Steve Gold, The Disability Odyssey continues
Forty-one States in FY 2006 received substantial Medicaid funds (from $10 m up to $419m per year) for MA's "Targeted Case Management" services.
On July 25, 2000, the U.S. Department of Health and Human Services' Center for Medicare and Medicaid Services wrote that Targeted Case management services could be provided "to institutionalized persons who are about to leave the institution, to facilitate the process of transition to community services."
CMS wrote that these services could be used "to enable the person to gain access to needed medical, social, educational and other services in the community," including housing, rental subsidies, personal attendant care services. CMS noted that it was encouraging States to use these services in response to the Supreme Court's Olmstead decision.
CMS told your State that Medicaid's federal reimbursement for Targeted Case Management services "may be furnished during the last 180 consecutive days of a Medicaid eligible person's institutional stay, if [the Targeted Case Management services were] provided for the purpose of community transition."
Put simply, States received federal reimbursement for the case management work it provided to persons in nursing homes and other institutions while these persons were still in the institution and were making all the necessary preparations to move back to the community.
We know that it takes quite a bit of time to transition people from institutions to the community. People often must obtain identification papers (a birth certificate, divers' license, baptism papers), apply for community benefits (food stamps, paratransit eligibility), make applications for affordable, accessible, integrated housing (whether public housing, vouchers, or other housing), as well as obtain appropriate durable medical equipment (many may need a motorized wheelchair which the nursing facility or other institution frequently did not provide).
CMS has issued an "Interim Final Rule" which will limit federal reimbursement for "transitioning to a community setting" to 60 days from the current 180 days. CMS has offered no explanation for the reduction and offered no examples of States' abusing the 180 days or any other reason for the reduction.
While it would be terrific if all the work could be accomplished in 60 days and the person transitioned to the community within 60 days, we all know that in many cases that is not possible. Even CMS does not respond to inquiries regarding SSDI or Medicare within 60 days!
Please write to: Dept of Health and Human Services, Attention CMS -2237 -IFC, PO Box 8016, Baltimore, MD 21244-8016, Re: Case Management Services' Interim Final Rule" and let Secretary Michael O. Leavitt hear your concern.
Don't delay. This must be done ASAP.
This CMS rule was issued on 12/4/07 and the comment period ends on 2/8/08.
You must have your comments in by 2/8/08.
- You can electronically submit comments. Click on the link "submit electronic comments on CMS regulations with an open comment period." Use Word format. Remember to cite correct CMS file number.
- Or by regular mail to:
Department of Health and Human Services
Attention CMS -2237 -IFC.
P.O. Box 8016
Baltimore, MD 21244-8016
Please use the correct CMS file number.
You may read the entire Interim Rule.
Source: Steve Gold, The Disability Odyssey continues
Write to stevegoldada@cs.com, call 215-627-7100, or visit the website http://www.stevegoldada.com
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