT OF TONS OF HOMES WE do not know what other VARIANTS is going to come about. WE CAN ALL GET SICK/DIE LIKE THIS. With that being said some of us take the pandemic and COVID-19 very seriously however we do have to comply with the rules of the program (DMAS)for our loved ones to be able to have a facilitator come to our homes. I personally DO NOT LIKE THE FACT that someone that has just been IN MULTIPLE HOMES in a days time each day “COULD COME INTO MY HOME AND GIVE US COVID…..” let me be clear COVID 19 is still spreading. So someone Has to come to my home just to do a routine check that can be done by phone or telehealth that is how germs and Covid & the flu etc. gets spreaded my facilitator that comes to my home has had Covid several times. I strongly strongly believe that it is due to going in and out of other peoples homes and Covid it is still a thing that we all need to take seriously not only that it will help keep the facilitators in their jobs and save them money and sickness if they don’t have to run from house to house making themselves sick but moreover putting extra miles on their cars and GAS is as high as it is it seems it would be a no-brainer for you all to do this. Especially if you are trying to keep Covid down why wait to new variance come out and then we all have to suffer the facilitators have kids at home as well that they can take Covid/the Flu back to. If doctors offices are able to continue with telehealth why can’t DMAS……THIS COULD KEEP THE FACILITATORS WITH DMAS IF THEY DO NOT HAVE TO QUIT DUE TO GAS & INFLATION LETS SAVE LIVES DMAS…..WE SHOULD BE ABLE TO HAVE A SAY WHO COMES IN AND OUT OF OUR HOMES…!!!! WITHOUT Compromising our love ones health assistance but more over our lives CAN U IMAGINE LETTING SOMEONE COME INTO YOUR HOME THAT HAS BEEN IN TONS OF HOMES AND GIVE YOU AND SOMEONE IN YOUR FAMILY COVID AND THEY DIE OVER A PROGRAMS UNWILLINGNESS TO DO TELE HEALTH. Why would DMAS NOT DO THIS??? COVID HAS SLOWED DOWN HOWEVER WHO KNOWS WHAT VARIANT MIGHT SPIKE AND WE BACK WHERE WE STARTED WHY RISK IT….??? It is my deepest hope DMAS THINK ABOUT SAVING LIVES…!!!! People don’t need to die in vain…… thank for your time!!!!
COMMENTS: Virginia Association of Community Rehabilitation Programs Dba vaACCSES
HCBS Medicaid Waivers – Amendment to CMS
Continued Permanent Use of Telehealth (Virtual Services) Platforms in Service Delivery
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.”
As the original advocacy group that asked Delegate Sickles and Senator Hanger to patron this budget amendment, we were clear that our intention, as well as our patrons, was to include group day services, community engagement and supported employment as services that were to be included in the provision of HIPAA compliant telehealth (virtual) methods of service delivery.
It has been almost two years since the amendment was approved by the General Assembly.
Group Day Services should be included in this submission of the amendment to CMS and should not have to wait for another opportunity for an amendment to CMS. CMS can approve this flexibility as they approve the other flexibilities proposed for Benefits Planning, Community Engagement, Community Guide, Individual & Family/Caregiver Training, Independent Living Support Services, In-Home Support Services, Peer Mentor Services, Service Facilitation, and Therapeutic Consultation. All have to be further developed through regulations and Manual revisions – to include Group Day Services is not only efficient but fulfills the intent of the General Assembly and the two leadership patrons.
The amendment can’t be more clear in requiring all services authorized during the pandemic that were delivered virtually during the pandemic – which included Group Day Services. Distance learning (telehealth) is a viable service delivery option and must be available to all DD Waiver recipients in the future. This will allow individuals to continue acquiring skills as authorized in their individualized plans as well as attain new skills and socialization opportunities needed in today's virtual environment. This is especially critical for individuals that have stamina issues that would like a combination of face-to-face and virtual (telehealth) options. We are not asking for 100% time to be telehealth. We understand that there must be “guard rails” or limits to virtual delivery of services. We are asking that a portion of their plans be able to include virtual delivery of services and skill building activities. For example, 3 days per week in person and 2 days a week of limited telehealth (virtual) hours in the morning/afternoon.
We are not asking that all CD services be included as 100% telehealth. There can be parameters that define both face-to-face requirements and telehealth (virtual) requirements by combining the two to allow the greatest flexibility on behalf of individuals and families.
DMAS is misrepresenting the fact that they have included Service Facilitation in their amendment by ONLY including 1 of our 5 services. Management Training, which is the only service under SF that was included in this draft amendment, is not typically a stand-alone service. It is usually done in conjunction with a Routine or Reassessment visit when the EOR requests retraining during a visit. Therefore, the reality of the amendment the way it is written is that DMAS has not included Service Facilitation at all in its request to continue to allow Telehealth as a delivery method after the PHE has ended.