Office for People with Developmental Disabilities (OPWDD) and the People
First Waiver. OPWDD and the Department of Health are working with CMS on
an agreement called the People First Waiver, a 1915 (b)/(c) concurrent
Comprehensive Home and Community Based Services (HCBS) waiver. This
agreement will renew the OPWDD 1915(c) Comprehensive HCBS Medicaid
Waiver for People with Developmental Disabilities and will also be the vehicle
OPWDD uses to authorize the creation of a managed care delivery system for
individuals with disabilities. The managed care delivery system will allow
individuals to enroll on a voluntary basis in a Developmental Disability
Individual Support and Care Coordination Organization (DISCO). Originally
planned for October 2014, the state now expects that DISCOs will begin
providing service in October 2015. DISCOs will be voluntary for both enrollees
and providers and will be implemented in select geographic regions across the
state. While the state hopes to create a mandatory managed care program for
Medicaid beneficiaries with developmental disabilities, they expect that full
implementation will take several years as DISCOs are established and approved.
DISCOs will be prohibited from doing direct marketing, and all education and
enrollment activities will be conducted by Maximus. The DISCO will be
responsible for providing care management to its enrollees, based on the HCBS
standards of the current 1915-c waiver, including the use of a care coordination
team and coordination of care across waiver providers, specialists, behavioral
health providers, and long-term care providers.
OPWDD is reviewing Medicaid managed care standards regarding network
adequacy to assess their relevance for the I/DD population. The state typically
requires a minimum of two of each type of provider in a region, but the concern
is that this standard may not be sufficient given the variety of needs of the
population and the range of services included in the benefit package. OPWDD is
also reviewing credentialing requirements for the DISCO, trying to determine
the division of responsibility between plans and providers. DISCOS will be
required to verify the license of all individual practitioners as well as ensuring
that all Direct Care Support professionals are evaluated for core competencies. A
self-directed program will be required of all plans. Finally, OPWDD must
establish an independent ombudsman program, provide consumer education
and advocacy services, and maintain a state-wide database on consumer
concerns and complaints.