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Spotlight on Home- and Community-Based Services: New Federal Opportunities?
/in COVID-19 Relief and Recovery Resource Center Blogs, Featured News Home Chronic and Complex Populations, Chronic Disease Prevention and Management, COVID-19, Health Coverage and Access, Medicaid Managed Care, Population Health, Relief and Recovery, Social Determinants of Health, State Resources, The RAISE Family Caregiver Resource and Dissemination Center, Workforce Capacity /by Kitty PuringtonOlder adults, people with disabilities, and their family caregivers have been hard hit by COVID 19. As states reel from the pandemic’s human and fiscal toll, policymakers are increasingly looking to home- and community-based services (HCBS) to address the pressing need for alternatives to nursing home care and supporting family caregivers who can help loved ones age in place.
Recent actions signal that the importance of HCBS is gaining traction at the federal level, and may receive significant attention in the coming months:
- The American Rescue Act, passed last month, includes a one-year, 10-point boost in Federal Medical Assistance Percentage (FMAP) for HCBS delivered between April, 2021 and March, 2022. The funding must supplement – not supplant – current state expenditures, and can be used for an expansive list of HCBS. These include Medicaid waiver services, but also case management and rehabilitative services, which are often used to support people with serious mental illness. The Centers for Medicare & Medicaid Services recently held a “listening session” to gather input for guidance that will be issued in the near future.
- The American Jobs Act, released by the White House on March 31, 2021, has been touted by the Biden Administration as an historic opportunity to rebuild America’s infrastructure. Interestingly, a full quarter of the total $1.2 billion proposed expenditure would go to “expanding access to quality, affordable home- or community-based care for aging relatives and people with disabilities.” The plan targets expansion of Medicaid HCBS and would improve wages and conditions for the nation’s direct care workforce, a majority of whom are women of color.
- Also last month, a group of members of Congress – Rep. Debbie Dingell (D-MI), Sen. Maggie Hassan (D-NH), Sen. Bob Casey (D-PA), and Sen. Sherrod Brown (D-OH) – sought input on the HCBS Act of 2021, draft legislation that would make HCBS a mandatory benefit in state Medicaid plans and expand the kinds of services offered, among other changes.
In the short term, states will need to act quickly to develop time-limited strategies to take advantage of the Federal Medical Assistance Percentage (FMAP) enhancement offered by the American Rescue Plan, and be prepared for other funding and policy opportunities as they emerge. States may choose to add enrollees to their existing HCBS programs, expand access by enhancing direct care workforce pay, focus on services to support family caregivers, and/or build on existing programs.
Explore the National Academy for State Health Policy’s (NASHP) State PACE Action Network for a new technical assistance opportunity for states to enhance or expand this home- and community-based services model. NASHP will continue to track these issues, and provide updates on state and federal initiatives that reflect the growing importance of HCBS.
States Redesign Home Visiting Programs for a Telehealth World during COVID-19
/in COVID-19 State Action Center Michigan Blogs, Featured News Home Care Coordination, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Equity, Integrated Care for Children, Integrated for Pregnant/Parenting Women, Maternal Health and Mortality, Maternal, Child, and Adolescent Health, Population Health, Social Determinants of Health /by Taylor PlattAs families face immense stress from the pandemic, states have rapidly reworked their home visiting programs to continue to support women and children. Because face-to-face services, including case management and family support and counseling, are no longer an option, health departments now deliver these vital services by telehealth. But with this new operating platform, states have needed to quickly address issues such as privacy requirements and billing, reimbursement, and enrollment processes as they launch their telehealth services.
Recently, the Centers for Medicare & Medicaid Services (CMS) released a toolkit in response to COVID-19 with guidance and steps for state Medicaid programs as they transition services to telehealth. The updated CMS guidance allows for greater flexibilities, including reimbursement for telephonic visits. To streamline the process, CMS stipulated that “no federal approval is needed for state Medicaid programs to reimburse for telehealth services in the same manner or at the same rate paid for face-to-face services, visits, or consultations.” However, a state plan amendment (SPA) is necessary to accommodate any revisions to payment methodology to account for telehealth costs.
Additionally, the Office of Civil Rights at the Department of Health and Human Services issued guidance that allows for enforcement discretion for noncompliance with the Health Insurance Portability and Accountability Act (HIPAA) regulatory requirements related to providers and telehealth, such as using non-HIPAA-compliant systems, such as the free version of Zoom.
How Michigan Converted its Home Visiting Service
Michigan, a state with a robust home visiting program prior to COVID-19, took quick action to support home visiting staff and the families they served to ensure continuation of services during the pandemic. The Maternal and Infant Health Program (MIHP) is administered and financed by the state Medicaid agency and is the largest home visiting program in the state. MIHP is available to all pregnant women enrolled in Medicaid and their infants up to age 12 months, with some exceptions. The program promotes healthy pregnancies and positive birth outcomes through a standardized, systemwide process of case management. When Michigan Gov. Gretchen Whitmer announced a state of emergency and stay-at-home orders in March 2020, the program quickly moved its home visiting services to telehealth.
The Michigan Department of Health and Human Services (MDHHS) updated guidance on telehealth visits for Medicaid beneficiaries. The provider bulletin allows for greater flexibilities on distant and originating sites and outlines the billing codes and modifiers providers should use. The MIHP operations team took numerous steps to ensure a smooth transition to telehealth services for their providers and families, including:
- Both the state Medicaid agency and the MIHP operations team had early and continued communication with providers, including making staff available to answer questions and provide support.
- The MIHP program created additional guidance specifically for MIHP providers. The guidance includes instructions on how to obtain and properly document verbal consent, billing procedures and codes specific to the MIHP program, and documentation procedures for all virtual visits.
- MDHHS held a provider webinar with detailed information related to telemedicine flexibility, including information targeted to MIHP providers and others.
- MIHP operations conducted a provider survey about how MIHP programs were continuing to provide services during this time, which netted a near 100 percent provider response rate. The survey revealed that a large majority of agencies adjusted successfully and quickly to the telehealth service delivery model. In addition, only a small number of agencies suspended services temporarily, primarily due to agencies shifting resources to cover COVID-19 emergency functions.
As states begin to reopen, many home visiting programs will begin to consider returning to face-to-face visits exclusively or as a part of their support programs. Considerations for the role of telehealth in home visiting is expected to factor into state decisions. While it is unclear how state home visiting programs will transition, some groups including The National Alliance of Home Visiting Models have encouraged all home visiting programs to continue to use telehealth to ensure the safety of women and their families, as well as home visitors. With the greater flexibilities allowed by CMS, states have the option to continue using telehealth for their home visiting programs during the pandemic. This allows for the continuation of important services for women and children and helps decrease the spread of COVID-19.
States will be weighing a number of considerations as they begin to open, including the benefits of telehealth for home visits and the costs associated with telehealth compared to in-person visits. These new policies will be important to monitor and will have implications for longer-term and possibly permanent use of telehealth to deliver essential services to families.
Additional Resources:
- NASHP Infographic: How State Medicaid Programs Can Use Telehealth to Serve Pregnant Women during COVID-19, May 2020
- NASHP Blog: States Rapidly Build their Telehealth Capacity to Deliver Opioid Use Disorder Treatment, April 2020
- Institute for the Advancement of Family Support Professionals: Rapid Response Virtual Home Visiting Collaborative
Six States’ Strategies to Providing Home Health Services to Children Enrolled in Medicaid
/in Medicaid Managed Care Connecticut, Delaware, Iowa, Maryland, Ohio, Washington Blogs, Featured News Home Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Coverage and Access, Health Equity, Integrated Care for Children, Long-Term Care, Maternal, Child, and Adolescent Health, Physical and Behavioral Health Integration, Population Health, Social Determinants of Health, Special Populations and Services, Workforce Capacity /by Olivia Randi and Kate HonsbergerTo improve the quality of services for children and youth with special health care needs (CYSHCN) and reduce health care costs, states are implementing strategies to improve access to home health services. Of particular importance as states confront COVID-19-related budget challenges, home health services can help to avoid costly emergency department use, hospitalizations, and institutional care.
The Early, Periodic, Screening, Diagnostic and Treatment (EPSDT) Medicaid benefit mandates coverage of all medically necessary services for children under age 21 who are enrolled in Medicaid. However, states vary in their definitions of medical necessity, prior authorization processes, and approaches to home health service delivery.
