The state is finalizing changes to the IHS waiver and it’s critical that families and providers share their experiences and concerns during the formal comment period ending this Wednesday April 15, 2020. Comments submitted now will be shared in the waiver application and provided to the US Center for Medicare and Medicaid Services which approves the waiver.
If you attended a listening session or submitted comments before March 16, you must share them again so that they are considered in the formal comment process.
Send comments to IHSWaiverRenewal@dhhs.nh.gov.
Comments must be submitted by NOON (12:00 pm) on Wednesday, April 15, 2020.
Waiver Presentation: https://www.dhhs.nh.gov/dcbcs/bds/documents/ihspubliccommentsessions.pdf
Draft waiver: https://www.dhhs.nh.gov/dcbcs/bds/documents/ihs-waiver-renewal.pdf
The state addressed many of the concerns in the earlier public comment sessions by expanding the work of direct support professionals, introducing new methods of participation to support individuals to participate in the Participant Managed and Directed Services (PDMS) model, raising the cap on respite services, and adding several new services.
Some of the remaining concerns include:
- The cap is too low.
In the current waiver, the maximum budget is $30,000 per family per year. This has been raised to $35,000. However, this is still too low for families with the highest needs. The cost to serve one of these children at Cedarcrest, the state’s only ICF/DD facility is over $100,000 more per child.
- Choice of case manager must be protected
The state must ensure that families are given true freedom to choose an independent case manager and all case managers, whether employed by the area agencies or independent, are held to the same high standards.
- Public comment period is too short, given the circumstances.
While the state is providing 30 days of comment, with the current COVID-19 crisis, this is not sufficient. BDS did not clearly communicate that comments submitted in the earlier listening sessions would not be included in the formal comment process.
- Need to ensure consistency across the state
The Bureau of Developmental Services must ensure that the waiver is implemented consistently across the state.
- Family input and experiences must be prioritized
The state must prioritize the experiences of families as it implements the new waiver.
Send your comments and concerns as soon as possible. Send comments to IHSWaiverRenewal@dhhs.nh.gov.
Comments must be submitted by NOON (12:00 pm) on Wednesday, April 15, 2020.
