Discussion on Day Programs
17 Nov 2011
As many ICF/MR providers are now aware, ODP has been scrutinizing the details of day program rates and costs that are reported on the MR46 cost report on Schedule 12, Miscellaneous Personnel Costs. ODP is requiring that ICF/MR providers obtain MPI#'s and service location codes from the vendor from whom they purchase services, and ODP is mandating that the rate an ICF/MR provider pays for day program service must be the same as the waiver-approved rates. Additionally, many day programs are "in-house," and as a related party, charges for day services have always been limited to actual costs. So does this mean that the waiver rate is applicable instead of actual costs? And some day program providers are still charging a daily rate to ICF/MR consumers, because they do not consider the service definitions and waiver rates to be applicable to ICF/MR.
As this information had not been requested previously, nor was it required on the cost report forms or instructions, it has been somewhat of a nuisance to gather the information after the fact. Some providers have been told that they are being "reported to BFO." Providers wishing to comply with ODP's request for additional information are having trouble obtaining it from the day service providers, probably because the day service providers don't understand why the ICFs/MR are asking the questions. There have been many questions and concerns about what is and what is not applicable to the ICF/MR programs; therefore, we have asked ODP to make this an agenda item at the next ICF/MR Task Force meeting on December 14, 2011.
ODP has issued the agenda for the December 14, 2011 meeting, and Kathy Deans will be presenting on this issue (as well as the conversion process for ICF/MR to waiver).
I am encouraging each agency to send someone to the Task Force meeting who can knowledgably ask questions and participate in a productive discussion on the day program services for ICF/MR consumers, and whether the service definitions and rates that are approved for waiver programs are also applicable to ICF/MR. Hopefully, this will result in everyone understanding what is required, what needs to be reported on the MR46 cost reports in the future, what costs are allowable, what can be requested in future waiver requests, and if there will be any impact at time of audit.
Click here for meeting agenda and location.