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Public Policy Update: “i” Services in 1115 Waiver May Help Those Waiting

North Carolina is in the process of seeking approval by the Centers for Medicaid and Medicare Services to add “i” home and community-based services (HCBS) under our state’s new 1115 Medicaid plan. These “i” HCBS services would offer additional supports to people with disabilities who are eligible for Medicaid. NC DHHS has requested that most “b3” services, as well as some new services, would be offered to all Medicaid eligible individuals who meet the criteria set for each service. These “i” waiver services would be defined state Medicaid benefits, so eligibility criteria and the type of services would be consistent across the state in all Tailored Plans (aka the LME/MCOs).

Unlike other waiver services, these “i” services are an entitlement for people who are eligible, meaning there is no cap on enrollment and people can’t be turned away for lack of slots or lack of local funds. There would be no “waiting list” for “i” services like there are for Innovations. The “i” services are however targeted at meeting specific needs and may have limits on the number of hours or have other limiting criteria. They are not as comprehensive as a full Innovations waiver slot.

The key to understanding who these new services might help is understanding Medicaid eligibility: “i” is an entitlement benefit for individuals who have Medicaid coverage by virtue of their income level or SSI eligibility. This “i” benefit does not waive​ Medicaid income requirements the way people with higher incomes are eligible for the Innovations waiver.

So, it will serve more people who are waiting for services on the Registry of Unmet Needs (RUN), but not everyone on the RUN who is waiting is financially Medicaid eligible outside of getting Innovations waiver services. It’s likely many adults waiting would qualify to get support, due to low incomes and SSI eligibility, as well as lower income Medicaid eligible children, but those with higher incomes who lack coverage and/or those who need income levels waived to qualify for Innovations would not be eligible for “i” services. Also note, “i” benefits, like other enhanced benefits in Medicaid, are not offered as part of a Medicaid Expansion/Coverage Gap program.

The proposed “i” services for people with I/DD include:

  • Community Transition
  • Respite
  • Community Living and Support
  • Supported Employment
  • Plus a few other services to support those with a primary diagnosis of mental illness or substance use disorders.

Once the plan is approved, and with sufficient funding from the enhanced federal Medicaid match and additional federal funds, most Medicaid b3 services would cross-walk over to the “i” benefit for Medicaid eligible who meet the criteria outlined for each service (diagnosis, medical necessity, etc.) This is a significant move forward to reducing the waiting list and better supporting people with IDD in their communities, but it WILL NOT cover everyone who needs services. NC must continue funding new Innovations slots, as well as open up Medicaid eligibility for children with disabilities. One option is to expand eligibility to include “family of one” where only the income of the child with a disability is looked at for purposes of determining Medicaid eligibility, outside of any determination of disability by Social Security. NC is one of only a few states without this option that could ensure that children with I/DD get access to earlier interventions and disability specific services.

As part of the approval process, there will be additional opportunity for public input in the months ahead. ASNC has been advocating for an entitlement program like these “i” services for over a decade and will continue to monitor the development and provide additional information about “i” services as well as any public comment opportunities.

 

Further Resources

CMS basic info on Medicaid waivers – https://www.cms.gov/Outreach-and-Education/American-Indian-Alaska-Native/AIAN/LTSS-TA-Center/info/state-medicaid-policies

 

NC DHHS Tailored Plan Updates- https://medicaid.ncdhhs.gov/providers/programs-and-services/behavioral-health-idd/behavioral-health-idd-tailored-plan

 

Comments to DHHS on Transformation, waivers, “i” services – Medicaid.Transformation@dhhs.nc.gov

 

Please contact Jennifer Mahan, ASNC Director of Public Policy, jmahan@autismsociety-nc.org for questions about public policy and advocacy.

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