Prior to National Academy for State Health Policy’s (NASHP) analysis, there was limited information available on home health services for CYSHCN, and few studies had analyzed states’ approaches to delivering these services.
In its new report, State Approaches to Providing Home Health Services to Children with Medical Complexity Enrolled in Medicaid, NASHP examines six states’ (WA, OH, IA, MD, DL, CT) strategies to support access to home health services for CYSHCN. These include addressing provider capacity, advancing the person-centered medical home model, streamlining prior authorization processes, collaborating with Title V Maternal and Child Health Services Block Grant Programs for CYSHCN, and promoting stakeholder collaboration.
Home health services are provided in a person’s residence and include:
- Nursing services;
- Home aide services provided by a home care agency;
- Medical supplies and equipment for use in home-based settings; and
- Physical and occupational therapy, or speech pathology and audiology services.
Through analysis of these states’ home health service delivery systems, NASHP identified several key insights that other state health policymakers can leverage in their own systems to improve service delivery and reduce costs. A shortage of home health providers was the primary challenge that states faced in delivering these services to CYSHCN, which states have addressed through training programs and by increasing or modifying reimbursement policies.
Partnerships across agencies and families were recognized as key to developing informed strategies to improve home health services for CYSHCN. States have leveraged these partnerships, as well as implemented technologies and streamlined processes, to deliver more coordinated, cost-effective home health services.
- Prioritize efforts to address provider shortages. To address the lack of home health provider capacity, several states have focused on developing, enhancing, and raising awareness of training programs to increase the supply of home health agency staff. States have also modified their reimbursement policies, including increasing their reimbursement rates for home health providers, and proposing a structured fee schedule to streamline the reimbursement process for home health agencies. Ohio, for example, allows for reimbursement of family caregivers for providing services for children enrolled in its Medicaid waivers in an effort to increase home health service provider capacity.
- Leverage the benefits of cross-sector and stakeholder collaboration. Partnering with a variety of state agencies, including Title V CYSHCN programs, provider groups, families, and other key stakeholders helps build the infrastructure necessary to deliver comprehensive home health services to CYSHCN. Stakeholder groups in Ohio, Maryland, and Delaware were crucial to developing strategies to improve access to home health services for CYSHCN. Two of these states also referenced the importance of family engagement to inform the work of the stakeholder group. In Ohio and Iowa, Medicaid agencies, providers, and Title V CYSHCN programs have formed collaborations to improve care coordination and access to home health services for CYSHCN.
- Adjust service delivery models to increase capacity. The medical home is a primary care service delivery model that emphasizes coordinated care through a team-based approach. Connecticut and Delaware, have looked to this model to encourage providers to improve care coordination for CYSHCN, including home health services. States have also looked to streamline their prior authorization processes to reduce administrative challenges for CYSHCN to access home health services. Delaware and Iowa are implementing changes to simplify this process through a “flag” in their data system and by developing a standardized prior authorization form for all managed care plans, respectively.
Other key insights from this analysis include seeking regular feedback from families, strengthening oversight, and customizing fee-for-services and managed care approaches. States interested in improving children’s access to home health services through Medicaid may benefit from the approaches implemented by the six states highlighted in this issue brief. For a list of NASHP’s reports, blogs, and other resources related to improving care for CYSHCN, please click here.
State Approaches to Providing Home Health Services to Children with Medical Complexity Enrolled in Medicaid
/in Policy Care Coordination, Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Coverage and Access, Health Equity, Integrated Care for Children, Maternal, Child, and Adolescent Health, Population Health, Social Determinants of Health, Workforce Capacity /by Kate Honsberger, Ellen Bayer, Anna Matilde “Tilly” Tanga and Karen VanLandeghemStates are implementing new and enhanced strategies to improve the delivery and quality of home health services (e.g., nursing, home health aides, therapies) for children with medical complexity enrolled in Medicaid. This policy brief examines how six states structure, finance and provide home health services that are designed to provide important home-based care and family supports, improve quality of care, and avoid costly, hospitalizations and institutionalized care.
Read a related NASHP blog, Six States’ Strategies to Providing Home Health Services to Children Enrolled in Medicaid.
Background
State Medicaid agencies can use home health services to improve the quality of care and life for Medicaid enrollees and reduce costs. Today, many states are renewing their focus on this critical set of services as part of their Medicaid delivery system reforms, including managed care delivery arrangements and value-based care. Home health services are important for individuals with complex needs, especially for children with chronic, serious, and complex conditions.
Quality home health care can help children avoid emergency department use and prolonged hospitalization or institutional care.[1] Access to high- quality home health services can improve the outcomes and health of children and their families.[2]
States seeking new ways to improve health outcomes for Medicaid enrollees with complex needs have been challenged by longstanding policy barriers and workforce shortages. Few policy studies have analyzed state approaches to coverage and delivery of home health services for children and youth with special health care needs (CYSHCN). This brief describes how six states structure and provide home health services to children enrolled in Medicaid.
Nearly 20 percent (14.6 million children) of US children from birth to age 18 have chronic or complex health care needs that require physical and behavioral health care services and supports beyond what children normally require.[3] CYSHCN often depend on home health services as part of primary and specialty care, and other services and supports.[4] Of CYSHCN in the United States, 52 percent are white, 21 percent are Latinx, and 18 percent are African American.[5] A subset of CYSHCN – children with medical complexity – who comprise approximately 0.5 percent of US children, are even more likely to require home health services.[6] In 2016, nearly 500,000 families of CYSHCN reported needing home-based medical and therapeutic services.[7]
Medicaid plays a crucial role in providing coverage for CYSHCN, serving almost half of the CYSHCN population (48 percent).[8] CYSHCN are eligible for Medicaid through a variety of coverage pathways, some of which are mandatory under federal Medicaid law and others are optional at the state level. These pathways include Medicaid coverage for children:
- Based solely on their household income;
- Enrolled in the Medicaid Aid to the Aged, Blind and Disabled (ABD) category of assistance;
- Receiving Supplemental Security Income (SSI);
- Enrolled in foster care or receiving adoption assistance;
- Enrolled through a Medicaid waiver, including the Katie Beckett waiver that provides home-based services for children with complex health care needs
How Home Health Services Are Defined, Delivered, and Covered
Federal regulations broadly define home health services to include a range of specific services for adults and children that are provided at a “beneficiary’s place of residence,”[9] including:
- Nursing services;
- Home aide services provided by a home care agency;
- Medical supplies and equipment for use in home-based settings; and
- Physical therapy, occupational therapy, or speech pathology and audiology services, provided by a home health agency.[10]
These services are outlined in federal regulations, but state Medicaid programs have the discretion to deliver them in varying ways, with unique policies and procedures. For example, a state may offer home nursing services through Medicaid managed care delivery systems but provide home-based therapies through a fee-for-service system. Prior authorization policies may also vary for different home health services within a state.
Home nursing care in particular can be an important service for children with medical complexity (CMC). CMC often face a range of conditions and diagnoses that require care in a home-based setting and without access to home health services they would face higher hospitalization rates.[11] Community-based care is also considered a best practice for children with special health care needs and is typically more cost effective than institutional care.[12]
Home health services are provided by a range of providers including nurses, home health aides, personal care assistants, and others. Additionally, families play a critical role in delivering home health services to children. Family caregivers provide over 1.5 billion hours annually of health care for their children, according to a recent report.[13] Several states have begun to recognize the invaluable role families play and, as a result, provide training support and reimbursement to family caregivers for certain home health services, such as personal care services.[14]
Medicaid Coverage of Home Health Services for Children
Medicaid coverage of home health services for children is established by the Early, Periodic, Screening, Diagnosis and Treatment (EPSDT) benefit. Medicaid EPSDT mandates coverage of all services that are medically “necessary health care, diagnostic services, treatment, and other measures to correct or ameliorate defects and physical and mental illnesses and conditions.”[15] Coverage of these services includes all mandatory and optional services that the state can cover under Medicaid, whether or not such services are covered for adults.[16]
The EPSDT benefit is mandated for all children enrolled in Medicaid under age 21. Determining if a service is medically necessary is a key step for states when establishing whether a service is covered under the EPSDT benefit.[17] States are required to determine medical necessity, but they do so in a variety of ways depending on the delivery system providing the service.[18] The table in Appendix A details how the six states define medical necessity under Medicaid EPSDT and the prior authorization processes states use to determine medical necessity for all services, including home health services.
