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The Re-KAPP 10.21.16

The Bigger the Challenge…the Bigger the Opportunity.”  ~ unknown


If you didn’t get to participate in one of the Re-KAPP Conference Calls today (48 callers at 10 am and 44 at 2 pm!)…here’s a summary!

Eligibility Issues/Billing Problems:

  • Please see separate blog post on this subject.  If you follow the process, use the form, copy me and follow-up…these should be resolved quickly.  I’m working with the Department leads on creating a Trouble Shooting Flow Chart for you to simplify the process, as the problem typically lies within a combination of DMS – DCBS – OATS (MWMA/Benefind), KY HealthNet, Fiduciary…

Workgroup Updates:

  • The 3 requests we made of Commissioner Anderson in our meeting with her August 12th, for IMMEDIATE RELIEF, were 1 – Recoupment, 2 – Monthly Summary vs. Daily Notes & 3 – Exceptional Rate Protocol.  These 3 requests were translated to Cabinet Workgroups.  The workgroups have completed their meetings and proposals and submitted them to Commissioner Anderson by the 15th…with the Ex. Rate Workgroup meeting with Commissioners Miller & Anderson yesterday 10/20 to do a follow-up presentation.  
  • The plan is for Commissioner Anderson to review the workgroup proposals (this weekend), send them to me for review…send them to Commissioner Miller for review…then send to YOU the providers for review and comment.  Commissioner Anderson believes if we come to an agreement quickly then an Emergency Regulation can be drafted for SCL and filed late November or early December.  
  • Additional information on the Exceptional Rate Workgroup:  KAPP with the assistance of Carol Muldoon, a consultant that ResCare has been working with to analyze this issue, was able to present calculations of “actual cost” to providers when supporting people in a staffed residence with more than one DSP.  We talked through models of what it does to the provider budgets when adding additional staff.  Commissioner Miller and Dep. Commissioner Jill Hunter (DMS) were very interested in understanding the dynamics of staffing, supervision and the needs of the participants in these scenarios.  Raymond Johnson presented the “formula” he uses to approve or deny requests.  There was clearly a major misunderstanding and disconnect between what is included in the daily rate, the actual costs in adding staffing hours and how providers “manage” homes.  I can tell you that Commissioner Miller seemed to understand the provider dilemma, and as a former CPA & hospital administrator, he was running his own numbers throughout the meeting.  Commissioner Anderson called me this morning to request QUICKLY additional information on how many people we are providing 1:1 services for without reimbursement.  I am requesting all SCL service providers to complete a 3 question Survey Monkey by MONDAY.  Here’s the link:

Complete Survey HERE!

  • We are trying to determine 2 different categories of need:  The first is the participants with the highest acuity levels that you may have transitioned out of ICF’s, admitted through emergency placement, etc. that require 1:1 supervision up to 24 hours in order to keep them safe, the community safe, prevent hospitalization, re-institutionalization, incarceration, etc.  The second is the participants you provide 1:1 supports to (up to 24 hours) because you’ve been “mandated” to by some entity…either the courts, guardian, case manager, family or DCBS.  These are cases where you believe the “mandate” of 1:1 is unnecessary and could/should be reduced.  
  • Your information is needed in order for the Commissioner of Medicaid to determine what this will cost the Cabinet to ensure providers are reimbursed for services provided, beyond the regulatory reimbursement levels.  
  • ***Note:  you should always question a singular “mandate” for 1:1, particularly from a Conflict-Free Case Manager.  They do not have the authority to do that.  They can make recommendations, and you should ALWAYS put whatever you need to in place to ensure the safety of the participant…but you should question, request full team meeting, contact your QA and/or KAPP to fully examine the issue.  While we believe that some people will need LONG TERM 1:1 supports, others who do not …those requests should decrease in numbers.  One thing the KAPP representatives assured the workgroup…we do not WANT to provide 1:1 services when it’s not necessary.  It is not only a financial loss, we do not have the workforce to do it and it is not always best for the participant.  

Regulatory Updates

  • SCL:  Still held up at CMS (Baltimore) for approval.  Another RAI (Request for additional information) was sent to Kentucky Medicaid along with a 3 month extension through December.  Commissioner Anderson told me they have answered the questions and responded.  Hopeful that it is approved soon.  (We will work with her to ensure any e-reg supersedes this approved reg.)  I also heard today from a member on our first call that Alisha Clark reported there will be a 30 day transition period for therapies after the CMS approval date.  
  • Emergency Slots for SCL are still being held up with this reg and won’t be released until it is approved.  One member (case manager) told us on the 2nd call today that some slots are being partially funded through state general funds.  Contact your local CMHC about doing a contract for this.  I’m assuming that is considered as crisis funds, but that the CMHC can secure it to where the $100/day doesn’t gradually reduce.  
  • Another piece of info from our first call this morning:  the Emergency Reg for Mental Health Providers/CMHCs to allow therapies to be provided by them should be filed first of November.  I will follow-up on this.
  • Michelle P. Waiver:  The renewal is due to be filed soon.  Commissioner Anderson reported that the product they have to submit is not ideal and does not incorporate the needed changes.  She wants providers to understand that it will be filed as a “placeholder” until we can fix it.  The draft will be sent out for public comment sometime next week. 

Waiver Redesign

  • The redesign workgroup has moved to weekly calls in order to gather information from other states and submit ideas to the Cabinet.  Some of the discussions so far have been whether to continue with 1915 c models or do a combined 1115 Waiver.  
  • Commissioner Anderson is discussing the idea of acuity payments or tiered rates based upon assessment.  KAPP will continue to research these issues and advocate for the best solutions.  The good news is that we are being asked.  
  • We will need information and help from YOU, the provider members, soon as we work to break down the regulations and redesign a system to move Kentucky Waivers into the future, incorporating principles of Managed Care.  We are exploring ALL possibilities including ACO’s and PLE’s (Provider Led Entities).  
  • I’ll continue to update you weekly on the workgroup’s progress.

SAVE THE DATE:  November 9th in LEXINGTON (updated location)  


KAPP Annual Membership Meeting & Elections

Time and Meeting Location to be announced early next week.

Confirmed Speaker:  Commissioner Debbie Anderson

ANCOR Featured our DSP Video in their Weekly Newsletter!

View HERE!

Hope this Re-KAPP has been helpful,


Shannon McCracken is a leader when it comes to supporting the needs of people with developmental and intellectual disabilities. After a decade of experience at the two largest SCL agencies in Kentucky, she made the decision to embrace a new opportunity and start her own company, Commonwealth Case Management. While in the field, Shannon has won numerous national awards and served in multiple leadership positions, most recently with the Kentucky Association of Private Providers (KAPP). From November 2009 - 2012, she served as the Vice-President of Public Policy for the KAPP Board of Directors and served as President from 2012-2015. In 2016, KAPP made a significant investment in its future and offered Shannon a full-time position as the State Executive Director. Being so involved has enabled Shannon to stay at the leading edge and have a great understanding of what it takes to support people with disabilities.

Shannon is a graduate of Western Kentucky University...wife to Tony, mom to Davis (19) & Caroline (17.)

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