– 1 Day: But Who’s Counting?
The recent glitch in the Xerox system that houses VaMMIS and the WebPortal may have delayed posting of several critical Memos – the Provider Enrollment information is referenced below, the necessary information for billing is contained in two News Posts from last week and the information about DSP training is below (the Memo is scheduled to come out next week). The DSP Supervisor Training materials were posted this afternoon on the Knowledge Center – clearly not a viable timeframe for meeting the DBHDS published requirements for all staff hired on or after 1 September to have the updated version of the training!
To accommodate the phase-in period, afford providers needed time to have their trainers update their credentials and to integrate the new materials into their training curriculum, DMAS will commence auditing for the new training requirements beginning January 1, 2017 for 120 day post implementation requirements (DSP supervisors) and beginning March 1, 2017 for 180 day post implementation requirements. During the phase in period outlined above DSPs and DSP supervisors personnel records must maintain documentation of training through the older materials (“Staff Orientation Workbook”) and successful completion of the accompanying test. Remember that all staff must pass the objective test associated with the Staff Orientation Manual prior to providing reimbursable services.
– 4 Days: More on DSP Training
The DSP Orientation Manual (2016) and related materials are posted on the DBHDS Website here (http://www.dbhds.virginia.gov/professionals-and-service-providers/developmental-disability-services-for-providers) and a “word” version of the Manual was also posted on the VNPP Provider Resources page this weekend – it will be easier for you to add sections of the new material to your existing training using the “word” version.
The DSP Supervisor Training, to be posted on the COV Knowledge Center and the Medicaid memo describing the process is not yet available; it is our understanding that once a Supervisor has completed their training you will be sent a copy of the answer key.
It is clear that it will not be possible to reasonably implement any of this process for new hires immediately and the regulations appear to give some flexibility. After the Medicaid memo comes out sometime next week, we will be able to give better suggestions.
– 6 Days: Reading Regulations 101
We recognize that the regulations which have been posted and shared in multiple ways are cumbersome, confusing and a bit intimidating! Even for those of us used to the regulatory process these are more challenging than most. So we have done the following to try to make the material more “user friendly!” On the Provider Resources Page there are a Table of Contents and the regulatory package has been broken into parts with the section numbers highlighted and (where possible) pages that only contained repealed sections/lines removed. We hope that this will make it easier to read.
The Provider Resources page is a public page, so feel free to share the information with other providers!
– 7 Days: Provider Enrollment Requirements
One of the memos we have been waiting for will describe the requirements for provider enrollment (not to be confused with provider qualifications/licensing); the Memo is in the last stages of the process before being posted, but the details are available in this Provider Enrollment Guidance document. The WebPortal Provider Enrollment section will not be ready to accept new service enrollments until 1 September, but this will give you the needed information about what, if anything, will be required.
– 8 Days: Regulations
We have reviewed the regulations which were signed by the Governor yesterday morning and will be effective 1 September; they will be posted for 30 days of public comment on 19 September, but as will all Emergency Regulations the public comment is really directed toward the revisions which will come in the proposed permanent regulations.
The issues we see are as follows:
Note: The regulations are organized with an overall section which describes the basics which apply to all Waivers (12VAC30-120-500), and the services and specifics of each Waiver (FIS-700; CL-1000 and BI-1500) For the most part services which are found in multiple Waivers, the description is found in 1000 et seq.
- There is, thoughout, a requirement for the supervision of DSPs to be provided by QDDPs based on the federal definition for QDDP which (generally) requires one year of documented experience working directly with individuals with developmental disabilities and at least a bachelor’s degree in a human service field. The definition will not permit the use of experience in lieu of a degree as the definition currently in DBHDS Licensing Regulations.
We have raised the concern and have proposed a solution! We believe that this will be one of several issues cleared up today!
- There are several conflicts in the qualifications for providers as outlined among the various sections – for example, in one place it states that a “day support license” is required to provide Community Engagement and in another it clearly says that a “Non-center based day support services”
- Community Coaching appears to be consistently listed as requiring a “day support” license.
