Thank you for the opportunity to provide feedback on the proposed updates to Chapter 6 of the DD Waiver Manual. We appreciate the continued efforts to improve processes and ensure quality services for the individuals we serve. We would like to highlight a few areas where additional clarity and adjustments would greatly support both providers and the individual and families we serve. 

Clarification on the Term “Provider” Throughout the manual, the term “Provider” is used in multiple ways. In some places, it refers to attendant care providers, while in others, it refers to contracted service providers. These are very different roles with different responsibilities. To avoid confusion, we recommend using clearer language that better describes these types of providers. This would help ensure everyone shares understanding when it comes to expectations, documentation, and compliance issues. 

Corrections, pended plans, and signatures:                                                                       We have concerns about the expectation to do a whole new plan of care with new signatures if changes or corrections are needed after the planning has taken place. Daily, a large number of Plans of Care are pended due to required updates and corrections.  For example, the number of approved hours may come back different from what was initially requested, or the support coordinator may add or revise outcomes or risks after the plan is written and signed.  Another example would be when the provider’s schedule conflicts with another provider’s schedule, since providers are unable to see other providers’ schedules in WaMS.  In these cases, are providers expected to do a second visit that they cannot be paid for in order to redo their plans of care? If so, this will further delay approval for services.  The current system is already very time-consuming.  While we understand the importance of complete and correct information, when a request is pended, the provider has 5 days to respond.  Then the Support Coordinator has 10 days to make a decision.  They may pend a second time, which gives the provider another 5 days and then the Support Coordinator another 10 days.  If a provider is required now to go back out to the home to re-write the plan of care with the corrections and get all new signatures, it will only add to the timeline to get approval for those services.  

If the provider uses electronic signature platforms, it’s important to consider the financial and practical challenges this creates. For example, when we explored using DocuSign, we found it would cost over $25,000. This is a significant expense, especially when providers are already struggling with limited reimbursement rates and administrative cost. 

Timelines for ISP Meetings and Reauthorizations: We strongly recommend clearer expectations around the timing of ISP meetings and the delivery of finalized documents. Specifically, we suggest including a requirement that Support Coordinators hold their annual ISP meetings at least 60 days before the reauthorization date. In addition, providers should receive the final ISP document at least 60 days before the authorization ends. This would give everyone involved enough time to write their portions of the plan, make needed corrections, and submit service authorizations in a timely manner, work through pends, and get approval prior to the end of the current plan year. Without this longer timeline, delays are common and lead to lapses for the families we serve. The Support Coordinator Handbook provides guidance that suggests that the ISP meetings should “ideally be held at least six weeks prior to the due date of the PC ISP.”  But, it is not required, nor does it require the Support Coordinator to send the providers the ISP in any kind of timeline.  Also, none of this is mentioned anywhere in the provider manual being reviewed for this public comment.