Reducing administrative requirements: HCS

The Texas Department of Aging and Disability Services convened a stakeholder meeting on Nov. 17, 2011, to receive input on potential areas in the Home and Community-based Services (HCS) program where administrative requirements could be reduced or streamlined.

Click here for the Status Chart for Implementation of Suggestions for Reducing Administrative Requirements in HCS in PDF format.

Status Chart for Implementation of Suggestions for Reducing Administrative Requirements in HCS
No.	Requirement	Description/Suggestion	Benefit	Implementation Decision	Status
1	Individual Plan of Care (IPC)	Submit all dental bills only through the bill system with a requirement to maintain proof of payment in an individual's file if the amount is less than previously approved in the Individual Plan of Care (IPC).	Reduced paperwork and elimination of a step in the submission process for dental bills.	DADS already is addressing this suggestion. Providers will be able to submit claims through the Texas Medicaid and Healthcare Partnership (TMHP) based on authorization when Single Service Authorization System (SSAS) rolls out. DADS will not be requesting any program changes to the Client Assignment and Registration (CARE) system at this time.	Completed
2	Transition of Individuals from State Supported Living Centers (SSLCs) to Providers of Community-based Services	For individuals moving from SSLCs to community-based services, streamline the transition process to support closer and more effective collaboration between SSLCs and potential providers.	Achieve more successful placement of individuals transitioning from SSLCs to community-based services.	DADS is already working on supporting smooth transitions to the community. The agency has hired two more staff at each SSLC to assist with transition activities.	Completed
3	Unconfirmed Allegations of Abuse, Neglect and Exploitation	Consider removal of the review process for all abuse, neglect and exploitation if an allegation is unconfirmed. Often recommendations by the Department of Family and Protective Services (DFPS) are not required by HCS program and are in conflict with HCS program provider policy and procedure.	Remove stress and administrative burden for both DADS and providers.	DADS Regulatory Services staff already reviews DFPS reports to determine if a provider is in compliance.	Completed
4	Quality Assurance and Improvement System (QAIS)	Update, reinvent and implement a process like QAIS with family, program participant and qualified team member involvement in the monitoring and interviewing processes. This change would reduce duplication of utilization review processes.	Include additional perspective, observations and contributions to QAIS. Also, reduce duplication of utilization review processes.	DADS already has revised the certification process to include more input from program participants, their families and service providers.	Completed
5	Review of Waiver Services	Review waiver services by component code rather than vendor number.	Reduce travel cost for survey teams.	DADS already offers providers the option to request certification review of contracts in close physical proximity during the same week.	Completed
6	Home and Community-based Services (HCS) and Texas Home Living (TxHmL) Surveys	Combine HCS and TxHmL surveys for those providers providing services through both programs.	Reduce travel costs for survey teams.	DADS already offers providers the option to request HCS and TxHmL surveys be conducted during the same week.	Completed
7	Consumer Direction Mechanisms	Expand the consumer direction mechanisms, which will require waiver amendments and rule modifications.	Expand mechanisms for consumer direction.	The Consumer Direction Workgroup is charged with providing recommendations to the Health and Human Services Commission (HHSC) and DADS regarding the expansion of the services available through self-direction and methods for increased flexibility within the Consumer Directed Services (CDS) option. The workgroup will submit its next biennial report to the legislature on September 1, 2012. That report will include recommendations, some directed to DADS and HHSC and some directed to the Texas Legislature.	Completed
8	Intellectual and Developmental Disabilities (IDD) System Improvement Workgroup	Continue the use of the IDD System Improvement Workgroup, which originally was established as the Case Management Transition Workgroup, to ensure all case management transition issues are addressed.	Saving will result in time and costs for providers and Local Authorities.	DADS will continue the IDD System Improvement Workgroup to address system issues, implement improvements and streamline processes.	Completed
9	Submission of Individual Plan of Care (IPC).	Eliminate HCS rule requiring providers to notify service coordinators 60-90 days before expiration of IPC. Service coordinators already have access to this information.	Require one less item to track for the service coordinator and the provider.	This change is already in a proposed rule change. Service coordinators have access to IPC expiration dates in the CARE system. Service coordinators can track expiration dates without notification of a provider.	Completed
10	Inspection of 4-Person HCS Group Homes	Allow HCS providers to receive fire safety inspection from local fire marshals, most of whom now use the International Fire Code (IFC) rather than the National Fire Protection Agency (NFPA). Currently, an HCS provider must have a 4-person home inspected by both a local fire marshal and a state inspector if the local fire marshal has adopted the ICF.	Reduce staff time, travel costs and costs for wages.	This change is already in a proposed rule change.	Completed
11	HCS Certification Standards	Revise the standards to certify HCS contracts to enable viable providers to become or remain certified to provide HCS. Examples of revisions could include decertifying providers who served no individuals within a fiscal year, increasing minimum standards for new providers, verification of financial viability, and maintaining a portion of a provider's HCS contract in light of deficiencies or sanctions in some but not all localities.	Increase quality of providers by ensuring financial viability for certification of HCS contracts.	DADS will research revision of the HCS certification standards.	Scheduled start is September 1, 2012.