Federal law underscores the role of states in providing community-based and home-based services for children enrolled in Medicaid. Most notably, the US Supreme Court case, Olmstead v. L.C., established that unjustified institutionalization of Medicaid beneficiaries violates the Americans with Disabilities Act. As a result of the ruling, states must cover services in their programs, including Medicaid, in the community rather than institutions.[19]
State Medicaid programs are using a variety of strategies to improve access to home health services, particularly for CYSHCN. Some strategies are unique to home health services and others focus on improving care overall. The six study states (WA, OH, IA, MD, DL, CT) use a variety of delivery systems to provide home health services. Their strategies include addressing provider capacity, advancing the person-centered medical home model, streamlining prior authorization processes, collaborating with Title V CYSHCN programs, and promoting stakeholder collaboration.
Innovations to Address Home Health Services Workforce Shortages
The availability of well-trained providers is foundational to the timely delivery of high-quality home health services for CYSHCN. The extensive needs of CYSHCN and children with medical complexity often require ongoing skilled care by nurses and therapists. The design of service delivery models, provider education and training, and the adequacy of home health provider payment rates are all important factors affecting the home health workforce for CYSHCN.
Lack of sufficient home health provider capacity is one of the most significant challenges for states. States are experiencing shortages of pediatric nurses, licensed practical nurses (LPNs), and physical, occupational, and speech therapists. As a result, CYSHCN and their families can often experience barriers and wait lists for home health services.
State Innovations
Staff shortages are attributed to a variety of factors including geographic access challenges in rural areas, lack of home health services training programs, and payment rates that lag behind those of competing institutions or nearby regions. In Ohio, staff shortages are mostly concentrated in rural areas. Maryland has provider shortages in areas that are adjacent to Washington, DC where Medicaid payment rates are higher. Maryland also experiences home health care provider capacity challenges in certain areas due to competition from nursing facilities within the state.[20] In Connecticut, home health agencies that serve CYSHCN enrolled in Medicaid face competition for pediatric nurses from hospitals.
States are actively seeking solutions to address provider shortages. The Maryland Department of Health developed the Task Force to Study Access to Home Health Care for Children and Adults with Medical Disabilities using input from a variety of stakeholders in an effort to improve LPN training in home nursing skills and use of durable medical equipment.[21] The Maryland task force explored a range of options including:
- Partnerships between home health agencies and nursing programs at universities and community colleges to create training programs for LPNs interested in home health work;
- Opportunities for agency staff to participate in training simulation labs; and
- Preceptorships in which families would participate in training environments with providers in training.
The task force also recommended that provider agencies pool their resources to provide home health skills training and use a skills checklist to evaluate LPN competency on an annual basis to allow for a better understanding of how to continuously improve home health LPN skills, certifications, and competencies.
In an effort to improve the supply of home health nurses, Ohio’s Medicaid agency has increased awareness of the state’s workforce loan forgiveness and training programs.[22] In addition, an Ohio children’s hospital has partnered with a home health agency serving CYSHCN enrolled in Medicaid to provide home health nurses with specialized training in pediatric nursing.
Several states have either considered or implemented increases in home health care provider payment rates as a strategy to increase the number of providers participating in the Medicaid delivery system. Given the substantial fiscal impact of increasing payment rates, states have had to weigh the impact that these rate increases would have compared to other strategies for addressing workforce shortages. Ohio increased payment rates for home health nurses in 2017. Maryland’s task force provided several recommended options for significant increases to Medicaid home- and community-based services waiver and other community-based nursing providers’ payment rates. After an analysis of the fiscal impact of proposed increases, Maryland’s task force suggested that a phased-in approach to increases could be a pathway to modifying rates. This approach was implemented, and in May 2018 Maryland announced a 3 percent payment increase.[23] In an effort to streamline the reimbursement methodology for home health agencies, Connecticut Medicaid proposed a structured fee schedule approved by the state legislature in 2017, which allows for improved fiscal monitoring and data collection. Delaware’s Children with Medical Complexity Steering Committee, in studying how to improve the system of care for children with medical complexity,[24] recommended a workforce study to investigate possible shortages of private-duty nurses available to provide care to this population.
Recognizing the different levels of care that CYSHCN may need from home health care can also help make the best use of the limited number of pediatric home health providers. Maryland Medicaid allows for reimbursement of several tiers of service, with different payment rates to meet a range of needs within the fee-for-service (FFS) component of the program. For example, Medicaid covers certified nursing assistants (CNAs) and certified medical technicians (CMTs) to provide services, such as medication administration, that do not require an LPN level of care.
States are also acknowledging the crucial role that families play in understanding and supporting the unique needs of children as part of broader strategies to address shortages of home health providers. For children enrolled in Medicaid waivers, Ohio Medicaid allows family caregivers to be reimbursed for providing home-based personal care services to children. The Maryland task force recommended efforts to foster dialogue between parents and home care providers to increase feedback, manage expectations, and increase transparency about wait times. In Delaware, CYSHCN families were extensively engaged in the state’s steering committee process that identified challenges and developed solutions for managing the health care needs of children with medical complexity.[25]
Innovations to Advance the Medical Home Model
The American Academy of Pediatrics has identified medical homes as a core component of a comprehensive system of care for CYSHCN.[26] The medical home model can create the infrastructure needed for primary care provider (PCP) practices to engage with and coordinate home health and other providers involved in the care of CYSHCN. The model can help integrate home health services with all aspects of children’s care and provide the care coordination support needed to monitor access to home health services, ensure that authorized services are delivered, and close gaps in care.
State Innovations
In Connecticut, the medical home model is central to the state’s managed fee-for-service approach to delivering care to all members, particularly CYSHCN. Primary care practices receive in-office, ongoing support to attain and maintain National Committee for Quality Assurance (NCQA) or The Joint Commission medical home recognition. In addition, care coordinators employed by the state’s contracted Administrative Services Organizations support primary care providers and offer home visits and telephonic follow-up as needed. To the extent that PCMH practices have difficulty connecting families with home health care providers, they work closely with the state’s medical, behavioral, and dental administrative services organizations (ASO) to find qualified providers. ASOs are organizations that are contracted by the state to provide administrative services such as management of claims and benefits and provider delivery reform support. Delaware’s steering committee on medical complexity[27] recommended implementing the PCMH model as part of a comprehensive strategy to manage the health care needs, including home health services, of this population. Delaware found that the PCHM model could help ensure primary care provider leadership in coordination across all sectors of the health care system, including home health.
Innovations to Streamline Prior Authorization
The prior authorization process within Medicaid is intended to hold providers accountable for delivering medically necessary care and achieving cost savings in the health care system. However, because CYSHCN often need home health and other services on an ongoing basis, requirements for repeated prior authorizations can have the unintended effect of impeding access.[28] Access to home health for CYSHCN can be further delayed because of administrative challenges associated with navigating multiple prior authorization processes and forms used by different managed care plans.
State Innovations
To streamline the process and reduce unnecessary duplication of effort, Delaware managed care plans are working on a method to create a “system flag” within the Medicaid managed care data system for children with medical complexity. Using this system strategy will streamline and simplify the prior authorizations process, so that prior authorization processes can be simplified and not overly onerous. Additionally, to enable ongoing monitoring of managed care organization (MCO) prior authorization processes, Delaware Medicaid requires quarterly reporting on prior authorization decisions. Iowa Medicaid has recognized the challenges and delays associated with lack of uniformity in prior authorization requirements for MCOs. The state is working with managed care plans to develop a standard prior authorization form to be used across all plans. This will ease the burden on providers who were forced to be familiar with a wide assortment of forms and processes for multiple MCOs. State Medicaid officials anticipate that the form will be available in the next 18 months.
