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Conflict Free Case Management

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Presentation on theme: "Conflict Free Case Management"— Presentation transcript:

1 Conflict Free Case Management
History HB-1343 Timeframes Options

2 What is the perceived conflict?
People receiving Home and Community Based Services (HCBS) under the Medicaid Program receiving Case Management (CM) and Direct Services from the same agency Perception of limited choice RFP Process Only referring to their own agency Federal regulation in 2014 requiring separation of CM and Direct Services

3 Conflict Free Case Management (CFCM)
CMS issued conflict of interest requirements in the rule for 1915(c) Home and Community Based Services (HCBS) waivers: Requirements at 42 CFR (c)(1)(vi) Per CMS, States are required to separate case management (person-centered service plan development) from service delivery functions1 Conflict occurs not just if an entity is a provider, but if the entity has an interest in a provider or is employed by a provider 1 1 This information is from CMS training titled “Conflict of Interest Rules in Medicaid Authorities”, which was conducted by CMS on January 13, 2016.

4 House Bill 17-1343: Definitions
Community Centered Boards: Eligibility Determination Administrative Functions Human Rights Committee (HRC) Supports Intensity Scale Assessment (SIS) Investigations Mistreatment, Abuse, Neglect, Exploitation (MANE) Early Intervention – Individualized Service Plans Refer to Case Management Broker Case Management Broker: Helps people choose a Case Management Agency (CMA) Possible option: Regional Accountable Entity (RAE) Case Management Agency: Intake and Assessment Develops Service Plans Helps people choose a Provider Agency Provide Targeted Case Management Services Options: Current CCB Another CCB A non-CCB CMA

5 House Bill 17-1343: Definitions
Business Continuity Plan Specifically how will Envision come into compliance with CFCM Options CCB CMA Provider Agency Cease Operations Fiscal Impacts of options Community Impacts of options Timeframes Decision deadline Draft Final Submit to HCPF Provider Agency Provides HCBS waiver direct services and supports Supports individuals in obtaining what is important to and important for them Cannot be the Case Management Agency for the person receiving direct services

6 Timeframes – Subject to Change
6/2017: HB was signed by the Governor 1/1/18: HCPF Rules should be published 7/1/18: CCBs must submit Business Continuity Plan (BCP) 6/30/19: HCPF analysis of expenses/impacts 6/30/20: CCBs must complete business operation changes 6/30/21: 25% of all people served must be through a conflict-free system 6/30/22: All people served must be through a conflict-free system

7 Four Options Continue providing Case Management and Direct Services, but not to the same person Become a Case Management Agency Become a Service Provider Agency Don’t do either and go out of business

8 Envision by the numbers
Medicaid Waiver DD percentage not served by Envision PS: 59% Medicaid Wavier SLS percentage not served by Envision PS:76% State SLS percentage not served by Envision PS: 75%

9 Sample Fiscal Impact Considerations
Facility costs Shared Administrative Functions Fleet lease obligations Operating lease obligations Unemployment insurance claims due to possible staff layoffs Business insurance costs Employee benefit costs less employees higher costs

10 Employee Count by Department
Administration 12 Adult CM Children’s CM Program Services 105 Excluding Crew 61 Crew 44 Total Employees 151

11 Questions and Comments


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