Wednesday, December 17, 2008

Frequently Asked Questions for Georgia's New NOW and COMP waivers

FAQ for the NOW and COMP waivers (All questions were answered by the Office of Developmental Disabilities):


1. When did the NOW and COMP waivers become effective? Answer: The NOW and COMP waivers became effective November 1, 2008.

2. What is the plan year for individuals receiving NOW and COMP wavier services? The plan year for individuals receiving NOW and COMP waivers services is from the individual’s birth date in one year to his or her birth date the following year.

3. Where are the waiver manuals? The NOW and COMP Part II and Part III Polices and Procedures are located on the Georgia Health Partnership website (www.ghp.georgia.gov, Provider Information tab, Medicaid Provider Manuals tab).

4. What are the services in the NOW/COMP waivers? Answer: The list of services in the NOW/COMP waivers are found in the NOW and COMP Part II Policies and Procedures, Chapter 900, Section 901. The NOW and COMP Part III Policies and Procedures provide the service requirements specific to the individual NOW/COMP service.

5. Are there annual maximums for NOW/COMP waiver services? Answer: Annual maximum unit and dollar amounts for NOW/COMP waiver services are specified in the chapter for each NOW/COMP service in the NOW and COMP Part III Policies and Procedures. For a summary for all NOW/COMP services, see Appendix A to the NOW and COMP Part III manuals.

6. What are the documentation requirements for NOW/COMP waiver services? Answer: General documentation requirements for NOW/COMP waiver services are in the NOW and COMP Part II manuals, Chapter 1100. Requirements specific to individual NOW/COMP waiver services are in the chapter for each NOW/COMP service in the NOW and COMP Part III manuals. Documentation requirements for participant-directed services are in the NOW and COMP Part II manuals, Chapter 1200, Section 1216.

7. When will there be family forums on the NOW/COMP waivers? Answer: Family forums on the NOW/COMP waivers began in 2008 and will continue as needed. Announcements are distributed to families, Support Coordination Agencies, DHR, Division of MHDDAD Regional Offices, and advocacy organizations.

8. Can families pay for services and be reimbursed? Answer: No. Families can not be reimbursed for their payments for services and goods.

9. Can my son/daughter continue to receive Natural Support Enhancement Services? Answer: No. The Natural Support Enhancement (NSE) service is no longer available. Former NSE services that are allowed under the new waivers are specified as NOW and COMP waiver services. Families should contact their Support Coordinator to discuss these changes.

10. Can participants receive Applied Behavior Analysis (ABA) services in the NOW/COMP waivers? Answer: Yes. ABA services include assessment, planning, consultation, family training, and individual skills training. The professional level assessment and plan development are available through Behavioral Supports Consultation services. Family training is also available through this service or through the NOW service, Natural Support Training. Skills training can be provided through Community Access and Community Living Support Services. Adults can also receive skills training through Prevocational and Supported Employment Services.

11. How do I change services for my family member? Answer: Families should work with their support coordinator to change waiver services.

12. How do I find out about self-direction of waiver services? Answer:The individual’s support coordinator can provide information about the self-direction of waiver services. The regional office can provide information about self-direction of waiver services for individuals who are not currently receiving waiver services and want this information. The following website will allow you to locate your regional office and its contact information (www.mhddad.dhr.georgia.gov, click on Consumer Information).

13. Where is there a list of approved providers for the NOW/COMP waivers? Answer: Regional offices maintain the list of approved providers. The following website will allow you to locate your regional office and its contact information (www.mhddad.dhr.georgia.gov, click on Consumer Information).

14. How did Day Habilitation Services transition to the NOW/COMP waivers? Answer: The federal government required the unbundling of Day Habilitation Services into two services: Community Access Group and Prevocational Services. Individuals who received Day Habilitation Services will receive one or both of these services in the NOW/COMP waivers.