Improving Collaboration with Title V CYSHCN Programs and Stakeholders
In some states, state Title V Maternal and Child Health Services Block Grant (Title V) CYSHCN programs partner with Medicaid agencies to coordinate home health services for CYSHCN. State Title V CYSHCN programs are mandated under federal statute to support coordinated, community-based care for CYSHCN. Additionally, state Title V programs have extensive data and expertise on the needs of the population, as well as connections to pediatric specialists who can facilitate access to home health and other needed services. In some states, Title V programs provide important gap-filling services and supports, such as durable medical equipment, to supplement Medicaid or private insurance.[29]
State Innovations
In Ohio, state Medicaid and state Title V CYSHCN program staff partnered to help ensure a smooth transition for CYSHCN who transitioned to Medicaid managed care in 2012, which included children who access home health services. Ohio Medicaid and Title V program staff meet monthly to review cases of CYSHCN who have reported issues with accessing services or experiencing barriers to care. For example, medical-necessity determinations have not always considered that, due to their development, children requiring durable medical equipment may need more frequent replacements than they were receiving. This case review process has allowed for better understanding of the unique needs of children with medical complexity and better implementation of EPSDT medical necessity policies by Medicaid managed care organizations.
The University of Iowa’s Child Health Specialty Clinics (CHSC), Health and Disease Management team helps coordinate care for a subset of Medicaid-enrolled CYSHCN who are served through Medicaid fee-for-service programs and are not part of the state’s Medicaid managed care program. In Iowa, CHSC is part of the state’s Title V CYSHCN program. Care coordinators help maintain ongoing communication with home health agencies to facilitate timely access to pediatric nursing services. CHSC also trains and certifies family navigators – individuals who have lived experience with CYSHCN – to support families on waiting lists for Medicaid waiver services. This work requires coordination and collaboration between CHSC and the state Medicaid program to ensure coordinate care for children who are served by both programs.
Creating Opportunities for Stakeholder Collaboration
CYSHCN typically need services from many programs, organizations, and care systems, including Medicaid, public health, education, social services, behavioral health and substance use, foster care, and others. However, these agencies and systems historically have operated in silos, with minimal data sharing, collaboration, or integration.[30] The lack of collaboration across systems can lead to care gaps, duplication of services, fragmentation of care, and long delays in obtaining services. State officials increasingly are recognizing the need for communication and collaboration across multiple stakeholders within and outside of government to develop effective solutions for delivering home health services for children.
State Innovations
Delaware’s Children with Medical Complexity Steering Committee convened for eight months in 2017 and 2018 to develop a comprehensive plan to manage the health care needs of children with medical complexity. The steering committee included Medicaid officials, as well as other state divisions and agencies, providers, health plans, and family representatives. The committee’s goals were to strengthen the system of care, increase collaboration across agencies, encourage community involvement, and ensure adequate and appropriate access to health services for Children with Medical Complexity.[31] The steering committee divided into four work groups to address key issues, including access, and submitted recommendations to the legislature. Families provided extensive input on the nature of challenges in access to services, the need for respite care, transportation, difficulties in obtaining durable medical equipment, appeal and fair hearings processes, and coordination among payers.
Ohio Medicaid officials also convened an interagency workgroup to identify potential gaps and duplication of services for CYSHCN served by both Medicaid and state Title V CYSHCN programs. This interagency effort has allowed for sharing of CYSHCN-specific knowledge from Title V CSYHCN staff about the needs of this population with Medicaid staff to better deliver services, including home health services.
Key Strategies and Conclusion
The experiences of the six states featured in this report provide insights for other states interested in improving their coverage and delivery of home health services for children enrolled in Medicaid.
Prioritize efforts to address provider shortages. The shortage of qualified providers is the single greatest challenge for states seeking to optimize home health services for CYSHCN. The complexity of this issue requires creative and multi-faceted solutions. Stakeholder task forces and study committees, partnerships with state workforce agencies, innovative approaches to education and training, review of Medicaid payment rates, and exploration of credentialing and reimbursing family caregivers all play important roles in state strategies to improve and expand the home health care workforce for CYSHCN.
Seek regular feedback from families. Family experiences and satisfaction levels are the ultimate determinant of quality care for CYSHCN. States can leverage a variety of tools for beneficiary feedback, including annual surveys, focus groups, stakeholder advisory committees, regional forums, and one-on-one stakeholder meetings. Advisory committees may be time-limited or ongoing, depending on the nature of the issue and state agency capacity. Feedback from a range of stakeholders — including families, providers, health plans, and care coordinators —c an be critical to learn from individuals with a variety of perspectives, identify the most pressing problems, and formulate effective solutions tailored to beneficiary needs.
Leverage the benefits of cross-sector and stakeholder collaboration. Delivery of comprehensive, high-quality home health services to CYSHCN requires active engagement of many entities and systems and state agencies have recognized the need to go beyond siloed approaches to policy and program development. Partnerships across state agencies, particularly between state Medicaid and Title V CYSHCN programs and with provider groups, families of CYSHCN, and other key stakeholders can expand the knowledge base of all participants, advance innovative approaches to training, facilitate data sharing, and help build the relationships and infrastructure needed to overcome access challenges.
Adjust service delivery models to increase capacity. States are considering and implementing a variety of creative approaches to address persistent provider shortages. These strategies include development of medical home models that rely on team-based care and use of non-licensed staff (e.g., certified nursing assistants and certified medical technicians) to provide services, such as medication administration, that do not require the involvement of nurses or LPNs. Changes to prior authorization and staffing rules, such as allowing multiple agencies to provide authorized services or adjusting pediatric nurse assignments, may help maximize staffing resources to mitigate capacity challenges.
Strengthening oversight to improve quality and access to services. Medicaid programs have a variety of tools to strengthen accountability for access to quality care in either fee-for-service or managed care delivery systems. States are using a range of strategies that include requiring flagging of CYSHCN in information technology systems for targeted support, establishing provider network requirements aligned with CYSHCN needs, and requiring regular managed care plan reporting to identify challenges in delivery of authorized services. Additionally, states are enhancing oversight of home health services through targeted external reviews to validate the availability of qualified provider panels and regular evaluation of service delivery.
Customize fee-for-service and managed care approaches to improve access. State officials in both fee-for-service and managed care environments have found effective ways to advance access to home health services for CYSHCN, and leadership in both systems have viewed the payment models as critical to their success. A fee-or-service model may offer the advantage of allowing home health providers a “one-stop shop” to receive prior authorization for home health and other services and can be simple for families to understand. A Medicaid managed care model may provide the infrastructure needed to achieve effective care coordination and cost savings.
Officials in Medicaid managed care states report using fee-for-service carve-outs for specific populations and/or services in a way that is seamless to CYSHCN families and helps advance access to home health and other needed services. In carve-out environments, close coordination between health plans and providers is critical to ensure access. The optimal mix of managed care, fee-for-service, and carve-out strategies to advance access to home health services for CYSHCN will vary depending on the unique populations, policy landscape, and health care delivery systems in individual states.
Conclusion
Focusing on the unique needs of CYSCHN represents a key opportunity for states to increase quality and access to these services. The six states highlighted in this issue brief have each found unique ways of tackling both access and quality of home health services in different delivery system models. The efforts of these states demonstrate that by analyzing barriers to access, such as provider shortages, and collaborating with both stakeholders and families, states can improve the quality and delivery of home health services for children in Medicaid.
Appendix A: Summary of State Characteristics Related to Delivery of Home Health Services within Medicaid
| Home Health Services for Children and Youth with Special Health Care Needs (CYSHCN) Delivery Systems
Fee for Service (FFS) or Medicaid Managed Care (MMC) |
|
| CT | Fee for service |
| IA | Medicaid managed care[32] |
| DE | Medicaid managed care[33] |
| MD | Medicaid managed care[34]
Managed care organizations (MCOs) “may not” be required to cover a number of specified services covered under FFS, including personal care services (assistance with activities of daily living) pursuant to COMAR 10.09.20.[35],[36] |
| OH | Medicaid managed care[37] |
| WA | Medicaid managed care[38] |
| Populations of CYSHCN Enrolled in Medicaid Managed Care | |
| CT | N/A |
| IA | Mandatory enrollment for all populations of CYSHCN
Voluntary enrollment for American Indians/Alaskan Natives (AI/AN)[39] Excludes children who are enrolled in the Health Insurance Premium Payment (HIPP) program from managed care. |
| DE | Mandatory enrollment in Medicaid managed care for all populations of CYSHCN.
