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Fiscal Intermediary Work Group Focuses on Best Practices and Roles of FIs

In its second meeting, the Department of Health's (DOH) Fiscal Intermediary (FI) Work Group discussed the feedback received from various stakeholders concerning the proper roles and responsibilities of FIs in the Consumer Directed Personal Assistance Program (CDPAP). The Work Group, which is composed of consumers, FIs, local social services district 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. DOH noted at the outset that the Work Group's role does not include deliberations over the FI reimbursement methodology and indicated that the method for implementing the FI reimbursement cut is still under consideration.

The Work Group carefully reviewed a lengthy slide deck developed by DOH that contained all of the recommendations received by stakeholders in response to DOH's request for feedback on FI best practices, the appropriate roles and responsibilities of FIs, quality measures, and FI selection criteria. Notably, the slides do not contain DOH proposals, but rather proposals from external stakeholders. Some proposals would conform to the current statutory and regulatory requirements and limits on FIs, while others would significantly expand or reduce the scope of the program. Among those who submitted comments, differences of opinion emerged between consumers who are seeking to maintain their own autonomy and minimize interference in their relationship with their CDPAS personal assistant (PA) and other stakeholders who are concerned about program integrity and the risks associated with poor quality care and neglect of duties.

For example, Work Group members expressed different perspectives on the imposition of requirements on FIs to train PAs, the need for and frequency of in-person monitoring of the consumer and PA, and the use of electronic visit verification (EVV) systems. In addition, some stakeholders called for even greater engagement of FIs in the employment of PAs, seeking recruitment assistance, background checks, and pre-screening of PA candidates. Consumers on the Work Group generally opposed these intrusions on their role as employers. In addition, some stakeholders proposed improved benefits for PAs. FI representatives pointed out that they cannot assume new roles or expenses in the context of looming rate cuts.

Some stakeholders proposed new requirements for the governance of FIs, seeking consumer representation on their governing bodies, robust committee and administrative structures, and firewalls between FIs and licensed home care services agencies (LHCSAs) that operate under a common sponsor. Others expressed a need to study these proposals carefully in light of legal and financial realities.

DOH noted that a request for applications (RFA) for FI services would likely be issued in early fall, with decisions released in January 2020. The Work Group was not able to discuss selection criteria in any detail within the time allotted for the meeting. Medicaid Director Donna Frescatore noted that the State is not seeking to select only one FI. She went on to say that the RFA would include certain required criteria as well as other qualitative information that would explain how an FI would fulfill certain objectives.

The next meeting will be held on July 10th. It will focus on quality and reporting requirements and may include additional discussion on the need for a local or regional presence by FIs, in-person monitoring by FIs, and PA training. DOH is seeking feedback from Work Group members on the proposals set forth in the slide deck and on quality measures in time for the next meeting.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124