While the history of the Indiana waiver system may seem chaotic and poorly thought out so far, the first portion of this history cannot hold a candle to the difficulties encountered from 2007 through now. It is in this flurry of events when consumers and providers were introduced to terms such as “ICAP,” “IPMG,” and “OASIS.”
In January, 2007, it was announced that an ICAP (Inventory for Client and Agency Planning) assessment would be given to each individual to determine an objective level of need. This would be given to 10,000 individuals during a pilot phase by Arbitre Consulting- A company contracted by Indiana to handle this massive project.
Meantime, January marked a change in residential and day services billing. The state, realizing that the system of paying providers regardless of whether or not services were provided would be causing them enormous difficulty with CMS, attempted to correct the problem by only allowing for billing on attendance days. While very tempting to providers to remind BDDS of their original concerns, most providers put most of their effort into putting together enough information to determine attendance patterns and retooling (again) to the latest model. As simply cutting revenue amounts to providers would close programs state-wide, “absenteeism factors” and other band-aids were applied to allow services to continue while a true objective allocation system and true uniform rates were developed.
Mid-2007 saw the launch of the “Pilot Project” for OASIS (the system to replace the current system with an objective method of allocation) in part of the state. Information meetings with Davis-Deshaies, Arbitre, and DDRS were scheduled to answer questions about the project. Providers meetings were scheduled separate from Family/Consumer meetings. Providers were also informed that they would be given several forms to collect cost information. As there was growing concern over the accuracy of the ICAP assessments, a helpline was developed to address these concerns as they came up.
In a May, 2007 memo, it was announced that CMS would allow a gradual phase-in of the OASIS model, with the pilot complete in 2008 and full implementation by mid-2009. This same memo also stated, for the first time, a promise that most providers and families have considered to be disingenuous at best: “Significant emphasis will be placed on gathering stakeholder input and creating a rate model and individual budget process that meet the needs of the people we serve and the providers that serve them.” It is this statement, along with the state’s refusal to disclose the mechanism for how allocations are determined, that has been central to the friction during the last few years.
From May until July, there was a flurry of confused activity. There was a rush to meet the original deadlines that were promised to CMS, and as a result, many corners were cut. A memo was sent out changing the due date for cost reports, immediately followed by one acknowledging an error in those cost reports. A policy bulletin reversed a previous memo, now stating that camp registration was not covered under waiver, but staff time was. Finally, all providers were asked to submit their most recent audited financial statements.
Finally, the rates that would be utilized for the pilot programs were released toward the end of the year. The Pilot would officially begin on January 1, 2008, for district 4 consumers. This was limited to residential, respite, and behavioral supports as well as adult foster care. Other services would begin in March. The rates, as well as the way that services were to be documented and billed were altogether new. While providers were apprehensive, assurances that everything would be subject to review based on the pilot program results made most willing to “wait and see” instead of passing judgment on the new program.
Although we did not make it to OBA in this post, my intent is to keep these sections as short and readable as I can. Part 6 will discuss the rise and fall of OASIS and uniform rate methodology. The final section will bring the history to a close as we begin talking in present tense.