DHS has released their recommended language and values for calculating rates under the new Disability Waiver Rate System (DWRS). There are several pieces of information we have received and want to share with members:
DHS draft legislative language is available here, and the values to populate the frameworks are available here. Also, a document outlining overall spending under the new system is available here, and a summary of the project they have used in meeting with legislators is available here. In conjunction, DHS updated the individual rate framework spreadsheets to match up with their language and values. Those are available on DHS’s website at this link: http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_150898
In order to complete an individual’s rate, you’ll need to have a budget neutrality factor. Right now, those frameworks have budget neutrality factors set to zero. Using their most recent spending estimates, the services in each of these buckets gets the following adjustments: -0.1% for residential services, 10.4% for day, -5.9% for unit with programming, and -20.5% for unit without programming. Those values will change, but they are what providers should use for the moment to calculate rates.
Here are some of the major changes from the last update included in DHS’s recommendation:
- Banding: When the new system comes online, every individual currently receiving service will have their rates banded for three years. Individual’s rates will move up or down by no more than 1% per year for three years. That adjustment does not begin for every individual at once. The transition to the new rate is tied to each individual’s annual review. So, if that is due to occur in August 2014, that is when that individual goes into the new rate system and their banding begins. DHS is also proposing to give some additional banding protection for individuals whose needs change. Banding would accommodate changes in an individual’s needs without requiring those individual’s rates to automatically move to the new methodology.
- Administration: Previously, it was understood that county staff would enter staffing information in the rate management system. Now, DHS’s position is that providers enter staffing information and county staff provides some sort of approval or sign off. There still needs to be clarification of how or if that information can be changed, but this should improve the process of getting data entered.
- Residential Transportation: DHS has changed the values attached to transportation costs for individuals. Previously, individuals requiring services of a full-sized adapted van got an adjustment of $4,290 per year to their rate. The value is lowered to $3,000 per year.
- Deaf and Hard of Hearing Customization: The add-on for customizations is dropping from $9.70 per hour to $2.50 per hour, and tightening up the qualification standards for individuals to receive the add-on to their rate.
- Supervisor Wages for Behavioral Services: Previously, the framework values for supervisor wages in behavioral specialist and behavioral analyst services were lower than the wage for the direct care staff. DHS increased the wages for supervisor time to the same level for these two services.
- Interim Values: To deal with issues that are unresolved or need additional work, DHS is proposing components or values in the frameworks be labeled interim. Their intention is that those values or issues will receive additional review and analysis, and will be addressed in future legislation. These include: transportation rates for day training and habilitation, transportation for adult day, structured day and prevocational services, geographic difference factor, day program facility rate, services where monitoring technology replaces staff time, shared services for independent living skills training and supported employment and billing for indirect services. This interim status is just a label, there is nothing in the language to sunset or change them at some future date.
Now that DHS has released a fully-formed recommendation, ARRM and our coalition partners are taking action. On Monday, we met and laid out a strategy to respond. Given the number of interim values and undefined processes, we will be looking at options for additional time to develop these pieces prior to implementation. Initially, the coalition will be sending a letter to DHS detailing all of our concerns with DHS’s proposal. ARRM members involved in the rate setting process have been helping draft that language, along with other coalition members. Once it’s finalized and sent to the department, we’ll pass it on to ARRM members.
Simultaneously, we’ll be drafting our own bill along with our coalition partners. At this point, the coalition includes MOHR, MnDACA, the Disability Law Center, The Arc of Minnesota, and Courage Center. The coalition informed legislative leaders and the governor in writing that we would offer an alternative bill.
Our approach will be a bit different in 2013. While significant differences still exist between our approach and DHS’s, there are fewer of them compared to last year. We’ll be using their legislation as a base, offering improvements and additions to address our specific concerns.
Last Thursday, the ARRM board adopted a resolution taking the following positions:
- To continue working with DHS and the DWRS work groups to develop a system that meets ARRM’s Payment Methodology Principles.
- To work with the Rate Setting Coalition to assure that a system is fully implemented only when satisfied that individuals have adequate resources to meet individual needs, within the parameters of budget neutrality.
As always, if members have specific questions on any particular item at any time, please contact me directly at
cwieber@arrm.org or 651-291-1086, extension 9.
~ Craig Wieber, Chief Fiscal Analyst