|
This communication highlights key activities that are underway to improve OPWDD’s Self-Direction program and clarifies existing Self-Direction policy.
Background
Self-direction is an OPWDD service model that offers people increased flexibility, choice and authority to direct their services. People who are eligible for OPWDD services and enrolled in the OPWDD Home and Community Based Services Waiver can choose to self-direct their services. When self-directing, a person can choose a mix of individualized services and supports that works best for their needs, select the staff they want to work with and create an individualized schedule. People who self-direct use a Self-Direction Budget to plan and manage their services within an annual funding allowance. They can choose to access all the same Medicaid State Plan and Waiver services as people who choose not to self-direct, as well as a few service options that are only available to people who self-direct.
Self-directing services has become an increasingly popular choice for people who receive OPWDD services. Currently, more than 31,000 people are choosing to self-direct their OPWDD services.
In recent years, OPWDD has worked closely with people with developmental disabilities, their family members and service providers to gain insight into the existing challenges and to enhance its effectiveness.
Current Activities Underway
In 2023, OPWDD released a Request For Proposals seeking a consultant to assess the self-direction model and provide recommendations for both short-term and long-term enhancements. This work is set to begin in 2024.
In addition to the evaluation, OPWDD is currently making the following improvements based on stakeholder feedback:
- Recently completed a Request For Information to begin the process to select an information technology system to streamline and better manage the Self-Direction program. The use of an information technology system will enable OPWDD to move from a manual to an automated system for reviewing and submitting self-direction budgets.
- Continuing an independent Support Broker option with increased accountability through central broker authorization and review processes.
- Managing Support Broker trainings with a single, statewide registration process and a web-based format.
- Implementing a Community of Practice for Fiscal Intermediaries to ensure consistency in reviewing requested community classes. In addition, this initiative aims to facilitate communication and drive common understanding among approximately 100 Fiscal Intermediary agencies in New York State regarding Individual Directed Goods and Services (IDGS) reimbursement.
- Fiscal Intermediary agencies will establish a dispute resolution process for participants whose requested reimbursements are denied for service compliance reasons.
- Incorporating HUD housing subsidy payment standards which has led to an increased subsidy amount for some. This reform benefits all people who use housing subsidies, not just people who use self-direction.
- Adjusting Fiscal Intermediary administrative fees, including a separate administrative fee for housing subsidies.
- Updating policies and Administrative Memoranda (ADMs) to provide greater clarity and guidance, including the Fiscal Intermediary, Broker, and Housing Subsidy ADMs which are in the process of being updated.
- Updating guidance and requirements for Individual Directed Goods and Services to improve consistency and transparency of reimbursement decisions among Fiscal Intermediary agencies.
For more information and to access Frequently Asked Questions about self direction, the distinctions between direct purchasing and reimbursement, and the IDGS Community Class policy, please visit:https://opwdd.ny.gov/providers/self-direction-providers#info-for-fiscal-intermediaries-(fi)
Clarifications to Existing Self-Direction Policy
OPWDD’s Self-Direction program delivers OPWDD services, most of which are paid in part by the federal Medicaid program. For this reason, services delivered through the Self-Direction option are subject to oversight and regulation by the federal Centers for Medicaid and Medicare Services as well as by OPWDD.
1. The IDGS Community Class category is designed for use in improving and maintaining community inclusion and integration by reimbursing for publicly available classes that teach a specific subject related to a person’s needs and goals (e.g., Art, Dance, Exercise, Cooking, Computer Training). Community Classes are eligible for Self-Direction Individual Directed Goods and Services (IDGS) funding when those classes meet the specified requirements, including:
- The class occurs in an integrated community setting.
- Class enrollment is open to anyone with or without a disability.
- Class content does not duplicate any Medicaid State Plan or Waiver service.
- The class provides instruction to the person by teaching them a specific subject related to the person’s needs and goals, for example, dance, exercise, or cooking.
- The purpose of these guidelines is to promote community inclusion and integration by providing access to all that the community has to offer the person being supported by OPWDD services.
- Classes that are designed for and offered exclusively to people with developmental disabilities, and are not available to the public, fail to meet these standards.
- The definition for Individual Directed Goods and Services, which includes the Community Class category is found in both the HCBS Waiver and ADM 2015-05R as: “Individual Directed Goods and Services (IDGS) are services, equipment or supplies not otherwise provided through this waiver or through the Medicaid State Plan that addresses an identified need in a person's service plan, which includes improving and maintaining the person's opportunities for full membership in the community.”
- The service rules ensure that community class programs do not duplicate a State Plan or Waiver service or exhibit the qualities of programs certified for people with developmental disabilities without being licensed, regulated and overseen by OPWDD and its quality assurance activities. This ensures OPWDD consistently addresses the Waiver assurances for all day service options, as required by the Centers for Medicaid and Medicare Services (CMS).
- Classes that are intended to provide caregiver relief or to teach adaptive skills to people with developmental disabilities do not qualify for community class reimbursement through self-direction. People should have these kinds of needs met through services like Respite, Day Habilitation or Community Habilitation.
2. New York State offers generous reimbursement options related to Self-Direction compared to other states. For example, in addition to Individual Directed Goods and Services (IDGS), New York State provides a separate, state funded reimbursement service called Other Than Personal Services (OTPS). Allowing reimbursement of up to $3,000 per year, Other Than Personal Services provides people with significant flexibility in funding items that promote independence and/or health and safety. This funding is available in addition to other reimbursements, including Family Reimbursed Respite and Housing Subsidy, making Self-Direction in NYS particularly advantageous for people with developmental disabilities who self-direct.
3. Anyone can report suspicious activities or suspected abuse or neglect. While it's generally expected that reports will be made to the service provider (Fiscal Intermediary) or Care Manager first, people have the option to report directly to OPWDD or to the Justice Center if they prefer. OPWDD provides resources for reporting incidents or abuse/neglect on their website, including business and after-hours contact information for the Incident Management Unit and Justice Center.
4. Fiscal Intermediary agencies are encouraged to directly purchase items on behalf of people who self-direct, rather than requiring them to incur upfront costs and seek reimbursement. For people with limited cash on hand, the direct payment can be very helpful in helping them to live independently. This practice also ensures timely payments and helps Fiscal Intermediary agencies maintain compliance with Medicaid and corporate regulations. Direct payments also allow the Fiscal Intermediary agency to know exactly how and when payments are made, information that can help them achieve more timely billing. They can also use their tax-exempt status and save money for self-direction participants.
Having trouble viewing this email? View it as a Web page.
|
