3 comments
Thank you for the opportunity to provide feedback on the proposed updates to Chapter 6 of the DD Waiver Manual. We appreciate the continued efforts to improve processes and ensure quality services for the individuals we serve. We would like to highlight a few areas where additional clarity and adjustments would greatly support both providers and the individual and families we serve.
Clarification on the Term “Provider” Throughout the manual, the term “Provider” is used in multiple ways. In some places, it refers to attendant care providers, while in others, it refers to contracted service providers. These are very different roles with different responsibilities. To avoid confusion, we recommend using clearer language that better describes these types of providers. This would help ensure everyone shares understanding when it comes to expectations, documentation, and compliance issues.
Corrections, pended plans, and signatures: We have concerns about the expectation to do a whole new plan of care with new signatures if changes or corrections are needed after the planning has taken place. Daily, a large number of Plans of Care are pended due to required updates and corrections. For example, the number of approved hours may come back different from what was initially requested, or the support coordinator may add or revise outcomes or risks after the plan is written and signed. Another example would be when the provider’s schedule conflicts with another provider’s schedule, since providers are unable to see other providers’ schedules in WaMS. In these cases, are providers expected to do a second visit that they cannot be paid for in order to redo their plans of care? If so, this will further delay approval for services. The current system is already very time-consuming. While we understand the importance of complete and correct information, when a request is pended, the provider has 5 days to respond. Then the Support Coordinator has 10 days to make a decision. They may pend a second time, which gives the provider another 5 days and then the Support Coordinator another 10 days. If a provider is required now to go back out to the home to re-write the plan of care with the corrections and get all new signatures, it will only add to the timeline to get approval for those services.
If the provider uses electronic signature platforms, it’s important to consider the financial and practical challenges this creates. For example, when we explored using DocuSign, we found it would cost over $25,000. This is a significant expense, especially when providers are already struggling with limited reimbursement rates and administrative cost.
Timelines for ISP Meetings and Reauthorizations: We strongly recommend clearer expectations around the timing of ISP meetings and the delivery of finalized documents. Specifically, we suggest including a requirement that Support Coordinators hold their annual ISP meetings at least 60 days before the reauthorization date. In addition, providers should receive the final ISP document at least 60 days before the authorization ends. This would give everyone involved enough time to write their portions of the plan, make needed corrections, and submit service authorizations in a timely manner, work through pends, and get approval prior to the end of the current plan year. Without this longer timeline, delays are common and lead to lapses for the families we serve. The Support Coordinator Handbook provides guidance that suggests that the ISP meetings should “ideally be held at least six weeks prior to the due date of the PC ISP.” But, it is not required, nor does it require the Support Coordinator to send the providers the ISP in any kind of timeline. Also, none of this is mentioned anywhere in the provider manual being reviewed for this public comment.
In Section:
Please edit the language for “The document cannot be altered once signed” to “The document cannot be altered once approved.”
If not, can you please clarify if a log of signatures, dates and times will suffice to show edits that are made prior to locking/approving the note?
Thank you!
Comment on Proposed Updates: Electronic Signatures
We appreciate DMAS’s continued efforts to ensure accountability and integrity in documentation for DD services. The updated focus on the structure and standards of electronic signatures is important and appreciated.
However, we respectfully suggest that this focus appears somewhat misplaced when viewed in the broader context of current documentation practices. Providers are still permitted to utilize handwritten notes or Word documents. These methods are far more susceptible to backdating, alteration, or other compliance vulnerabilities. This raises the question of whether the current emphasis on tightening requirements only for electronic health records (EHRs) is the most efficient or equitable approach.
Since the 2014-15 shift encouraging providers to move toward EHR systems, it seems more aligned with long-term Medicaid goals to prioritize universal adoption of secure, certified electronic health record systems. EHRs inherently offer time-stamped, tamper-evident records.
Focusing regulatory energy on strengthening compliance within already compliant EHR systems, while continuing to allow easily alterable handwritten or Word-processed notes, may inadvertently discourage EHR adoption despite their greater transparency and security.
A more balanced approach may be to:
Thank you for the opportunity to provide input.