The Choice Voucher System in the Children’s Waiver Program
Audrey Craft, Specialist, Federal Compliance, MDHHS
Rebecca Craft, Case Manager, Macomb County CMH Services
Terri Nekoogar, Program Supervisor, Specialized Children and Family Services, Macomb County CMH Services
Rebecca Wilson, parent, Macomb County
What We Plan to Cover Today
Services that can and can’t be vouchered
Involuntary termination
Advantages of Vouchering
How the System Works
PIHP/CMHSP, FI and Parent responsibilities
Implementation issues
The experience of a family
The Fundamentals
CMHSPs must offer Choice Voucher option to families of children on the CWP and HSW.
The CMHSP can not require that families use the Choice Voucher option.
The CMHSPs are responsible for providing information about participant directed opportunities.
The CMHSPs are responsible to ensure contracts are established and contractual obligations are met.
The Fundamentals
CWP consumers can direct a single service or all of their services for which consumer direction is an option.
Hourly care staff are hired under “employer authority and professional staff are hired under “budget authority”.
Resources to support the chosen consumer-directed services are transferred to a fiscal intermediary which administers the funds and makes payment upon
authorization of the consumer’s representative.
The Fundamentals
The fiscal intermediary must meet requirements as identified in the “MDHHS/CMHSP Managed Mental Health Supports and Services Contract – Attachment C3.4.4”
Monthly all-inclusive code – T2025
Services That Can Be Vouchered
Home care training, non-family
Home care training, family
Community Living Supports
Respite
Specialty Services (Music, Art, Rec and Massage Therapy)
Mental Health State Plan services except Targeted Case Management
Services That Can’t Be Vouchered
Two waiver services are considered provider managed services only:
1. Environmental accessibility adaptations/specialized medical equipment/supplies.
2. Financial management services.
Private Duty Nursing May Not Be Vouchered
Involuntary Termination of Choice Voucher System
A CMHSP may terminate a Choice Voucher Arrangements when the health and welfare of the consumer is in jeopardy due to the failure of the responsible parent to direct services and supports or when the responsible parent consistently fails to comply with contractual requirements.
Advantages
Control over resources allocated to the child’s IPOS.
Pay for staff may be higher than those staff hired through an agency.
Ability to choose and manage providers
How the System Works
1. Family & CMHSP, using the PCP process, develop child’s IPOS identifying needed services and supports
2. Parent implements arrangements through the Choice Voucher System (for one or more service)
3. A Choice Voucher Agreement between the CMHSP and Parent is signed.
4. The funds in the CWP budget are lodged with a fiscal intermediary.
How the Choice Voucher System Works, (cont.)
5. Parents directly employ qualified workers or contract directly with providers to provide services identified in the child’s IPOS and CWP budget
6. Parent enters into an Agreement with each person or agency hired
7. Required criminal background checks and training of staff completed prior to the beginning of work
What is a Fiscal Intermediary?
A Fiscal Intermediary (FI) is an independent legal entity that acts as a fiscal agent of the CMHSP for the purpose of assuring financial accountability for the funds comprising a child’s CWP budget.
FI Functions
The FI has three basic areas of performance: – to ensure compliance with requirements of manage-
ment of public funds.
– to function as the employer agent and ensure compliance with the legal requirements of being an employer.
– to otherwise facilitate a smooth relationship between the parties and meet the needs of the CMHSP and families.
FI Administrative Functions
Safeguard, manage and account for funds disbursed from the CMHSP
Disburse funds to vendors and providers after obtaining
– Purchase of service and employment agreements
– verification that the Medicaid Provider Agreement has been signed by each provider
– Timesheets, datasheets and/or invoices have been approved by responsible parent
FI Employer Agent Functions Issue payroll payments to workers hired
directly by the family
Withhold income, Social Security, and Medicare taxes from paychecks and make payments to the appropriate authorities for taxes withheld
Make payments for unemployment taxes and worker’s compensation insurance to the appropriate authorities, when necessary
The Role of the Parent Provide all necessary information to the Fiscal
Intermediary to ensure that all required documentation and written agreements are in place
Authorize disbursement of funds for services and supports (timesheets, datasheets and invoices)
Provide documentation that providers meet CMHSP requirements (criminal background checks, trainings)
The Role of the Parent
If FI serves as their Employer Agent, provide FI with the information and documentation necessary to perform Employer Agent duties
Communicate with the FI and CMHSP and seek assistance from these entities as needed
Provide feedback to FI to enable it to improve its service delivery
The Role of the PIHP/CMHSP
Provide Case Manager services to the family
Develop IPOS and allocate funds for services that will be implemented through CVS
Contract with a FI to handle disbursements of funds and other support functions
Monitor the system to ensure successful use, implementation, and compliance with federal regulations
Ensure provider qualifications
How Parties Work Together Agreements
Choice Voucher Agreement
Agreement between CMHSP and Parent
Describes the Choice Voucher Arrangement
Describes the responsibilities of the parties
Describes how services and funds are used and any limitations on their use
Describes the conditions for voluntary or involuntary termination of the CV Arrangement
How Parties Work Together
Agreements
Fiscal Intermediary Agreement
Between the CMHSP and the Fiscal Intermediary (FI)
Sets forth the scope of FI Services
The Responsible Parent is not a party to this agreement
The responsible parent may have a choice of FI if the CMHSP contracts with more than one
How Parties Work Together
Agreements with Providers
Between the Responsible Parent and Providers
Written Agreements Required
Employment Agreement With a directly employed worker
Purchases of Services Agreement With a directly contracted professional provider or agency
Medicaid Provider Agreement Must be signed by all providers
Implementation Issues
Informing families of all implementation issues along with discussing the pros and cons of using the Choice Voucher System is key to a good outcome
Implementation Issues
Staff Training
Parental responsibilities
Emergency staff back up
Implementation Issues
Details, details, details: splitting hours between voucher and agency, non- compete clauses, length of time it will take to get staff trained
Ethics:
- Transitioning from agency to voucher
Keys To Success
Relationship Based Option
- Acceptance / Gentleness / Encouragement
- Family Focused
Establishing Parameters
- Roles / Expectations
Keys To Success
IPOS Training
- Development / Independence / Safety
- CLS & Respite
- Documentation
The Family Story Benefits of the Choice Voucher System
Recruiting and maintaining staff
Communication with staff and valuing staff
Organization is the key!
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References
(1)Mental Health and Substance Abuse Administration, Michigan Department of Community Health, Choice Voucher System, Self-Determination Technical Advisory, Version 3.0, December 2015 at http://www.michigan.gov/documents/mdhhs/CHOICE_VOUCHER_SYSTEM_for_Children_12_2015_515803_7.pdf.
(2) Fiscal Intermediary Technical Requirement. Found in the PIHP contract at: http://www.michigan.gov/documents/mdch/FY09-10MAContractwithallattachments_312218_7.pdf.
Contact information
Audrey Craft, 517.241.5757 [email protected]
Kelli Dodson, 517.335.6078 - [email protected]
QUESTIONS????
