OPWDD Transformation Agreement
Fiscal Policy for ICF/IID Conversions - January 2018
The New York State Office for People With Developmental Disabilities (OPWDD) received federal approval of its plan to transition individuals residing in both campus- and community-based Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID) operated by the State and its network of partnering non-profit agencies into more integrated and individualized options in the community. As a result, the State continues to support efforts to reduce its voluntary-operated ICF/IID capacity as we move toward our Transition Plan end date of October 1, 2018.
One strategy to help achieve that goal is to convert the ICF/IID to a more individualized residential program model. (A conversion is defined as closing the ICF/IID and opening the same facility as an Individualized Residential Alternative [IRA] through the HCBS waiver with no change to certified capacity, location of the program, or to the individuals residing in the program.) In doing so, OPWDD will expect and require that the agencies will work closely with individuals, their family members, advocates, and circle of support to undertake a comprehensive, person-centered planning process for each individual residing at the converting ICF/IID to ensure development of appropriate Individualized Service Plans and delivery of the identified community-based supports and services.
The ability to convert will be limited to only those ICF/IID that have a capacity of no greater than 14 persons; however, ICF/IIDs that have a larger capacity could also transition to HCBS-authorized residential services if the service provider believes the policy identified herein results in sufficient revenues to cover costs.
Effective July 1, 2017, the following reimbursement strategy will be used to convert ICF/IID to Supervised and Supportive IRAs providing individualized Waiver services (Residential Habilitation).
1) The conversion funding will be based upon a review of the average direct care and/or clinical support hours being reimbursed in the ICF/IID from which the individual is transitioning, as calculated per the current rate methodology. These hours will be compared to the average direct care and/or clinical support hours being reimbursed in the Provider’s Supervised or Supportive IRA program, as calculated per the current rate methodology.
2) If the average direct care and/or clinical support hours calculated for the support of individuals residing in the ICF/IID are higher than the hours calculated for the support of individuals currently being served by the proposed service provider in the IRA program, then an ICF/IID conversion amount will be added to the existing IRA rate. The ICF/IID conversion add-on amount will be determined by multiplying the additional needed direct care and/or clinical support hours by the respective cost components as calculated in the Supervised or Supportive IRA rate reimbursement. There will be no change to the other cost components associated with delivering the requested service(s); the only change to the IRA rate will be the number of direct care and/or clinical support hours available to appropriately support the transitioning individual(s).
· Provider agencies may choose to convert an ICF/IID to an IRA and simultaneously downsize the program. In these situations, the funding will be based upon the overall capacity of the IRAs as if they were a single facility. It is the provider’s responsibility to determine if this funding policy will be sufficient to meet the needs of the impacted individuals and cover fixed costs as the ICF(s) downsize.
· For day services provided outside of the residence (“off-site” day services), funding levels will be established that are consistent with the corresponding provider-specific reimbursement rates in effect at the time of conversion, and will vary depending upon the agency responsible for delivering such services. Recommendations concerning the establishment of reimbursement levels for individuals who require the provision of day services in the residence (“on-site” day services) will be advanced later; however, conversion proposals for those individuals who do not require in-home day services should proceed in accordance with this financing proposal.
· Agencies will need to comply with all applicable billing, claiming and service documentation requirements for the service to which the ICF/IID converts.
· To the extent individuals who are impacted by the conversion of the ICF/IID are eligible for template funding, they will continue to receive the template rates in effect for both residential and day services in lieu of the reimbursement levels developed in accordance with the above-referenced financing proposal.
· This strategy is effective until there is one year of cost experience of the now converted ICF/IID operating as an IRA reflected in a base year used for rate setting purposes.