This article was contributed by Jennifer Mahan, Director of Advocacy and Public Policy, and Kerri Erb, Chief Program Officer.
Federal Guidance on Autism Services under Medicaid
“Will Medicaid cover autism services including Applied Behavioral Analysis?” Many families have asked this question since the Centers for Medicare & Medicaid Services (CMS) issued new guidance earlier this year telling state Medicaid programs that they must cover services for autism under federal requirements for children and youth under the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit. The short answer is that we do not yet know what will happen. This new Medicaid guidance is in response to several lawsuits around the country and confusion over who and what is covered under EPSDT. The guidance from CMS stops short of requiring Medicaid to cover specific types of services or approaches to autism treatment such as Applied Behavioral Analysis (ABA). The memo says states must address the treatment of children with autism in Medicaid, but mentions ABA as only one of an array of possible services a state might use. No specific timeline was given for states to review current autism services and implement any needed changes.
ASNC staff have met with NC Department of Health and Human Services officials and have urged them to use more autism-specific services across Medicaid as well as increase knowledge about the use of EPSDT. NC DHHS has been reviewing the guidance from CMS and says that it is moving forward with efforts early next year to begin working on the issue.
Input Sought on Services System and Innovations Waiver
During the past few months, NC DHHS conducted a series of community listening sessions across the state to seek information about what’s working and what’s needed to advance the system for those with intellectual and developmental disabilities (IDD), including autism. Dave Richards, the Deputy Secretary of Behavioral Health and Developmental Disabilities Services, and other NC DHHS staff worked with local managed-care organizations (LME/MCOs) and Consumer and Family Advisory Councils (CFACs) to hear from people in their own communities across the state. If you were not able to attend those meetings, they are still accepting comments via email at IDDListeningSessions@DHHS.NC.Gov.
Some of the areas of concern that emerged from those meetings were:
- waitlists for services
- the process of obtaining and maintaining services
- appeals, communication and coordination across systems
- availability of qualified workforce
- specialty services (such as those provided for people with Autism Spectrum Disorder)
- lack of care coordination/case management
Taking this information, the state has said it is working to make gains in the IDD system that are meaningful, effective, flexible, person-centered, and sustainable for the people of NC.
Many people in NC receive services through the Innovations (formerly known as CAP) waiver. At this time, the state has a stakeholder group reviewing the waiver itself, service definitions, and other elements as the waiver moves to a renewal in January 2016. The group has been discussing new service definitions; changes to current service definitions; financial, quality and utilization issues; resource allocation; care coordination; communication; and education. For more information and a look at the presentations, check NC MHDDSAS: CAP-MR/DD.
Home and Community-Based Services Workgroups
North Carolina is working on a plan to comply with the new Home and Community-Based Services standards issued by the Centers for Medicare & Medicaid Services (CMS). The new standards require states to change policies for programs such as the Innovations waiver to make sure that people using those services have person-centered plans, have more choice and control over their living situations (such as access to visitors, privacy, communication tools, etc.), and are in settings that are otherwise “home-like,” while still ensuring the health welfare and safety of the individual. NC must assess its current program policies and submit a plan by March of next year on how it will make any needed changes to meet the new requirements. Note that settings such as nursing facilities and intermediate care facilities for the mentally retarded (ICFs/MRs) are not addressed by these new regulations. You can review the planning toolkit here, including a link to the Federal Register with the announcements about regulatory changes. ASNC and many other stakeholders are also involved in the workgroup that is processing how this will roll out in NC.
ASNC has been represented at community meetings by staff members, families from local ASNC chapters, and in the NC DHHS stakeholder groups mentioned above, by ASNC Chief Program Officer Kerri Erb. ASNC values your input on our efforts to create better services for people on the autism spectrum. You can contact Kerri at kerb@autismsociety-nc.org to provide feedback on the Innovations wavier of HCBS regulations, and she will relay your concerns. Or, you may contact DHHS directly at IDDListeningSessions@dhhs.nc.gov (with “waiver” in the subject line) to provide feedback on the waiver and changes to best meet the needs of individuals with ASD in a flexible and sustainable manner. In addition to the state, each LME/MCO conducts gaps and needs assessments in their communities each year. Stay in touch with your LME/MCO to advise on your perceptions of gaps and needs in your area.
If you have questions about public policy issues, please contact Jennifer Mahan, Director of Advocacy and Public Policy, at 919-865-5068 or jmahan@autismsociety-nc.org.
Tags: ASNC, Asperger Syndrome, Asperger's Syndrome, autism, autism advocacy, autism north carolina, autism society north carolina, autism society of NC, Autism Society of North Carolina, Autism spectrum, autism support, Developmental disability, managed care, medicaid, NC CAP MR/DD waiver changes, North Carolina, public policy