CMS and DODD reach agreement about Conflict of Interest

The Ohio Department of Developmental Disabilities (DODD) announced on June 23 that the Center for Medicaid Services (CMS) has accepted the state’s plan of compliance regarding Conflict Free Case Management, giving County Boards until 2024 to come into compliance.

Summit DD representatives hosted community meetings in May about potential system changes that offer individuals more integrated choices and the County Board’s role as a service provider as part of the CMS transition plan.  “Summit DD is not going away,” stated Superintendent John Trunk during these community meetings. “Our role as a direct service provider may be changing, but our support to families and individuals will continue at an even greater level in the future.”

Trunk explained Summit DD is vital to coordinate services, secure and fund the local share of Medicaid waivers, connect families to quality service providers, provide health and safety services and provide early intervention and transition support to families.

What is Conflict Free Case Management?

New CMS regulations effective in March 2014 prohibited providers of Medicaid-funded Home and Community-Based Services (HCBS) from also providing case management services.  Locally, we refer to these essential case management services as Services and Supports Administration, or SSA.  HCBS include supported employment, adult day services, vocational habilitation, non-medical transportation and residential services.  Summit DD does not provide residential services, however approximately 490 individual receive adult day support, 200 individuals receive supported employment services and 571 individuals receive transportation services directly from the board.  This represents approximately 44% of all individuals who are receiving these services.  Summit DD service coordinators also provide case management services to approximately 3,000 adults and children.

After initial proposals to “grandfather” current County Board enrollees was rejected by CMS, the state submitted a proposal to allow additional time beyond the suggested five years to come into compliance.  CMS responded to the state in June, recognizing that Ohio has already made significant progress to eliminate the conflict of interest, and recognized that more time would be needed to develop provider capacity.

What is the Timeline for Implementation?

As the agreement between DODD and CMS currently stands, County Boards will not be permitted to provide HCBS to new enrollees, including adult day support, vocational habilitation, supported employment and non-medical transportation, unless there is no other willing and qualified provider in the geographic region to do so.  Qualified means certified and evidence must be shown that no certified providers were willing to serve an individual.

County Boards, including Summit DD, are required to submit a plan by September 1st that shows annual benchmarks for the recruitment of sufficient qualified providers and for the reduction of individuals utilizing Summit DD as a provider of HCBS.

By 2020 no more than 30% of percent of individuals who are receiving case management from Summit DD may be receiving HCBS from the Board.  By 2024 Summit DD must be in total compliance.

What are the Next Steps?

  • Summit DD will be developing annual benchmarks for compliance by 2024 by September 1. We will share those benchmarks throughout the transition process.
  • Summit DD will continue working with current providers and recruiting additional providers to ensure that capacity exists for adult day support, supported employment and non-medical transportation that are already underway. Summit DD may also assume increase monitoring and oversight responsibilities of providers when the County Board is no longer a provider.
  • Service and Support Administrators (SSA) will begin conversations with you if you currently receive adult day, vocational habilitation, supported employment or non-medical transportation from the County Board. Summit DD’s goal is to ensure a smooth transition to a qualified provider of your choice when you are ready to take that step while meeting annual benchmarks.  The Board also understands that we will need to review our facilities and offerings during this transition.
  • It is also expected that CMS will respond to DODD’s transition plan to more inclusive services later this summer. The transition plan to more integrated settings will impact both the County Board as a provider through 2024 and all other providers.

Summit DD remains committed to providing open, transparent communication to all stakeholders and to getting input as we implement these required changes.  We have scheduled public meetings in September (see below) to share future plans and any additional information about the CMS transition plan.  Likewise we will continue to share updates about the process through blog posts, direct mail, social media (Facebook, Twitter, Pinterest and LinkedIn), our hotline at 330-634-TALK (8255) and through our monthly enewsletter informDD.

Community Meetings
September 14 – Red Cross of Summit and Portage Counties
September 16 – The Natatorium
September 21 – Barberton Public Library
Meetings are scheduled from 6-7 p.m.

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