AI/AN are exempt from managed care enrollment.[40] |
| MD | Mandatory enrollment for all populations of CYSHCN[41] |
| OH | Managed care enrollment is mandatory for:7
· Children receiving Title IV-E federal foster care maintenance; · Children receiving Title IV-E adoption assistance: · Children in foster care or other out-of-home placement; and · Children receiving services through the Ohio Department of Health’s Bureau for Children with Medical Handicaps (BCMH) or any other family-centered, community-based, coordinated care system that receives grant funds under the Social Security Act and is defined by the state in terms of either program participation or special health care needs. Managed care enrollment is optional/voluntary for: · American Indians who are members of federally recognized tribes; or · Individuals diagnosed with a developmental disability who have a level of care that meets the criteria specified in state regulations and receive services through a 1915(c) home- and community-based services (HCBS) waiver administered by the Ohio department of developmental disabilities (DODD). |
| WA | Mandatory enrollment for most populations of CYSHCN
Voluntary enrollment for children in foster care or receiving adoption assistance[42] |
| Early, Periodic, Screening, Diagnosis and Treatment (EPSDT) Medical Necessity Definition in States’ Medicaid Managed Care Contract, Provider Manual, or Other State Documents | |
| CT | Definition of medical necessity |
| IA | State regulations do not include a definition specific to EPSDT. IAC 79.9(2) includes an overall definition of medical necessity definition.[43]
The Amerigroup Medicaid managed care contract similarly includes a general definition of medical necessity.[44] |
| DE | Medical necessity is defined as the essential need for health care or services which, when delivered by or through authorized and qualified providers, will:
For members enrolled in Diamond State Health Plan – Plus (DSHP-Plus) long-term support services, provide the opportunity for members to have access to the benefits of community living, to achieve person-centered goals, and live and work in the setting of their choice. In order that the member might attain or retain independence, self-care, dignity, self-determination, personal safety, and integration into all-natural family, community and facility environments, and activities. The contractor shall not arbitrarily deny or reduce the amount, duration or scope of a medically necessary service solely because of member’s diagnosis, type of illness or condition. The contractor shall determine medical necessity on a case-by-case basis and in accordance with this section of the contract.[45] |
| MD | Per Maryland EPSDT regulations,[46] MCOs must cover the following for Medicaid enrollees under age 21: Health care services that are medically necessary, which means that the service or benefit is:
· Directly related to diagnostic, preventive, curative, palliative, rehabilitative, or ameliorative treatment of an illness, injury, disability, or health condition; · Consistent with current accepted standards of good medical practice; · The most cost-efficient service that can be provided without sacrificing effectiveness or access to care; and · Not primarily for the convenience of the consumer, the consumer’s family, or the provider. Health care services described in the regulation include (but are not limited to): · Chiropractic services; · Nutrition counseling services; and · Private duty nursing services including: o An initial assessment and development of a plan of care by a registered nurse; o On-going private duty nursing services delivered by a licensed practical nurse or a registered nurse; and o Durable medical equipment. |
| OH | Per state regulations, medical necessity in EPSDT is defined as procedures, items, or services that prevent, diagnose, evaluate, correct, ameliorate, or treat an adverse health condition such as an illness, injury, disease or its symptoms, emotional or behavioral dysfunction, intellectual deficit, cognitive impairment, or developmental disability.[47] |
| WA | Per state regulation,[48] the standard for coverage for EPSDT is that the services, treatment or other measures are:
· Medically necessary; · Safe and effective; and · Not experimental. EPSDT services are exempt from specific coverage or service limitations which are imposed on the rest of the Categorically Needy and the Medically Needy program. Services not otherwise covered under the Medicaid program are available to children under EPSDT. The services, treatments and other measures which are available include but are not limited to: · Nutritional counseling; · Chiropractic care; · Orthodontics; and · Occupational therapy (not otherwise covered under the MN program). · Prior authorization and referral requirements are imposed on medical service providers under EPSDT. |
| Entity Reviewing Prior Authorization Requests | |
| CT | Most prior authorization requests are reviewed and processed by the department’s Administrative Services Organization (ASO), Community Health Network of Connecticut (CHNCT)[49] |
| IA | In Medicaid fee for service, the Iowa Medicaid Enterprise (IME) Medical Services Unit reviews prior authorization requests and makes coverage determinations. [50]
In managed care: [51] MCOs must use “appropriate licensed professionals” to supervise medical necessity determinations and specify the type of personnel responsible for each level of UM. MCOs must document access to board-certified consultants to help make medical necessity determinations. Any decision to deny long-term support services (LTSS) must be made by a long-term care professional with appropriate expertise providing LTSS. |
| DE | MCOs receive and review prior authorization requests for covered services including:
· Home-based services:
|
| MD | MCOs receive and review prior authorization requests for home-based services.[53] |
| OH | The Ohio Department of Job and Family Services reviews prior authorization requests for services other than those provided by MCOs.[54] |
| WA | The state’s Developmental Disabilities Administration reviews prior authorization requests for private-duty nursing.[55]
The Washington Health Care Authority reviews prior authorization requests for durable medical equipment.[56] Medicaid personal care is authorized by Home and Community Services and Developmental Disabilities administrations within the state’s Department of Social and Health Services.[57] |
Notes
[1] Simpser E, Hudak ML, AAP Section on Home Care, Committee on Child Health Financing. Financing of Pediatric Home Health Care. Pediatrics. 2017;139(3):e20164202
[2] Foster, C.C., Agrawal, R.K., & Davis, M.M. (2019). Home Health Care For Children With Medical Complexity: Workforce Gaps, Policy, And Future Directions. Health affairs, 38 6, 987-993
[3] Child and Adolescent Health Measurement Initiative. 2018 National Survey of Children’s Health (NSCH) data query. Data Resource Center for Child and Adolescent Health supported by the U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA), Maternal and Child Health Bureau (MCHB).
[4] MaryBeth Musumeci and Julia Foutz, “Medicaid’s Role for Children with Special Health Care Needs: A Look at Eligibility, Services, and Spending,” Kaiser Family Foundation, February 2018, https://www.kff.org/medicaid/issue-brief/medicaids-role-for-children-with-special-health-care-needs-a-look-ateligibility-services-and-spending/.
[5] Child and Adolescent Health Measurement Initiative. 2017-2018 National Survey of Children’s Health (NSCH) data query. Data Resource Center for Child and Adolescent Health supported by the U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA), Maternal and Child Health Bureau (MCHB).
[6] Dennis Kuo et al., “A national profile of caregiver challenges among more medically complex children with special health care needs,” Archives of Pediatrics & Adolescent Medicine 165, no. 11 (November 2011): https://dx.doi.org/10.1001%2Farchpediatrics.2011.172.
[7] Ibid.
[8] MaryBeth Musumeci and Julia Foutz, “Medicaid’s Role for Children with Special Health Care Needs: A Look at Eligibility, Services, and Spending,” Kaiser Family Foundation, February 2018, https://www.kff.org/medicaid/issue-brief/medicaids-role-for-children-with-special-health-care-needs-a-look-ateligibility-services-and-spending/.
[9] 42 CFR § 440.70
[10] Ibid.
[11] Gay, James C., Cary W. Thurm, Matthew Hall, Michael J. Fassino, Lisa Fowler, John V. Palusci, and Jay G. Berry. “Home health nursing care and hospital use for medically complex children.” Pediatrics 138, no. 5 (2016): e20160530.
[12]CMCS, and SAMHSA. “Joint CMCS and SAMHSA Informational Bulletin: Coverage of Behavioral Health Services for Children, Youth, and Young Adults with Significant Mental Health Conditions,” May 7, 2013. https://www.medicaid.gov/federal-policy-guidance/downloads/CIB-05-07-2013.pdf.
[13] Romley, John A., Aakash K. Shah, Paul J. Chung, Marc N. Elliott, Katherine D. Vestal, and Mark A. Schuster. “Family-Provided Health Care for Children With Special Health Care Needs.” American Academy of Pediatrics. American Academy of Pediatrics, January 1, 2017. https://pediatrics.aappublications.org/content/early/2016/12/23/peds.2016-1287.
