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CDPAS FI Workgroup Discusses Quality, Selection Criteria

The third meeting of the Department of Health's (DOH) Fiscal Intermediary (FI) Workgroup picked up where the last meeting left off, with participants carefully reviewing the long list of recommendations received from various stakeholders in response to a DOH request for input. Most of the time was spent on discussing possible ways to measure FI quality as well as the selection criteria recommended for inclusion in the forthcoming procurement process. DOH anticipates issuing a request for applications (RFA) for FI services in early fall, with decisions released in January 2020. The workgroup, which is composed of consumers, FIs, local department of social services (LDSS) staff, managed care plans, and provider associations, is charged with helping the State to develop selection and contracting criteria for FIs while also considering other issues, including quality and reporting requirements.

Although several concerns have been generated by the FI Rate Structure policy guidance DOH released earlier this month, the Department has consistently messaged that the reimbursement changes are outside of the workgroup’s jurisdiction. The guidance, Managed Care Policy 19.01, is available here. In response to plan concerns regarding the timing and financial implications of the guidance, DOH met by phone with associations and promised to provide some further clarifications.

While few of the recommendations received universal support or opposition, the workgroup process served to clarify many of the suggestions, with participants helping to refine them by suggesting further considerations or parameters. During the discussion, workgroup members:

  • Reviewed the suggestion that plans contract with any willing FI during the transition period, with DOH staff noting that the State has not used this approach in other transitions and is more likely to support use of single-case agreements than a contracting mandate;
  • Expressed varying understanding of what discrepancies between authorized and actual hours might indicate, with DOH asking whether such data could be used to identify staffing shortages;
  • Pointed out the increasing cost of certain requirements such as TB tests for Personal Assistants (PAs) and the need to have costs such as PA physicals treated in a consistent way;
  • Voiced concern that reduced funding will make it more difficult for FIs to continue existing or implement new quality tracking and training initiatives being suggested;
  • Helped other stakeholders understand timing delay dynamics from different perspectives: the process of a Consumer Directed Personal Assistance Services (CDPAS) client hiring, and the FI onboarding, a sufficient number of PAs and beginning services, especially in areas where staffing is most difficult, can violate the requirement that plans disenroll members who do not receive services for a period of 30 days;
  • Heard DOH indicate that satisfaction and reduction in avoidable hospitalizations are State priorities and will likely be included in quality measurement. DOH can access hospitalization data so would likely not require additional reporting;
  • Were asked to share with DOH any good satisfaction surveys currently in use;
  • Stressed the importance of ensuring that satisfaction measures not measure issues on which FI behavior may have no bearing (e.g., client’s satisfaction with their PA);
  • Learned that DOH will compile a list of FIs based on the information request currently with plans and County DSS Offices to achieve a standardized process for informing consumers selecting an FI. 

DOH wants to ensure a smooth transition process that includes appropriate client protections for individuals who may need to change FIs. Because there was insufficient time to address these issues, DOH intends to extend the length of the fourth and final workgroup meeting to have a full discussion of the topic. The Department is seeking input and has distributed a list of transition-related questions that they wish to address (available here). The final meeting is currently scheduled for Aug. 7th.

LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841