Quality Assurance Plan for Home and Community-Based Services

Transcription

1 Quality Assurance Plan for Home and Community-Based Services Summary Report of Plans Forwarded by Counties and Tribes For 2008 Department of Human Services Continuing Care Administration July 2008 Final Report Prepared by Sarah Myott & Jolene Kohn Aging and Adult Services

2 Table of Contents Executive Summary... 1 Introduction... 2 Summary of Major Findings... 4 I. Participant Access... 4 II. Participant-Centered Service Planning and Delivery... 5 III. Provider Capacity and Capabilities... 5 IV. Participant Safeguards... 7 V. Participant Rights and Responsibilities... 8 VI. Participant Outcomes and Satisfaction... 9 VII. System Performance... 9 Conclusion...10 Appendix A: CMS Quality Framework...12 Appendix B: Survey Results Tables...13 Page 2 of 16

3 Executive Summary Minnesota s Home and Community-Based Services (HCBS) programs are administered by the state and managed by lead agencies, including counties, and tribes and managed care organizations (MCOs) under contract with the Department of Human Services (DHS). Under this arrangement, lead agencies are responsible to carry out a variety of delegated quality assurances related to desired participant and HCBS system outcomes. DHS requires all lead agencies to submit HCBS QA Plans as a method to ensure that delegated quality assurance activities are carried out. This report summarizes the Home and Community-Based Services Quality Assurance Plans (HCBS QA Plans) completed for calendar year 2008 and forwarded to DHS by the eighty-four county agencies and one tribal agency that administer HCBS programs. A separate report has been developed on the responses of the nine MCOs. Overall, lead agencies reported that required assurances are in place for these programs. The most common areas where some lead agencies reported non-compliance include: meeting timelines for LTCCs, ensuring providers have individual back-up plans and agency-level emergency contingency plans, and always providing consumers with service agreements or prior authorizations that includes information about appealing service decisions. Lead agencies reported a wide variety of strategies and level of formalization around their program administration practices, particularly in the area of provider capacity and competencies. Case managers are reported as having a central role in meeting many program assurances, particularly around provider monitoring and consumer satisfaction. In response to the findings, DHS recommends that lead agencies improve or continue to (1) ensure that their HCBS programs meet all standards and assurances, (2) work internally to streamline waiver administration practices, (3) coordinate and target quality assurance resources, and (4) capture information gathered by case managers/care coordinators on a more systematic basis. DHS will provide support to lead agencies in these efforts through working with lead agencies and other stakeholders in the development of a streamlined and comprehensive process for quality management across HCBS waiver programs. Page 1 of 16

4 Introduction The Home and Community-Based Services Quality Assurance Plan (HCBS QA Plan) is submitted on a scheduled basis by each county, tribe and managed care organization (MCO), referred to as a lead agency, that administers the five Home and Community-Based Services (HCBS) waiver programs 1, the Long Term Care Consultation (LTCC) and Alternative Care (AC) programs. The HCBS QA Plan survey for calendar year 2008 was conducted in the fall of 2007 with lead agencies that administer one or more of these programs. This report provides a summary of the HCBS QA Plans submitted by the eighty-four county agencies and one tribal agency that administer the HCBS programs. A separate report has been developed on the responses of the nine MCOs. This report, along with the 2008 County/Tribe HCBS QA Plan survey instrument, was developed by the Aging and Adult Services Division, with input from staff from DHS s Disability Services Division. Purpose of the HCBS QA Plan The HCBS QA Plan survey provides assurances to the Department of Human Services ( the Department or DHS ) that the lead agency: Implements HCBS programs according to statute and federal requirements; Carries out delegated quality assurance, monitoring, and assessment activities necessary to achieve desired program outcomes; and Has policies and practices in place to ensure the health and safety and participation and choice-making of consumers participating in HCBS programs. These assurances, in turn, allow DHS to provide the Center for Medicare & Medicaid Services (CMS) with assurances that DHS is administering the HCBS programs according to state and federal requirements. All states participating in 1915(c) (Medicaid) waiver programs must provide assurances concerning the quality of care and services provided through these programs as a condition of federal approval of the state waiver plan. CMS organizes these assurances into a Quality Framework that focuses attention on participant-centered desired outcomes along seven domains. See Appendix A for information on the seven Quality Framework focus areas. HCBS QA Plan Survey Scope The HCBS QA Plan survey is organized by CMS s Quality Framework. The survey includes both questions asking lead agencies to verify administrative requirements and also open-ended questions which elicit a narrative response. Appendix B of this report includes tables which summarize the results of the closed-ended administrative verification items. In the past, the HCBS QA Plan survey has focused on the collection of administrative verification from lead agencies that assurances are in place to address elements of program administration and desired participant outcomes. Beginning with the 2008 HCBS QA Plan, DHS adapted the survey format to include additional focus on a particular Quality Framework area of interest to DHS. The 2008 survey included additional focus on Provider Capacity and Capability. It is expected that future HCBS QA Plans will continue to require verification of overall quality 1 This includes the Elderly Waiver (EW), Community Alternatives for Disabled Individuals (CADI), Developmental Disabilities (DD) Waiver, Traumatic Brain Injury- Neurobehavioral Hospital (TBI- NB), Traumatic Brain Injury- Nursing Facility (TBI-NF), and Community Alternative Care (CAC) programs. Page 2 of 16

