Sent: Tuesday, January 4, 2011 3:28 PM
From: Lello, Angela
To: Ackermann, Misti J (DADS)
Subject: TCDD Comments on HCS Billing Guidelines
Thanks for the opportunity to give you feedback on the HCS billing guidelines. I principally focused our comments (below) on issues that present barriers to community integration for HCS participants. Please don’t hesitate to contact me if you have any questions.
Angela Lello Public Policy Director
Texas Council for Developmental Disabilities 6201 East Oltorf, Suite 600 Austin, Texas 78741
(512) 913-7498 mobile
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TCDD Comments on HCS Billing Guidelines
Employment Assistance services will be added to HCS effective 9/2011. The current HCS guidelines for Supported Employment list activities that help HCS consumers in accessing employment. Until Employment Assistance services are added to the HCS waiver, the billing guidelines should be revised to allow providers to bill for any assistance they provide to help a consumer secure competitive employment. Also, the billing guidelines should clarify what interaction, if any, a consumer must have with DARS prior to receiving supported employment. At times, some providers have said they could not bill for supported employment unless a “denial” letter is obtained from DARS. It is burdensome and time-consuming to require a consumer to receive a “denial” letter from DARS when the vocational rehabilitation services DARS provides are distinctly different from Medicaid-funded supported employment.
Many consumers and advocates have expressed dissatisfaction with day habilitation programs that result in little or no meaningful activity in community-settings. Workshop-based day habilitation programs are often seen as the only viable model for the HCS program. The description of day habilitation notes that the service is designed to assist an individual to integrate and participate successfully in the community. If HCS participants are receiving day habilitation services in a fully segregated setting where the only people without disabilities are the paid staff, then they are not being integrated into the community. It would be difficult to conclude that such segregated services would help a person learn to be integrated either. The billing guidelines need to be revised to emphasize that community-based integration is the ultimate goal of day habilitation. The billing guidelines should encourage providers to move away from the “day wasting” model of day habilitation services.
Adaptive Aids – Dental
At times, people in the HCS program cannot receive all of the dental treatment they require. Many people with developmental disabilities require some form of sedation in order to receive certain treatments. The billing guidelines should be reflected to allow for the purchase of sedation and other dental services that are not covered in other billable services. This would prevent unnecessary institutionalization in hospitals or ICFs for the purpose of receiving specialized dental care.
The lack of transportation services has been a barrier to accessing and participating in community activities for many consumers. Transporting an individual is an un-billable activity under supported employment but is a billable activity under supported home living. If providers cannot afford to transport multiple participants to different locations, then often all the consumers are forced to go to the same location (e.g. day habilitation workshop) and do not receive truly individualized services. It is unclear as to why transportation is an allowable activity for one service and not the other. The HCS billing guidelines should be revised to allow providers to transport an individual if not doing so would create a barrier to full community integration. Also, the billing guidelines should enable participants to receive assistance from their HCS provider to access and utilize public transportation services, which will increase community integration.