Last week, the Michigan Department of Health and Human Services (MDHHS) announced that it has asked federal regulators for an additional year to implement the 1915(i) State Plan Amendment (SPA) to transition eligibility determinations for behavioral health community support services from prepaid inpatient health plans (PIHPs) to MDHHS. Some services covered under the 1915(i) state benefit include community living supports, enhanced pharmacy, environmental modifications, respite care, and specialized medical equipment and supplies.
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A spokesperson from MDHHS told State of Reform that this extension, from October 2022 to October 2023, will allow for the process change to come into compliance with the eligibility determination requirements for the 1915(i) state benefit for behavioral health community support services.
Per these requirements, MDHHS is charged with the responsibility of determining needs-based eligibility for the state community support services benefit, as eligibility must be determined “through an independent and unbiased evaluation of each individual.”
According to MDHHS, the PIHP provider network will perform the face-to-face assessments, compile required documentation and submit findings to MDHHS, and MDHHS will make the determination of needs-based criteria through an independent evaluation of the submitted findings.
For these independent evaluations, MDHHS is required to use “validated instruments specific to each individual’s condition that identifies the individual meets all eligibility requirements for 1915(i) services,” including the Child Adolescent Functional Assessment Scale and the Supports Intensity Scale.
MDHHS cited the need to transition staff resources from the COVID-19 public health emergency to the SPA implementation as the reason for the requested extension.
“The additional year will allow MDHHS to continue to work on the implementation process for eligibility determination requirements in order to comply with [federal regulations specified in the] Social Security Act,” the spokesperson said. “Implementation work has fully resumed but additional time is needed to adequately transition the eligibility determination from the PIHPs to MDHHS. Again, this extension does not have any other impacts on the SPA 1115 Behavioral Health Demonstration.”
MDHHS also reported that this is a cost neutral change. The PIHPs and MDHHS will use a capitated payment arrangement for services, and MDHHS will use an electronic data platform called the Waiver Support Application portal to manage all eligibility determinations.