Page 5 Bullet #7
“The authorized start date of services will not be prior to the date the service authorization request is initially submitted to DBHDS for an eligible individual…… it is recommended to be submitted at least 30 days prior to the requested start of services….”
Comment: Providers have been directed not to schedule annual review meetings. They are told it is the responsibility of the CSB. There have been times when the individual is not aware of who his/her support coordinator is at the time, and they are not contacted or have a meeting scheduled until 1-2 weeks prior to the plan turning over in WaMS. Even after an annual plan meeting is held, providers are at the mercy of the Support Coordinator to submit the Part III in WaMS and “assign” the provider to specific outcomes. We have experienced that not happening until less than 3 days ahead of the new plan starting. Once a provider submits information into the WaMS system, they are again beholden to the Support Coordinator to push the submission button to lock in a date. Even after multiple phone calls and emails, this has still been an issue for providers. This has increased with the high rate of turnover in the Support Coordinator role.
Recommendation: Add a 10 business day grace period for authorization start dates.
Page 17 in the 4th paragraph
“Community Guide activities conducted not in the presence of the individual, such as researching and contacting potential sites, supports services and resources, shall not comprise more than twenty-five percent of authorized plan for support hours.”
Comment: Allowing only 25% of the research and contacts to be outside of the presence of the individual is not reasonable in today’s housing climate or the current paperwork procedures for individuals utilizing the SRAP or Housing Choice voucher programs. (I know this is a Waiver manual requirement, but I want them to hear this one as often as possible.)
Recommendation: This piece should be increased to 50% of the allowable hours and should allow phone/telehealth meeting options to increase efficiencies. Not doing so will mean the potential for individuals with disabilities to miss out on important options and/or providers to discontinue providing this support.
Page 34, Last paragraph
“When the provider anticipates a need for an increase in service hours due to holiday, doctor visits, closure of day or employment sites, for which the back-up plan is not an option, the provider may submit an authorization request that includes (1) an explanation of the insufficiency of the back-up plan……
Comment: This requirement to discuss why a back-up plan is not sufficient is not listed in regulation, nor should it be the provider’s responsibility to research and investigate why a back-up plan is not an option for an individual. The individual utilizing supports are also not required to ask someone named in a back-up plan prior to utilizing supports that have been vetted and awarded to them based on need by the Medicaid Waiver program. This is an egregious overstepping of boundaries and a waste of resources that could be used to simply support the individual in need.
Recommendation: Strike this paragraph from the manual. It should not be a pre-requisite to check with the person named in the back-up plan if a planned service is not available and another provider/service is able to step in and meet the need. The same is expense is being utilized, and the most important factor is that the individual has the safety supports he/she needs immediately.