FSSA’s Spend Plan for Implementation of the Enhanced FMAP for HCBS

On July 7, 2021, FSSA released it spend plan for the enhanced FMAP that is available for HCBS through the federal American Rescue Plan Act.  The initial spend plan was submitted to CMS on Friday, July 9^th, and the entirety of the spend plan can be found here.  Importantly, while this spend plan creates a framework for use of the enhanced FMAP, there are still significant details for FSSA to develop to put these components in place, which will allow time for additional stakeholder feedback and input.

Some of the relevant highlights of the spend plan are as follows:

• Phase I:  Stabilize Community Provider Networks
  • Provider Stabilization Grant Program:  FSSA will work with stakeholders to develop a stabilization grant program to address COVID-19 related expenses, including costs related to compensation and benefits (including incentives related to the COVID-19 vaccine), COVID-19 testing, personal protective equipment, and other COVID-19 related expenses.
  • Workforce Stabilization Grant Program:  To recognize the extraordinary efforts of the direct support workforce, FSSA will distribute a grant specifically to support frontline staff who worked to support their communities through the COVID-19 pandemic.  Prior to soliciting applications, FSSA will determine a set number of categories that individuals could fall into, depending on their duration of tenure as an active frontline employee during the COVID-19 public health emergency.  Tied to each category will be a corresponding bonus amount per employee.  These bonus amounts will be tiered accordingly, with the largest bonus amount correlated to the longest tenure period category, and so on.  FSSA will require that this amount be passed on to each staff member represented in the calculation but will provide a small percentage fee for the administration of the pass through.
• Phase II:  Effectively Advance HCBS in the State of Indiana
  • Recruitment and Retention of Workforce:  FSSA plans to develop a comprehensive direct service workforce strategy.  Included in this will be a research review of evidence-based or best practices used by other states and organizations that led to increased recruitment, retention, and career satisfaction among direct service workforce.  In conjunction with this work, FSSA will hold a Workforce Summit with Providers, Direct Support Workers, the Department of Workforce Development, Educational Institutions, Individuals Served, Families and Others to share the results of the research and to hear from direct support workforce subject matter experts, which will help to inform FSSA’s long-term plan.  As part of the implementation of this comprehensive strategy, FSSA plans to explore how to use a pay-for-outcomes strategy in regards to provider recruitment and retention strategies.  One example of a potential pay for performance measure is the percentage of staff hired with a certain level of training.
  • Expedited Eligibility:  FSSA is committed to developing an expedited eligibility model for Indiana to decrease the waiting time for HCBS delivery to likely Medicaid beneficiaries. The agency plans to utilize a combination of state process changes, IT system improvements, communications, and training to implement the model.  State process changes will build upon FSSA’s expedited eligibility pilot to offer expedited application processing statewide for the HCBS population.  FSSA also plans to create a specialized LTC Eligibility unit that will focus on applications for members needing LTSS.  The unit will have expertise in assisting HCBS applicants and be specially trained in the special income limit and budgeting processes for HCBS members.
  • HCBS and mLTSS Value-Based Purchasing (VBP):  FSSA’s long-term goal is to align cost and quality of services to enhance sustainable health and well-being outcomes.  FSSA is currently in an early stage of this effort and will continue to evaluate which providers to move to VBP.  Following this determination, FSSA hopes to engage a vendor to recommend performance measures.
  • HCBS Rating Methodology:  FSSA has begun work on an HCBS reimbursement approach and will continue this methodology work under the spend plan.  Some of the primary goals of the methodology work includes moving away from reliance on provider cost reports and improving the alignment and continuity of rate setting across FSSA’s divisions to provide HCBS reimbursement that is consistent and predictable.  FSSA’s intent is to implement rating methodologies that are easily understood by HCBS providers and that offer greater stability for their business planning purposes.  To that end, rate methodology updates will also reflect labor and expense changes driven by the COVID-19 public health emergency.  Another key goal of the rating methodology work is to deliver rates that support the sustainability of the HCBS programs with a specific focus on how rates impact the provider’s ability to hire and retain adequate staff to deliver the services needed by HCBS eligible Medicaid members.

We will keep you updated on future opportunities for feedback and input, and if you have any questions, please contact Laura Brown at Lbrown@ihca.org.