The rollercoaster ride for the ICF-IID world continues its up and down motion. In the communication of Nov. 15, 2012, the Ohio Department of Developmental Disabilities (DODD) shared with providers that state-wide IAF assessments would be conducted during the first quarter of 2013 in accordance with §11 of Sub. H.B. No. 303.
Those state-wide assessments have been in process since Jan. 2, 2013 and are continuing throughout the first quarter until every individual is re-assessed by reviewers from the state using the revised IAF instructions and tool.
How does the process go? The facility is contacted one to two weeks before the reviewers arrive so that the visit is not a surprise. The reviewer completes an IAF form for each individual (based on brief observation and primarily from the documentation in place), and observes a meal time and a medication pass for that individual. The reviewers should also ask facility staff if what they observed was typical for those individuals. If it was not, the facility should be allowed to provide documentation to support this. So, although the visit is no surprise, very often the results have been.
Early results and discussions with clients indicate that the case mix scores are generally going down – anywhere from 5 percent to 45 percent - with obviously huge implications for the rate setting July 1, 2013. As we look at those results, the main areas of loss of coding for case mix results occur in the Behavior domain and the Out of Home Health Care item. Please use the IAF Tracker & Calculator to calculate the IAF score based on the DODD review and return it to your Plante Moran consultant.
As always, Plante Moran will do as much as we can to help with any aspect of the re-basing project. Various members of our team are involved in trade associations and work closely with the various state offices. In addition, three of our nurses took the DODD IAF training, passed the demonstration test and are available to assist.
How can Plante Moran help? We have a three-pronged approach:
- If your individuals have not been re-based, we can advise you regarding what to gather and how to gather so that the necessary documentation to support IAF coding is readily available and accessible for review.
- We can conduct a financial reimbursement impact analysis with your preliminary results** to assist in the direction of a possible reconsideration request and/or assist in future considerations for strategies beginning July 1, 2013.
- When the certified official results are received by the facility – and if the case mix scores decreased - we advise you to submit a written request for reconsideration. In other words, if the facility disagrees with the results and believes the individual was not coded accurately, the facility must submit a written request for reconsideration to the DODD no later than 15 calendar days after the receipt of the letter. And yes, Plante Moran can help with that process and advise staff about what to compile, how to compile and how to write the appeal. The Department will issue a written decision regarding the reconsideration no later than 30 days from the date of the receipt of the request, or June 1, 2013. This is the only chance to appeal.
** Preliminary results are given to the facility by the reviewers just before they leave. They will give a copy of the completed IAF form for each assessed individual, although these results are not final. The information the reviewers compile is sent to the Division of Medicaid Development and Administration (MDA) for processing. Once reconciled, the MDA sends out by certified mail the official results of the reviews (and is required to do so no later than April 30, 2013).
Contact your Plante Moran consultant to discuss further and we’ll help you hang on during this rather scary rollercoaster ride.