Additional Staffing Requests/Awards under CILA & DT Programs

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Purpose

This memorandum rescinds Information Bulletins DD.14.036 and DD.14.037 and identifies the current processes for additional staffing requests and awards under the Community Integrated Living Arrangements (CILA) and Developmental Training (DT) Programs.

Background

Information Bulletins DD.14.036 and DD.14.037 were developed and issued to enhance and facilitate the processes for requesting and authorizing additional staff supports under the CILA and DT programs. During initial implementation, however, issues of significant concern have arisen. We are therefore stepping back and placing on hold further implementation until additional work can be accomplished to address the identified concerns. We appreciate the cooperation of providers and other advocates throughout this matter.

Process and Procedure

Next Steps Regarding Changes that Occurred Effective July 1, 2014 - The Division is undertaking the following action steps:

1. Matrix rates in the CILA Program will be restored for all individuals who had them on June 30, 2014. "Matrix rates" is a term used to describe rates that were adjusted for staffing levels above the base rates due to the extraordinary behavior issues of the collective individuals in the setting.

   Matrix rates are different from 53R/D because they assume additional staff hours are awarded to address the needs of several individuals; 53R/D authorizations are awarded to provide additional staff hours for one specific individual. Matrix hours are part of the per diem rate, so they are not billed separately and do not require additional documentation; 53R/D hours are billed separately and require specific documentation for audit purposes.

2. Providers who had higher DT rates on June 30, 2014, to reflect enhanced staffing patterns within the DT program, will have those rates restored. If any providers have concerns about this, they should contact the Rates section of the Division by October 1, 2014.
3. The Division will issue new rate sheets for the individuals whose rates are changing back to what they were on June 30, 2014.
4. If a provider has billed for 53R/D hours delivered in July and August, and the hours are now being restored to the per diem rate effective July 1, 2014, the provider must void the bills that have previously been submitted for 53R/D.
5. The workgroup who worked on the bulletins will be reconvened and expanded to include additional representatives specifically and significantly impacted by the changes.
   1. The workgroup will review the matrix issue.
   2. It will specify requirements for documenting the provision of 53R/D services. For example:
      • Name and identification number of staff person providing the hours of service,
      • Date, time, and duration of service, and
      • Name and identification number of individual receiving service.
   3. It will develop training for providers to explain the 53R/D service and documentation requirements.
6. Should a provider prefer to keep the additional staff hours separate from the base rate and bill the hours under 53R/D, the provider can opt to do that. The provider must ensure an adequate audit trail is in place. Any provider wishing to opt for continued 53R/D authorization should contact the Rates section of the Division by October 15, 2014.

53R/D Awards Previously Issued Beginning in FY14 (These awards were not part of the changes that occurred on July 1, 2014)

As of July 1, 2013, (the beginning of FY14), the Division began funding additional staffing hours through 53R/D. It was known by the provider at the time of the award that the hours would be separately billable and would require additional documentation. These awards were not impacted by the changes that recently occurred effective July 1, 2014 (the beginning of FY15). If you are a provider that received one of these awards, the awards are unchanged.

• Award letters issued for new placements or new modifications to existing rates beginning in FY14 with billable 53R/D hours will remain in place as issued. Providers were aware of the billable hours when they accepted these awards.
• These awards that began in FY14 were scheduled for reviews beginning in FY15. These reviews of the 53R/D services currently authorized will be placed on hold until the workgroup completes the tasks above and training is delivered.

Pending and New Staff Hours Requests

• New requests for additional staffing hours may still be submitted for approval. A portion of the rescinded bulletins will be re-issued as soon as possible for official direction in submitting these requests. In the meantime, providers may continue to submit requests following current practices.
• Any requests currently under review by the Division will continue to be processed.

The Division is working as quickly as possible to produce these changes. If individual providers still have concerns, they can call the Division for individual discussion and assistance.

Effective Date

This bulletin is effective immediately.