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HCA Comments on Independent Assessor Proposed Rule 

ast week, HCA submitted comments on the recently revised proposed rule by the state Department of Health (DOH) that establishes an Independent Assessor and other changes to Medicaid-covered personal care services (PCS) and consumer directed personal assistance services (CDPAS).

In our comments, we urge the IA implementation to be tabled and withdrawn, raising concerns with the stricter eligibility standards for PCS and CDPAS services. We also suggest ways to streamline the new Independent Medical Review of 12-plus hour cases and support certain changes to the Consumer Directed Personal Assistance Program. 

However, the rule also contains a proposal we strongly support: allowing nurse practitioners and physician assistants to sign orders for home care. While we expressed approval for the proposal — having long sought broader allowances for practitioner orders — our comments took issue with the requirement that the medical professional who conducts the examination must not have “established a provider-patient relationship with the individual prior to the clinical encounter from which the practitioner order is completed.”

At last week’s Managed Care Policy and Planning meeting (see the March 15 Situation Report), DOH indicated that it hopes to finalize these regulations by April 1 and implement the changes sometime in May or June depending on obtaining certain approvals by the U.S. Centers for Medicare and Medicaid Services and fulfilling other requirements. 

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HCA Comments on Independent Assessor Proposed Rule 

Situation Report | March 22, 2021

Last week, HCA submitted comments on the recently revised proposed rule by the state Department of Health (DOH) that establishes an Independent Assessor and other changes to Medicaid-covered personal care services (PCS) and consumer directed personal assistance services (CDPAS).

In our comments, we urge the IA implementation to be tabled and withdrawn, raising concerns with the stricter eligibility standards for PCS and CDPAS services. We also suggest ways to streamline the new Independent Medical Review of 12-plus hour cases and support certain changes to the Consumer Directed Personal Assistance Program. 

However, the rule also contains a proposal we strongly support: allowing nurse practitioners and physician assistants to sign orders for home care. While we expressed approval for the proposal — having long sought broader allowances for practitioner orders — our comments took issue with the requirement that the medical professional who conducts the examination must not have “established a provider-patient relationship with the individual prior to the clinical encounter from which the practitioner order is completed.”

At last week’s Managed Care Policy and Planning meeting (see the March 15 Situation Report), DOH indicated that it hopes to finalize these regulations by April 1 and implement the changes sometime in May or June depending on obtaining certain approvals by the U.S. Centers for Medicare and Medicaid Services and fulfilling other requirements.