Transcript Monitoring Compliance Income and Residency

Bettina Carroll
Director for Programs and Contract Management
HIV Care Services/Public Health Solutions
September 18, 2012
Background
• April 2011 HRSA implemented Monitoring Standards for
RW Part A/B grantees
• Introduction of Eligibility Determination Screening
process
• Programs required to assess and maintain
documentation of client eligibility including:
proof of income-based on EMA-developed criteria
proof of residency-within the five boroughs of NYC,
Westchester, Rockland and Putnam counties
Implementation Process
• New York City Department of Health and Mental
Hygiene Bureau of HIV/AIDS Prevention and Control
(DOHMH/BHIV) issued correspondence to providers
(10/31/11 and 12/16/11): Documentation of Proof of
Residency
Policy overview (including exempt service categories)
Process for implementation of process
Timeline for implementation of process
Overview of acceptable documentation
Implementation Process (cont’d)
• JoAnn Hilger, MPH/DOHMH, presented HRSA Monitoring
Standards for Ryan White Part A & B Grantees to the HIVCS
CAG on October 26, 2011
 Clients will be subject to income eligibility standards starting
March 1, 2012
 Clients will be required to provide evidence of EMA residency
for eligibility starting March 1, 2012
• HIV Care Services Contractor Newsflash – December 2011 detailed client eligibility review and documentation process to
be initiated as of March 1, 2012
Implementation Process (cont’d)
• Amended Contract Scope of Services language with FY 22
contract renewals
• Initiated monitoring of compliance as of March 1, 2012
• Provided technical assistance to programs regarding
implementation
• Documented “recommendations” for compliance in site visit
reports
• Postponed implementation of compliance actions until
September 2012
Site Visit Monitoring of
Eligibility Check Compliance
Ninety-seven (97) routine/reimbursable site visits for the applicable service
categories were conducted for services delivered in the contract period
beginning 3/1/12. Below are the aggregate numbers for programs compliance
in checking eligibility.
# of programs that
were compliant
with conducting
checks
# of programs that
were not compliant
with conducting
checks
# of programs that
were partially
compliant with
conducting checks
Income eligibility
37 (38%)
9 (9%)
51 (53%)
Residency
eligibility
34 (35%)
9 (9%)
54 (56%)
Issues related to compliance
(feedback from providers)
• Client resistance to/fear about providing documentation
• Time consuming process (particularly with “old” clients)
• Difficulty getting documents from homeless clients
• Difficult to obtain copy of documents for clients seen in
the home; innovative methods may breach
confidentiality
Issues related to compliance
(feedback from providers cont’d)
• Unaware of/confused about when requirements for
eligibility checks should be implemented
• Unaware of acceptable documentation for eligibility
checks
• Transient population (inconsistent attendees)
• Clients forget to bring documentation
Questions from programs regarding
documentation of eligibility
• Can e-PACES be used to verify residency and income
eligibility?
• Can transportation logs be used for residency
documentation?
• If the same documentation is used to establish eligibility
in successive years (no status change), is it necessary
to re-copy documents?
• Can mail from the program sent to a client’s address be
used as proof of residency?
Questions from programs regarding
documentation of eligibility (cont’d)
• Can a HASA referral letter document residency and
income eligibility?
• Can identification cards for other health insurance, with
Medicaid-similar income criteria, be used to document
income eligibility?
Best Programs Practices
• Development of a form/checklist of documents needed
to enroll clients
• Development of “eligibility documentation” section
created in the client record
• Development of Attestation Form detailing required
elements as statements; used at point of reassessment
Sample Attestation Form: courtesy of HHC Harlem
Hospital
This is to certify that I, _______________________________ can attest that the following has
Changed
Not Changed
as of _____________ (Date):
Yes
New Information ______________________
Client Household Income
No
Yes
New Information ______________________
Medical Insurance Information
No
Yes
New Information ______________________
Client Home Address
No
______________________________
Client Signature
_____________________________
Staff Signature
Next Steps
• HIVCS and DOHMH will review current process and
need to revise the scope amendment to adjust
documentation requirements:
Inclusion of additional acceptable documentation
Process to collect/reflect documentation
Questions for the CAG
• What barriers have you found in implementing the
process?
• How have you addressed these concerns?
• Are there suggestions for eligibility documentation which
we have not considered?