5 assurances and will also include special focus on particular aspects of HCBS program administration HCBS QA Plan Focus: Provider Contract Inventory In order to have more detailed information available at the state level regarding HCBS provider capacity and consumer choice statewide, the 2008 Plan format included a separate work sheet to be completed by each lead agency. The lead agency was asked to provide an inventory of all their HCBS providers under contract to deliver HCBS services. This inventory was not submitted as part of the web-based survey but was required as part of the documentation of assurances related to provider capacity and consumer choice captured in the HCBS QA Plan. Each lead agency completed a provider inventory for each HCBS program the lead agency is under contract to manage. Although the analysis of the provider inventory information is not part of this report, it will be summarized and made available in the summer of Page 3 of 16

6 Summary of Major Findings This report summarizes the major themes and findings across the responses of the county and tribal lead agencies. Like the Home and Community-Based Services Quality Assurance Plan (HCBS QA Plan) itself, the findings are organized around the seven domains reflected in the federal HCBS Quality Framework (Appendix A). Tables summarizing the quantities of lead agency responses to yes/no verification questions are included in Appendix B of this report. Some Comments about the Findings These findings are based solely on the information provided by lead agencies in their HCBS QA Plan responses. Unless otherwise noted, the HCBS QA Plan survey asks verification questions in a yes/no format and does not require further explanation, although space is provided to do so. Although the amount of information provided by lead agencies has increased significantly since previous HCBS QA Plans, there continues to be a lot of variance in the level of detail provided by lead agencies. I. Participant Access Lead agencies were asked to report on a number of assurances related to the Long Term Care Consultation and Access to HCBS programs. Overall, lead agencies reported high compliance in performing the required activities in these two areas. Long Term Care Consultation Although lead agencies reported high compliance in performing required LTCC activities, eight out of the eighty-five (9%) agencies reported that they are not always able to complete inperson assessments within ten working days of referral. In order to meet this requirement, many lead agencies reported that they have (or plan to) reassessed their intake and screening processes to identify improvements. Some agencies also reported efforts to shift staff responsibilities and/or addition of staff positions in order to better meet LTCC timelines. Some agencies noted that barriers to timeliness of LTCC include staff shortages and delays in discharge planning and consumer schedules. Access to HCBS Programs In addition to the requirements under the LTCC program itself, the LTCC assessment process, DD screening, level of care determination, additional assessments and support planning helped establish service eligibility for HCBS programs. All agencies reported compliance across all assurances in this area. In addition, many lead agencies commented in their plans about the multitude of variables which impact access to services. These included public awareness of programs, coordination with referral sources, provider availability, and lead agency staffing. Waiting Lists for Services Sixty-eight agencies or 80% of lead agencies indicated that they have persons who have been identified as eligible and waiting for HCBS in their service areas for at least one HCBS program. Waiting lists are most common in the DD program where sixty-three agencies reported having a waiting list. In addition sixteen agencies reported a waiting list for CADI, four for TBI-NB, three for TBI-NF and two for CAC. Page 4 of 16

