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11/4/21  8:32 pm
Commenter: Moms In Motion/At Home Your Way

Provider Input on DD Manual: Covered Services & Limitations Chp 4
 

COVERED SERVICES & LIMITATIONS

DD Manual Chapter 4

 

  1. Manual pg 203 - Service Facilitation begins after CD services in general have been described. The following regulation should be added to the language in this manual (12VAC30-122-150, A, 2, d, e, and f) before what is currently on pg 204:

    • A. Criteria for consumer-directed model of service delivery.

      • 2. Requirements for individual.

d. Individuals choosing consumer-directed services may receive support from a CD services facilitator. Services facilitators shall assist the individual or his EOR, as appropriate, in accessing and receiving consumer-directed services. This function shall include providing the individual or EOR, as appropriate, with employer of record management training including a review and explanation of the employee management manual and routine and reassessment visits to monitor the CD services.

e. If an individual choosing consumer-directed services chooses not to receive support from a CD services facilitator, then another family member or caregiver other than the EOR shall perform all of the duties and meet all of the requirements of a CD services facilitator, including documentation requirements identified for services facilitation. However, the family member or caregiver serving as the services facilitator shall not be reimbursed by DMAS for performing these duties or meeting these requirements.

f. The individual's support coordinator/case manager may also function as the paid services facilitator.

  • If the change proposed here is made, the last bullet on page 205 can remain as is.

  • Based on the proposed suggestion here, the explanation in paragraph 1 of page 207 needs to be moved up or copied in the CD section above SF.

  1. Manual pg 204, last paragraph --> After the first sentence, adding the following would be beneficial:

    • “If the individual chooses NOT to have service facilitation, the support coordinator must document which family member or caregiver other than the EOR shall perform all of the duties and meet all of the requirements of a CD services facilitator.”  (VAC1230-122-150, A, 2, e)

  2. Manual pg 205, paragraph 3 --> “When two individuals who live in the same home….”.

    • Adding the following additional statement would be beneficial , “If the individual has chosen not to have Services Facilitation, then the family member or caregiver acting in that capacity will be responsible this assessment.”

  3. Manual pg 205, paragraph 4 --> In order to gain more clarity, a modification to the first sentence is suggested “An individual who has chosen consumer direction may choose, at any time, to voluntarily change all or part of their services to the agency-directed model as long as he/she/they continues to qualify for the specific services.  For example, he/she/they may choose to move just Respite or part of the Personal Care hours to agency, while maintaining all, or a portion of their Personal Care under the consumer-directed model of service.”  The second sentence in that paragraph needs to read, “The services facilitator, or family member or caregiver acting in that capacity, and the support coordinator are responsible for assisting….”

  4. Manual pg 207, paragraph 2: “If an individual choosing consumer-directed services chooses not to receive support from a CD services facilitator, then another family member or caregiver, other than the EOR, can perform all of the duties. The family member or caregiver serving as the SF will not be reimbursed by DMAS for performing these duties or meeting these requirements.”

    • While this aligns with the regulations, how is this NOT a conflict of interest?

      • This section should clearly state what the requirements are, as the regs do, for individuals choosing this option.

        1. “...meet all of the requirements of a CD services facilitator, including documentation requirements identified for services facilitation.”

          1. This should state the educational requirements, knowledge, and all the same requirements that a contracted CDSF provider would need to meet. 

  5. Manual pg 207, paragraph 3

    • Rewording this section for better understanding/clarification:

      • “Transitions from the CCC Plus Waiver to a DD waiver will only occur only on the first day of a month.”

      • “The SF, or family member or caregiver acting in that capacity, has a role to play in this process in order to ensure continuity of care.”

      • bullet 2: There needs to be a space between the words "should" and "call" in the last sentence.

  6. Manual pg 208, bullet 5

    • Rewording this section for better understanding/clarification:

      • “For consumer-directed services, the services facilitator, or family member or caregiver acting in that capacity, must submit the Fiscal Agent Request Form to the FE/A and initiate the change in fiscal employer agent, if applicable, and the change from CCC Plus Waiver services to DD Waiver services.”

