Indiana’s Office of Medicaid Policy and Planning (OMPP) provided the following update to IHCA concerning the implementation of the CMS HCBS rule. To view a PowerPoint from CMS concerning the final rule, click here. IHCA will maintain active involvement with OMPP as the implementation plans become more clear.
The Centers for Medicare and Medicaid Services (CMS) issued a final rule for home and community-based services (HCBS) effective March 17, 2014. Indiana has six 1915(c) HCBS waivers, one grant and three 1915(i) HCBS State plan programs that are affected by this rule:
1915(c) HCBS Waivers
• Aged and Disabled Waiver (A&D)
• Traumatic Brain Injury Waiver (TBI)
• Money Follows the Person Grant (MFP)
• Community Integration and Habilitation Waiver (CIH)
• Family Supports Waiver (FSW)
• Psychiatric Residential Treatment Facility Transition Waiver (PRTF)
1915(i) HCBS State Programs
• Adult Mental Health & Habilitation Services (AMHH)
• Child Mental Health Wraparound Services (CMHW)
• Behavioral and Primary Healthcare Coordination (BPHC)
States submitting a 1915(c) waiver renewal or waiver amendment within the first year of the effective date of the rule need to develop a transition plan to ensure that the specific waiver meets the settings requirements. Within 120 days of the submission of that 1915(c) waiver renewal or waiver amendment the state must submit a plan that lays out timeframes and benchmarks for developing a transition plan for all the state’s approved 1915(c) waiver and 1915(i) HCBS state plan programs.
The Community Integration & Habilitation Waiver (CIH) is due to expire September 30th. Given the short time frame since the March 17, 2014 effective date of the final rule, CMS has advised the state to develop a high level transition plan specific to the CIH waiver for submission with the renewal.
This initial transition plan will outline timeframes for the assessment of current licensure and certification requirements, for assessing those settings which may not be compliant, and for developing a comprehensive transition plan and process for bringing all HCBS settings into compliance. The CIH initial transition plan, or “work plan”, will be posted for 30 day public comment by the middle of July. Following review of the public comments the CIH renewal will be submitted to CMS.
Submission of the CIH renewal will trigger the 120 day period for Indiana to develop a more comprehensive transition plan for all the state’s approved 1915(c) and 1915(i) HCBS programs. We anticipate that the comprehensive transition plan will be released for additional public comment in late October with submission to CMS due by early December.
The HCBS Final Rule Compliance Project team is being lead by Angie Amos and is composed of staff from each of the FSSA Divisions (DA, DDRS, DMHA, and OMPP). The team has been reviewing standards (e.g. licensing, certification, etc.) to possibly address provider groups on the basis of state requirements (both in identifying compliant settings and possibly targeted elements to be addressed). This triage approach will allow us to systematically focus on those areas most at risk of being noncompliant. Assessment tools are being developed which can then be used to evaluate individual settings.
Assuring compliance with the HCBS Final Rule is a large, long term project. CMS is developing additional guidance which will address the implications regarding the Final Rule for non-residential settings, transition planning, and person-centered planning. Indiana will submit a more fully developed transition plan for assuring compliance with these areas after receipt of the technical guidance from CMS. A 30 day public input period will be provided prior to the submission of any revised Transition Plan.
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