The Department of Human Services (DHS) November 1 Video Conference, Rate Setting Methodologies (for the DD, CAC, CADI and TBI waivers) Initiative Stakeholder Preparation, previewed a year of change with dramatic differences from elderly waiver rate setting process.  The handouts used at the videoconference can be found on the DHS website.  As we identify developments and raise issues in this article, please note:

A) The number of people served on the CAC, CADI, DD and TBI waivers in housing with services settings is approximately 1,200, which is less than 5% of all people served on the CAC, CADI, DD and TBI waivers.  Many of the documents in this rate setting process assume that providers only serve residents on public programs.  Care Providers of Minnesota serves on a stakeholder group that has been developing these rates, and will continue to explain to stakeholders in this process how and why providers with a housing with services registration and a Class A or Class F home care license operate differently than family or corporate adult foster care.

B) DHS is open to feedback in writing at dsd.rates@state.mn.us.

C) Stakeholders can participate in phone conference calls with DHS staff on many Fridays from 11 am to noon to discuss the rate setting methodologies, as detailed here.

D) No implementation date for the new rate setting (besides “no later than 12/3/2011”) has been set.  DHS staff acknowledge that the transition process to a new system will be a challenge.  Care Providers of Minnesota will also assist members in this process.

The videoconference provided updated documents to the Residential Services Framework and definitions that were initially released in May.  DHS has now released draft rate frameworks for Customized Living, 24 Hour Customized Living, Foster Care, Residential Care and Supported Living Service, which are all examples of residential services.  These frameworks can be accessed here.  Here are some headlines:

1) Before counties submit worksheets to the state to determine provider rates, they will have to work with providers to gather information that will fill in very detailed worksheets.  The service component definitions used in the worksheets can be found here.  These terms are used in the residential service rate component tools that can be found here.  (You may have to use the arrows at the bottom of the spreadsheet to access the Shared Staffing Pattern and Shared Information pages of the workbook.)  The service component definitions and residential service rate component tools will both need to be accessed in order to comprehend the rate setting proposal.

Some terms in the various documents in this initiative that need further definition or could be a source of confusion are:

Planned Capacity/Beds – The number of people who currently live or are expected to live at the residence.  This could be a real challenge for providers experiencing frequent changes in occupancy.

Licensed Capacity/Beds – This number is not necessarily what you have submitted for your housing with services registration or Class A or Class F home care license.  Licensed capacity is important because it is addressed in the one-page policy statement utilization factor “that will assist providers in paying for fixed costs associated with providing residential services at less than full capacity.”  There is no similar policy for elderly waiver.

In theory, a provider would work with a county to determine the planned capacity of a provider for serving people on the CAC, CADI, DD and TBI waivers.  However, if your client population changes over time in terms of the number served on CAC, CADI, DD and TBI waivers, the implementation of this policy could be very challenging.

Supervisor and Nursing RN – Members will need to articulate to counties that when a provider is operating under a Class A or Class F Home Care license, an RN must be doing the supervision of unlicensed personnel and LPNs in addition to the direct care they may provide.

Technological Alternatives to Staff – This only applies to residents of a supported living services residential setting.

2)  The Residential Service Rate Component Tool has three spreadsheets that are very detailed and remind one of some of the challenges that we encountered in the development of the Elderly Waiver Rate Setting Tools.

Shared (Direct) Staffing Pattern – This spreadsheet seeks to have a provider identify staffing by hour by day for the direct staff, awake overnight and asleep overnight employee categories.  As you know, occupancy can vary greatly over time.  We expect identifying this number will be problematic in this spreadsheet that assumes only four people in a residence.

Shared (Staffing) Information – This spreadsheet takes information from the shared (direct) staffing pattern and adds the shared hours of the supervisor, nursing RN and nursing LPN and total technological alternatives to direct staff hours.  The spreadsheet asks providers to indicate the number of people living in the residence.

Individual (Staffing) Information – This spreadsheet provides an opportunity for additional individual hours for direct staff, other staff – supervisor, nursing RN and nursing LPN – to be allocated to each of four clients.  We understand the vast majority of our members serve more than four clients, and will continue to provide feedback to DHS for changes.

When presenters were asked how often these staffing patterns could be changed, the answer was that they could change when there is a re-assessment of a client.  That would seem to be a very burdensome process.

In summary, the rate setting process for CAC, CADI, DD and TBI waivers is roughly where elderly waiver rate setting was two years ago.  We now have some additional specifics from May of 2010 on the rate setting process that DHS is proposing to use.  DHS plans on releasing the service or payment rates in early 2011, with the need for them to be operational by the end of 2011.  Many members spent a great deal of time influencing the elderly waiver rate setting process, and we expect a similar effort will be needed with the CAC, CADI, DD and TBI waiver rate setting tools.  If you have questions, please contact me at pmanz@careproviders.org or 952-851-2484.

Phil Manz
952.851.2484
pmanz@careproviders.org

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