[14] Coleman, Cara L. “Not Just Along For The Ride: Families Are The Engine That Drives Pediatric Home Health Care.” Not Just Along For The Ride: Families Are The Engine That Drives Pediatric Home Health Care | Health Affairs, April 18, 2019. https://www.healthaffairs.org/do/10.1377/hblog20190415.172668/full/.
[15] 42 U.S.C. § 1396d(r)
[16] 42 U.S.C. § 1396d(a)
[17] EPSDT – A Guide for States: Coverage in the Medicaid Benefit for Children and Adolescents: http://www.medicaid.gov/Medicaid-CHIP- Program-Information/ByTopics/Benefits/Downloads/EPSDT_Coverage_Guide.pdf.
[18] Clary, Amy, and Barbara Wirth. “State Strategies for Defining Medical Necessity for Children and Youth with Special Health Care Needs,” October 2015. https://oldsite.nashp.org/wp-content/uploads/2015/10/EPSDT.pdf.
[19] U.S. Department of Justice. Civil Rights Division . “Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C,” n.d. https://www.ada.gov/olmstead/q&a_olmstead.pdf.
[20] Maryland Department of Health. Task Force Report on Access to Home Health Care For Children and Adults with Medical Disabilities. December 27, 2018. Baltimore, MD. Accessed on November 13, 2019. Available at: https://mmcp.health.maryland.gov/Documents/JCRs/2018/Report%20on%20Access%20to%20Home%20Health%20Care%20for%20Children%20and%20Adults%20with%20Medical%20Disabilities.pdf
[21] Ibid.
[22] Ohio Association of Community Health Centers. Benefits & Loan Repayment Programs. Accessed on November 27, 2019. Available at: https://www.ohiochc.org/page/168
[23] Maryland Department of Health. December 27, 2018.
[24] Delaware Health and Social Services Division of Medicaid and Medical Assistance. Delaware’s Plan for Managing the Health Care Needs of Children with Medical Complexity. May 15, 2018. Newcastle, DE. Accessed on November 13, 2019. Available at: https://dhss.delaware.gov/dhss/dmma/files/de_plan_cmc.pdf
[25] Ibid.
[26]https://www.aap.org/en-us/professional-resources/practice-transformation/medicalhome/Pages/home.aspx
[27] Delaware Health and Social Services Division of Medicaid and Medical Assistance. May 15, 2018.
[28] Honsberger,K., et al. How States Structure Medicaid Managed Care to Meet the Unique Needs of Children
and Youth with Special Health Care Needs. April 2018. Washington, DC. National Academy for State Health Policy. Accessed on November 28, 2019. Available at: https://oldsite.nashp.org/wp-content/uploads/2018/04/How-States-Structure-Medicaid-Managed-Care.pdf.
[29] Association of Maternal & Child Health Programs. National Title V Children and Youth with Special Health Care Needs Program Profile. April 2017. Accessed on November 29, 2019. Available at: http://www.amchp.org/programsandtopics/CYSHCN/Documents/CYSHCN-Profile-2017_FINAL.pdf.
[30] Silow-Carroll, S., et al. Interagency, Cross-Sector Collaboration to Improve Care for Vulnerable Children: Lessons from Six State Initiatives. Health Management Associates. Prepared for the Lucile Packard Foundation for Children’s Health. February 2018. Accessed on November 28, 2019. Available at: https://www.lpfch.org/sites/default/files/field/publications/hma_interagency_collaboration_national_report_02.15.2018.pdf
[31] Delaware Health and Social Services Division of Medicaid and Medical Assistance. May 15, 2018.
[32] “Medicaid for Kids with Special Needs (MKSN).” Iowa Department of Human Services. Accessed December 13, 2019. https://dhs.iowa.gov/ime/members/medicaid-a-to-z/MKSN.
[33] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care MASTER SERVICE AGREEMENT,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[34] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.63. Maryland Medicaid Managed Care Program: Eligibility and Enrollment.
[35] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.70. Maryland Medicaid Managed Care Program: Non-Capitated Covered Services
[36] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.20. Community Personal Assistance Services
[37]“The Ohio Department of Medicaid, Medicaid Ohio Medical Assistance Provider Agreement for Managed Care Plan,” n.d. https://medicaid.ohio.gov/Portals/0/Providers/ProviderTypes/Managed Care/Provider Agreements/Medicaid-Managed-Care-Generic-PA.pdf
[38] Washington State Health Care Authority. “Washington Apple Health Managed Care Contract,” n.d. https://www.hca.wa.gov/assets/billers-and-providers/model_contract_ahmc.pdf.
[39] Iowa Department of Human Services. Iowa Health Link contract with Amerigroup, effective January 2016. http://dhs.iowa.gov/sites/default/files/AmeriGroup_Contract.pdf
[40] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care Master Service Agreement,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[41] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.63. Maryland Medicaid Managed Care Program: Eligibility and Enrollment.
[42] “Health Care Services and Supports.” Apple Health managed care | Washington State Health Care Authority. Accessed December 13, 2019. https://www.hca.wa.gov/health-care-services-supports/apple-health-medicaid-coverage/apple-health-managed-care#changes-to-apple-health-managed-care.
[43] Iowa Department of Human Services. “General Provisions for Medicaid Coverage Applicable to All Medicaid Providers and Services.,” n.d. https://www.legis.iowa.gov/docs/iac/rule/441.79.9.pdf.
[44] Amerigroup RealSolutions in Healthcare. “Medical Policy: Medical Necessity Criteria.” Accessed July 10, 2019. https://medicalpolicies.amerigroup.com/medicalpolicies/policies/mp_pw_a044145.htm
[45] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care Master Service Agreement,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[46] http://mdrules.elaws.us/comar/10.09.67.20
[47] Lawriter – OAC – 5160-1-01 Medicaid medical necessity: definitions and principles. Accessed December 13, 2019. http://codes.ohio.gov/oac/5160-1-01.
[48] Chapter 182-534 WAC: Accessed December 13, 2019. https://apps.leg.wa.gov/wac/default.aspx?cite=182-534&full=true#182-534-0100.
[49] Connecticut Department of Social Services (DSS). “Connecticut InterChange MMIS,” September 28, 2018. https://www.ctdssmap.com/CTPortal/Information/Get Download File/tabid/44/Default.aspx?Filename=ch9_auth_v4.5.pdf&URI=Manuals/ch9_auth_v4.5.pdf.
[50] Iowa Department of Human Services. “ALL PROVIDERS IV. BILLING IOWA MEDICAID,” February 1, 2018. https://dhs.iowa.gov/sites/default/files/All-IV.pdf?080220190110.
[51] Iowa Department of Human Services. “Iowa Health Link MCO Contract ,” February 1, 2016. https://dhs.iowa.gov/sites/default/files/AmeriHealth_Iowa_Contract.pdf?050820191355.
[52] “Physical Health Prior Authorizations.” AmeriHealth Caritas Delaware. Accessed December 13, 2019. https://www.amerihealthcaritasde.com/provider/resources/physical-prior-auth.aspx.
[53] Division of State Documents. Accessed December 13, 2019. http://www.dsd.state.md.us/comar/comarhtml/10/10.09.04.06.htm.
[54] Lawriter – OAC – 5160-1-31 Prior authorization [except for services provided through medicaid contracting managed care plans (MCPs)]. Accessed December 13, 2019. http://codes.ohio.gov/oac/5160-1-31.
[55] Chapter 182-551 WAC: Accessed December 13, 2019. https://apps.leg.wa.gov/wac/default.aspx?cite=182-551&full=true#182-551-3400.
[56] Washington Apple Health (Medicaid). “Medical Equipment and Supplies Billing Guide,” August 1, 2019. https://www.hca.wa.gov/assets/billers-and-providers/Med-Equip-Supplies-bi-20190801.pdf.
[57] “Health Care Services and Supports.” Medicaid Personal Care | Washington State Health Care Authority, January 1, 2018. https://www.hca.wa.gov/health-care-services-supports/program-administration/medicaid-personal-care.
Slide Deck: How States Can Improve Home Health Delivery for Children with Medical Complexity
This slide deck features innovative solutions states have implemented to address challenges in home health delivery, such as provider shortages, lack of coordination between Medicaid, Title V CYSHCN programs, and other stakeholders, and cumbersome prior authorization processes.
