On September 28, 2017 the Bureau of Developmental Disabilities Services (BDDS) posted a bulletin announcing the publication of the 2017 Wellness Coordination Guide with several updates and changes from previous guidance issued on this service.
The 15 page 2017 Wellness Coordination Guide is available here. We encourage a thorough review by all members; however, we wanted to draw your attention to the following critical changes identified by INARF.
We understand the scope of changes the State could make were limited without doing a waiver amendment to change the actual waiver service definition. In this respect, the changes outlined in the wellness coordination guide probably did all that BDDS could do without submitting a waiver amendment. At some point in the future the tier structure of this service and the monthly rate will need to be addressed via a waiver amendment.
In review of the final guidelines we were pleased with the following clarification(s):
• They do not require a nurse to do all wellness and risk training.
• We believe there was improvement/consolidation/simplification in the wellness and risk plan requirements.
• We were pleased that a comprehensive review of the record is considered as a consultation.
• We were pleased you can now count a visit while an individual is in the hospital as face to face in meeting tier requirements.
See below for additional information and INARF's comments regarding the changes (included in red):
The Wellness Coordination provider is responsible for the appropriate training of Direct Support Professionals (DSPs) of all HCBS providers to ensure implementation of Risk Plans in a fashion that recognizes the complexity of the individual’s needs and within an appropriate timeframe, with a maximum timeframe of 30 days from the start of the service or when the risk plan has been revised. It is expected that the wellness nurse provide relevant and necessary training on all risk plans. However, the wellness nurse has the ability to determine the most appropriate means for the training to be supported (via train the trainer, consultation, direct support, via web teleconference), based on the complexity of an individual’s needs, and the Direct Support Professionals’ background and level of experiences. The nurse is not required to personally conduct all of the trainings, but is responsible for determining the most appropriate training plan/approach to be used, and documentation must reflect that the nurse determined the most appropriate training approach and the individual’s medical needs were considered in this decision.
This includes the language INARF was advocating for, in that the nurse does not have to do the training; however, the nurse has to document the most appropriate means for the training method which seems better and offer more flexibility than the prior guidance regarding training.
Activities must occur weekly, regardless of the number of weeks in a month.
-One of the consultations can be a comprehensive record review. This is a positive and something that does not appear to be in previous versions.
-Other health care providers certainly would include nurse colleagues within your agency so nurses do not miss this opportunity to document a consult when discussing a client’s case with other nurses from your agency.
BDDS removed the language regarding partial weeks when outlining the face to face weekly requirement. It is unclear what that means for providers. For example: If a Sunday falls on October 30 and the month ends on the 31st, does there need to be a face to face in that partial week in order to bill for the service? The language from the previous guidance seemed to require it. This is silent. INARF will seek clarification.
So long as a person is hospitalized for 30 days or less, consultations and face to face visits are allowed while an individual is hospitalized. Face to face visits with participants are allowable on date of admission and date of discharge as well as any dates the participant is not in an non-hospital institutional setting. Consultations with professionals or the IST during member inpatient stays can be utilized in lieu of the face to face requirement for a given month and based on their assigned Wellness Coordination Tier activities. Anytime a person is hospitalized for an entire month, you may not bill wellness for that month. This appears to include the month of February which has either 28 or 29 days which is the only month in conflict with the 30 day or less guideline.
Attachment A Wellness Provision and Associated Timelines
Please note under the addition of Wellness to a CCB/NOA, INARF will ask for clarification if the State is continuing the prior practice of auto assigning a Wellness provider to all persons with health scores of 5 and above and if so how the timelines apply to providers who do not choose to accept the auto assigned individual/service based on their capacity.
We hope this information is helpful. If you have questions, please contact the INARF office.