CMS proposes more routine reassessments of HCBS needs to promote person-centered care planning
Sitting on her living room couch – the place in her home that normally serves as a sanctuary – Diane was very aware of all her limitations. The four-hour assessment she had just completed was at times too intimate for comfort as she outlined the difficulties she faces preparing meals, getting dressed and performing other daily activities.
Diane’s case manager assured her this was the best way to figure out how to build a person-centered plan of care – one that included all the services she would need to live at home safely and independently. Diane knew she needed to trust the case manager, just as so many of her peers had trusted theirs. She’d seen the improvements in their lives, and she wanted the same, not only for herself, but for her children who were constantly worried about her.
Enrollment in a home- and community-based services (HCBS) Medicaid waiver program often begins with meetings and assessments like these. These assessments are crucial to determine the level of care and types of services eligible program participants need to live and thrive in their homes and communities.
The Centers for Medicare & Medicaid Services (CMS) has proposed these assessments occur on a more regular basis.
In the new proposed rule (CMS-2442-P: Medicaid Program; Ensuring Access to Medicaid Services), the agency has outlined several ways it would like to see states improve and standardize the way state Medicaid agencies and managed care organizations (MCOs) develop and implement person-centered plans of care. One way is to increase the frequency of reassessments to every 12 months for at least 90 percent of individuals continuously enrolled in a state’s HCBS programs. This frequency of reassessment would allow agencies and MCOs to adequately accommodate for any functional and circumstantial changes that necessitate adjustments in the person-centered services provided.
CMS acknowledged in the proposed rule that changes in functional needs or circumstances requiring an updated plan of care do not occur very often, but routine assessments are “important safeguards that are in the best interest of beneficiaries because they ensure that an individual’s section 1915(c) waiver program services change to meet the beneficiary’s needs most appropriately as those needs change.”
With regular intervals for reassessments, CMS said agencies will be better equipped to adjust plans of care to accommodate major life changes like availability of natural supports (family) or other requests like choosing a different provider.
The proposed rule, more than 300 pages long, seeks to improve access to HCBS through increased transparency and accountability, standardizing data and monitoring and creating opportunities for states to promote active beneficiary engagement in their Medicaid programs.
The rule garnered a lot of attention during the comment period. Between its March release and July, CMS received hundreds of comments from advocacy groups, state agencies and others about the proposed changes to current HCBS program management requirements.
When it comes to the reassessment provisions, CMS received a commentary from the National Association of Medicaid Directors (NAMD), ADvancing States and the National Association for State Directors of Developmental Disabilities Services (NASDDDS) asking the agency to define reassessment more explicitly so their state partner agencies would understand what was required for reassessments. These groups also expressed concern that frequently conducting reassessments may overburden participants. Some state commenters said they were already meeting the annual re-assessment requirement, some called for a good-cause exemption and others called for no exemptions. Others suggested a “screening” be developed to determine if a full assessment was required.
The Arc of Minnesota and The Arc of Northland commented that underlying assessment issues must be addressed before further regulation is put into effect. They believe current assessments are subjective, inaccurate and administered by professionals without proper training. They reminded CMS that assessments force members, like Diane, to relive their worst days and then relay them to someone whose interpretation directly impacts the support they receive, potentially triggering fear and trauma.
At FEI, we recognize the magnitude of the impacts this proposed rule may have on our state partners, and we are prepared to help. With our configurable case management solutions, we can design business rules and automated processes that will ensure our solutions support CMS requirements for assessment and person-centered care building.
We stand ready to work with you to mitigate subjectivity and inaccuracy concerns with comprehensive case management and assessment tools. We offer a software as a solution (SaaS) case management platform that meets common CMS requirements, but is also configurable to address unique state waiver program needs. When it comes to person-centered care, our case management solutions provide our partners with a 360-degree view of waiver program participants, which includes all touchpoints with state or managed care services and providers. Additionally, our solutions use business rules to auto-populate person-centered plans of care based on intake and assessment data, as determined by our state partners. Those auto-generated plans can be altered by service coordinators or administrators with intimate knowledge of a participant’s unique needs – minimizing the impact on enrollees like Diane, yet obtaining the information the case managers need to create a person-centered plans of care.