  7. Manual pg 209, bullet 1, & bullet 3

    • Rewording this section for clarity:

      • Change language to "consumer training" instead of "management training", which is a different billable code for CDSF providers.

  8. Manual pg 209, last bullet

    • The language used here compared to the regulations (12VAC30-122-500, B, 4) is different enough to cause confusion and we request modification.  Alignment with the regulation is suggested:

      • “The services facilitator, during routine quarterly visits, shall also review and verify….”  The manual says, “routine semi-annual visits”.  This language should be changed to match the regs. The manual should also add “or family member or caregiver acting in that capacity” to that sentence as well.  

  9.  Manual pg 210, bullet 1, 2, 3:

    • Suggested modification: “The services facilitator, or family member or caregiver acting in that capacity, must be available during standard business hours to the individual or EOR by telephone.” 

  10. Manual pg 210, bullet 4

    • Alignment with the language used in the regulations is requested/suggested (12VAC30-122-500, B, 8):

      • “Service facilitation service shall be provided on an as-needed basis as mutually agreed to by the individual, EOR, and services facilitator but at a minimum quarterly routine visits shall take place.”

      • The manual has been changed to say, “Services facilitation will be provided on an as-needed basis as mutually agreed to by the individual, EOR, and services facilitator but, at a minimum, routine semi-annual visits.  

        1. The manual should be changed to match the regs.

      • Also, the language “or family member or caregiver acting in that capacity” needs to be added.  

  11. Manual pg 210, last sentence

    • Requested modification of the language used:

      • “The SF, or family member or caregiver acting in that capacity, may not be the individual enrolled….”

  12. Manual pg 211, 

    • 1st sentence - modification of language requested: “The SF, or family member or caregiver acting in that capacity, must document….”

    • 2nd sentence -  modification of language requested: “Should a CD employee not report for work or terminate employment without notice, the SF or family member or caregiver acting in that capacity, upon the individual’s or EOR’s request….”

  13. Manual pg 211, “Service Documentation and Requirements”

    • 1st sentence - modification of language requested:  “The services facilitator, or family member or caregiver acting in that capacity, must maintain….”

  14. Manual pg 211

    • Bullet 1 - Request modification of language used:

      • Currently reads “….receipt of training on his responsibility for the accuracy….”

      • change “his” to “his/her/they” in sentence

    • Bullet 2 - TYPO ..."hat" should be "that"

    • Bullet 3: Please clarify the following:

      • What is considered “contact” (method, details, etc).

      • Are providers (CDSF specifically) being asked to document every single phone call received/made to a client or others related to client (ie Support Coordinator, et al)?

      • What is considered a “medical record”?

        1. Is it enough to make a note that the Client et al was contacted?  More detail necessary.

        2. Does this need to be noted on a formal DMAS document such as a DMAS-99?

    • Bullet 5 - Provider Input

      • SFs should not have to maintain a copy of the SIS in their records, since that evaluation is the responsibility of the Support Coordinator.  SC maintain that document, not the SF, and therefore should not be part of the CDSF documentation requirements.

  15. Manual pg 212, bullet 2: “In a situation whereby the individual’s needs have changed significantly, the plan for supports must be reviewed by the provider.

    • To align with the regulation (12VAC30-122-500, E, 3, g) for this requirement the manual should be modified to say, “Documentation indicating that desired outcomes and support activities of the plan for supports have been reviewed by the consumer-directed services facilitator provider quarterly, annually, and more often as needed.” 

      • The language in the manual should match the regs.

    • Sub-bullets: These sub-bullets do not exist in the regs.

      • Providers, specifically us as CDSF providers, should not be required to document MORE than what is in the regulations.

      • This makes the manual more restrictive than the regulations.

  16.  Manual pg 212, bullet 3

    • MISSING: the number of calendar days in the manual language.

    • The regulations state no time limit.  Introduction of a time limit on when the review must be submitted to the Support Coordinator is more restrictive than the regs.  

  17. Manual pg 212, bullet 3, sub-bullet 1

    • This is not a sub-bullet of bullet 3 in the regulations.

    • This needs to be a dark bullet and moved left to align with the others.

CommentID: 116664