7 II. Participant-Centered Service Planning and Delivery Lead agencies must be able to demonstrate for their HCBS programs that (1) the assessment of individual strengths and needs is linked to care and community support planning, and (2) services planned are individualized, appropriate and preferred. In their HCBS QA Plans, lead agencies consistently indicated that they are developing and monitoring community support plans according to requirements. Consumer Choice of Services and Providers Agencies were asked to describe the materials provided to consumers to help ensure their choice of services and providers and to describe how these materials are provided. Most lead agencies rely upon DHS brochures that have been developed to provide program information for consumers. A few lead agencies reported they review these types of materials with consumers on at least an annual basis, though it is anticipated this is common in other lead agencies. Many lead agencies reported they provide consumers with lists of providers at assessment, while nine counties specifically mentioned using locally-developed information packets as well. There were five counties which reported that they make information on service and provider options available online. III. Provider Capacity and Capabilities States must be able to provide evidence to CMS that there are sufficient HCBS providers and they possess and demonstrate the capability to effectively serve participants. Lead agencies carry out delegated activities that support achievement of the desired outcomes. DHS adapted the 2008 HCBS QA Plan to include a special focus on the assurances related to provider performance and capacity. There were no administrative verification items in this section; all questions were open-ended and responses for this section were provided in a narrative format (and thus there is no summary table in Appendix B for this focus area). Provider Recruitment Based on their HCBS QA Plan responses, there appears to be a lot of variance among lead agencies in provider recruitment strategies. Some lead agencies have an annual provider recruitment process while others recruit on an as-needed basis. The use of requests for proposals (RFPs) and newspaper ads were the most commonly reported recruitment strategies. A number of agencies also reported the use of radio, county/resource fairs, word-of-mouth, annual provider meetings, consumer/family referral and mailing lists. Many lead agencies gave examples of new services they have recently developed or expanded as a result of recruitment. Some lead agencies referred to the use of the DHS Gaps Analysis or other formal needs assessment to identify service development needs. Some lead agencies reported that they do not have a recruitment process and/or assess for specialized needs because they: Don t have a need for new providers or are satisfied with current capacity Have enough providers that seek them out Have no untapped provider capacity in their area Are more focused on retaining current providers Agencies commonly work with their existing provider network to expand or enhance services as their primary means of assuring provider capacity. This can be a strategy in conjunction with Page 5 of 16

8 finding new providers or in some lead agencies this is the only approach used. Counties often also work with other counties in their region and draw on regional resources to meet local need. Providers often also seek counties out and lead agencies use these to build on their county network. Provider Cultural Competency Lead agencies were asked to describe the strategies they use to recruit culturally competent providers. Most counties reported having little or no need to target recruitment of culturally competent providers because they do not have the cultural demographics to warrant this effort. However, a number of counties are addressing this need and many also anticipate an increased need for culturally competent providers as their community demographics change. Many counties reported that they do face barriers in serving consumers with limited English proficiency due to rural location and limited local resources. The counties that did talk about their strategies to recruit culturally competent providers discussed: Use of language interpreters Encouraging providers to hire bilingual staff Recruitment of community members to become provider staff Working with tribes to increase culturally competent services for American Indian populations Requiring or assisting providers with training on cultural competency Some have access to culturally-specific provider agencies Provider Qualifications Lead agencies were asked to describe the policies and practices they use to ensure that providers meet standards and qualifications. Most commonly agencies referred to the contracting process to ensure qualifications are met. A number of agencies reported using the DHS model contract template as a means for ensuring necessary provider qualification components are included. In addition, many counties require documentation of licensing, insurance and annual resubmission. Other documentation also requested of providers includes: Staff position descriptions and proof that educational requirements are met Ongoing submission of criminal background check, training info Staff training plan Staff and organizational charts Copies of provider surveys by DHS Licensing and the Department of Health Required attendance at provider in-service training held by lead agency Some lead agencies mentioned additional requirements developed by the lead agency, including allowing only licensed providers to provide unlicensed services; limiting by geographic location; requiring that providers are open for a certain amount of time; or be enrolled in Minnesota Health Care Programs in order to become qualified. Lead agencies are reminded that federal regulations prohibit the local implementation of provider standards higher than those applicable statewide that limit participant access to otherwise qualified providers. DHS is currently working with CMS on this issue as part of the waiver renewal process and communications. Page 6 of 16

