INFO MEMO 2007-12
STATE OF WISCONSIN
Department of Health and Family Services
Division of Long Term Care
Info Memo Series
Date: November 5, 2007
To: Listserv
For: County Departments of Human Services Directors
County Departments of Social Services Directors
County 51 Coordinators
County Fiscal Contacts
County COP and Waiver Coordinators
Human Services Area Coordinators
Area Administrators
Community Integrations Specialists
From: Sinikka Santala Administrator
Subject: LTC Fiscal Update Memo #2
This informational memo clarifies the Department of Health and Family
Services (DHFS) policy on approving the use of Community Options Program
(COP) Risk Reserve and on awarding COP High Cost Funds as counties
implement managed long-term care expansion.
COP Risk Reserve
Background
1999 Wisconsin Act 9 allows counties to establish a risk reserve with
unspent COP (GPR) funds. In Family Care, a risk reserve is a key component
of financial management. The COP risk reserve provision in Act 9 allows a
similar financial management mechanism in the waiver programs. A county
may use COP risk reserve funds to pay for unanticipated expenses in any of
the Department's Home and Community Based Waiver (HCBW) programs. Unspent
COP risk reserve funding may be carried forward each year. For further
detail please refer to Informational Memo #140 dated March 31, 2000 which
can be found on the Department's website at: http://dhfs.wisconsin.gov/dsl_info/
Policy
Counties have asked the Department to clarify allowable uses of COP
Risk Reserve funds prior to, and during, a transition to Family Care. COP
Risk Reserve may not be used to offset the required contribution of county
funds under managed long term care expansion. However a county may use COP
Risk Reserve for the following purposes:
- To meet or contribute toward meeting risk reserve requirements
associated with a contract between the Department and a county-based
MCO. Note: COP Risk Reserve funds may not be used to meet risk reserve
requirements for a private MCO;
- To meet or contribute toward meeting risk reserve requirement of an
MCO governed by a Family Care District or Long-Term Care District, as
approved by county board resolution;
- To pay COP administrative costs, as approved by the Department under
s.46.27 (7)(fr);
- To pay COP-allowable service costs for persons served through all
waivers in the period prior to and/or during a county's transition to
managed long-term care. Note: A county may not use the COP risk
reserve funds to replace the county's required managed long-term care
contribution as coordinated with the approved managed long-term care
enrollment plan. However, a county may use risk reserve funds to pay
one-time expenses on behalf of current waiver participants or offset
increases in locally supported expenses, such as those due to
inflation or provider increases. Risk reserve funds, as COP funds,
must be funding of last resort. DHFS will approve risk reserve
expenditures only when a county provides reasonable documentation that
other program funding is projected to be fully expended prior to the
end of the year and un-reimbursed expenditures remain.
- To pay COP-allowable service costs for persons in the children's
long term care waivers and for individuals who have a mental illness
and do not meet Family Care eligibility, after a county's adult waiver
population has transitioned to managed long-term care.
Note: A transitioning county may request a special variance to carry
forward the entire risk reserve to offset COP allowable costs in the year
following transition to managed care. These carry-over funds could be used
to support expenditures for home modifications, vehicle modification,
adaptive equipment etc. that would have otherwise resulted in a COP high
cost request for the remaining COP population. However, while the
carryover of the risk reserve may exceed 15% of the post-transition COP
allocation in this first year, the resulting balance at the close of the
year may not exceed the 15% requirement.
- To establish a COP risk reserve for COP eligible children and
persons with a mental illness who do not transition to managed long-term
care.
Note: Funds retained for the purpose of continuing a COP Risk Reserve
for COP eligible children and persons with a mental illness may not exceed
15% of the county's remaining COP allocation level after current eligible
COP and waiver participants have transitioned to managed long-term care.
COP High Cost Funds for Counties in Transition
Background
Within the
statewide Community Options Program, the Department maintains a fund for
exceptional needs of HCBW recipients. Exceptional funds are awarded to
applicant counties for the improvement or expansion of long-term community
support services for clients. Services may include: a) start-up costs for
developing needed services for eligible target groups; b) home
modifications for COP eligible participants and housing funding; c)
purchase of medical services and medical equipment or other specially
adapted equipment; and d) vehicle modifications. The exceptional needs (or
high-cost) fund is maintained by the Department using COP and COP-W GPR
funds allocated but not spent in the prior calendar year (s.46.27(7)(g),
Wis. Stats.). Awards to counties are available only when COP
under-spending is available.
Policy
A county planning to implement managed long-term care may
continue to request COP High Cost funding under the current review process
until the county's managed long-term care start date (the first date of
enrollment for managed long-term care services in that county). To qualify
for high cost funds, projects or services must be completed and paid in
full prior to the date the consumer enrolls in managed long-term care. The
Department will recoup COP high cost funds from a county if the individual
enrolls in managed long-term care prior to the date the project or service
is complete and paid in full.
During the period when a county's waiver participants are dis-enrolling
from the waiver and enrolling in managed long-term care, the Department
will consider a county's COP High cost request only when consumer needs
arise that are unexpected, services to meet those needs cannot be delayed,
and other waiver funding is not available to support the cost. Again, COP
High Cost funds may only be used for projects or services paid in full
before an individual enrolls in managed long-term care.
We hope you find these changes helpful. If you have questions or
concerns, please contact the following individuals:
MEMO WEB SITE: http://dhfs.wisconsin.gov/dsl_info/
cc: Joyce Allen, DMHSAS
Fredi Bove, DLTC
John Easterday, DMHSAS
Beth Wroblewski, BLTS
Irene Anderson, BLTS
Mike Linak, BLTS
Sandy Blakeney, BLTS
FMBS Team
Last Revised: October 24, 2008 |
