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Authors Posts by Carol Ferenz

Carol Ferenz

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ODP Announcement 20-094 provides an update regarding the Quality Assessment and Improvement (QA&I) interim review process for Fiscal Year (FY) 2020–2021 as a result of the impact of the COVID-19 pandemic.

ODP received approval from the Centers for Medicare and Medicaid Services (CMS) through an Appendix K amendment to conduct a QA&I “interim” review for FY 20–21 and to delay the implementation of Cycle 2, Year 1 activities until FY 21–22. The approved changes for the interim review period include:

  • The QA&I activities will begin on September 1, 2020 and end on March 31, 2021
  • The timeframe under review will be July 1, 2019 through February 29, 2020 (unless otherwise specified)

The announcement also provides specifics regarding the sampling, tools, individual interviews, self-assessments, desk & onsite reviews, entrance and exit conferences, spreadsheet, corrective action plan, and the comprehensive report.

The updated resources and materials for the interim review are available on the MyODP Training & Resource Center and can be accessed using the following path: Resources > ODP Information > QA&I Process. Please send questions via email directly to the QA&I Process Mailbox.

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ODP Announcement 20-095 provides a revision to Announcement 20-074 published on June 17, 2020 related to CPS retainer payments. For the period of July 1 through September 30, 2020, ID/A Waiver funds, under authority of the approved Appendix K waiver amendment, will be used to make retainer payments to CPS providers.

After evaluation of the re-opening status for facility-based CPS services, ODP has determined that all facilities that have submitted the Provider Attestation Form as per instructions in ODP Announcement 20-085 will receive a July retainer calculated at 50% of average monthly billing for 7/1/19–2/29/2020.

There is no change to the calculations described in Announcement 20-074 for retainer payments for August and September. July retainer payments are anticipated to be dispersed in the third (3rd) week of August.

To be eligible for retainer payments in July, August and September, providers are reminded they must complete and submit the Provider Attestation Form for Retainer Payments.

The Appendix K amendments approved by the Centers for Medicare and Medicaid Services on March 18, 2020 and July 23, 2020, require ODP to conduct an analysis of any retainer payments made for the period of July 1 through September 30, 2020, and reconcile the payments if needed to ensure that no duplicate payments have been made for services rendered. Additional details will be provided by ODP on the payment dates and reconciliation process.

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RCPA continues our advocacy efforts with the Office of Developmental Programs (ODP) as they are evaluating the ongoing impact of COVID-19 and considering the appropriate percentage for retainer payments for providers. Additionally, we have been advocating on a federal level for the Centers for Medicare and Medicaid Services (CMS) to allow for more flexibility with retention and advanced payments to providers during this pandemic.

Senator Casey, along with eight other United States Senators, sent a letter to CMS regarding retainer payments for HCBS services. The letter, addressed to CMS Administrator Seema Verma, expressed their concerns regarding the “limits imposed on retention and advanced payments as outlined in Frequently Asked Questions issued by CMS on June 30, 2020. The ongoing COVID-19 pandemic has levied unprecedented strains on providers’ HCBS programs. We urge you to reconsider this guidance and adopt an approach that will provide continued financial relief that ensures the availability of HCBS during and after the COVID-19 crisis for millions of individuals living with disabilities.” The letter was shared with ODP as well.

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ODP Announcement 20-091 is to inform all impacted parties that there will be a delay in the implementation of the certification and credentialing requirements for employment services in the Adult Autism Waiver.

Due to the COVID-19 Pandemic, the Office of Developmental Programs has received approval from CMS to delay the implementation of these requirements. Each of the aforementioned requirements are being delayed by one year. The following timeframes now apply:

Staff hired prior to January 1, 2021 must have one of the following by July 1, 2021:

  • A CESP credential;
  • A Basic Employment Services Certificate of Achievement from an ACRE organization member that has an ACRE-approved training; or
  • A Professional Certificate of Achievement in Employment Services from an ACRE organization member that has an ACRE-approved training.

Staff hired on or after January 1, 2021 must have one of the above credentials or training within six months of hire.

Beginning July 1, 2021, newly hired staff who do not have the required certification when hired must work under the supervision of someone who is certified. This can occur for no longer than 6 months from the date of hire to allow the new hire time to obtain the certification.

ODP recommends that all impacted providers that have staff who are required to have one of these employment credentials or certificates start the process now if they have not already done so. There will be no further delays granted in implementation of this qualification criteria.

These changes will be reflected in a future amendment to the Adult Autism Waiver. Questions about this communication should be directed to the appropriate regional office of the Bureau of Supports for Autism and Special Populations.

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