9 Provider Performance and Monitoring Provider monitoring processes vary across the state. In general formalized processes are not used in many counties, though more lead agencies are reporting the use of formal provider monitoring than in previous HCBS QA Plans. Most counties monitor their providers in some fashion and at a minimum have strategies to prevent and reported any major problems on an as needed basis. A number of counties have plans underway to make their provider monitoring process more systematic. Lead agency HCBS QA Plan responses indicate that case managers play a critical role in, and often are primarily responsible for, provider monitoring. Case managers have a role with provider monitoring through their direct contact with consumers, requesting and reviewing of provider reports and ongoing monitoring of care plan implementation. The required minimum case manager visits are viewed as an essential tool for monitoring provider performance at the individual consumer level. A number of agencies even increased the frequency of visits as an added effort to monitor providers and care plan implementation. Despite the critical role case managers hold and the amount of information they obtain through their reviews, this review is often handled on an individual consumer basis and few lead agencies self-reported any efforts to systematically capture this feedback to assess and improve broader provider monitoring or improvement systems. Many counties mentioned a reliance on the licensing and contracting processes for provider monitoring and review. However, lead agencies did not clearly describe how their contract managers use contracts to influence or monitor provider performance. Agencies also commonly use other strategies to monitor providers including consumer surveys, regional or host county collaboration and provider record review. Counties more clearly articulated their practices around responding to provider performance issues as they are raised. Depending on the issue, counties most often start by meeting with the provider to work toward improving or solving performance concerns. When issues cannot be resolved through this process, other steps are taken, including removing the consumer from the provider s services and/or terminating contracts. Lead agencies provided much less detail about how they monitor unlicensed providers. When monitoring of unlicensed providers was discussed, lead agencies mentioned contracting less often and focus more on the role of the case manager and consumer and family feedback. The strategies mentioned included: More documentation required about service delivery Provider checklist outlining standards, expectations, training requirements Quarterly provider visits and/or reports Provider in-services Background checks and local vulnerable adult reports IV. Participant Safeguards The HCBS QA Plans also address assurances intended to make sure participants are safe and secure in their homes and communities, taking into account their informed and expressed choices. Agencies were asked to assess the adequacy of their quality assurance system for assuring the health and safety of waiver participants. Page 7 of 16

10 Backup and Contingency Plans Overall, agencies reported compliance across the health and safety assurances. However, some counties reported that they do not ensure providers have back up plans (five counties) and/or a contingency plan for a community-wide emergency (six counties). Most of these counties reported plans to meet these requirements moving forward. It is important for lead agencies to note the difference between back up plans and contingency plans. A back up plan is established related to individual consumers for when usual support providers are not available and the lack of immediate care would pose a serious threat to health and welfare. In contrast, a contingency plan is established at the provider or agency level and establishes a response plan in the event of a community-wide emergency. The presence of health and safety policies and practices can vary by program within a lead agency. When noted, counties most commonly indicated that referenced health and safety policies were present for the DD waiver but not for other waivers. Some counties noted that they plan to expand their practices/policies currently in place for one waiver to the other waivers. Monitoring of consumers on an individual basis was most often referenced as the primary means of addressing participant safeguards. The quality assurance mechanisms already in place through provider licensing and lead agency contracting to address participant safeguards were also referenced. Many agencies rely on the licensing process as a means to ensure providers are following requirements and as a way to verify compliance and investigate violations. Lead agencies also often incorporate language into their contracts to help monitor provider practices around participant health and safety, such as requiring documentation of provider training. A few counties also noted that the DHS Model Contract includes a number of assurances related to participant safeguards. V. Participant Rights and Responsibilities Lead agencies were asked to verify that they carry out efforts intended to ensure that participants receive support to exercise their rights and receive support to accept personal responsibility. Overall, agencies reported compliance with the assurances related to consumer rights and responsibilities. However, five counties reported that consumers do not always receive copies of service agreements or prior authorizations that include information about appealing service decisions. In addition a few (1-2) counties reported that they do not ensure the following, but plan to make changes in order to meet these requirements: Consumer receives information about their right to be free from maltreatment and how to report it Consumer receives information regarding Ombudsman services Consumer always receives a copy of assessed needs Consumer has access to guardianship or conservator services when needed and appropriate Lead agencies commonly mentioned that consumers are provided with information packets which include materials related to consumer rights. Materials developed by DHS are frequently used across many lead agencies. Some specifically mentioned in their plans that this information is reviewed with consumers on an annual basis. Page 8 of 16