- We had some concerns about how to implement the proposed new training and competency requirements, but the regulations give ample time for us to train the trainers/supervisors and to integrate the new material into existing training, processes and procedures. They also require that the advanced core competencies for individuals in Levels 5, 6 & 7 be required for DSPs and DSP Supervisors specific to the individual’s needs and level. This appears to acknowledge that the individual’s needs will factor into which training may be necessary.
We recognize that the regulations as posted are difficult to read; it is, however, important for all providers to be very familiar with the content. When they are posted on the 19th – they will likely not contain the track changes and be easier to manage. We will try to create a reference table soon!
– 9 Days: Updates
- The regulations have been signed and are now final – effective 1 September; there are a number of issues which we are still reviewing and trying to sort answers for you. Stay tuned!
- WaMS will apparently be more accessible to providers on September 1st than we believed. Providers should be obtaining their log-on credentials and reading the Manual posted on the WaMS site (the one posted on the DBHDS site is not accurate!)
- We are still waiting for the following memos – Provider Enrollment, Service Authorization (which will have the necessary information about billing for services including group home services), and the Competency/Training Requirements for DSPs.
- We also want to remind all Day Support providers that no services will change on 1 September – the provider (with the individual/team) will convert to new services or continue in Group Day services either at a date of the provider’s choice or at the annual plan date for the individual.
- Rate charts will be posted on the DMAS website (and we will send them out as soon as we have them) which will have the complete billing codes for all of the services including the modifiers necessary to bill appropriately for each tier!
- We also understand that at least some pre-voc providers who have tried to become DBHDS Licensed are not yet licensed. They will not be able to complete the provider enrollment and that cannot be done retroactively.
– 10 Days: First Look at the Proposed Emergency Regulations
The Emergency Regulations for the implementation of the three Waivers have reached the Governor’s Office in their review process and are now posted and available on the Provider Resources page.
We will analyze what is posted and try to summarize anything unexpected by tomorrow; it is, however, a document to be read carefully as it is the controlling document for the three DD Waivers to be implemented 1 September.
We were also informed today (and the Emergency Regs confirm) that the form numbers posted below for forms regarding staff training and competencies are incorrect – as of today they have not been updated on the website; we believe that the only change to be made will be in the suffix letter (a or b).
– 11 Days: No News Is Not Necessarily Good News
The biggest news for today is that there is really no news except that, from multiple sources, there have again been changes in critical systems and information that will have direct impact on providers. We need to remember that the Medicaid Regulations (which are moving fairly rapidly though the approval process, though they are not yet publically available) will be the controlling document for implementation.
We are still waiting for a couple of critical Medicaid Memos which will provide clear direction and, hopefully, answer the questions we still have that will enable services to continue and be billed. It is our understanding that the first to come out will be about provider enrollment – while providers may not have to “re-enroll” for services that already provide; providers will apparently be required to take some action to enroll for the “new” services. Stay tuned!
– 12 Days: Updated Basic Mechanics
DMAS had confirmed than the full chart of rates/billing codes will be posted on their website on or before 1 September. We have received memos about Residential, Day and some other selected services including nursing services and Therapeutic Consult.
There are still too many issues to count with the proposed implementation of the WaMS system; we do know, however, that the DBHDS optimal plan and what the CSBs are able or willing to accomplish may be two different things. Our focus, in the near term, is to structure a solution that allows services to be authorized, billed and paid. We do not place any priority on the DBHDS efforts collect information on types of services vs SIS Level, amounts of natural supports and how they change over time, etc.
We understand the role the DBHDS has in approving service plans for the purpose of service authorization, but that function should only insure that the plan falls within the description of the allowable activities in the service and was developed in accordance with the person-centered process – determined by the team as led by the individual.
– 14 Days: Basic Mechanics
The latest we have is that it is unlikely that either the memo clarifying the “service authorization” processes (transitional and ongoing) or the memo articulating the requirements for provider enrollment in new services will be available before the end of next week. This will give providers only a few business days to accomplish tasks which in other circumstances would have been completed weeks, if not months, in advance. The “service authorization” memo will include the basic mechanics of billing for group home residential which will convert to new codes, units and rates dependent on both the SIS Tier and the licensed capacity of the site on 1 September.
