| A last minute 3% Cost of
Doing Business (CODB) was added to the DHS budget for DD and MI programs. It
was approved. What does that mean for us? Here is the most recent news from
IARF:
DDD IMPLEMENTATION OF 3% CODB
The 3% increase will be applied to
fee-for-service rates and the remaining DDD programs that are grant funded.
The Association sought clarification from the Speaker’s Office about whether
the 3% applies to ICFDD funded DT programs. Their intent was to include
ICFDD funded DT programs. To date, DHS officials have said the 3% does not
apply to the ICFDD funded DT programs (Alvin Eades, CLO, JDC), as the
ICFDD’s did not receive the 3% CODB. The Speaker’s Office told us that DHS
would be responsible for implementation of the 3% CODB, so we will talk to
the Department about the legislative intent for ICFDD funded DT programs.
The Association also spoke with the
Speaker’s Office and GOMB about why ICFDD’s were not included in the 3% CODB.
We were told the perception was that ICFDD providers had received an
increase when long-term care received an insurance adjustment last year.
GOMB said ultimately tight time constraints crafting the budget and the
limited amount of funding available for the CODB contributed to ICFDD’s
being excluded. The Speaker’s Office has told several family members, who
have relatives in ICFDD’s, they will try to make an ICFDD increase a
priority for FY07.
The Association will continue moving
forward with our strategy to obtain a 3% CODB for ICFDD’s during the veto
session. This is the earliest we will be able to advocate for an increase
because we will need to make a change in the substantive statute that
contains the automatic inflator of the ICFDD rate. As you know, the General
Assembly has chosen to freeze rates each year instead of allowing the
automatic inflator to go into effect.
DMH
IMPLEMENTATION OF 3% CODB
Currently, DMH is having internal
discussions concerning the distribution of the 3% CODB. The 3% cannot be
“applied” to the MRO rates as DCFS and DOC did not get a 3% CODB and
Medicaid regulations prohibit increasing the rate for only a certain segment
of service providers covered under Rule 132. The following options are being
considered by DMH regarding distribution of the CODB.
-
Set the 3% aside in a contingency fund to
aid agencies experiencing hardship during the transition to FFS.
-
In the FY06 Contracts there is language
allowing for funding reallocation mid-year based on provider claiming
activity. DMH has suggested using the 3% for those providers that are
billing over their targets and not reallocating funding from providers
whose claiming activity is below target.
The Association is still receiving feedback
from the Behavioral Health Committee to determine the best way to apply the
3% so that we can offer input to DMH. Member feedback thus far is that the
3% should apply to all agency MH contracts (including grants and MRO), the
3% should be applied across-the-board to all agencies and those agencies
that have successfully met their MRO billing targets should not be penalized
financially for doing so. |