New Federal Rule Change Offers Opportunity – State Wide Medicaid Waiver Transition Plans Open for Public Comment

by John Dickerson, Executive Director, The Arc of Indiana

Indiana is approaching 20,000 Hoosiers supported by the Family Supports (FS) Waiver and Community Integration and Habilitation (CIH) Waiver.  These programs, known federally as the Home and Community Based Services (HCBS) Medicaid Waiver program, have new federal rules designed to address how well people are integrated into their communities

Although Medicaid is a federal program, it is operated differently in each state.  States have been directed to address their individual state programs within these new federal rules.  Indiana will have three critical areas to address:  community living, person-centered planning and employment.   Each state is to assess how well they are doing to achieve the goals of the program and write a transition plan on how they will improve and meet the goals of the program nationally.

Indiana’s Division of Disability and Rehabilitative Servcies (DDRS) and the Office of Medicaid Policy and Planning (OMPP) have developed two transition documents outlining Indiana’s plans to meet HCBS rules for both the FSW and CIH Waivers.  The transition plans include information about Indiana’s assessment process to date, plans for continuing assessments, how compliance will be identified, and the strategies to be utilized to come into compliance with the HCBS rules.  The plans for both waivers will be submitted to the Center for Medicare and Medicaid Services (CMS) no later than December 31, 2014 and are available for review at the following links:

Family Supports Waiver Comprehensive Transition Plan

Community Integration and Habilitation Comprehensive Transition Plan

Comments will be accepted now through December 1, 2014 and may be emailed to DDRSpolicies@fssa.in.gov  or submitted in writing to:

Waiver Public Comment
c/o The Division of Disability and Rehabilitative Services
402 W. Washington St., Rm. W451
Indianapolis, IN 46204-2243

It is important to note that the transition plans are just the start of an important process.

A critical part of Indiana’s proposed transition plan includes gathering responses from individuals who receive funding for community based living supports.  With the help of the Indiana Institute on Disability and Community (IIDC), Indiana is going directly to people and those who know them best to identify how they feel about where they live and their involvement in and access to the community.

This first ever community living survey is based upon the tremendous success that FSSA had in working with IIDC on an employment survey that has provided wonderful data for over a decade.   The survey, which is currently being developed, started with six pages of single-spaced questions suggested by HCBS officials.  IIDC has broken it down to less than 25 critical questions that any individual or those who know them best can answer.

We believe this is an excellent approach.  One might assume that those who live in small, community based settings are connected to their communities and are involved in things that are important to them.   Or, it might be assumed that someone living independently may feel isolated and alone.  It is important, however, never to assume.  We need to listen and learn directly from those individuals themselves.   We believe this process can lead to a critical new approach in creating true community inclusion for people with I/DD that goes well beyond just looking at the definition of the setting in which in individual lives.

After undergoing testing and a pilot, the survey will be available to community residential service providers in the first quarter of 2015. Providers will be asked to ensure surveys are completed for the individuals they serve.  Data will be available to the state and providers to help determine what needs to be improved.  The Arc has asked that surveys be included in the files of individuals who are surveyed to help Medicaid Waiver teams utilize the information for improvement in their programs and services.

I have recently been asked if the state is compiling a list of residential settings that will not meet the definition of community.  The answer is, no.  We all know of settings that on the surface will be challenged to meet the new definition.   This new process will change the focus from looking at just an address and location to the life of the person that lives there.

Will certain programs have to change?  Very likely, but they will be changing to reflect the ability of people to be supported in their community.  FSSA will utilize survey responses to work with providers in developing plans that will move them to HCBS requirements for community inclusion.  It will require change over a period of time, not overnight.  Simple changes may be required to happen more quickly, complicated changes may take considerably more time.  But one thing is for sure, no decisions have been made ahead of time.  Decisions will be made based on responses to the survey.

From The Arc’s perspective, going directly to people, including those that know them best, will provide a way to identify and celebrate success, as well as identify what changes are needed to help people achieve their goals and have a life they want to live.  It is a great start and a great opportunity.

We will continue to share new information, including when the survey process begins.  Watch for news and information on our website, www.arcind.org and in our weekly e-newsletter.  You can subscribe to the e-newsletter at: www.arcind.org/contact-us/e-newsletter-sign-up  If you have questions or concerns, please contact us at: thearc@arcind.org