Acknowledgements: This issue brief was written by Kate Honsberger, Anna Matilde Tanga, and Karen VanLandeghem of the National Academy for State Health Policy (NASHP), and Ellen Bayer, a NASHP consultant. The authors wish to thank participating states’ Medicaid and Title V CYSHCN program staff for their time and willingness to be interviewed and their review. The authors also wish to thank officials at the Health Resources and Services Administration, Maternal and Child Health Bureau for their review and input.
This project was supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number UD3OA22891, National Organizations of State and Local Officials. This information or content and conclusions are those of the authors and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the US government.
States Race to Secure Home- and Community-Based Services during COVID-19
/in The RAISE Act Family Caregiver Resource and Dissemination Center Blogs, Featured News Home Care Coordination, Chronic and Complex Populations, Chronic Disease Prevention and Management, Community Health Workers, COVID-19, Health Coverage and Access, Long-Term Care, Population Health, Social Determinants of Health, State Resources, The RAISE Family Caregiver Resource and Dissemination Center, Workforce Capacity /by Wendy Fox-Grage, Salom Teshale and Paige SpradlinUpdated May 7, 2020
In the past two months, 35 states* have rapidly amended their Medicaid home- and community-based services for older adults and their family caregivers to ensure access to long-term services and supports during the COVID-19 crisis. Under new federal rules, the states applied for Medicaid 1915(c) Appendix K waivers to make temporary or emergency-specific changes to protect enrollees.
Most of the states have also received approval for home- and community-based services waivers targeting other populations, such as children and people with intellectual/developmental disabilities. Of these 35 states, 19 (AK, AR, CO, DC, GA, IA, KS, KY, MA, MD, MN, MO, NM, NV, OR, SC, UT, VA, and WY) have Appendix K combination waivers that allow them to modify many waiver programs with one Appendix K application.
A Landscape of Flexibility
Overall, states are incorporating flexibilities to help Medicaid enrollees with long-term needs receive services, and some states have included flexibilities to help enrollees remain on the waivers during the emergency period. The major policy changes affect the following:
Telehealth: Nearly all of these states permit added flexibility for services, such as telehealth, or allowing services to be provided in alternative settings, such as private homes. To cut down on outsiders from entering family homes, many states are allowing for electronic and telephonic case management, service planning, evaluations, and monitoring, as well as electronic signatures or verbal approval to avoid face-to-face meetings.
Family caregiver supports: States often rely on family caregivers to provide home and community-based services to Medicaid enrollees. Recognizing this, some of these new COVID-19-related flexibilities directly assist family caregivers. Several states (AK, AZ, CA, CO, CT, DC, FL, GA, IA, KS, MS, NM, NC, ND, OK, SD, UT, and WV) are allowing family caregivers to provide services and, in some states, receive reimbursement when the hired aide is not available.
Meals and other services: To provide added support, many states (such as AZ, CO, CT, IA, KS, KY, LA, MA, MS, NC, ND, OK, SC, and UT) are expanding home-delivered meals. Several of these states (including AZ, CT, IA, MA, MS, SC, and UT) are allowing for non-traditional providers to provide the meals.
Providers: Many states are relaxing provider qualifications, including training, certification, and recertification requirements, to incorporate new, current, returning, or out-of-state providers. Several states also allow for flexibility on certain types of background checks, or qualifying relatives/family members to be direct care workers pending background checks. States (such as AK, AR, CO, DC, GA, KY, LA, MA, MS, NE, ND, OR, UT, and WA) allow for temporary payment rate increases for some providers to ensure continuity of services. Additionally, many states (such as AK, AZ, CO, DC, FL, GA, IA, KY, LA, MT, NM, NC, NY, OK, OR, UT, VA, PA, and WA) allow for retainer payments if a Medicaid enrollee or provider is not available because of COVID-19. These states often limit the payment to no more than a certain number of consecutive days, for example, 30 days.
Reporting: A number of states are loosening reporting requirements. For example, Kansas has requested a nine-month extension for its waiver reports and Oklahoma requested flexibility on its audit requirements.
State Medicaid programs have great flexibility in what services they provide and how they fund them, especially during the pandemic. For example, states can tap the temporary 6.2 percentage federal matching increase that was recently enacted in response to COVID-19. These Appendix Ks are an important tool for states because home- and community-based services waivers are serving people in the community who meet the level of care needs for services in nursing homes.
Next Steps
These policy changes are temporary, only lasting during the pandemic. After the COVID-19 crisis, it will be important to better understand the impact of these policy changes (telehealth, family caregiver supports, meals, provider flexibilities, and the ease of reporting) on cost and quality of life and determine if some of these changes should continue after the public health crisis abates.
The National Academy for State Health Policy (NASHP) developed an interactive map of state Appendix K waivers and will continue to update this information as more states make these modifications. In addition, NASHP’s RAISE Act Family Caregiver Resource and Dissemination Center, funded by The John A. Hartford Foundation and in collaboration with the US Administration for Community Living, published a report and interactive map on Medicaid information, training, and counseling resources for family caregivers.
*As of May 7, 2020, the 35 states that modified their aging and disability waivers were Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Florida, Georgia, Iowa, Kansas, Kentucky, Louisiana, Maryland, Massachusetts, Minnesota, Mississippi, Montana, Nebraska, Nevada, New Mexico, New York, North Carolina, North Dakota, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Utah, Virginia, Washington State, Washington, DC, West Virginia, and Wyoming.
State Medicaid Strategies to Maintain Access to Care for Children with Special Health Care Needs during the Pandemic
/in COVID-19 State Action Center Blogs, Featured News Home Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, COVID-19, Maternal, Child, and Adolescent Health /by Kate Honsberger and Karen VanLandeghemStates and the federal government are taking unprecedented steps to address the health needs of individuals impacted by COVID-19, including children and adults with chronic and complex health care conditions who are vulnerable to infection and to changes in the health care delivery system that may impact their ability to access much-needed primary and specialty care, home- and community-based services.
States are modifying Medicaid policies and programs so individuals and their families can continue to access critical services during the pandemic.
Nearly 20 percent of US children up to 18 years (14.6 million) have a chronic or complex health care need that requires physical and behavioral health care services and supports beyond what children normally require. Medicaid plays a crucial role in providing coverage for children and youth with special health care needs (CYSHCN), serving almost half of the CYSHCN population (48 percent).
Read the NASHP blog, States Modify Medicaid Home- and Community based Waivers to Respond to COVID-19
The Centers for Medicare & Medicaid Services (CMS) recently released guidance to states outlining strategies, existing federal authorities, and authorities granted through Section 1135 waivers – waivers that are only available to states during an emergency or natural disaster. The 1135 Medicaid emergency waiver, emergency Medicaid State Plan Amendments (SPAs), and 1915(c) Appendix K authorities enable states to implement temporary policies to help maintain access to care during the pandemic. There are also additional steps states can take without CMS approval to help ensure CYSHCN and their families can access services during the pandemic.
Relaxing prior authorization requirements: State Medicaid programs may require that certain services, such as behavioral health and home health services, receive prior authorization before being approved for Medicaid reimbursement. For children, these prior authorization processes will also determine if services are medically necessary and therefore are covered under the Medicaid Early and Periodic Screening, Diagnostic, and Treatment benefit. Using a 1135 waiver, states can temporarily waive prior authorization requirements for services or extend existing prior authorizations for services to help ensure that CYSHCN are able to access needed services through Medicaid providers without prior authorization delays. CMS does note that states can amend their prior authorization policies in fee-for-service delivery systems and can direct managed care organizations to do so without CMS approval. SPAs may be needed depending on the goal and scope of services included. For example, if a state wanted to waive or extend prior authorizations for prescriptions, it may need an SPA to change the quantity authorized.
Closing home health services gaps: Using the 1915 (c) Appendix K waiver authority, states can expand the number of qualified Medicaid providers by loosening qualifications, including permitting payment for services rendered by family caregivers or legally responsible individuals, if this strategy is not already included in their waiver. This strategy can be a welcome support to family caregivers in a time of crisis who otherwise might not be able to access home-based care. Alaska’s approved 1915(c) Appendix K waiver includes provisions that allow providers to hire family caregivers as direct service workers when “regular staffing for services approved in a support plan cannot be assured.” The services include respite care, supportive living services, and in-home supports. One of West Virginia’s approved waivers allows for legal representatives to be paid as personal attendants “should the member’s primary caregiver become unable to provide services/supports.” Five other states (Colorado, Connecticut, Kansas, New Mexico, and Pennsylvania) have included payment for family caregivers in their approved 1915(c) Appendix K waivers for some, if not all, of their 1915(c) waivers.
