Developing Business Rules and Standards for the Delivery of SDS, FMS and I&A Supports

April 21, 2015

Today’s Presenters

Susan Flanagan, M.P.H., Ph.D.

Westchester Consulting Group

Mollie Murphy

Annkissam

2

Objectives of Today’s TA Webinar

• Present an overview of key steps for building a strong foundation for SDS programs.

– Key Entities Crosswalk– SDS Program Business Rules– FMS and I&A Standards– Standard Forms and Agreements– SDS Operations Manual

• Review Examples, when available.

3

Objectives of Today’s TA Webinar (cont’d)

• Discuss how OR DHS might implement these steps for their SDS programs.

• Address questions from OR DHS staff.

4

Who is on the call today?

5

Key Steps for Building a Strong Foundation for SDS Programs

• Often states have implemented self-directed service (SDS) programs “organically” without implementing a strong programmatic foundation.

• This has resulted in some states having to go back and accomplish this “after the fact.”– States have found it difficult to put the “genie back in

the bottle” programmatically once a SDS program has been implemented.

6

Key Steps for Building a Strong Foundation for SDS Programs (cont’d)

• There are a number of activities states can undertake to build a strong foundation for their SDS program. These include developing:

– A Key Entities Crosswalk as discussed in Webinar #1.– SDS Program Business Rules– FMS and I&A (e.g., Support Broker) Standards– Standard Forms and Agreements– SDS Program Operations Manual

7

Key Entities Crosswalk• As discussed in Webinar #1, a first step in

developing or evaluating a state’s SDS Program is creating a Key Entities Crosswalk. The Crosswalk should: – include all entities that have a role in regulating,

administering, using and providing self-directed services (SDS) and describe their role, responsibilities and qualifications and training requirements; and

– be used to clarify roles and responsibilities and requirements and identify gaps and duplicative activities.

8

Key Entities Crosswalk (cont’d)

• The Crosswalk should be a “living” document and updated once the SDS Program Business Rules are developed, annually and when agency reorganizations occur.

9

SDS Program Business Rules

• Another key activity that is essential to building a strong foundation for a SDS Program is developing SDS Program Business Rules.

• These rules should address the essential elements of providing SDS and FMS and I&A supports and should be used to develop FMS and I&A Standards and a SDS Program Operations Manual.

10

SDS Program Business Rules (cont’d)

• The initial Key Entities Crosswalk should be updated to reflect these business rules, as applicable to document “who does what.”

• Review example SDS Program Business Rules provided (Handout #1).

11

FMS and I&A Standards

• Many states contract with vendors to provide FMS and I&A support services for SDS Programs. (See Handout #2). – However, often state program agency staff are not

knowledgeable about the federal and state requirements to provide these supports.

– States need a “SDS program team” who are knowledgeable and are the “experts” for the program.

12

FMS and I&A Standards (cont’d)

• Developing and implementing FMS and I&A standards are important for a number of reasons.– The exercise helps reinforce SDS program staff’s

knowledge about these supports and requirements.

– They are the basis for the Scope of Work in an FMS and/or I&A Request for Proposal (RFP), or similar procurement vehicle.

13

FMS and I&A Standards (cont’d) #2

– They also are the basis for developing an:• FMS and I&A Entity Performance-based Contract,

– Can be executed by a state program agency and/or managed care entity with the FMS and/or I&A entity.

• FMS and I&A Entity Readiness Review Protocol, and• FMS and I&A Entity Ongoing Performance Review Protocol.

• Each standard should include the tasks to be performed by the FMS or I&A entity.

14

FMS and I&A Standards (cont’d) #3

• Example Standards for VF/EA FMS Entities include:– Developing, maintaining and updating a state-specific

VF/EA FMS Policies and Procedures Manual.– Qualifications for VF/EA FMS Staff.– Billing/Invoicing for SDS (labor) and Individual-

directed goods and services and VF/EA FMS Administrative Fee.

– Managing Medicaid/Public Funds.

15

FMS and I&A Standards (cont’d) #4

– Receiving Federal and State Authority to Act as a VF/EA FMS for Participant/Representative-Employers.

– Providing Customer Service.– Coordination and Communication Between and Among

the VF/EA FMS, SDS Program Coordinator, I&A Entity and Case Management Staff.

– Assisting in the Provision of Participant/Representative- Employer, I&A and Case Management Staff Orientation and Training.

16

FMS and I&A Standards (cont’d) #5

– Enrolling Participant/Representative-Employers with the VF/EA FMS and Registering Them As Employers.

– Enrolling Qualified Direct Support Workers (DSWs) and Individual-directed Goods and Services Vendors with VF/EA FMS Entity.

– Dis-enrolling Participant/Representative-Employers with the VF/EA FMS Entity and Terminating Status as an Employer.

– Processing DSW Payroll and Related Taxes.– Establishing and Maintaining Files.

17

FMS and I&A Standards (cont’d) #6

– Preparing and Submitting Required VF/EA FMS-Related Reports.

– Brokering Workers Compensation Insurance Policies for Participant/Representative-Employers.

– VF/EA FMS Quality Management Activities.

18

Standard Forms and Agreements

• Developing and implementing standard forms and agreements is another activity that helps build a strong SDS program.

• Forms may include, but not be limited to:– Consumer Inquiry Form– Participant/Representative Consent Form– Participant/Representative Agreement– Authorized Representative Designation Form– Emergency Backup DSW Designation Form

19

Standard Forms and Agreements (cont’d)

– Participant Voluntary Termination Form– DSW Competency Certification Statement– DSW Information Change/Termination Form– DSW Agreement– Fraud Statement– Progress Notes

20

SDS Program Operations Manual (cont’d) #2

• Once the SDS Business Rules, FMS and I&A Standards and Standard Forms and Agreements are developed a state should develop, implement and maintain an SDS Program Operations Manual.

– The manual should include the policies, procedures and internal controls for all the tasks associated with administering the SDS program.

21

SDS Program Operations Manual (cont’d) #3

– Workflow charts should be created, as appropriate.– Agency staff should work on the section(s) of the

manual that are relevant to their work area(s).– Managed care issues should also be addressed, as

applicable.– Once the manual is completed, an in-service training

session should be conducted with all relevant agency staff annually and more often as necessary.

– The manual should be reviewed and updated at least annually, and more often as necessary.

22

Processing, Discussion and Questions (cont’d)

• What is your biggest insight about what you just heard?

• What features/recommendations presented could be implemented in Oregon?– What resources would be needed?– What challenges would be encountered and how

could they be addressed?

23

Where to Find Help

• To request TA:

http://www.hcbs-ta.org/request.aspx

• For additional information:

http://www.hcbs-ta.org

24