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April 29, 2017

Process Updates: Requests for Corrective Action Plans

Medicaid, in collaboration with the Division of Family and Community Services, has updated processes for requesting and processing Corrective Action Plans (CAP) from Home and Community-Based Services providers. The updates are being made to ensure a consistent CAP process across Department programs.  The time frames and documents associated with the CAP process have been standardized to provide plenty of time and opportunity for providers to fix issues, and promote clear communication between the Department and providers. These changes will be effective May 15, 2017.

If a provider receives a Request for Corrective Action, the provider is expected to implement an acceptable CAP within 45 days. The provider will then be asked to supply evidence that the CAP has been successfully implemented. During the CAP process, Department QA/QI staff will work with the provider to remedy any issues by offering the following:

• Technical assistance;
• An onsite meeting; and/or
• Any other reasonably necessary support to help the provider comply.

If a provider is unable to supply an acceptable CAP or provide proof of successful implementation of a CAP, the provider may be referred for actions against their Medicaid Provider Agreement. You can find rules regarding Provider Agreement Enforcement Actions in IDAPA 16.03.09, “Medicaid Basic Plan Benefits,” subsection 205.03. 

Initial Approval of the Statewide Transition Plan

Idaho Medicaid’s Home and Community Based Services (HCBS) project team is pleased to announce that Idaho has received initial approval of the Statewide Transition Plan (STP) from the federal waiver authorities. Initial approval of the STP means that Idaho has completed a systemic assessment of residential and non-residential HCBS service settings. Using the systemic assessment, Idaho identified gaps between Medicaid program areas and federal HCBS regulations in order to plan the remediation actions Idaho will take. Finally, Idaho identified the timeframes that the state will use to fully comply with the federal HCBS regulations. The Centers for Medicare and Medicaid Services (CMS) has reviewed Idaho’s STP and determined that the systemic assessment, remediation actions, and the timeframes are appropriate to comply with the federal timeframes and issued Idaho an initial approval.  

Idaho has much work to do in order to receive final approval of the STP.  Idaho must complete the following actions in order to obtain final approval:

  • Complete site-specific assessment of all HCBS settings
  • Develop a remediation plan for providers that do not comply with the HCBS regulations
  • Validate documentation from providers who have undergone remediation
  • Identify and assess settings that are presumed to have institutional characteristics
  • Identify a plan for participants who live in non-compliant setting to transition to compliant HCBS settings

Establish a plan for ongoing monitoring of HCBS settings in IdahoThe HCBS project team is working diligently to ensure that Idaho is working toward final approval of the STP. Idaho will continue to work closely with CMS to ensure that their concerns and expectations are addressed. Idaho’s initial approval letter is located on this site, under the Resources tab.

HCBS Provider Toolkit

The Division of Medicaid with the Department of Health and Welfare has developed a provider toolkit to assist all Idaho providers of Home and Community Based Services (HCBS) to comply with the new HCBS federal regulations and HCBS-related IDAPA rules. The provider toolkit gives Medicaid providers guidance about how to come into and remain compliant with the regulations and rules.  This toolkit contains information about the HCBS IDAPA rules, the intent of the HCBS IDAPA rules, best practices for compliance with HCBS IDAPA rules, and the Assessment documents that providers will be required to complete.  The toolkit also includes a glossary of terms that relate to HCBS settings, a participants right document,  sample policies and procedures for certified family homes, as well as additional resources for providers. 

The HCBS provider toolkit can be located on this page under the “Provider Toolkit” section in the right hand column. A hard copy of this document can be accessed at the regional Medicaid offices throughout the state.  The locations of the regional Idaho Medicaid offices are: Coeur D’ Alene, Lewiston, Caldwell, Boise, Twin Falls, Pocatello, and Idaho Falls.  

An updated training schedule has been included on this page as well.  This training schedule is entitled “Home and Community Based Setting training”.  This document is located under the “What’s New” section on the right hand side of this web page.

HCBS Rules

Medicaid Home and Community Based Services (HCBS) went into effect Friday, July 01, 2016. The Medicaid HCBS rules are contained in the Medicaid Enhanced rules in IDAPA 16.03.10 and the Consumer-Directed Services rules in IDAPA 16.03.13 which are published on the Idaho Department of Administration Website.  A direct link to these two sections of rules is posted on this page, under the “What’s New” section.

The Medicaid HCBS rules implement requirements to ensure that individuals receiving Medicaid Home and Community Based Services are integrated in and supported to gain full access to their community. Idaho Medicaid is currently working with stakeholders to establish a resource toolkit that will  assist Idaho providers of Medicaid HCBS services to come into compliance with the new HCBS IDAPA rules.  

Home and Community Based Settings 

The Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) published regulations in the Federal Register on January 16, 2014, which became effective on March 17, 2014, implementing new requirements for Medicaid’s 1915(c), 1915(i), and 1915(k) Home and Community-Based Services (HCBS) waivers. The purpose of the regulation is to ensure that individuals receive Medicaid HCBS in settings that are integrated in and support full access to the greater community and that the individual’s role in service planning is optimized. This includes opportunities to seek employment and work in competitive and integrated settings, engage in community life, control personal resources, and receive services in the community to the same degree as individuals who do not receive HCBS.

CMS expects all states to develop a HCBS transition plan that provides an assessment of potential gaps in compliance with the new regulation, as well as strategies and timelines for becoming compliant with the rule’s requirements. CMS further requires that states seek input from the public in the development of this transition plan.

Idaho has completed its’ fourth version of the state plan. This plan sets forth the actions Idaho will take to operate all applicable HCBS programs in compliance with the final rules. It is Idaho’s effort to comply/demonstrate compliance with the regulations around Home and Community Based (HCB) setting requirements. To access the updated Idaho Transition Plan, please go to Resources in the right hand column, Idaho Transition Plan – Version 4.


Ask The Program

We are interested in receiving your comments, recommendations, and questions as we work to move to full compliance with the new HCBS setting requirements. The State’s Transition Plan - Version 4 is posted here under Resources.  If you have any questions or comments about the plan or the new requirements (see Final Regulation under Resources) please send us an email and we will get back to you as soon as possible.

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