DHS has released a manual/rule change for public comment until August 11, 2017. After that, you will not be able to get your comments on the record. In addition, they are hosting a public hearing on August 8.
You should read the manual for yourself to make sure you cover everything that concerns you. However, even if you read it, you might still wonder what to say. The comments below are an example of what one person plans to send in.
Use the form below. By choosing “Submit,” you will send an email directly to the appropriate DHS representative. Enter your information, and type your comments into the text box. You may copy/paste the comments listed at bottom into the comment section of the form, but don’t do so unless you have read it first and agree with it all. The following comments are just examples of one person’s opinions. Public comments are most effective when you make them more personal to you!
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This is my public comment regarding PASSE-New-17up.doc:
Section 211.000 – It says that the PASSEs should begin October 1, 2017. I believe that this model is not ready to begin taking on clients for several reasons. Rules like this one still have to be sent through the legislature for their approval. The Insurance Department isn’t supposed to approve the PASSEs until mid-September, which will only leave them a couple of weeks before they start managing people’s care. We don’t know what the rules will be, and we don’t know who the PASSEs will be. If the PASSEs aren’t ready and don’t do a good job, they could make mistakes. This will hurt people. I want DHS to push the date back and allow us to keep things the way they are until the PASSEs have had adequate time to review all of the finalized rules and to hire and train people who understand the rules.
Section 214.000 – It says that people can choose another PASSE during the first 90 days and once every year. How will we know what the differences between each PASSE is? I want to pick the best PASSE, but I don’t understand all of the rules or what they all offer. (At this point, I have reason to wonder if the PASSEs themselves understand the rules, as they have not been finalized.) It also says “on the beneficiary’s annual anniversary of attribution to a PASSE.” Is this a single day to respond, or is it a week? You need to define how long that amount of time would be.
Section 214.000 D – It says a client can move because of “poor quality of care,” but how do we prove that? That is a relative term. Who determines what kind of care is poor? I believe that the patient should determine whether care is poor and what that means in their situation.
Section 215.000 – What if the abeyance is due to DHS/Medicaid’s fault in paperwork (and the client can prove that)? Will the coordinator help the recipient to know that their Medicaid eligibility is in dispute and help them to figure that out?
Section 222.000 G – “The right to be provided written notice of a change in the beneficiaries care coordination” should be at least 14 days, not 7 days. If you are relying on snail mail, half of the time can be used simply in sending the notification, leaving the receiver very little time to respond or make other arrangements. Why isn’t this policy the same as 223.000 B, allowing 30 days from the time it goes into effect?
Section 231.000 – The travel times and distances listed need to be cut in half, especially for DD and BH providers who are seen on a more frequent basis. For example, it is not in the best interest of a child or adult to have to travel an hour to and then an hour to return from a location to see a therapist multiple times per week.
Section 241 G, 242 A, & 243.000 – DHS needs to give the PASSEs enough money to have a qualified individual available to help me whenever I need them, as many times as I may need them. Many providers seem to be concerned that the amount announced at the AR Waiver Conference (in July 2017) of $177 is not enough. I want them to get what they need so they can give me what I need. After December 31, 2018, they should have a different funding source and should not use any money from recipients’ care for administrative funding needs.
Section 242.000 – It says in the document that care coordinators will be employees of the PASSE (241 B). However, it does not say where the care coordinators should be located. Because Arkansas is so rural, care coordinators located in the communities they serve would be most knowledgeable for their clients.
Section 254.000 – Will DHS be required to submit the data received from PASSEs, such as data that shows savings or lack thereof, for public viewing? We want to see that data as well.
Section 261.000 – This says that grievances must be resolved within 30 days of the filing date. What will happen in the meantime? If a person needs treatment, do they have to wait all that time to receive it?
Section 264.000 – This description needs more definition. Who may serve on a Consumer Advisory Council? I believe that beneficiaries or direct consumers should serve, but caregivers who speak in place of beneficiaries who can’t speak for themselves should also be able to serve.