April Young, Policy Analyst, Texas Health and Human Services Commission, has responded to the questions.
On Tuesday, August 11, 2015, Service Providers and CPSH met to discuss using Community first Choice (CFC) funds to provide support for adults interested in living in Neighborhood Homes. (Here is a summary of the meeting.)
At the meeting, the Providers asked several questions about CFC. The providers stated their decision to support the Dallas Housing Authority on the Neighborhood Homes project would require receiving answers to the questions.
April Young, Policy Analyst, Texas Health and Human Services Commission has provided answers to these questions. Here they are.
What are the rules for CFC? If they haven’t been published, when will they be published?
CFC rules are published and can be found in the Texas Administrative Code Title 1, Part 15, Chapter 354, Subchapter A, Division 27. They were effective June 1, 2015.
CFC rules pertaining to the intellectual and developmental disability (IDD) DADS waivers (Home and Community-based Services, Texas Home Living, Community Living Assistance and Support Services, and Deaf-Blind Multiple Disabilities) will be effective March 2016. This rule packet was presented August 20th at the Managed Care Advisory Committee (MCAC) meeting. There was opportunity for public comment at the MCAC meeting, and no public comments were received. The rule packet will also be presented September 17th at the DADS Council meeting, where there will be another opportunity for public comment. After the DADS Council meeting, the rule proposal will be published in the Texas Register in November 2015 for a 30 day comment period.
Until the DADS rules are published, Home and Community-based Services (HCS) and Texas Home Living (TxHmL) providers are to follow the requirements set forth in http://www.dads.state.tx.us/providers/communications/2015/letters/IL2015-28.pdf
What are the billing guidelines for CFC? If they haven’t been published, when will they be published?
Each managed care organization (MCO) will have their own billing guidelines. In order to access those billing guidelines, please contact the MCO for further information.
For DADS TxHmL and HCS providers, the CFC billing guidelines can be found here: http://www.dads.state.tx.us/providers/CFC/docs/CFCBillingGuidelines.pdf. On August 24, 2015, DADS posted a draft of revised TxHmL and HCS CFC billing and payment guidelines for review and comment. The revision, to become effective September 2015, instructs HCS and TxHmL providers to bill transportation to the waiver.
What will CFC pay for regarding overnight care? Is the attendant allowed to sleep?
Reimbursement of overnight care in CFC depends on individual specific need and hours as determined by the functional assessment (H6516) and documented and justified in the plan of care. The H6516 can be accessed here: https://www.dads.state.tx.us/forms/H6516/. The total number of hours authorized are dependent upon the individual’s needs.
In response to the question whether or not the attendant is allowed to sleep, please note the attendant must be performing activities for the member in order to be reimbursed.
The providers have submitted individual plans for CFC and not heard back on the plans. What is the hold up?
We take this question to mean the Local Intellectual and Developmental Disability Authorities (LIDDAs) are submitting individual plans for CFC and haven't heard back from the MCOs. If this is the case, the LIDDAs can contact the MCOs to see what the status of the referral is and when the joint meeting with the member will be held to confirm the individual plan. If the MCOs are non-responsive, HHSC would like more specific examples so that follow up can be done with the MCOs.
The Program Providers and Local Authorities appear not to know how to work with the MCOs. How can this be addressed?
HHSC facilitates a bi-weekly Monday meeting with the Texas Council of Community Centers, three LIDDAs, and representatives from MCOs to help increase coordination and understanding between the two entities. We believe progress has been and continues to be made in this area. Please keep us informed if there are continuing concerns.
What is the process when a person on the Medicaid Waiver interest list wants to use CFC? Is this documented? Where can I get a copy?
Individuals interested in CFC and on a 1915 (c) waiver interest list maintain their place on the interest list and may receive CFC, if they qualify. The majority of individuals on an interest list who already have Medicaid may contact their MCO to begin the process of determining CFC eligibility. If the individual does not have Medicaid, they may contact their LIDDA to begin the intake process. Please note the LIDDAs have been given names of individuals in their service area who are on a waiver interest list and already have Medicaid. The LIDDAs are working through those lists now.
This provider summary link on the HHSC CFC website provides further information on which entity does what task: http://www.hhsc.state.tx.us/medicaid/managed-care/community-first-choice/docs/cfc-summary.pdf.
The policy the MCOs are required to follow can be found at the following link and may be helpful: http://www.dads.state.tx.us/handbooks/sph_policy/HHSC/05-07-15_001.pdf
Services Providers who will now support the Dallas Housing Authority on the Neighborhood Homes project should complete the Interest Form, here. (Those that have already completed the form and support the project DO NOT need to submit the form again.)