HCBS Settings Reviews

May 04, 2021

We typically do not republish memos/information that has been widely distributed via the DBHDS Listsrv, but thought this memo warranted some special attention.  First, I believe that this is the first official notice that Virginia has agreed to extend the deadline to March 2023 as CMS has allowed.  This pushes the internal compliance deadline to September 2022 (six months ahead of the final deadline) to allow individuals who must relocate to maintain their Waiver status ample time to do so.  

Themes of this memo seem to revolve around provider compliance and cooperation – difficult at any time and extremely difficult when so many reviews, inspections and regulatory changes are going on simultaneously.  Sadly, we can not make any of the above “go away,” but we can emphasize that the HCBS reviews are serious and seriously important – failure can end your provider agreement, if not for your entire program at least for a location or two! 

Points that we gleaned from the memo that seem particularly important are:

• Update your contact details in RedCap – they are using that email address as the primary contact
• Be sure you are clear about what information is required – see page 3 of the memo for a list
• Apparently they are creating folders specific to each site in eDocs – as I am unable to access a sample, I can only suggest that you be certain of the instructions prior to uploading and confirm which “region” is relevant to each location
• This is a good time to review the specific policies that you provided in RedCap which formed the basis for your organizational compliance and note the compliance factors on page 4 as well as the “key principles” on page 5 (this is the original document with which we began this process)!