2022-2023 HCBS Rate Review Projects
HCBS Rate Review Updates
FSSA met with stakeholders on May 31, 2023, and June 1, 2023, to share a rate project update as the state finalizes provider rate increases for the Family Supports Waiver and Community Integration and Habilitation Waivers ahead of the submission to federal partners at the Centers for Medicare and Medicaid Services. Please see the links below for additional information. FSSA will accept comments through June 16, 2023 at HCBS.Ratemethodology@fssa.IN.gov.
- Division of Aging public notice
- Division of Aging rate review
- Division of Disability and Rehabilitative Services public notice
- Division of Disability and Rehabilitative Services rate review
- Home Health public notice
- DDRS Public Notice - July 2023 Rates RHS Alignment
- HCBS Rate Update Meeting Announcement for DDRS Waiver Providers (May 31, 2023)
- HCBS Rate Update Meeting Announcement for Division of Aging Waiver Providers (June 1, 2023)
- Assisted Living Home and Community-Based Service Rate Review Project-Draft Rate Presentation
- Division of Aging Home and Community-Based Service Rate Review Project-Draft Rate Presentation
- DDRS Home and Community-Based Service Waiver Rate Methodology Project Update
- Proposed HCBS Division of Aging Updates (June 1, 2023)
- Proposed HCBS DDRS Updates (May 31, 2023)
- Proposed HCBS Rate Updates (Mar. 3, 2023)
- Proposed HCBS Rate Updates (Mar. 1, 2023)
- Proposed HCBS Rate Updates (Feb. 27, 2023)
Home- and community-based services rate review webinar (Oct. 31, 2022)
- October 3, 2022 Division of Disability and Rehabilitative Services Stakeholder Meeting recording
Frequently asked questions
Rate methodology project overview and background
Project goals and objectives
FSSA aims to develop rate methodologies and rates for the Division of Disability and Rehabilitative Services that comply with Centers for Medicare and Medicaid Services rules and that achieve:
- Alignment and transparency - bring continuity and alignment across the rate methodologies and rates, providing a consistent framework
- Sustainability - facilitate adequate participant access to services, as required by CMS and be sustainable under the FSSA budget and operations
- Promotion of person-centeredness - striving to align provider and participant incentives to achieve access to person-centered services, encourage appropriate utilization and drive healthy outcomes for all Home- and Community-Based Services participants
- Reduce disparities - Analyze and quantify disparities in access, quality, site of care, and person-centeredness, then build payment structures to level the playing field
Rate methodology development process
FSSA has engaged Milliman to conduct HCBS rate methodology projects that are expected to culminate in the submission of waiver amendments and possible state plan amendments to CMS for federal approval. Rate methodology projects will involve the following phases:
- Project and stakeholder engagement planning
- Rate methodology development to achieve FSSA goals and objectives
- Rate setting and calculations based on final selected rate methodologies
- Waiver/state plan amendments and CMS approval process
Note that rate calculations will follow and be informed by the rate methodology project phase.
Balanced input from the full range of stakeholders is critical to this process. FSSA wants to hear from a variety of stakeholders, including providers and associations, participants, families, caregivers and advocacy groups, and other key state and federal government stakeholders.
Stakeholder engagement will include:
- In-person meetings
- Bulletins and FAQs
- Rate methodology projects website and email address
In addition, per federal requirements, at the conclusion of each project there will be an official 30-day public comment period, followed by 30 days for FSSA to review and respond to public comment. CMS then has a 90-day approval process which may be extended based on their findings.
FSSA will implement rate reviews for the DDRS during the fall and winter of 2022.
In addition to encouraging stakeholder participation in future meetings, FSSA requests that stakeholders submit comments via email: HCBS.Ratemethodology@fssa.IN.gov
2022 HCBS Survey Information - DA
Purpose of survey
The purpose of this survey is to gather input to help build an understanding of provider costs and inform payment rate assumptions. The provider survey is an important part of the information/data being collected for the HCBS rate review. Stakeholder input is key to understanding service delivery and related costs, challenges, and opportunities. Data elements collected during the survey may include general information, cost structure, staffing, training, benefits, PTO, transportation, and service specific information.
The survey will be requested from each agency that has delivered an in-scope service within the last year.
How to participate
On November 28, 2022, an email was sent to each agency with a link to complete the survey. The email included a unique, random username along with the link to the survey. The password was delivered in a separate email. Please note, only one username/password combination was made available to each provider agency, and only one survey may be submitted per agency.
How to access technical assistance
There are a number of technical assistance tools available:
- Survey PDF on landing page to use as a reference
- Section instructions within the survey
- Pop ups within the survey for more information, instructions, and/or examples
- Training video with a survey walkthrough
If technical assistance is still needed or if you are unsure if you should have received the provider survey, please email HCBS.Ratemethodology@fssa.IN.gov.
