The Ohio Department of Developmental Disabilities (DODD) has announced that the federal Centers for Medicare & Medicaid Services (CMS) has accepted the state’s proposal as a plan for compliance that meets the federal requirements regarding Conflict Free Case Management. DODD had previously submitted their proposal to CMS on January 9, 2015.
The following elements are included in the DODD proposal:
- County boards of DD will not be permitted to provide waiver services to new enrollees unless there is no other willing and able provider in the geographic region to do so. DODD has not set a date certain as an effective date for this to occur.
- County Boards of DD will be permitted to continue to directly provide waiver services to existing enrollees that choose to remain in their programs until 2024. Over the 9-year period, county boards will work to reduce their number of enrollees by transitioning them to private providers. In accordance with the recently revised Free Choice of Provider rule, counties are required to recruit providers of these services and will need to submit benchmarks to DODD by September 1 of this year. The 9-year transition period will allow boards to develop private provider capacity, particularly in geographic areas where the capacity does not currently exist.
- In addition to the above, CMS has asked DODD to ensure that county boards will reduce the number of waiver enrollees directly served by boards to 30% on a statewide aggregate by 2020. This means private providers would be serving 70% of waiver enrollees in these services in Ohio by 2020.
DODD formally submitted the proposal last week to CMS as a part of the state’s waiver renewals and amendments previously submitted in March 2015. Immediate approval from CMS is expected. OACB will continue to be actively engaged with lawmakers, DODD policymakers, and potentially CMS officials on the specific and more nuanced aspects of implementation. OACB’s first priority is to ensure expectations are clear and all questions to regulatory agencies are answered as definitively and quickly as possible.
Additional resources on this topic will be shared with members via OACB PolicyBrief and posted online at www.oacbdd.org/cms.