Mary K Hall

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-----Original Message-----
From: Mark Watson <mwatson@opra.org>
Sent: Wed, Jul 29, 2015 4:19 pm
Subject: CMS letter to Director McCarthy July 23, 2015 - Ohio Statewide Transition Plan

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OPRA ROUNDUP ALERT

On July 23, 2015, the Department Of Health and Human Services, Centers for Medicare & Medicaid Services (CMS) issued a letter to Director McCarthy, Ohio Department of Medicaid. In this attached letter, CMS acknowledged they have reviewed Ohio’s Statewide Transition Plan (STP). CMS appreciated the substantial progress Ohio has made toward ensuring compliance with the new requirements and the overall detail of the STP. CMS indicated a few areas where additional data is needed regarding assessment process and outcomes, remedial action processes, and the monitoring process. These are the areas of focus.

Assessments:

· Site-specific assessments process – CMS would like additional information regarding the methods used to validate the results of the provider self-assessment surveys.

· Outcomes of site-specific assessments – Additional information is needed with regard to the outcomes of the completed assessments, including the provider self-assessments and participant experience assessments.

· Ongoing Monitoring – For all setting types, CMS would also like more detail regarding ongoing monitoring and provider compliance reviews.

Remedial Actions:

· Systemic remediation – The Grids “describe the impact of the federal regulations on applicable State statues, administrative rules, administrative and operational policies” and identify the regulations, medications required, action steps, and timeline.

· Setting remediation – Providers will develop remediation strategies to come into compliance. However, at this point there is little details as to what these remediation strategies will entail.

Relocation

More details are being requested regarding the relocation processes to include reasonable notice, assuring critical services are in place and timeframes for planning these activities to ensure the effective transition.

Heighten Scrutiny

The state should clearly lay out its process for identifying settings that are presumed to have institutional characteristics. If the state determines it will submit information on these settings, the presumption will stand and the state must describe the process for informing and transitioning the individuals involved to either compliant settings or to non-Medicaid funding streams. CMS is concerned that the state’s assessment plan will not be completed until sometime in 2017. The state will need to revise and resubmit its STP being reposted for public.

As we review this letter with other stakeholders, if you have any additional questions or comments please email mdavis@opra.org

Thank you and if you need anything do not hesitate to contact me.

Mark A. Watson, MSW

Policy & Operations Coordinator

Ohio Provider Resource Association

1152 Goodale Blvd

Columbus OH 43212

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