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Public Notice of Waiver Renewal- April 2017


Friday, April 21, 2017

Home and Community-Based Services Waiver for 
Persons with Intellectual and Developmental Disabilities

The Director of the Department of Health Care Finance (DHCF), pursuant to the authority set forth in an Act to enable the District of Columbia to receive federal financial assistance under Title XIX of the Social Security Act for a medical assistance program, and for other purposes, approved December 27, 1967 (81 Stat. 744; D.C. Official Code § 1-307.02) (2012 Repl. & 2016 Supp.)), and the Department of Health Care Finance Establishment Act of 2007, effective February 27, 2008 (D.C. Law 17-109; D.C. Official Code § 7-771.01 et seq. (2012 Repl.)), and the Director of the Department on Disability Services (DDS), pursuant to authority set forth in Title I of the Department on Disability Services Establishment Act of 2006, effective March 14, 2007 (D.C. Law 16-264; D.C. Official Code § 7-761.01 et seq.), hereby give notice of their intent to submit an application for renewal of the District of Columbia Medicaid program’s Home and Community-Based Services (HCBS) Waiver for Persons with Intellectual and Developmental Disabilities (IDD) to the Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) for review and approval.  

The renewal application for the HCBS Waiver contains changes to the methods and standards for setting payment rates for some services, substantive changes to the amount, duration, and scope of some services, substantive changes to service definitions, proposes several new services, and changes some provider qualifications, among other things.  

DHCF and DDS have reviewed the existing rates and propose the following substantive changes in rate methodologies and reimbursements to be effective upon approval by CMS and publication of implementing regulations:

  • Individualized Day Services:  The rate methodology and subsequent rates for this service have been changed.  The changes in the rate methodology decrease the one to one service as compared to the FY 2017 rate from $38.00 per hour to $34.16 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $35.04 per hour.  The changes in the rate methodology increases the standard service (one staff person to two waiver participants) as compared to the FY 2017 rate from $21.44 per hour to $23.73 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $24.32 per hour.

The rate methodology changes are:  a) Decreased employee related expenses percentage (ERE) from 22% to 20%. b) Decreased indirect front line manager hours from 75 hours per year to 52 hours per year. c) Increased indirect Qualified Intellectual Disabilities Professional (QIDP) hours from 30 hours per year to 40 hours per year and Training staff hours from 30 hours per year to 40 hours per year. d) Increased transportation from $2,000 per year to $4,000 per year for 1:1 services and to $6,000 per year for group services. e) Increased program supplies and activities from $2,500 per year to $4,000 per year for 1:1 services and to $6,000 for group services. f) Reduced non-billable Direct Support Professional (DSP) hours from 10.75 hours per week to 9.25 hours per week.  g) Changed the group rate methodology to account for an 85% utilization rate for both waiver participants in the group. 
The changes are proposed to increase the amount of time spent in training and spent by the QIDP in supporting the DSP, and to increase the amount of funding available to facilitate high levels of community participation and integration. The change in ERE reflects a mix of part-time and full-time personnel in the DSP positions. 
The estimated change in annual aggregate expenditures as a result of these changes is $245,169.56.

  • Supported Employment:  The rate methodology and subsequent rates for this service have been changed.  The changes in the rate methodology decrease the paraprofessional service as compared to the FY 2017 rate from $28.84 per hour to $26.95 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $27.65 per hour.  The changes in the rate methodology increase the professional service as compared to the FY 2017 rate from $47.92 per hour to $49.16 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $50.44 per hour. The changes in the rate methodology increase the group service as compared to the FY 2017 rate from $11.52 per hour to $13.03 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $13.37 per hour.

The rate methodology changes are:  a) Increased the DSP wage for paraprofessional and group services to $14.80, or the 25th percentile for Rehabilitation Counselors in the D.C. metropolitan area. b) Decreased the non-billable hours for professional services from 13 hours per week to 9.25 hours per week, and for paraprofessional and group services from 10 hours per week to 5.75 hours per week. c) Increased professional indirect RN hours from 10 hours per year to 12 hours per year and Training staff hours from 30 hours per year to 40 hours per year. d) Increased paraprofessional and group indirect QIDP hours from 20 hours per year to 30 hours per year and training from 20 hours per year to 40 hours per year. e) Eliminated travel and reduced program supplies from $2,200 per year to $1,000 per year in paraprofessional and group services. 
The changes reflect program variances between the professional and paraprofessional services.  The reduction in non-billable hours reflects that paraprofessional and group supported employment services have not been highly utilized for job development activities.  Increases to training hours reflect the current DDS requirements.  Increases in RN and QIDP hours reflects an expectation that people with a higher level of need will enter supported employment services as a result of the District’s Employment First policy. 
The estimated change in annual aggregate expenditures as a result of these changes is $82,708.88.

  • Companion Services: The rate methodology and subsequent rates for this service have been changed.  The changes in the rate methodology increase the 1:1 service as compared to the FY 2017 rate from $19.08 per hour to $20.20 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $20.73 per hour.  The changes in the rate methodology decrease the group service as compared to the FY 2017 rate from $11.76 per hour to $9.76 per hour.  This rate will be inflated by the Consumer Price Index for FY 2018, estimated to be 2.6%, to $10.01 per hour.

The change reflects the increase necessary to match the Medicaid State Plan PCA service rate.  The decrease in the group rate is a result of a change in the group rate calculation method that assumes a group of three waiver participants and an 85% utilization rate for all three waiver participants.  
The estimated change in annual aggregate expenditures as a result of these changes is $553.00.

A summary of all of the proposed substantive changes to the renewal application and copies of the proposed waiver renewal application may be obtained on the DDS website at http://dds.dc.gov/page/waiver-amendment-information or upon request from Erin Leveton, Program Manager, DDS State Office of Disability Administration, Department on Disability Services, 250 E Street, SW, Washington DC 20024. 
  
There are two opportunities to provide comments on the proposed HCBS waiver amendments:
Written comments on the proposed waiver renewal shall be submitted to Erin Leveton, Program Manager, DDS State Office of Disability Administration,  Department on Disability Services, 250 E Street, SW, Washington DC 20024, or via e-mail at [email protected], during the thirty (30) day public comment period, starting from the date this notice is published.    

DHCF and DDS will hold a public forum during which written and oral comments on the proposed waiver renewal will be accepted. The public forum will be held at the DC Department on Disability Services, 250 E Street, SW, Washington DC 20024, on Tuesday, May 2, 2017 at 10 am.       
Copies of this notice also will be published on the DDS website at https://dds.dc.gov and on the DHCF website at https://dhcf.dc.gov.

For further information, contact Erin Leveton, Program Manager, DDS State Office of Disability Administration, at (202) 730-1754, [email protected]