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September HCBS Transition Plan Update

October 3, 2016

In September, the states of Iowa and Pennsylvania were granted initial approval of their HCBS Transition Plans by the Center for Medicare and Medicaid Services (CMS). The state of Florida released a revised version of its HCBS Transition Plan and posted it for public comment.

Iowa HCBS Transition Plan

Iowa was granted initial approval of its HCBS Transition Plan on August 9, 2016.  In its initial approval letter, CMS stated that Iowa completed its systemic assessment, identified areas in need of remediation, and clearly outlined the ways in which it would perform that remediation.

CMS reiterated in its letter the need for Iowa to address several specific concerns it had in order to receive final approval. Among these requirements, CMS requested that Iowa provide additional details with regards to its site-specific and provider self-assessment processes. They also asked that Iowa ensure  all settings which cluster participants, including non-residential settings providing group supported employment services, for the purpose of receiving HCBS services, be evaluated for full compliance with the Final Rules. That includes how Iowa will determine which settings have the effect of isolating individuals, including non-residential employment settings, as part of their heightened scrutiny process.

In its crosswalk and timeline, the Iowa Transition Plan identifies specific actions it has taken or will take to support full Final Rules compliance, including compliance with the employment-related provisions. On May 4, 2016, Iowa implemented new supported employment rules for the Intellectual Disability, Brain Injury, and Habilitation program waivers. The new rules “implemented changes to the provider qualifications, service definitions, and reimbursement methodologies for HCBS Prevocational and Supported Employment services” and will bring these services into compliance within the definitions and service structure provided by CMS. Most of these changes are listed in Iowa’s Attachment B for the Transition Plan. The service definitions of all Iowa waivers have been altered so that they further competitive integrated employment for individual beneficiaries rather than for groups of persons with disabilities.

For more information, read the Iowa HCBS Transition Plan and Attachment B, which lists changes to Iowa’s rules concerning supported employment.

Pennsylvania HCBS Transition Plan

On August 30, 2016, CMS granted the state of Pennsylvania approval of its HCBS Transition Plan. In its initial approval letter, CMS stated that Pennsylvania had completed its systemic assessment, outlined its intended remediation strategies, and responded quickly to all of CMS’ remaining concerns and feedback on the Transition Plan.

CMS identified several remaining issues in Pennsylvania’s plan including, but not limited to, requesting assurance that it had assessed all non-residential services under Office of Developmental Programs (ODP) waivers for compliance, and for how it intends to monitor ongoing compliance.

Pennsylvania’s responses to public comments indicate that the state is planning several initiatives it will use to reform delivery of employment services in the state. Pennsylvania’s ODP has sponsored intensive workshops on how prevocational service providers can transition people with disabilities from segregated settings to community-based employment. ODP is also funding a project to develop provider capacity in providing supported employment services. Pennsylvania’s Department of Human Services (DHS) is also collaborating with Pennsylvania’s Office of Vocational Rehabilitation to develop employment resources for supporting people with disabilities that significantly impact their employment.

For more information on the Pennsylvania HCBS Transition Plan, read the Transition Plan, Pennsylvania’s responses to public comments on the Plan, and the initial approval letter by CMS.

Florida HCBS Transition Plan

On August 26, 2016, Florida released a Revised HCBS Transition Plan and posted it for public comment. The public comment period ended on September 25, 2016.

Florida has developed an assessment of its residential settings, including whether people are supported to seek competitive integrated employment in the broader community.

With regard to ensuring that the state meets its employment-related HCBS setting obligations, the state has created waiver service definitions and provider manuals that require service providers to (a) develop programs and services that support people to live as independently as possible, including integrated community employment;  (b) conduct an orientation annually that informs service beneficiaries of employment opportunities in the community; and (c) reduce noncompetitive employment and promote competitive integrated employment.

For more information, read the Florida HCBS Transition Plan.