In August, PCG attended and presented at a successful and informative National Home and Community-Based Services (HCBS) Conference in Baltimore, MD. This annual event is a unique opportunity for federal, state, and local policymakers to meet up with the people who administer, manage, and deliver HCBS programs across the country.
This year, the conference hosted more than 1,500 attendees and over 130 sessions. Presentations provided helpful insights into the goals and priorities of federal agencies like Centers for Medicare and Medicaid Services (CMS), Administration for Community Living (ACL), and the Office of Inspector General (OIG)—as well as recent successful efforts and lessons learned from various state HCBS programs. Below, we have compiled a few key themes and topics from this conference.
Critical Incidents
Presentations from CMS, OIG, and several states taking action on the issue highlighted that critical incidents involving Medicaid beneficiaries are becoming a key priority for the federal government. As PCG’s Jamin Barber reported last month, this urgency is largely due to results from recent OIG state audits that identified considerable gaps in the way these incidents are reported and managed. CMS and OIG plan to visit all states in the coming months and years to evaluate this issue further.
To better safeguard the health and safety of individuals receiving HCBS waiver services—and to ensure a smoother CMS/OIG visit—states should have processes and systems in place to address key areas of Critical Incident Management. Examples include:
- An Incident Management System (IMS) to ensure that incidents are reported, investigated, and tracked.
- Holding Incident Reporting Trainings to ensure case managers, providers, and stakeholders understand what constitutes a critical incident and how to properly report one.
- Using Data Analytics to identify unreported incidents using claims and other data.
- An incident management process improvement process—used to periodically evaluate current processes, identify gaps and problems, and redesign the process as needed to ensure proper reporting and investigation.
For more information about federal compliance standards, as well as how PCG’s critical incident management solutions can assist states in addressing the key areas above, click here.
Relevant Conference Presentations:
- CMS Intensive: Promoting Health & Welfare for People Receiving HCBS
- ACL/CMS Track: Enhancing Health & Welfare of Individuals Receiving HCBS: Federal & State Efforts
- Incident Management: Using Data to Identify, Manage, & Prevent Abuse & Neglect
Electronic Visit Verification (EVV)
With the January 1, 2020 deadline approaching to implement EVV for Personal Care Services (PCS) under the 21st Century CURES Act, providers and states alike are seeking clarification and answers to their questions as they refine their approach to EVV.
At the HCBS conference, CMS provided the following updates and information on their EVV requirements:
- Services delivered in the community: CMS will only require EVV for services that are delivered in-home, not services delivered in the community. States will have the option for a more robust EVV approach that reflects community integration.
- Family members: Family members delivering services may be exempt from EVV requirements.
- Good faith efforts: Several states are currently applying for, and CMS is in the process of evaluating and granting, “good faith effort” extensions to allow the deadline of EVV implementation to be postponed by one year.
- As of the conference, CMS had received twelve applications and granted five approvals.
- If a state is interested in applying for a good faith effort, CMS recommends doing so by November.
CMS certification is a critical requirement for state Medicaid agencies seeking to receive reimbursement for implementation and operational costs associated with EVV. Click here for PCG’s detailed overview of CMS’s updates, including lessons learned about CMS EVV certification from the Ohio Department of Medicaid (ODM).
For states seeking an EVV technology to meet CMS certification requirements, PCG’s EVV Careify solution satisfies all requirements of the 21st Century CURES Act and serves as a third-party EVV data aggregator. For additional information about Careify, view its webpage here.
Another major EVV-related development announced at the conference was ADvancing States and the National EVV Association’s official State EVV Implementation Tracker release. This single website contains the current status of EVV implementation in each of the 50 states—view it here.
Relevant Conference Presentations:
- CMS: EVV Implementation
- Navigating CMS Certification for Electronic Visit Verification Operations
- EVV Requirements in the 21st Century CURES Act
- Latest CMS Informational Bulletin
HCBS Settings Final Rule
CMS presented on the HCBS Final Rule: Current Issues and Future Directions, during which staff reviewed its requirements for final approval of a State Transition Plan:
- Report on completed site assessments and validations
- Remediation strategies to be completed March 17, 2022
- Communication with individuals receiving services who reside in non-compliant settings
- Monitoring and quality assurance to ensure going compliance
- Heightened scrutiny review approach for settings presumed institutional
As part of its session, CMS shared five key strategies to assist states with a successful transition period:
- Alignment of policies, regulations, and rule across programs and organizations
- Stakeholder engagement including education, training, and technical assistance
- Capacity building to further provide supports to cover unmet needs
- Value-based payment reform to incentivize integration, individualization, and person-centered thinking
- Ongoing monitoring and quality assurance to ensure transitions translate permanently into compliant approaches
If you would like to learn more about how PCG is helping state HCBS programs to evaluate their compliance with the final rule (including overviews of our previous HCBS support work in several states), click here.
Relevant Conference Presentations:
- CMS Intensive: HCBS Regulation Implementation
- ACL/CMS Track: Raising the Bar in Medicaid HCBS & Community Inclusion – Showcasing Transformation
- CMS Track: Engaging Hard-to-Serve Populations & Innovative Services in HCBS
Rate Setting and Value-Based Payment Models
PCG’s Sarah Salisbury led an interactive session at the conference entitled, “Rate Re-basing: Turning a Sometimes Painful Process into a Data Treasure Trove.” Panelists from the states of Illinois, New Mexico, and Colorado and audience members shared their perspectives and experiences with rate re-basing, underscoring lessons learned and the importance of thorough, informed data collection in this process.
Ultimately, the common takeaway from each of these states’ re-basing experiences was that while rates do matter in and of themselves, they can also be leveraged to achieve better outcomes for individuals and families. With a clear vision and strategic planning as a foundation, and creative data analysis as a key component of the rate development process, states can achieve policy goals. View the presentation’s slide deck here to learn more.
Other Relevant Conference Presentations:
- Value-Based Care “From A to V”: Leveraging Partnerships & Payment to Drive Quality & Manage Costs
- CMS Track: National Trends in Fee-for-Service Rates within 1915 (c) Waivers
- State Experiences with HCBS Rate-Setting
- CMS Track: Value-Based Payment for HCBS
- More Bang for Our Buck: Developing a Report Card & Value-Based Payment for Assisted Living
- Leveraging Medicare Fee-for-Service Reimbursement to Address Social Determinants of Health
Additional Info
The full list of all 130+ conference presentations, as well as links to their materials, can be found on the ADvancing States website here. If you have additional questions about the HCBS conference, or how PCG can assist your state, please feel free to contact Kevin Hutchinson at khutchinson@pcgus.com or 919-576-2210.