Bettina Carroll Director for Programs and Contract Management HIV Care Services/Public Health Solutions September 18, 2012
Jan 22, 2016
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 ResidencyPolicy overview (including exempt service categories)Process for implementation of processTimeline for implementation of processOverview 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
This is to certify that I, _______________________________ can attest that the following has
Changed Not Changed as of _____________ (Date):
Client Home Address No Yes New Information ______________________ Client Household Income No Yes New Information ______________________ Medical Insurance Information No Yes New Information ______________________ ______________________________ _____________________________ Client Signature Staff Signature
Sample Attestation Form: courtesy of HHC Harlem Hospital
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?