It is relevant to note that providers continue to not have access to the SIS scores that have, we understand, been entered into VaMMIS. We may be able to “see” that information in WaMS when it comes on-line; at best, you can calculate from the SIS you have on hand and make adjustments to you billing when the information is available. If you use a rate that reflects a higher Tier than that assigned, you should be paid at the lesser amount. VaMMIS should pay the lesser of the amount billed or the amount authorized.
We do understand that if no SIS has been done, a tiered service may be billed at Tier 2 rates and the provider will be held harmless for any pay-back if the final Tier assigned is Tier 1; the provider will be able to adjust their billing if the Tier assigned is higher than Tier 2.
As Day Support services will convert at a date picked by the provider, there may be minimal impact on Day Support providers on September 1st. As providers choose, and can consider the options available for the use of the new services, then conversion to new codes, units and rates will occur.
On the bright side, we understand that providers currently enrolled as a provider of a specific service will not have to “re-enroll;” in other words if you have been providing group home residential services, you would not have to re-enroll to provide the same service.
Also on the bright side, we understand that if the data migration from the IDOLS system to the WaMS system occurs as planned, the current authorizations will remain intact. The SA number (which is required for billing) resides in the VaMMIS system and will not be affected by this data swap.
Existing codes for services will continue to exist as providers can go back as far as one year to make adjustments or correct errors in billing. Existing codes for Day Support (97537 and 97537 U1) can be used until the provider is able to convert services for all. The alternative would have individuals with different units (hours vs blocks), and rates, and potentially different service descriptions all in a single program/site – a less than ideal situation!
– 15 Days: Services
The last we saw anything that described the services available in each of the three Waivers was when the Application was submitted to CMS for approval in early April. I have received verbal assurance from DMAS that the service descriptions are essentially unchanged. It is, however, true that as we get closer to implementation there are multiple interpretations of exactly how the services will work especially how “new” services will relate to others and to existing services.
The most frequent question seems to be about Community Engagement. The Community Engagement Service is currently being done by a number of providers who have never had a “center-based” Day Support and have managed community-based services with a small staff to individual ratio (no more than 1:3). This has been, and continues to be, a separate service from any residential service.
While there may be some very creative ways to use this service or the Community Coaching service to offer new opportunities for individuals to be better engaged in their communities, this is not intended to “supplement” the residential billing. This service could be added during the individual’s PCP meeting to address a need not able to be met by the Residential, Employment or other Day Services provider.
More on WaMS:
The following is posted on the WAMS website at https://www.wamsvirginia.org (registration information is available from DBHDS):
The Virginia Waiver Management System (WaMS) will be fully operational on Thursday, September 1st, 2016. As part of full WaMS release on 09/01/2016, all data will be migrated from existing systems (DD, IDOLS, etc) in order to allow seamless operation. Examples of data to be migrated to WaMS include, but not limited to, persons (program participants), waitlist individuals, and service authorizations. To prepare the system for the release:
- WaMS will be down from 8 PM until midnight on Friday August 19, 2016.
- You can continue using WaMS until the end of day on 08/23/2016 to add staff to your organization and assign them the proper roles. On Wednesday 08/24/2016, WaMS will be taken down completely and will be inaccessible until the system is fully operational on 09/01/2016.
Please be aware that:
- Any staff information you enter in WaMS through 08/23 will be retained when WaMS goes live on 09/01/2016. For instructions on how to set up staff profiles, please refer to the instructions here.
- Any other data you enter (e.g., persons your organization is serving) will be removed from the system prior to the full release. Therefore, it is not advisable to enter real data in the system at this time, except for staff profiles.
And the Provider WaMS Manual is available!
– 16 Days:WaMS Update
While providers are not actively participating in discussions about the WaMS implementation we have been able to keep up with some of the discussion; what we know at this point is as follows:
- There was no interaction with CSB representatives in the WaMS development stage and the resulting product is causing significant consternation because of the requirements for, among other things, “double entry” of vast amount of information. The CSB position, and this would be our position also, is that the single source for any service plan, record of services, or review of services would be the provider’s primary record.