11 VI. Participant Outcomes and Satisfaction All but three counties reported that they use one or more structured methods to gather feedback from consumers and/or their family/informal caregivers (See Table 8 in Appendix B). This is a significant increase from reports in previous years. Lead agencies most commonly reported the use of consumer and family/informal caregiver interviews to gather feedback. In many counties, consumer input is gathered as part of the case manager visit and is used to address participant-specific concerns. Some counties reported gathering consumer input through a structured process outside of case manager visits. Very few counties reported using consumer input for system-wide analysis and improvement and instead use this type of input to enhance the individual care planning process or for staff performance reviews. VII. System Performance Lead agencies were given an opportunity to describe any continuous quality improvement efforts they have undertaken in the previous two years. The most frequent improvement reported by lead agencies is around contracting with the implementation of the DHS model contract and/or the incorporation of specific provider standards or outcomes. Other improvement efforts mentioned included: Developing or increasing service capacity Regular meetings with local providers to update, discuss, and explore ideas for improving services Increasing lead agency staff capacity through the adding or reorganizing of positions Streamlining/standardizing processes and practices between public health, social services and mental health departments within the agency Cooperating with neighboring counties to expand provider networks Improving public outreach Providing training opportunities to service providers Page 9 of 16

12 Conclusion Overall, lead agencies reported required assurances are in place related to the seven Quality Framework focus areas. Nonetheless, DHS has identified recommendations for lead agencies along with opportunities for DHS to support lead agencies in these areas. DHS recommends that lead agencies: Continue to ensure that their HCBS programs meet all standards and assurances. Results of the 2008 HCBS QA Plan survey indicate that improvement is particularly needed for some lead agencies to ensure that: o In-person LTCC assessments are completed within 10 working days of referral o HCBS providers have individual back up plans and contingency plans for community-wide emergencies o Consumers always receive a copy of service agreements or prior authorizations that includes information about appealing service decisions o Participant access to qualified providers is not limited through the local implementation of provider standards higher than those applicable statewide Continue to work internally to streamline waiver administration practices. In many lead agencies, local administration of Minnesota s five HCBS waiver programs is split between public health and social services departments. A number of lead agency responses, read as a whole, indicate strong partnerships between departments which generally lead to better consistency in waiver administration and achievement of quality assurance objectives. In other responses, particularly where entirely separate responses were received from public health and social services, significant partition and variations in approach and practice between a lead agency s departments were noted. In general, these responses indicated less coherence in overall waiver administration and in demonstrating efficiency and effectiveness in quality assurance outcomes. Coordinate and target quality assurance resources as part of efforts to streamline HCBS program administration. For example, in an effort to maximize existing resources, lead agencies can consider: o Increasing coordination across internal departments and/or creating cooperative agreements with other counties in order to pool contract management and/or provider monitoring resources. o DHS initiatives underway when planning the focus of local quality assessment and monitoring activity in the future. These initiatives are noted in the next section. For example, DHS is engaged in developing statewide surveys to gather direct consumer experience data, as well as strategies for reporting this data to lead agencies. Lead agencies may want to consider how the availability of county- and provider-level survey results may replace or enhance their existing or planned local consumer feedback mechanisms. Capture information gathered by case managers/care coordinators on a more systematic basis. Many lead agencies designate the roles and responsibilities of case managers as the primary mechanism for the monitoring of consumer satisfaction and provider performance. It is recommended that feedback gathered by case managers be Page 10 of 16

13 more systematically captured and integrated with provider monitoring mechanisms for quality assessment and planning purposes. In connection with the results of the 2008 HCBS QA Plans, DHS will: Verify requirements addressed in this HCBS QA Plan in the course of other DHS quality management activities, such as community support (care plan) audits, lead agency visits and routine requests for information by DHS. This is a federal requirement of DHS as the State Medicaid Agency responsible for quality management oversight of the HCBS waiver programs. While not required to be attached to the QA Plan when submitted, the lead agency must be able to provide tangible evidence to verify their answers to each question on this survey. Conduct follow up with individual lead agencies, when necessary, regarding any lead agency practices that prevent HCBS program assurances from being met. Continue working with lead agencies and other stakeholders in the development of a streamlined and comprehensive process for quality management across HCBS waiver programs. DHS is currently involved with multiple stakeholders in the development an overarching HCBS Quality Management Strategy to achieve more efficient and effective discovery, remediation, and quality improvement outcomes at all levels of waiver administration. This includes: o The development of standardized, statewide consumer surveys to capture participant feedback and make it available in a way that makes the information useful for quality assessment and improvement activities at local, regional, and state levels. o Implementation of a unified system and process for critical incident reporting to improve the collection, analysis and follow-up on critical incidents reported to lead and state agencies. o Integration and improvement of the quality and type of data used for quality management purposes o Development and implementation of a new approach to provider network management, to design and implement more efficient and effective provider capacity development and provider monitoring strategies that can be implemented statewide. This new approach will have a significant impact on local quality management responsibilities related to capacity, choice and provider competency. Page 11 of 16