12	Policy Change Letters	Send policy change letter once a quarter or month, unless the nature of change letter is urgent.	Reducing the frequency of sending policy change letters would allow HCS providers and families more time to review letters without feeling overwhelmed with information.	DADS is developing a regular schedule for provider manual updates.	In Progress
13	Investigation Responsiveness	Improve investigation responsiveness by DFPS. Overly lengthy investigation process results loss of labor while staff suspended with pay.	Reduce cost to provider.	DADS will follow up with DFPS on this suggestion.	In Progress
14	Administrative Portions of Current Rate Structure	The administrative portions of the rates received by the provider do not sufficiently fund the cost of the provider's coordination responsibilities. Review the administrative portions of the current rate structure to adjust for increased administrative compensation to providers.	Better funding of providers will result in improving the quality of services delivered by providers.	HHSC already is reviewing this issue as part of the Consolidated Budget Process.	In Progress
15	Administrative Reduction Proposals	Approve only those administrative reduction proposals that continue or enhance the certification principles for the HCS program.	Use creative ideas to streamline or relieve unnecessary administrative burdens to complement the principles serving as the critical underpinning of HCS.	This is DADS goal as well.	In Progress
16	Managing Individuals' Personal Funds	Providers should have the option to manage or contract the service managing an individual's personal funds.	Reduce administrative costs for providers.	DADS staff recommends researching how to make management of personal funds a part of the array of reimbursable services.	In Progress
17	Electronic Submission of Documentation	Allow submission by electronic scan or email into drop-box system in a computing cloud or virtual server.	Reduce time and costs with electronic submission by potentially cutting down on processing of documentation and reduce risk of an individual's service plan expiring during period of document processing.	DADS recommends piloting electronic submission of documentation for the HCS program. Agency will model current pilot for electronic submission of documentation for the Community Based Alternatives Program.	In Progress
18	Purchasing of HCS Services and Supports	Increase flexibility to purchase services and supports (e.g., durable medical equipment, adaptive aids and vitamins) for individuals in the HCS program. Remove the requirement for DADS approval on purchases within a certain dollar amount, and use a fee schedule or range for those purchases over that amount with an option for DADS to approve exceptions.	Reduce time and costs associated with purchases.	DADS will initiate a project to research use of a fee schedule in the HCS program. On October 1, 2011, DADS initiated a similar project for the Community Based Alternatives program.	In Progress
19	Requirements for Medical Professionals Serving Individuals Transferring into HCS Program	When transferring into the HCS program, providers must obtain signed contracts, evidence of licensure/credentialing and other paperwork from individuals' doctors and other medical professionals, who sometimes do not want to supply information. Recommend removing these requirements.	Not requiring signed contracts and other information would save time for doctors and other medical professionals and would allow individuals to continue receiving care from doctors and other medical professionals with whom they have established relationships.	DADS will follow up with the Private Provider Association of Texas to discuss this suggestion. Current rule only requires that program providers obtain qualifications.	In Progress
20	Entering Monthly Critical Incident Report into CARE	Eliminate the requirement to enter a monthly critical incident report into CARE. If incident fits the criteria for reporting to Adult Protective Services, incidents will be reported to appropriate authority.	Elimination of monthly critical incident reporting into CARE would free up time for the provider to complete other tasks.	DADS will review types of reports entered into CARE to the necessity of each and at what frequency.	Not Implemented
