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Home & Community Based Services (HCBS)

Power Hour: Compliance Time

Dr. Tiffany Swan

San Diego Regional Center

hcbs.frule@sdrc.org

Lindsay Reyes

Lindsay.Reyes@sdrc.org

Amy MacKenzie

Amy.Mackenzie@sdrc.org

Anna Keller

Anna.Keller@sdrc.org

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Next sessions of Advanced HCBS Training

8/13, 8/14, 8/15

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Agenda

  • Review of HCBS Final Rule and Statewide Transition plan
  • What is needed for HCBS compliance?
  • Modifications
  • Corrective Action Plan
  • Takeaways
  • Questions

HCBS Resource Public Page

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Why is HCBS Final Rule Important?

On March 14, 2014, the federal Centers for Medicare & Medicaid Services (CMS) set forth The Final Rule (requirements) for homes and programs where Home and Community-Based Services (HCBS) are delivered. Vendors must meet this criteria in order to qualify for federal funding under the Medicaid program (called “Medi-Cal” in California). SDRC is devoted to assisting our vendors in meeting the rules. Our goal is to provide technical assistance to vendors in order to obtain 100% compliance by August 31, 2024.

For vendors who do not meet HCBS compliance their federal funding will be reduced to 50% and they will not be able to continue to provide services.

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Statewide Transition Plan

Timeline:

CMS and DDS are requiring the following timeline of SDRC to report – Number of Visits, Number of Vendors found in Compliance, Number of Vendors found to be working towards Compliance, Number of Vendors who are current under a Corrective Action Plan (CAP), Number of Vendors who not able to comply with their CAP and Number of Vendors who are Appealing the CAP. SDRC goal is to work with each vendor prior to issuing CAP.

  • (Quarter 1) January 1, 2024 – February 29, 2024: 25% Completed Visits
    • 25% Verification of Providers who have corrective actions required to be completed by March 31, 2024.
  • (Quarter 2) March 1, 2024 – April 30, 2024: 50% Completed Visits
    • 50% Verification of Providers who have corrective actions required to be completed by May 31, 2024.
  • (Quarter 3) May 1, 2024 – June 30, 2024: 75% Completed Visits
    • 75% Verification of Providers who have corrective actions required to be completed by July 31, 2024.
  • (Quarter 4) July 1, 2024 – August 31, 2024: 100% Completed Visits and compliance.
    • For Providers who have corrective actions plans are required to be completed by September 30, 2024.

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HCBS Final Rule Requirements: The Setting (All Providers)

The setting is integrated in, and supports full access of individuals with disabilities, to the greater community to the same degree of access as their non-disabled peers.

2. Choice of Setting

The setting is selected by the individual from among setting options including a nondisabled specific setting and an option for a private unit in a residential setting.

3. Right to be Treated Well

The setting ensures an individual's right of privacy, dignity and respect, as well as freedom from coercion and restraint.

4. Independence

The setting optimizes but does not regiment, individual initiative, autonomy and independence in making life choices, including but not limited to: daily activities, physical environment, and with who to interact.

5. Choice of Services & Supports

The setting facilitates individual choice regarding services and supports and who provides them.

1. Access to Community

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HCBS Final Rule Requirements: Residential Settings

7. Privacy

Each individual has privacy in their sleeping or living unit; including doors lockable by the individual, choice of roommate, freedom to furnish/decorate their living unit

8.Schedule & Access to Food

Individuals have freedom and support to control their scheduled and activities, and have access to food at any time.

9. Right to Visitors

Individuals are able to have visitors of their choosing at any time.

6. Residential Agreement

In a unit or dwelling is a specific physical place that can be owned, rented or occupied under a legally enforceable agreement by the individual receiving services.

10. Accessibility

The setting is physically accessible to the individual.

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What Is Needed For HCBS Compliance?

  • Are the house rules updated and approved by the HCBS team?
  • Are there locks with a key on the bedroom doors and locks on the bathroom doors?
  • Does the schedule of activities reflect choice and independence?
  • Is there a current IPP for each resident?
  • Are the Rights of the Individuals posted and accessible?

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What Is Needed For HCBS Compliance Con’t.

  • Have resident council/house meetings been implemented and documented ?
  • Are all admission agreements current (under 10 years) with the correct name, address, and the tenant rights document?
  • Are residents able to eat where, what and when they desire without restrictions?
  • Are visitors welcomed without restrictions?
  • Are daily living items accessible?

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What Is Your Status?

Have you received an email from HCBS team or SC?

Have you responded to the email from the HCBS team or SC?

If you don’t know your status of compliance email the HCBS team at HCBS.frule@sdrc.org

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MODIFICATION: A modification is when there is a health and safety concern that would create a restriction to one or more of the Federal Regulations…

Work with the planning team to create a modification on the IPP/IPA.

•Identify specific & individual assessed need (Add CDER Qualifier if applicable)

•Document the positive interventions & supports

•Document less intrusive methods tried but not successful

•Include clear description to the specific assessed need

•Monitoring Plan: Roles and Responsibilities

•Establish a Timeline

•Informed consent of individual & ensure this will not cause harm to individual

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CORRECTIVE ACTION PLANS:

Starting 8/12/24, we will begin issuing CAPS if compliance has not been met or responses to communications have not been received.

Per the 12/1/23 DDS directive:

If a provider is found to not be in compliance with any of the federal HCBS requirements, SDRC will implement the Corrective Action Plan (CAP) processes used in California Code of Regulations, Title 17 section 56056 for residential facilities, which include the provision of vendor appeal rights.

https://www.dds.ca.gov/wp-content/uploads/2023/12/HCBS_Directive_Monitoring__Corrective_Action_12012023.pdf

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PRO TIPS FOR HCBS COMPLIANCE

  • Give individuals the opportunity to choose what they want for themselves and teach them to be independent.

  • Treat others the way you want to be treated.

  • What is important to the individual vs. for the individual. Work towards meeting the individual’s wants. If there are concerns utilize education, a planning team meeting, and modifications to the IPP.

  • House Meetings are invaluable to discuss choice, services, privacy, visitors, and conflicts.

  • Have conversations with all the individuals you are supporting to promote communication, self advocacy and problem solving skills.

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DEADLINE TO HCBS-FR

COMPLIANCE is

AUGUST 31, 2024!

50% of your funding will be withheld if compliance has not been met by August 31, 2024. Are you compliant with HCBS Final Rule? hcbs.frule@sdr.org

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If you have not been contacted please send us an email to obtain the status of your HCBS compliance.

(include your name, vendor name and vendor #)

Questions / Comments:

Email: HCBS.FRule@sdrc.org

Website: HCBS - SDRC (sdrc-hcbs.info)

1st Wednesday of the month

2 pm to 3 pm - via Zoom

Next Power Hour:

9/4/24

10 am-11am

Via Zoom

Topic:

TBD