15. How did Day Supports Services transition to the NOW/COMP waivers? Answer: The federal government required the unbundling of Day Supports Services into five services: Community Access Group, Community Access Individual, Prevocational, Supported Employment Group, and Supported Employment Individual Services. Individuals who received Day Supports services will receive one or more of these services in the NOW/COMP waivers.

16. How did Supported Employment Services transition to the NOW/COMP waivers? Supported Employment Services transitioned to Supported Employment Group Services. Individuals who received Supported Employment Services will receive Supported Employment Group Services until his or her birth date and the development of the NOW/COMP Individual Service Plan.

17. How did Personal Support transition to the NOW/COMP waivers? Answer: If a person transitioned from Personal Support Services to the COMP waiver, he or she transitioned to Community Living Support (Daily). If a person transitioned from Personal Support Services to the NOW, he or she transitioned to Community Living Support (15 Minutes) and Community Access Individual (15 Minutes) Services.

18. Under Participant Direction, are representatives and individuals allowed/required to employ individuals under the following services: Adult Physical Therapy Services; Adult Occupational Therapy Services; Adult Speech and Language Therapy Services; Behavioral Supports Consultation Services; Environmental Accessibility Adaptation Services; Natural Support Training Services; Specialized Medical Equipment; Specialized Medical Supplies and; Vehicle Adaptation Services or are these services provided by providers authorized and enrolled under the Medicaid Waiver and selected by families? Answer: Under participant direction, all the listed services in the second paragraph are vendor payments by an enrolled Financial Support Services provider. The listed services can also be provided by an enrolled Medicaid provider.

19. Does this mean under Vendor status there is no provider credentialing? If so, who does the credentialing? Answer: It means that providers do not directly enroll as a Medicaid provider when a family self-directs. The provider must meet the requirements as specified in the NOW and COMP Policies and Procedures. The family with the assistance of the Support Coordinator assumes the responsibility of assuring that vendors meet these requirements.

20. Can a provider of SMS issue a debit card to families (individuals), at the provider's risk, in order to give families control of where they get their specialized medical supplies? Families and individuals like to be wise purchasers of service and this would allow them to choose the best vendor and best price. The provider would have to submit only those expenses that meet the ISP requirements for the purchase of supplies and if the family/individual didn't purchase the items required, the provider would be at risk for this expense. Answer: The Department of Community Health has confirmed that the use of debit cards is not allowed.

21. Under Respite care for overnight, how can a family receive respite from an employee for two concurrent overnights without it running into overtime (this would be a 48 hour period)? Under FLSA rules, as an employee they must receive overtime wages. Answer: A family could employ different individuals to provide the respite on concurrent overnights and not exceed the overtime requirements.

22. In the NOW manuals it indicates that participant directed services would need to choose vendors for some services. However there are differences in the requirements for documentation on the part of the vendors (specifically behavioral supports consultation services for one). If all BSCS providers are considered vendors regardless of participant direction, what is the criteria for the different documentation requirements in the manual? Will BSCS and other vendors under participant direction get paid through the FSS or will they be required to bill medicaid for service payment? Answer: Documentation requirements for participant directed services are as indicated in Chapter 1200 of the NOW and COMP Part II Policies and Procedures on the Georgia Health Partnership website (www.ghp.georgia.gov, Provider Information tab, Medicaid Provider Manuals tab). BSCS providers can enroll as a Medicaid provider and bill Medicaid directly for their services. When a participant opts to self-direct BSCS, the BSCS provider gets paid through FSS.

23. The policies seem to prevent an Medicaid Waiver provider organization from using contracted private home respite providers. Is this correct? Answer: No.

24. Under the requirements for provider agencies: f. allows for contracted professionals. Does this mean agencies can contract with other professionals to deliver services? Answer: Yes, but all service specific qualifications, state professional license, and agency license requirements specific to the service must be met.