14 Appendix A: CMS Quality Framework All states participating in 1915(c) (Medicaid) waiver programs must provide assurances concerning the quality of care and services provided through these programs as a condition of federal approval of the state waiver plan. The Center for Medicare & Medicaid Services (CMS) organizes these assurances into a Quality Framework that focuses attention on participantcentered desired outcomes along the following seven domains: I. Participant Access: Individuals have access to home and community-based services and supports in their communities. II. Participant-Centered Service Planning and Delivery: Services and supports are planned and effectively implemented in accordance with each participant s unique needs, expressed preferences and decisions concerning his/her life in the community. III. Provider Capacity and Capabilities: There are sufficient HCBS providers and they possess and demonstrate the capability to effectively serve participants. IV. Participant Safeguards: Participants are safe and secure in their homes and communities, taking into account their informed and expressed choices. V. Participant Rights and Responsibilities: Participants receive support to exercise their rights and in accepting personal responsibilities. VI. Participant Outcomes and Satisfaction: Participants are satisfied with their services and achieve desired outcomes. VII. System Performance: The system supports participants efficiently and effectively and constantly strives to improve quality. The federal framework and related materials can be reviewed at: Page 12 of 16

15 Appendix B: Survey Results Tables 85 County/Tribe lead agencies responding Table 1. Participant Access: Long Term Care Consultation Program Requirements Do the lead agency LTCC staff Yes No N/A* Information and Referral Provides information and referral about long term care options? 85 0 Carries out member education activity related to the availability of HCBS 84 1 Provides early intervention activities 85 0 Provides information about the availability of assistance in applying for Minnesota 85 0 Health Care Programs Nursing Facility Admissions and Relocation Assistance Conducts telephone or in-person screenings for nursing facility admission Visits people under 65 admitted into facilities as outlined in law and within the timelines proscribed by law Completes nursing facility level of care determination 85 0 Completes Level I screening for mental illness or mental retardation as required 85 0 under state and federal law for facility admissions Provides relocation assistance to assist people in returning to community settings 85 0 after facility admission Community Provides face-to-face assessment to all citizens requesting such assistance 85 0 Completes in-person assessments within 10 working days of referral 77 8 Completes Level I screening as part of community assessment 85 0 Develops community support plans for all citizens requesting such assistance 85 0 Provides information to the person about freedom of choice between institutional 85 0 and community-based services * Tribal lead agencies are not currently required to carry out these functions Table 2. Participant Access: Access to Publicly-Funded Home and Community-Based Waiver Programs Does the lead agency Yes No N/A* Use the Long Term Care Consultation Assessment form to complete face-to-face assessments Use the DD screening document when completing full-team face-to-face assessments Apply all of the following service eligibility criteria The person has been assessed using the required assessment tools and processes 85 0 (such as TBI and CAC assessment tools) The person has been determined to meet the level of care requirements? 85 0 (Including, when applicable, hospital, nursing facility, and ICF/MR level of care determinations) The person's community support plan indicates the need for a service that is only 85 0 available through one of the HCBS programs The person's community support plan will reasonably ensure health and safety 85 0 There is no alternative payer for the HCBS service needed 85 0 A reassessment is conducted to determine re-eligibility AND care plans are 85 0 subsequently updated at the required minimum frequency. * Tribal lead agencies are not currently required to carry out these functions Indicates that this is not a practice required by the waiver plan or state law Page 13 of 16

