DIDD Shares Plans for Big Changes in Medicaid Waiver Employment, Day Services
By Jeremy Norden-Paul
About the Author
Jeremy Norden-Paul is the state director of Employment and Day Services for DIDD. He began his career as elementary special education, and then became an employment consultant with a provider agency. Jeremy took a position with Teach for America in Nashville, and he joined the DIDD team in 2016.
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Later this fall, the Department of Intellectual and Development Disabilities (DIDD) is making some significant changes to how employment and day services are provided under the 1915(c) waivers, the “traditional” DIDD Medicaid waivers. DIDD believes these changes will have a positive impact because they will:
- Give people more flexibility in how they receive employment and day services,
- Provide new services to explore and pursue employment,
- Allow people to use their home as a base, and
- Empower people to achieve greater independence.
However, before DIDD can implement the changes, they will first be shared with the public for review and comment. After DIDD addresses the comments, the proposed changes will then be submitted to the federal Centers for Medicare and Medicaid Services (CMS) for final approval.
During the public comment period, which is scheduled to occur in mid-May, you will have the opportunity to review all of the proposed changes, ask questions, and provide comments. DIDD highly encourages all persons supported, family members, support staff, and other advocates to take advantage of this opportunity to give feedback. DIDD and TennCare have spent several months seeking feedback from providers and making changes, but now is the chance to make sure the changes make sense to you. You can also watch this short video to hear a brief overview of the proposed changes.
There are several significant changes that are addressed in this FAQ document, and in the documents posted on the DIDD website under the “Waiver Information” section. However, DIDD wants to take this opportunity to make sure everyone understands what the most significant changes are and how they will affect services if they are implemented.
First, DIDD would like to eliminate the 6-hour requirement, which has been a topic of great concern for several years. Currently, a person needs to receive six hours of employment or day services in order for the provider to be reimbursed for that day. This has led to many people feeling pressured to spend extended periods of time outside of the home, which has not always felt person-centered. Under the proposed changes, the 6-hour rule will no longer exist. Instead, a person can receive services in 15-minute increments—for any duration of time, at any time of day, and on any day of the week—as long as it does not exceed the limit of 60 hours of employment and day services during a 14-day billing cycle. This change is in direct response to feedback from individuals, families, and providers, and DIDD believes it will provide greater flexibility and a more person-centered approach to day services.
Along with increased flexibility, the proposed waiver changes will impact how people receive services in their homes. Currently, many people travel to a day center before going out in the community, and often return to the day center during the day for meals, to rest, to use the restroom, etc. Under the proposed changes, all people will have access to a new service called “Intermittent Employment and Community Participation Wraparound.” This will allow a person to start their day at home, use their home as a base throughout the day instead of going to a day center, and return to their home after work or spending time in the community. During the 14-day billing cycle, up to 40 of the 60 total hours referenced above can be received as “Intermittent Employment and Community Participation Wraparound.” People can still use the day center as their base if they choose, but DIDD believes this new wraparound service will provide greater flexibility and more person-centered options.
The proposed waiver changes will also impact the service that is currently known as In Home Day. Currently, when people want to use their home as their base, the provider is required to bill for In Home Day, even if a person also spent time in the community. Under the changes, this will no longer be the case. No one will be expected to be supported at home for the entire day, just because they want to use their home as their base for part of the day. We also recognize there are a small number of people who are truly not able to leave their homes on some days due to illness, injury, recovery from hospitalization, sustained behavior challenges, and some people who cannot leave their home at all due to end-of-life circumstances. For these individuals, there will be a “residential special needs adjustment-homebound” for people also receiving residential services, and a “non-residential homebound service” for people who do not also receive residential services. However, retirement will not be a criterion that qualifies a person for these homebound adjustments/services. Adults of typical retirement age can choose how they spend time at home and in the community, and for what duration of time. They will also have access to wraparound services in their homes. DIDD encourages people of typical retirement age to speak with their circles of support about this change to make sure they have the opportunities and supports that match their interests, preferences, and goals.
Employment services and supports is one of the areas most affected by the proposed waiver amendments. Under the changes, people will have access to several new services that will help them explore the possibility of employment and pursue their employment goals more effectively. This is good news, because there are many people supported by DIDD who want to work in the community but have not yet had the opportunity. The Exploration service will help someone determine if he or she wants to work in the community. If so, the Discovery service will help someone figure out what kind of job he or she would like to pursue, and Job Development is a service that will help the person actually obtain the job. In addition to these new services, the proposed waiver changes will also provide ongoing job coaching services to help someone keep his or her job, as well as grow professionally over time. DIDD believes these changes will help more people obtain competitive integrated employment, achieve the greatest possible independence, and have access to all of the benefits that come with being employed.
While these are the changes that will have the most significant impact on employment and day services, DIDD hopes everyone will familiarize themselves with the proposed changes, provide feedback during the public comment period, and speak with their circles of support to make sure they understand how the proposed changes will affect their unique situations. Although change can be challenging, and it may take some time to adjust, these proposed waiver amendments will help DIDD fulfill its vision of supporting Tennesseans with intellectual and developmental disabilities to live fulfilling and rewarding lives.