21	Curriculum/Certification Process for Licensed Vocational Nurses	DADS and Board of Nursing (BON) should create on-call or telephone triage curriculum or certification process for licensed vocational nurses (LVN) who have multiple years of experience.	An on-call or telephone triage curriculum or certification process would reduce costs for the HCS provider.	No change. As required by Senate Bill (S.B.) 1857, 81st Legislature, Regular Session, 2011, DADS and the BON, in consultation with the S.B. 1857 Advisory Committee, is implementing a pilot program to evaluate LVNs providing on-call services by telephone for individuals receiving services in the HCS waiver, Texas Home Living waiver and Intermediate Care Facilities for Persons with Intellectual or Developmental Disabilities with a capacity of 13 or fewer beds. This pilot ends September 1, 2015. DADS, the BON, and the S.B. 1857 Advisory Committee will evaluate data collected throughout the pilot period and will make recommendations for future policy based on the pilot's outcomes.	Not Implemented
22	Certification Process for the HCS Program	Implement a multiyear certification process for the HCS program.	Reward compliant providers and provide more frequent oversight for those not in compliance.	No change. The certification process supports protection of the health and safety of individuals participating in the HCS program.	Not Implemented
23	IDD as a Diagnosis to Participate in the Day Activity and Health Services (DAHS)	Use IDD as a recognized diagnosis to qualify an individual in the HCS program to participate in the Day Activity and Health Services and Adult Day Care. Currently, qualifying an individual in HCS to participate in either of these services requires two medical diagnoses.	Create access to federally funded Medicaid services.	No change. DADS is unable to accept IDD as the sole diagnosis for DAHS due to CMS requirements under Section 1902 of the Social Security Act.	Not Implemented
24	Day Habilitation Service Funding	Fund day habilitation services, a non-waiver service, through the Department of Assistive and Rehabilitative Services (DARS). This funding change would remove application of an administrative fee. Training through day habilitation services is truly for daily living skills which DARS supports. In addition, DARS could fund work adjustment training for those individuals participating in piece rate activities.	Change in federal versus state liability for funding.	No change. The day habilitation service component assists individuals with acquiring, retaining or improving self-help, socialization and adaptive skills necessary to live successfully in home and community-based settings. Day habilitation does not include services funded under section 110 of the Rehabilitation Act of 1973 or the Individuals with Disabilities Education Act (20 U.S.C. 1401 et seq.).	Not Implemented
25	Day Activity Health Services (DAHS) for All Types of Medicaid Programs	Allow provision of DAHS in all types of Medicaid programs.	Reduce state liabilities and costs.	No change. Individuals with IDD who meet the eligibility for DAHS under Section 1902 of the Social Security Act can and do receive DAHS.	Not Implemented
26	Direct Bill to Medicaid for Dental Services	Allow dentists to bill directly to Medicaid for dental treatments and assessments.	Free up time for the provider by eliminating the need to bill for dental services.	No change. The maximum of $1,000 for dental services is only available within the waiver. DADS does not establish Medicaid policy for dental services outside the waiver.	Not Implemented
27	Legislatively Directed Limits to Amount, Scope and Duration of Services	End legislatively directed limitations to the amount, scope and duration of services an individual receives. Instead, rely on appropriate IPC development and DADS utilization review processes.	Innovation and individual direction rather than limitations will increase an individual's independence, health, safety and community involvement and often remove administrative burden for the provider by shifting more of the responsibility to individuals and their allies.	No change. This would require legislative direction.	Not Implemented
28	Capping Practices on IPCs	Stop capping below the real hard cap. This requires providers to send an information packet to get soft cap increase increased.	Reduce paperwork for providers and cash flow issues resulting from holding funds.	No change. No caps exist for IPCs.	Not Implemented
29	Renewal of IDRC Assessment	Renew the IDRC Annual Assessment to the same renewal time at the Inventory for Client and Agency Planning (ICAP).	Reduce administrative time and paperwork.	No change. The current process for the IDRC is programed in the SSAS, which is scheduled to roll out later in 2012. Changes to programming in CARE would be a cost issue. In addition, the Code of Federal Regulation (CFR) and waiver require annual evaluations of the individual's Level of Care (LOC).	Not Implemented
