Comments on CDPAP Reimbursement, Rule # HLT-53-19-00012-P
The CDPAP program is designed to allow consumers to exercise self-directed care in the community and keep them out of higher cost, institutional settings. Fiscal intermediaries are the entities that enable the program to function by performing multiple, critical functions for the consumers and their caretakers. The State is seeking to change the reimbursement for fiscal intermediaries, and to change it in such a way as to undermine the administrative backbone to the program, thus compromising the care system for thousands of New Yorkers who benefit from the program, including myself.
To date, fiscal intermediaries have been reimbursed for all reasonable administrative costs. However, the State is advancing a new methodology that that would reimburse FIs at a flat per member per month rate, set in three tiers based on the needs of the consumer. This is despite the fact that the Department of Health has not determined that any CDPAP administrative costs are unreasonable and should not be reimbursed.
FI’s try to provide the best Consumer Directed services to maximize self-direction, and to innovate where possible. This rate change will make that impossible.
What will be lost? Individuals often do not come to Fiscal Intermediaries knowing how to perform their duties. FI’s teach consumers what is entailed in hiring, training, scheduling, supervising, and sometimes terminating "Personal Assistants.” There are discrimination laws. FI’s have to explain what is permissible and what is not. The FI’s trained staff monitors consumers. With the new RFO process, FI's will have to complete orientations as well,
FI’s have to do the following:
- Explain the obligations imposed as a result of the Consumer Directed Program being a Medicaid program with state and federal rules.
- Ensure that the time reports received from Consumers are accurate, and that Consumers only submit time for authorized hours.
- Purchase and implement an Electronic Visit Verification system. FI’s often provide education and resources to Consumers on handling supervisory issues with their Personal Assistants, and investigating compliance concerns and complaints.
- Recruit and train their staff, Boards.
- PEER mentoring support,
- On-boarding Reps coming out to the home of the Consumers
These are services which keep me safe and well in the community and ensure that my care is compliant with the law. Please do not be blind to these needs; please do not blindly cut reimbursement to this program!