Comprehensive Services

Waiver Reform

The Department of Human Services and the Department of Health Care Policy and Finance oversee Medicaid services for residents with developmental disabilities. These agencies must ensure that the waiver meets the needs and supports of those individuals being served, and that the services comply with federal Medicaid regulations.

During FY2003-04, the federal Centers for Medicare and Medicaid Services (CMS) reviewed Colorado’s home and community based services Medicaid waivers for persons with developmental disabilities. The final report on the Comprehensive Waiver program was issued in April 2004 and a renewal of the waiver was approved September 24, 2004. The renewal was conditioned on various changes, including (1) removal of certain program costs from the Waiver program and their transition to the Medicaid State Plan and (2) steps to increase financial oversight and accountability for the program, including steps to “unbundled” services and costs in the comprehensive waiver program.

In FY2004-05, Colorado unbundled the collection of service encounter data and differentiated costs through Community Centered Board (CCB) audits, but the billings were still bundled. In addition, the CCBs continued to negotiate rates as the Organized Health Care Delivery System (OHCDS). CMS has since stated that: billings must be unbundled, all providers must have the choice to bill directly or to use CCBs as the OHCDS, and that there must be a uniform rate setting methodology.

The State is implementing several changes for July 2006 to address these issues with the Comprehensive Services Waiver including (1) detailed billings that unbundled services, (2) notification of all providers of their option to become Medicaid providers and to bill directly, and (3) a short-term plan for uniform rates.

FY2006-07 will be a time of full transition to the adjustments required. The transition will entail creation of a long-term uniform rate setting methodology that relies, in part, on the use of an intensity tool that will assist in identifying each individual’s level of need for support. Extensive training will be required for all system players in order for transitional issues to be addressed and for changes in administrative functions to be fully implemented.