Extending timelines for Medicaid fair hearings and appeals: When prior authorization for services is denied, Medicaid enrollees are entitled to appeal and a fair hearing process. Under the 1135 waiver authority, states can extend the 90-day timeframe for enrollees to request a fair hearing to 120 days. This extended timeline can help provide families of CYSHCN with additional time to have denied services reviewed for approval during a fair hearing. To date, 39 states have included this provision in their approved 1135 waivers.
Increasing opportunities for telehealth: CYSHCN often need to access primary and multiple specialty providers on a regular basis to manage and treat their condition. With COVID-19 impacting the ability of providers to conduct typical office hours and the need for CYSHCN with potentially compromised immune systems to limit their time outside of the home, telehealth services are a valuable alternative for care. States are taking steps to make accessing services via telehealth easier, and CMS has encouraged states to increase the use of telehealth services. According to federal guidance, “No federal approval is needed for state Medicaid programs to reimburse providers for telehealth services in the same manner or at the same rate that states pay for face-to-face services. A SPA would be necessary to accommodate any revisions to payment methodologies to account for telehealth costs.” Alabama recently sent a memo to providers outlining temporary expansion of Medicaid coverage for telehealth services that includes chronic disease management and behavioral health services.
The impact of COVID-19 on public health, state budgets, health care delivery systems, and CYSHCN and their families that these systems serve, will last much longer than the pandemic itself. State Medicaid, public health, mental health, and other state agencies that serve CYSHCN and their families are currently experiencing an overload on their programs, infrastructure and workforce. They also face new policy questions that had not been necessarily considered prior to the pandemic and challenges to their public health and health care coverage systems that are unprecedented in recent history. NASHP staff will continue to report on state strategies that assure access to health care services for CYSHCN and their families. Questions that will be considered include:
- How are changes in federal and state policies helping children and adults with chronic and complex health care conditions maintain access to and continuity of care during the COVID-19 pandemic?
- What other policy changes are states considering, and is additional federal guidance needed to further support state efforts?
- Should policies enacted to ensure access to services during the pandemic be extended beyond the emergency period?
- What impact do temporary policy changes have on the ability of states to measure quality of care for children and adults with chronic and complex conditions in the short- and long-term?
- What are the budget implications of these types of changes to state policies?
New Medicaid Funding Could Help States Better Integrate Care for Children with Medical Complexity
/in Policy Blogs Children/Youth with Special Health Care Needs, CHIP, CHIP, Chronic and Complex Populations, Cost, Payment, and Delivery Reform, Eligibility and Enrollment, EPSDT, Health Coverage and Access, Integrated Care for Children, Integrated for Pregnant/Parenting Women, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Medicaid Managed Care /by Hannah Eichner and Kate HonsbergerEarlier this month, the Senate passed the Medicaid Services Investment and Accountability Act of 2019 (H.R. 1839), which contains funding mechanisms and reforms that allow states to improve care coordination for children enrolled in Medicaid. As of early this week, the bill was on the President’s desk awaiting his signature.
This legislation significantly gives states the option to establish health homes for children with medical complexity (CMC) to promote better care coordination. The concept of giving states this option was originally proposed in the Advancing Care for Exceptional (ACE) Kids Act and was debated in Congress for several years before it was passed as part of H.R. 1839.
Medicaid health homes (originally established under Section 2703 of the Affordable Care Act – ACA) provide targeted and coordinated care for patients with chronic conditions who are enrolled in Medicaid. The goal of health homes providers is to “integrate and coordinate all primary, acute, behavioral health, and long-term services and supports to treat the whole person.”
Medicaid health homes do not allow states to specifically limit enrollment in health homes by age, but through health home provider requirements states may limit who can provide the health home services (e.g., pediatric providers). Since this option has been available, state Medicaid agencies have used health homes to target and provide coordinated care to specific populations, such as children with behavioral health needs. In a departure from the previous health home requirements, this new health home option would allow states to specifically target children under age 21 with complex health care needs.
The new legislation contains provisions that will be important for states to consider:
- Start date: States may submit Medicaid state plan amendments related to health homes for children with medical complexity beginning Oct. 1, 2022.
- Enhanced federal match: To encourage uptake of this state option and to help with start-up costs, during the first two fiscal year quarters that a Medicaid state plan amendment is in effect, the Federal Medical Assistance Percentages (FMAP) for payments made to designated health homes will be increased by 15 percent, but cannot exceed 90 percent. This is a more limited federal match than health homes established by the ACA, which receive a 90 percent FMAP for the first eight quarters.
- Target population: The legislation stipulates that enrollment in a health home program must be provided as an optional basis for children with medical complexity. It clearly defines eligibility for children younger than 21 with medical complexity as having:
- One or more chronic conditions that cumulatively affect three or more organ systems and severely reduces cognitive or physical functioning – such as the ability to eat, drink, or breathe independently – and that also requires the use of medication, durable medical equipment, therapy, surgery, or other treatments; or
- One life-limiting illness or rare pediatric disease, as defined in section 529(a)(3) of the Federal Food, Drug, and Cosmetic Act.
- One or more chronic conditions that cumulatively affect three or more organ systems and severely reduces cognitive or physical functioning – such as the ability to eat, drink, or breathe independently – and that also requires the use of medication, durable medical equipment, therapy, surgery, or other treatments; or
- Types of services:
- Services provided by health homes will include the six core health home services required under Section 2703 of the ACA: comprehensive care management, care coordination, health promotion, comprehensive transitional care, patient and family support, and referrals to community and social support services.
- Further, this new health home option for children with medical complexity must provide access to the full range of pediatric specialty and subspecialty medical services, including services from out-of-state providers if medically necessary.
- Health home qualifications:
- Health home providers have traditionally included designated providers, teams of health professionals, and health teams.
- The legislation stipulates that the Secretary of Health and Human Services (HHS) will establish standards for qualifying as a health home. The standards will include requirements related to: coordinating prompt and coordinated care among various types of providers, establishing a family-centered care plan, working in a culturally- and linguistically-appropriate manner, and coordinating care with out-of-state providers.
- State reporting requirements: States must report to HHS information including: the number of children participating in the program, the nature and prevalence of the chronic conditions of enrollees, the type of delivery systems and payment models used in the program, quality measures used in the program, and health home provider characteristics.
- State planning grants: Beginning on Oct. 1, 2022, HHS can award up to $5 million in planning grants to interested states.
The legislation also requires the HHS Secretary to issue guidance to state Medicaid agencies by October 2020 on best practices for using and coordinating care from out-of-state providers for children with medical complexity. States will be required to report on implementation of this guidance within their health home programs.
The National Academy for State Health Policy (NASHP) will continue to monitor progress on this legislation and if signed into law, NASHP will follow its implementation and highlight potential issues for states as they pursue this new Medicaid option. For more information about state strategies to improve care to children with special health care needs, visit NASHP’s Children and Youth with Special Health Care Needs Resource Page.
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For individuals living with complex, often chronic conditions, and their families, palliative care can provide relief from symptoms, improve satisfaction and outcomes, and help address critical mental and spiritual needs during difficult times. Now more than ever, there is growing recognition of the importance of palliative care services for individuals with serious illness, such as advance care planning, pain and symptom management, care coordination, and team-based, multi-disciplinary support. These services can help patients and families cope with the symptoms and stressors of disease, better anticipate and avoid crises, and reduce unnecessary and/or unwanted care. While this model is grounded in evidence that demonstrates improved quality of life, better outcomes, and reduced cost for patients, only a fraction of individuals who could benefit from palliative care receive it. 























































































































