- DBHDS is trying to create a Waiver Management System that includes not only individual participant information (as the IDOLs/VaMMIS system does currently) but the details of the assessment (SIS), services authorized/billed and the service plans (to eventually include an activity calendar to show how each individual spends their week). They are, in effect, creating the individual’s record within the WaMS to facilitate the data analysis that they feel will assist them in assuring that the services used and the services “needed.”
- One of the data elements that will need to be entered, as DBHDS now understands that they do not have this data in any of their current systems, is which individual lives in which Group Home – this is obviously important because the reimbursement rate is dependent on licensed capacity. To date, there is no time frame for that to occur, but DMAS has always assured us that thee will be no interruption in billing!
– 17 Days: Staff Development & Competencies
Neither the revised Orientation Manual for Staff nor the training for Supervisors/Trainers is available today. However, the related forms which are now DMAS Forms have been posted. We have put the link at the top of the “Provider Resources” page on our website (Hint! Select “Intellectual Disabilities Waiver” as the category.)
The posted forms fall into four categories:
- Competencies Checklist for DSPs and Supervisors [DMAS P241-b]
- Assurances for DSPs and Supervisors for DBHDS Licensed Services [DMAS P242b & P245b]
- Assurances for DSPs and Supervisors for non- DBHDS Licensed Services [DMAS P243b & P246b]
- Special competencies for those seeking additional reimbursement for services for individuals with SIS Levels 5, 6, or 7. [DMAS P244b – Health, P240b – Behavior, or P201a – Autism]
The Medicaid memo which describes the expected implementation is in draft form and working it’s way through the approval process at DMAS. Given the very tight timeframe and the expectation that the new material will be used for staff hired on or after 1 September, there are some things you can do to prepare:
- While there will be 90 days for the supervisors/trainers who are currently certified to recertify through the Knowledge Center; the expectation that new staff will receive the revised training is, of course, extremely problematic if not impossible for providers who do continuous recruitment. We will let you know as soon as the materials are available on the Knowledge Center and will work with DMAS to try to make this requirement a bit more flexible!
- In addition to the training – which is very similar to the 2012 package which is currently in use, but has some nice new features – there is also the expectation that supervisors/trainers will assess the competencies listed on the checklist listed above and that the agency head or designee will perform a similar role for the supervisor/trainers. The checklist is to be completed upon hire and annually thereafter; it is to be completed for all currently trained staff within 180 days (by March 1, 2017). The printed instructions for use are as follows (some formatting/highlighting added for clarity):
Virginia’s Competencies for Direct Support Professionals and Supervisors who support individuals with Developmental Disabilities
This checklist is a tool to guide the development of DSPs and their supervisors in understanding their role in supporting people with DD in positive ways. The focus is on basic DSP and supervisor ability to meet the requirements of the DD waivers and to support individuals to have a life that includes what’s important TO each person based on his or her own desires and what’s important FOR each person in terms of health, safety and value in the community. Direct Support Professional refers to anyone directly supporting individuals with DD in a waiver funded service in Virginia. The initial and ongoing completion of this checklist is the responsibility of direct supervisors who oversee the work of DSPs providing support under any of Virginia’s DD waivers. A supervisor’s ability to meet the required competencies is determined by the provider’s director (or designee), as well as through site visits conducted during program reviews.
The columns in the checklist serve as a location to note dates, activities and observations that support a determination of proficiency with each competency.
- The Training Received column provides for recording the dates and details of formal and informal training efforts related to the competency.
- The Implemented Skills column provides space to record the dates and descriptions of the supervisor’s direct observation of the related competency.
- The last column Proficiency Determined is a location to record the date that the ability is confirmed by the supervisor through discussion and observation of the DSPs abilities and understanding. DSPs and Supervisors have achieved each competency once all related skills and behaviors are observed. If a behavior related to any skill does not apply in the current role, indicate as not applicable.
This checklist must be updated at least annually and as needed to ensure that DSPs and their supervisors are proficient in the competencies as described. Competencies may be documented on this tool or adapted into an electronic format as long as the competencies and areas of reporting remain consistent with this document. The initial completion of the checklist and annual updates must be maintained in personnel documents and available for review by the Department of Behavioral Health and Developmental Services, the Department of Medical Assistance Services and other reviewers as needed.
