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Comments on CDPAP Reimbursement, Rule # HLT-53-19-00012-P

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The proposed changes to the Consumer Directed Personal Assistance Program (CDPAP)’s reimbursement structure will deeply impact the quality of care for myself and other seniors/disabled throughout the State. CDPAP was created on the premise that it is consumer directed: giving recipients the flexibility and freedom in choosing their caregivers. This is especially important in our community. Fiscal Intermediaries (FIs) are able to intimately manage caregivers who provide us with important cultural competencies from whom they would otherwise not be able to receive care. FIs Onboard. Check in monthly. Orient. Pay Medicals. pay overtime. and provide peer mentoring among others,

The proposed rule change will surely adversely affect Fiscal Intermediaries (FIs) throughout the State. This will have detrimental effects on the responsiveness and familiarity of caregivers with myself and others.

One such example is "overtime", which was drastically reduced - or even eliminated - last time when the cuts were implemented temporarily. It had a very negative effect on our services, it was only after the court order striking it, that it was put back, we are not ready for it again.

While there is surely a need to achieve savings throughout the Medicaid system, there are less drastic methodologies of imposing cuts and other areas of home care where substantial savings could be realized without impacting care in communities like ours. While we appreciates the steps the Department of Health has taken to rein in Medicaid spending, we believe that the proposed cuts to reimbursement rates will have drastic unintended consequence on home care throughout the State. Therefore, we respectfully request that proposed cuts structure not be implemented, and subsequently the Department of Health works with responsible Fiscal Intermediaries and stakeholders in the field to determine realistic solutions that can effectuate real cost savings.

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