When it is due
The survey is due at midnight on Friday, December 16, 2022.
Reminder emails will be sent at periodic intervals during the survey window.
Survey training for providers
General process steps for survey:
- The primary agency contact designated by DA received two separate emails from Milliman on November 28, 2022 which invited them to participate in the survey and included unique usernames and passwords. The use of unique usernames and passwords will ensure the confidentiality of the respondent’s data throughout the process, while allowing the primary contact to move in and out of the survey, as needed, during the submission window.
- Email #1: Provided a direct link to the survey and a username that the respondent will use to login.
- Email #2: Contained a randomly generated alpha-numeric password.
- Respondents will be able to access and edit their survey submission until the survey closes at midnight on December 16, 2022. However, respondents are encouraged to submit the survey as soon as it is completed to reduce the number of “follow up” contacts required.
- After logging into the survey, respondents will be prompted to answer several general questions about their agency. After the initial general questions are completed, you will be able to navigate to the various sections within the survey via the Section Navigation page. The Section Navigation page will serve as your home page in the survey, to track progress and continue where you may have left off. Respondents can log off and log back in at any time and will return to the Section Navigation page each time they log back in. Respondents may also freely navigate between sections using this view.
- We encourage the primary contact to request help from colleagues (“collaborators”), if helpful for survey completion (additional details provided below).
- Respondents will have access to the full survey during the submission window, up to the point of final submission. The respondent will be prompted to review all submissions and complete any missing data fields prior to final submission.
- Once the survey has been submitted, a final message appears thanking the respondent for their participation and providing additional links to the website and email address. If additional clarification is needed, a follow-up email will be sent to the primary contact. Otherwise, no further action is needed after submission.
- At various points throughout the survey completion window, reminder emails will be sent to primary contacts who have not yet completed their survey. Milliman/Axon will also be able to see which agencies have not yet opened their surveys so that we can appropriately follow up and/or secure an alternate primary contact for that agency. Primary contacts can be reassigned, as needed, throughout the survey window. If your agency’s primary contact is no longer able to serve in this capacity, please contact HCBS.Ratemethodology@fssa.IN.gov.
Frequently Asked Questions for the 2022 Division of Aging HCBS Rate Review survey
December 9, 2022
November 28, 2022
Note: These FAQs will be updated as needed during the survey administration period.
- What is the purpose of the survey?
The purpose of the survey is to capture an understanding of service deliver costs for providers of home and community-based services and to inform payment rate assumptions. Results from the survey will help inform the independent rate model that will be used to develop new rates for existing home and community-based services.
- When will the survey be sent?
The survey was released on November 28,2022 with a due date of December 16, 2022.
- Who will receive the survey?
A link to the survey will be sent via email to each provider agency (only one response per agency).
- Who is the best person to complete the survey?
The survey will ask questions about financial information and services provided. Milliman will send the survey to the primary contact on file. We encourage the primary contact to request help from colleagues. The primary contact is responsible for submitting the survey once all parts are complete. If the agency would like to change the primary contact, please contact HCBS.Ratemethodology@fssa.IN.gov.
- What type of data will be requested?
The types of data requested will include service delivery costs, including those related to direct care/clinical care staffing and supervision, employee benefits, administrative costs, program support costs, overhead, and transportation. Data requested will be in aggregate, and specific to the services each agency provides.
- How long will the survey take to complete?
It is expected that the survey will take several hours to complete in its entirety. The length of time it takes to complete the survey will vary depending on the size of the organization and the number of home and community-based services provided.
- Will survey responses be shared with participants?
- Who can we contact if we have questions on how to complete the survey?
If you have questions that are not addressed by the instructions or training video on this website, please send an email to HCBS.Ratemethodology@fssa.IN.gov.
Frequently asked questions Division of Disability and Rehabilitative Services 2022 home- and community-based rate analysis, October 2022
Note: These FAQs will be updated as needed during the rate review process.
Any input and feedback regarding the rate analysis project can be provided to DDRS at HCBS.email@example.com.
- Will the slides from the stakeholder kickoff meeting on October 10, 2022 be posted/shared?
- When will the rates be updated? What role does legislation have?
DDRS and FSSA are expecting to propose a rate update to be effective early in the next biennium. Implementation of the rate update is subject to legislative approval of funding in the next biennium's budget. FSSA and DDRS intend to develop an initial set of rates through the end of 2022, and consider additional adjustments throughout the first quarter of 2023.
- What can we do to help with the rate review process?