These competencies must be updated annually by the supervisor (for DSPs) or the agency’s director (or designee) for supervisors. Providing a signature and date of review below confirms that the DSP or supervisor continues to meet these competencies. If competencies do not continue to be demonstrated, provide 180 days for repeating the test and reconfirming that the competencies are met. The following update form may be utilized for three consecutive years before a new checklist is needed for updates. A new competency checklist is needed in the 5th year.
We found the format for the checklist challenging and offer a version in Word attached here. [NOTE – this is an exact duplicate of the text posted including two items with the same number and item #1.1.2 which was not checked for either DSP or Supervisor, but would appear to apply to both]
The initial review by any provider will need to be how this device can be integrated into existing provider policies and procedures for staff development, performance evaluation, meeting standards of conduct, etc. For many providers the checklist may simply serve as a place to draw together material that already exists such as records of training (formal, informal and individual specific), performance evaluations, on-the-job training checklists, etc. The checklist itself, especially those items which are subjectively measured, may not be sufficient to document/justify separation from employment – nor should it be. The evaluation of performance should be ongoing and (as every labor law lawyer will attest) clearly documented.
When the 2016 Staff Orientation Manual is available, providers with more robust Staff Development programs will have the opportunity to integrate the new material into their existing training – that will, of course, take some time and effort. The expected measure is 80% or better accuracy on the test and the appropriate “Assurances” signed, dated and filed. We will share a Word version of the manual when we have it – much easier to integrate new material into existing training!
– 19 Days: DBHDS announced to the CSBs last evening that they do plan the IDOLS shutdown for August 23rd – the announcement is here. When we had this discussion several weeks ago, VNPP asked a number of operational questions because of the potential for significant impact on providers; sadly we have not received any clarification – so we will ask again! It is probably prudent to work closely with your CMs to push through anything which is in need of renewal between now and mid-September if you can do so. It is also probably prudent to print (or save in some way) everything that is in process in IDOLS.
Rounding Rule – The following is the likely “rounding rule” which will be used by DMAS for Group Day, Community Engagement & Community Integration billing:
“Only whole hours can be billed. If an extra 30 or more minutes of care are provided over the course of a calendar month, the next highest hour can be billed. If less than 30 extra minutes of care are provided over the course of a calendar month, the next lower number of hours must be billed. Providers may bill for services more than one time each month per member. However, the rounding up of hours is for the total monthly hours and not each time the provider bills DMAS.”
EDCD – Chapter V pg 12 & 13
7 June Update
The Guide to Estimate Revenues for Group Home and Day Support/Community Engagement Services which we released several weeks ago in the hope that those providers who had not yet calculated their expected revenues by establishing the Level/Tier for each individual who will be in a residential or day service that will have a tiered rate system could do so. The same calculation was sent out today in a memo released by DBHDS. Unfortunately, there are still a couple of unknowns:
- We have confirmed the statement made today by DBHDS that there are significant errors in the data provided to the CSBs – it will be difficult, therefore, to confirm Levels/Tiers against the list provided to the CSB.
- We have also found that some of the Levels/Tiers listed in the data provided to the CSBs are higher than those which can be calculated – while that might be advantageous, there is no way for a provider to determine that without checking with the CSB.
- There is no documentation for the higher levels available to the providers; at this point we can offer no guidance on how to absolutely to determine the Levels/Tiers accurately (other than doing the calculation yourself and trusting your work!) At some point in the future, we have been assured that the Tier will be visible in the MMIS billing system in the fairly near future.
- In cases where a provider bills at a level lower than authorized, the claims can be adjusted to the correct level; if the provider mistakenly bills a rate higher than indicated, the MMIS system will pay at the the billed rate or the authorized rate which ever is lower.
- The feedback we have from the the Provider Call managed by DMAS/DBHDS is mixed; routine opportunities for providers to ask questions and for all parties to hear the discussion and answers are always valuable, and we hope they will continue. On the other hand, it was very discouraging to hear all that is still unknown, unavailable or undecided in the first week of June!