DDRS has released another OASIS bulletin. The document is 11 pages and will be available in the yahoogroups files section. We are highlighting the FAQ and encourage families to read the entire bulletin, and email the OASIS Help Line at OASIS-ICAPHelp@fssa.IN.gov or call (317) 234-5222 with any questions/concerns.
FREQUENTLY ASKED QUESTIONS
The following questions are based on feedback from consumers, providers and families since the release of the previous OASIS bulletin:
Question: Because Service Definitions go into effect at the same time a person goes onto a new plan, persons in the same household will work under different requirements. How do we address recordkeeping for staff and keep accurate records for an audit during this time?
Answer: The Service Definitions have not changed for RHS. Only the rate and manner of reimbursement have changed. Therefore, one method of record keeping should work for all consumers within a household.
Question: May a provider use an existing day service facility to provide Respite Care Services outside of regular business hours?
Answer: No. Respite Care Services may only be provided in the individual’s home or place of residence, in the caregiver’s home or in a non-private residential setting (such as a respite home) or camp setting. However, a provider may offer Facility Habilitation—Individual and Group services outside of the typical work week for habilitation services.
Question: Is the Service Definition for Respite Care Services changing? What are the setting options available to provide Respite Care Services?
Answer: The primary service location for Respite Care must be provided in the individual’s home or place of residence, in the caregiver’s home or in a non-private residential setting (such as a respite home) or camp setting. However, a consumer may access community activities while receiving Respite Care Services. There is no expectation of community access during Respite, but a consumer’s team may agree to include some community based activity during Respite Care. There is no additional compensation for costs associated with community access (such as mileage, admission fees, etc.)
Question: In the previous OASIS bulletin, the ‘Activities not Allowed’ for Respite Care Services differs from what is shown in the BDDS provider manual. Can you clarify?
Answer: The definitions in the HCBS Waiver Program Provider Manual are correct. We made an error in oversight by omitting a portion of the Activities not Allowed (see bulleted list below for the complete list.) We will be updating the Service Definitions and Documentation Standards charts and will post the comprehensive listing of all BDDS waiver services online in the near future.
Activities not Allowed under Respite Care Services:
• Respite care shall not be used as day/child care to allow the persons normally
providing care to go to work
• Respite care shall not be used as day/child care to allow the persons normally
providing care to go to school
• Respite care shall not be used to provide service to a member while member is
• Respite care may not be used to replace skilled nursing services that should be
provided under the Medicaid State Plan
• Services provided by the parent of a minor child or the individual’s spouse
• Respite care must not duplicate any other service being provided under the
individual’s Plan of Care/Individual Service Plan (POC/ISP)
• Reimbursement for room and board
• Services provided to an individual living in a licensed facility based setting
• The cost of registration fees or the cost of recreational activities (for example, camp)
• When the service of Adult Foster Care of Children’s Foster Care is being furnished to the individual
Question: Our Facility Based Habilitation-Group day service program does not begin or end at the top of the hour. May we bill for partial hours, and if so, what is the base for the ratio?
Answer: Providers may bill a partial hour of service to a consumer. Individual service notes should clearly indicate the start and stop times for each consumer, and the provider may bill for that time. Providers may also establish a ½ hour Group Log to capture those less than one hour time periods, or may start an hourly Group Log at 8:30 a.m. to 9:30 a.m., etc. The start time is at the discretion of the provider. The group ratio is established based on the actual experience of the group.
Example: If you provide 4:1 services for a half hour, then you may claim it as such.
Warning: If you do not preload the consumer service plan with these variances, you could exhaust an NOA/CCB early in a month, and still be responsible for providing services to the consumer.
Question: As a service provider, do we submit numbers for actual time served, or do we round to whole numbers or quarter hours?
Answer: The billing system used by DDRS’ fiscal intermediary accepts partial units. Therefore, providers should record and bill actual time served for each consumer, including partial hours of service.
Question: Will BDDS continue to require monthly waiver reports for individuals who move to the newly established Uniform Rate Methodology?
Answer: Yes, monthly waiver reports will continue to be required for individuals moving to the Uniform Rate Methodology until further notice.
Question: Can a consumer receive Pre-Vocational Services in the same facility or program area where sheltered work is provided (if the required consumer-to-staff ratio is met)?
Answer: Yes, providers may mix services in a singular area. However, be very careful when assigning individuals on the Group Logs. Sheltered Employment and Pre-Vocational Services have different ratio requirements. Pre-Vocational Services should differ for a consumer based on the skill they are developing while in that service. Pre-Vocational service goals must be generalized to any work environment and cannot be based on a specific contract of any workshop.
Question: A few of our consumers hover just above or below the 50% Federal minimum wage. Does this mean that they move them from one service to another throughout the day? Also, if records indicate that a consumer is reimbursed at a rate above the 50% Federal minimum wage during only part of the time they are receive Pre-Vocational Services, may we bill for that time?
Answer: A consumer’s plan will never include Pre-Vocational and Sheltered Employment services at the same time. Because change requests may only occur quarterly for these services, no consumer will move between services more than quarterly. If a consumer’s wage increases above 50% of the Federal minimum wage during the quarter, this is acceptable. The provider can then do a quarterly review and move the consumer at the next quarter.
Question: During a recent meeting, I heard that determination for Pre-Vocational or Sheltered Workshop services will be made on a quarterly basis, as determined by the consumer’s average wage for the quarter. The Service Definitions do not indicate that this is how determinations are made, please clarify.
Answer: Pre-Vocational versus Sheltered Employment services is determined by the following process: Divide the previous quarter’s gross earnings for each service by the hours of attendance for that service. If the hourly wage falls below 50% of the Federal minimum wage, the consumer may access Pre-Vocational Services for the next quarter. If the wage exceeds 50% of the Federal minimum wage, Pre-Vocational Services should be discontinued for the next quarter and the provider should request a budget for Sheltered Employment for that consumer for the next quarter. A one-for-one exchange of hours between the services is allowed. To increase above the one-for-one exchange in hours, a new budget must be prepared and submitted to the BDDS service coordinator and include justification for the request or a Plan Update must be submitted by a case manager requesting an increase in Pre-Vocational service hours.
Question: An individual is working in the community and receives Supported Employment Follow Along (SEFA) during part of the week. The consumer also attends a production facility for part of the week. While working at the production facility, the individual typically earns less than 50% of the Federal minimum wage. Is the individual still eligible to receive Pre-Vocational Services?
Answer: Yes, the 50% minimum wage rule is a distinguishing determinant on Sheltered Employment versus Pre-Vocational choice. Consumers may earn greater than 50% in SEFA and remain in Pre-Vocational Services as long as the Pre-Vocational wage does not exceed 50% (when averaging the wage over an entire quarter).
Question: Can a provider bill for Pre-Vocational Services when providing transportation to a community based Pre-Vocational setting?
Answer: Transportation to or from a worksite is only billable if coming from or going to a facility based environment. Pre-Vocational Services may not be billed as transportation.
Question: May a consumer who is on the SS waiver utilize Transportation Services when travelling to and from their place of employment.
Answer: Transportation Services are only available for travel to and from a facility based day service. SEFA and other non-facility work environments are not billable as Transportation. Providers may assist consumers in purchasing a bus pass for transportation to facility activities.