25. One of the requirements for Agency Directors is that they are responsible for managing the agency's funds. In larger organization, this functionality belongs to financial staff with oversight provided by the director. Is this adequate? Answer: Yes. The agency director is ultimately responsible for the management of the funds since the agency director provides oversight.

26. In natural Supports Training if the unit is billed at a 15 minute rate, how can a NST provider bill for the costs associated with sending a family to a training event or conference? Is it billed for every 15 minutes of training provided to the family in the event or conference? Answer: Yes.

27. In Biennial Medication Assessment the policy appears to require an assessment at all sites two times per year. Is this correct? If so, is a separate assessment for each site required? It also appears that the policy assumes that there will be findings, requiring an attestation that all issues have been corrected. Is this correct? Answer: Your question has been forwarded to the Department of Community Health. An answer will be provided once response from DCH is received.

28. In Biennial Medication Assessment the policy requires an independent licensed Pharmacist or a licensed Registered Nurse. Does the Registered Nurse also have to be independent? Answer: Your question has been forwarded to the Department of Community Health. An answer will be provided once response from DCH is received.

29. There is a biennial Medication assessment required for all organizations that secure their medications from a retail pharmacy. By law, providers cannot secure these medications, but these are the consumer's medications, purchased with their Medicaid or personal funds. What is the requirement here for providers? Answer: Your question has been forwarded to the Department of Community Health. An answer will be provided once response from DCH is received.

30. Under the NOW Manual it states that the only services that may be offered under Hospice are: Community Access; Prevocational Services and; In-home Respite as long as they are not duplicative of the Hospice services. However it also states that Waiver providers must offer the same service to a member that has elected to receive hospice that it offers to members who do not. Is this statement requiring providers to continue to provide the other services on the ISP even though it is unreimburseable? Answer: The hospice requirements have not changed from the MRWP to the NOW waiver. The only change is the name of the services listed. Please see the MRWP Chapter 900, Section 904. The listed services are those considered to not be duplicative of the hospice services and therefore reimbursable for the provider.

31. Are annual limits for related to Community Access, Prevocational or Supported Employment services combined? Specifically, let’s suppose a participant is working on community integration for social skills and participating in the community, but has also has a job. Given that there would be enough resources in the allocation could the participant use the maximum of community access individual (1440 units) and also some of the supported employment units? In other words, are service caps on community access group and individual; supported employment and; prevocational taken as a whole or does each service represent a separate cap on the amount of units a participant can use? Answer: Each service cap is separate, but available funding for these services is dependent upon the needs of the participant and the waiver allocation for that participant.

32. Is there a group of services that can go above the caps for service? Answer. Information on exceptional rates requests, including services for which requests can be made, is in the NOW and COMP Part II Manual Chapter 1000 posted on the Georgia Health Partnership website.

33. Is there a process to increase someone's allocation if there is an exceptional circumstance? If so what is this process? Would it require a new or addended ISP, SIS and HRST? Answer. Yes. There is a process in which the request is made by the support coordinator to the regional office. It requires support for the request that could include a new SIS or HRST. If approved, it would require a new or addended ISP.

34. What types of services under self direction can families use vendors and what services are required to be delivered by an employee of the family? Answer. Under self-direction with payment by a fiscal agent, Community Living Support is an employee only option. This means that the family hires the individual and submits timesheets. There are no vendor payments.

Under self-direction with payment by a fiscal agent, Community Access Group and Community Access Individual are primarily the employee only option. This means that for most self-directed Community Access services there is the hiring of employees and the submission of timesheets. Vendor payments under Community Access services are only for registration fees to summer camps, peer discussion and support groups, cultural programs and events, physical fitness and weight reduction programs when specific to the disability or therapeutic in nature and tied to an ISP goal. Vendor payments do not include after school activities/programs, and other ongoing activities, assistance, and skills training under Community Access Services.

A family can have GCSS provide traditional Community Living Support or Community Access Services, and self-direct other services. An individual can receive a mixture of self-directed and traditional services.

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