Waiver Amendment Comments Needed

January 08, 2017

It is clear to most that one of the less desirable aspects of the Waiver Redesign has been the lack of information and the lack of access to what used to be called “exceptional” rates and which will be “customized” rates in the future.  DBHDS has consistently talked about the option for additional funds to meet particularly challenging needs, but always without much specificity of the reality of using that option. Those who received exceptional rates prior to September 1st have lost that funding, at least in the short term.  Those Sponsored Residential individuals have been able to continue to receive the exceptional rate, but as of January 1 that too is gone.  And in the case of SRS – there are no plans currently to have that funding available in the future. It is, of course, true that the new rate structure does accommodate for higher need.  What is also true is that in some cases, the revenue for a specific individual has been reduced.  Whether or not the logic used by DBHDS is valid, providers feel deceived. The option available now is to make public comment on the Waiver Amendments released on Friday – they are (like most CMS documents) intimidating, but the “meat” of the amendment is in the “Purpose” statement at the beginning: Customized Rates – CL Amendment Customized Rates – FIS Amendment