Milliman will be requesting stakeholder input on key information needed to understand the cost of providing services, such as wages, benefits, documentation requirements, travel, professional training, and administrative costs. Your input can help ensure we account for all appropriate costs. Stakeholders can respond to the provider survey in early November, or by providing input and feedback regarding the rate analysis project at HCBS.firstname.lastname@example.org.
- What is the best way to contact FSSA concerning a relevant data resource or other information pertinent to the rate review?
Please send input and feedback regarding the rate analysis project to HCBS.email@example.com.
- The October 10 presentation indicated an increase in participation of Medicaid waivers of approximately 68% since 2015. How many of those participants are on Community Integration and Habilitation Waiver vs. Family Supports Waiver?
The graph below is consistent with the participation graph from the October 10th presentation, but illustrates the participation growth separately for CIHW (darker blue) compared to the FSW participation growth (lighter blue). As illustrated below, most of the participation increase was observed in the FSW.
- The federal government reimburses states for some of the cost of the CMS programs, such as FSW and CIHW. How much is the federal reimbursement for FSW and CIHW compared to state costs?
Historically, approximately 2/3 of the cost for FSW and CIHW comes from federal funding with the remaining 1/3 of the cost designated from state funds. For federal fiscal year 2024, should the public health emergency have ended, the federal share will be 65.62%. However, this is subject to change each federal fiscal year, and the federal funding match cannot go below 50 percent.
- Will this rate review set in motion a more consistent process of rate reviews on a regular schedule over the coming years?
Yes, we hope to have rate reviews at least every five years to better align with CMS guidance.
- How will this rate review account for the following non-benefit expenses incurred by providers: training, quality, and Human Rights Committee? These are not part of the typical administrative expenses incurred by providers.
We intend to reflect all three of these expenses in the rate build-up, but in different ways. For training, we intend to explicitly reflect annual employee time spent on training. To support quality, the rate build-up will incorporate assumptions that are consistent with quality, such as appropriate staffing ratios, training time, and documentation time. We intend to include costs for the Human Rights Committee in the administrative load. We welcome feedback on the approach for each of these items.
- How does the rate review affect Direct Service Professional passthrough audits? Will the monthly audits continue when new rates are put into effect?
DDRS intends to have the providers maintain responsibility for the monthly DSP passthrough audits.
- Will DDRS base rates off current wages rather than lower historical wages? If so, how will that be accomplished?
The Bureau of Labor and Statistics publishes monthly data on wage increases by industry, with data available as recent as three months ago. Although the rate model framework may start with historical data, it will be adjusted to reflect recent wage increases. In addition, we will incorporate an estimate of future wage inflation from the current time to the anticipated time of implementation.
- Are rates for the Division of Aging being reviewed as well?
There is a second concurrent rate review project under way for the Division of Aging waivers: the Aged and Disabled Waiver and the Traumatic Brain Injury Waiver.
- Some services have not had a rate update in many years. Will they be included in the review?
As part of the project, the State will review and align rates for all services that have a fixed fee schedule amount. As part of this alignment, some of the rates for some services may go down while others may go up.
- How is the cost of providing these services in a residential facility determined? And how will this rate review ensure the cost of providing these services in the community does not exceed the cost of providing them in a facility?
Residential rates will not be reviewed as part of this project. Cost neutrality compares the average annual cost in an intermediate care facility to the average annual cost for an individual receiving LTSS in the community through the CIHW or FSW. The average community cost is required to be less than average facility cost.
- Will we still have the Algo scores to tie funding by person?
There will not be a change in Algo scores as part of this project.
- Will the rates be adequate to prevent closing and ensure enough providers?
One of the rate review's goals is for the updated rates to be adequate to support quality services from an efficient provider. We intend to develop rates that will allow for sufficient access and to sustain a healthy provider base.
- Is there a consideration for the influx of children under 7 to the waiver?
This question relates to the waiver redesign, and will be reflected in the rates after the redesign is closer to implementation.
- Will this be just for FSW and CIHW?
Yes, the scope of this rate review is for FSW and CIHW.
Your participation in the survey is much appreciated!
This document is intended has been prepared solely for the internal business use of the Indiana Family and Social Services Administration and the FSSA Division of Disability and Rehabilitative Services. Milliman understands that the information in this document will be shared with providers of DDRS services for the purpose of supporting the submission of survey data.
The contents of this document are not intended to represent a legal or professional opinion or interpretation on any matters. Milliman makes no representations or warranties regarding the contents of this document to third parties. Similarly, third parties are instructed that they are to place no reliance upon this information prepared for FSSA and DDRS by Milliman that would result in the creation of any duty or liability under any theory of law by Milliman or its employees to third parties.
The services provided for this project were performed under the signed Consulting Services Agreement between Milliman and DCS approved January 4, 2022.