30	IDRC Assessment Submission to DADS	Allow a provider to directly submit an individual's IDRC assessment without review from a service coordinator.	Reduce time required for submission of IDRC assessment to DADS.	No change. The service coordinator serves as an independent quality assurance component. The service coordinator review is based on the premise that the service coordinator has had interaction with the consumer and provides the opportunity for the local authority to notify DADS of a concern regarding IDRC information that may be in error or seems inappropriate. This allows DADS staff to scrutinize those assessments needing a secondary look at their eligibility status. Without the quality assurance component, this eligibility reassessment activity will result in automatic authorizations for almost all. It is unlikely CMS will approve the process in the waiver. Currently, the service coordinator has seven days to agree with the IDRC assessment. If the service coordinator does not take timely action, the process continues without his/her review. If the service coordinator disagrees, he/she must provide the reason(s) to utilization review (UR) for the disagreement. The process is automated and has defined time lines so there is not a delay in services.	Not Implemented
31	Review Requirement of IDRC Assessment by Service Coordinator	Have the service coordinator review the initial IDRC assessment for an individual. However, require no service coordinator review and approval on subsequent IDRC assessments.	Increase the process for completing and submitting an IDRC Assessment to DADS.	No change. The service coordinator serves as an independent assurance component. Currently, the service coordinator has seven days to agree with the IDRC assessment. If the services coordinator does not take timely action, the process continues without his/her review. If the service coordinator disagrees, he/she must provide the reason(s) to Utilization Review for the disagreement. The process is automated and has defined time lines (seven days) so there is not a delay in services. The service coordinator does not approve IDRC assessments. DADS staff are responsible for approving initial assessments at enrollment, and changes to subsequent IDRC assessments are subject to UR oversight.	Not Implemented
32	Documenting Functional Eligibility	Reduce the frequency of functional eligibility documentation to less than annually unless a presenting change in an individual's condition or functional eligibility is identified by the provider.	Reduce the administrative burden for DADS and providers.	No change. The CFR and waiver require annual evaluations. Changes to the SSAS programming would have a cost associated.	Not Implemented
33	Redundancy in Residential Reviews	Remove redundancy of residential reviews of Foster Care/Companion Care Homes under the HCS Program. Both DADS Regional Authorities and DFPS conduct residential reviews, sometimes both during the same month. This appears to be overkill and a waste of families' time and taxpayers' dollars.	Create immediate cost savings.	No change. This would require legislative direction. DADS Regional Authorities and DFPS may visit residences, but do not conduct residential reviews.	Not Implemented
34	Requirement to Conduct Annual Unannounced Visits to Foster Care Homes	As the result of S.B. 643, 82nd Legislature, Regular Session, 2001, DADS must now conduct unannounced visits to HCS providers with foster homes at least every 12 months. Consider incorporating this additional visit into the annual review process or conducting this visit every other year based on performance.	Generate costs saving for DADS and providers.	No change. This would require legislative direction.	Not Implemented
35	Require Surveyors to Survey Only One Area of State	Though DADS hires surveyors in specific areas of the state, surveyors can conduct surveys all over the state. Recommend letting surveyors only complete survey in the area of the regional offices from which they work.	Save time and money.	No change. Due to the size of Texas, surveyors cover areas outside the regional office from which they work. In addition, DADS intentionally mixes surveyors from the branches to determine if standards are interpreted consistently across the state.	Not Implemented
36	Annual Surveys for Providers Receiving Zero Deficiencies	Reduce annual survey review to every other year for providers who receive zero deficiencies. However, receiving a deficiency would revert to an annual review for a provider.	Achieve reductions in staff surveyors and travel costs.	No change. Any reduction in annual surveys may reduce the health and safety of individuals participating in the HCS program.	Not Implemented