16 Table 3: Number of Counties with Waiting Lists for HCBS Programs HCBS Program Number of counties CAC 2 CADI 16 DD 63 TBI-TB 4 TBI-NF 3 Table 4: Participant-Centered Service Planning and Delivery Does the lead agency s community support planning, policies and practices result in a plan with the following characteristics Is based on and documents assessed needs and strengths of the individual, as 85 0 expressed by that individual and identified in an assessment Verifies consumer s choice between waiver services and institutional care 85 0 Reflects consumer-identified Preferences 85 0 Reflects consumer-identified Decisions 85 0 Reflects consumer-identified Strengths 85 0 Reflects consumer-identified Goals 85 0 Documents the range of service options/types that will fulfill the consumer s 84 1 identified needs Documents consumer s choice between service providers 84 1 Documents family/informal caregiver concerns and needs, as applicable 85 0 Addresses how family/informal caregiver will be supported/needs will be met, as 85 0 applicable Includes professional recommendations for supports as well as the person's 85 0 choice of supports Documents how the consumer is supported in managing any risks involved with 85 0 their individual choices and identified needs Includes the frequency and mode of case management contact 84 1 Includes provider(s), service type, frequency, and duration of services to be 85 0 provided to the individual Documents that a reassessment was completed when significant change occurs, 85 0 as applicable Documents changes to services that result from a reassessment 85 0 Table 5: Participant Safeguards Does the lead agency Yes No Monitor the health and safety of the person 85 0 Evaluate unsafe home conditions 85 0 Evaluate need for supervision 85 0 Incorporate personal risk management in support planning 83 2 Have face-to-face or telephone contact with the person as indicated in the 85 0 community support plan Have communication procedures in place for the provider to follow in order to 85 0 contact the lead agency or case manager regarding a consumer Ensure providers have a plan for person s backup assistance when providers aren t available and lack of immediate care would pose a serious threat to health and welfare (This assurance is intended to be in place at the individual client level and to reflect individualized planning.) 80 5 Yes No Indicates that this is not a practice required by the waiver plan or state law Page 14 of 16

17 (Table 5 Cont ) Does the lead agency Yes No Ensure providers have a contingency plan for emergencies when the lack of immediate care would pose a serious threat to health and welfare (This assurance is directed at community-wide emergencies such as those posed by inclement weather.) Have policies and procedures that address: 82 6 Prevention of abuse, neglect and exploitation 85 0 Screening for abuse, neglect, and exploitation 85 0 Identification of abuse, neglect, and exploitation 85 0 Reporting of abuse, neglect, and exploitation 85 0 Lead agency staff training directly related to abuse, neglect, and exploitation 84 1 Communication processes that create an appropriate, efficient feedback loop 84 1 between Adult Protection and lead agency case managers Annually verify provider training directly related to abuse, neglect, and exploitation Table 6: Specialized Planning for Health and Safety Does the lead agency Yes No Have any particular policy or practice related to ensuring medication management plans are implemented Have any particular policy or practice related to ensuring appropriate uses of behavioral services Table 7: Participant Rights and Responsibilities Does the lead agency ensure the following Yes No Consumer receives information about their right to be free from maltreatment and 83 2 how to report it Consumer receives information about data privacy 85 0 Consumer receives information about their rights to appeal lead agency decisions 85 0 regarding services and/or access to programs Consumer receives information regarding Ombudsman services 83 2 Consumer always receives a copy of assessed needs 83 2 Consumer always receives information about all HCBS waiver services 84 1 Consumer always receives a copy of service agreements or prior authorizations that includes information about appealing service decisions Consumer has access to guardianship or conservator services when needed and appropriate Table 8. Participant Outcomes and Satisfaction: Types of Feedback Methods Structured feedback methods used by the lead agency within the last two years Number of lead agencies 47 Consumer satisfaction or experience surveys related to the provision of HCBS services Consumer interviews related to HCBS services 62 Consumer focus groups related to HCBS services 6 Other consumer input/feedback strategies 41 Family/informal caregiver satisfaction or experience surveys 25 Family/informal caregiver interviews 57 Family/informal caregiver focus groups 4 Other family/informal caregiver input/feedback strategies 41 None 3 Indicates that this is not a practice required by the waiver plan or state law Page 15 of 16

18 Table 9. Participant Outcomes and Satisfaction: Consumer Input Strategies Did your consumer input strategy ensure consumers with the following Yes No characteristics were provided appropriate assistance and/or accommodation to give them a meaningful opportunity to participate in the feedback process Consumers who speak a language other than English Consumers who have difficulty reading 78 6 Consumers who have mental or cognitive disabilities 80 3 Consumers who have challenges with communicating 80 4 Consumers with hearing impairments 79 5 Table 10: Minnesota Records Retention Law Does the lead agency assure compliance with documentation, maintenance and retention of client records requirements under the Minnesota Records Retention Law for five years from the date of the last activity on the record? (Required by MN Rules, Chapter through ) Yes No 85 0 Indicates that this is not a practice required by the waiver plan or state law Page 16 of 16