The Division received substantial feedback from individuals served, families, providers, and other system stakeholders – totaling nearly 700 comments. Based on those comments, the submitted amendment contains several changes from the draft amendment released for public comment on November 25th. While INARF believes that additional public comment should have been sought prior to submission to CMS, the Association is appreciative of the Division’s efforts to be responsive to comments received. INARF would also like to thank our members for responding to our Call to Action and submitting comments to the Division.
In terms of changes from the original draft amendment, the most notable is the “unbundling” of Wellness and Transportation from Enhanced Residential Living (ERL), permitting these to continue to be provided as separately billable services. The Division has also moved away from establishing a household rate for ERL. Instead, they will use the current Residential Habilitation and Support Daily (RHS-D) rates, plus 2.5% to account for the anticipated final rate restoration installment included in the 2015 Budget Bill. Additionally, since ERL is available to all individuals who share staff regardless of Algo level, DDRS will add ERL rates for individuals with Algo levels 0 – 2, as they were previously ineligible for RHS-D.
Over the next few days, INARF staff will complete a thorough analysis of the submitted amendment – including the proposed rates - and will provide additional details on changes. We will also identify issues that will be critical for the DDRS Advisory Council’s Sub-Committees to address through policy development and implementation planning. In the interim, please let us know if you have questions or need additional information.