37	Duplication of Utilization Review	Remove duplicate utilization reviews because one review is sufficient.	Reduce costs and staff time for DADS and providers.	No change. Use of utilization reviews is a statutory requirement.	Not Implemented
38	Streamline All Survey into One	Streamline separate surveys, such as bill audit, program audit, utilization review and residential review, into one survey every year.	Reduce costs and staff time for DADS and providers.	No change. DADS conducts separate surveys because each focuses on different aspects of HCS services delivered by a provider.	Not Implemented
39	Requirements for Fire Alarm and Sprinkler System	Eliminate requirements for fire alarm and sprinkler systems if an individual living in a three or four bed HCS group home has a prompt response on escort. Would continue to have individuals and staff participate in scheduled fire drills and fire safety training. In addition, all group homes would continue to have fire extinguishers and smoke detectors.	Achieve significant costs savings with elimination of fire alarm and sprinkler systems.	No change. DADS does not have the authority to change Life Safety Code requirements.	Not Implemented
40	Requirement for Service Coordinator	Eliminate service coordinator as required by CMS. Too much overlap occurs between service coordinator and the private provider foster care/case manager.	Cost savings.	No change. This is a CMS requirement. Any change would require legislative direction.	Not Implemented
41	Responsibilities of the Service Coordinator	Revamp responsibilities of the service coordinator who provides limited services while the case manager carries a large workload. Additional responsibility could include involvement in maintenance of individuals Medicaid eligibility. In addition, families report not receiving any additional services from the service coordinator.	Give more responsibilities to the service coordinator and reduce workload and costs of wages for case manager.	No change. DADS will continue to work with providers to examine the role and responsibilities of the service coordinator.	Not Implemented
42	Unallowable Billable Items and Services	Review unallowable billable items and services to consider if they are billable. Need to ensure that cost reports represent the cost of doing business and fully support the ability of providers to meet the certification principles.	Provide more equitable reimbursement for services provided. In addition, improve quality of services provided and satisfaction of providers and their direct support staff.	No change. DADS must follow CMS requirements for allowable expenses; Medicaid allowable expenses cannot surpass Medicare allowable expenses. In addition, HHSC will continue to review allowable costs to determine if any improvements or adjustments can be made.	Not Implemented
43	List of Excluded Individuals and Entities (LEIE) Checks	Assist providers by making improvements to HHSC Office of the Inspector General database. For example, change the procedure to complete the list of excluded entities annually rather than monthly for employees and contracted/ subcontracted staff.	Save time for administrative time.	No change. This would require legislative direction.	Not Implemented
44	Cost Report Process	The cost report is overly prescriptive, burdensome and costly, and it does not provide any useful or timely data for the legislature about the costs of providing services. Recommend examining ways to redesign and streamline to improve the cost report process and database. For example, require cost reporting every other year rather than annually.	Reduce administrative costs for providers and HHSC.	No change. HHSC is revising the cost report system into the State of Texas Automated Information Reporting Systems (STAIRS).	Not Implemented
45	CARE System	Update the CARE system or find a better state database for providers to report to the state. Providers should not have to provide information already in CARE.	Reduce costs and time entering information into CARE.	No change. HHSC is already addressing this suggestion. On November 5, 2012, billing for HCS and the Texas Home Living will move from CARE system to the Texas Medicaid and Healthcare Partnership (TMHP) claims system (TexMedConnect). Migration of the billing and claims adjudication to TMHP will provide for more accurate and timely claims processing and provider payment. In addition, use of the TexMedConnect claims system will provide for a better user interface and consistency of billing across all long-term services and support programs.	Not Implemented

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Updated: November 21, 2012