From: Secretary Tim Keck, Kansas Department for Aging and Disability Services (KDADS)
Date: March 13, 2017
Re: RFP for “No Wrong Door” Aging and Disability Resource Center RFP
During the next several days you will no doubt receive a large number of similar emails and letters objecting to a Request for Proposal (RFP) from KDADS posted on the Kansas Department of Administration website on February 22. This email is being sent to you in order to provide factual information about that RFP. There has been a great deal of misinformation circulated regarding this RFP, and the agency would like to set the record straight about what the RFP does -- and does not – seek to accomplish.
Since 2012 KDADS has contracted with the Southwest Kansas Area Agency on Aging to provide information to Kansans on their long-term care and support options through a program called the Aging and Disability Resource Center (ADRC). The Southwest Kansas Area Agency on Aging has in turn subcontracted with the 10 other Area Agencies on Aging to provide statewide ADRC coverage so that all 105 counties in the state of Kansas have access to a local ADRC.
Part of the ADRC mission is to complete initial and annual functional eligibility assessments for Kansas’ Home-and Community-Based Services Medicaid waivers for Frail Elderly, Physical Disability and Traumatic Brain Injury, as well as Money Follows the Person and PACE (the Medicaid alternative Program for All Inclusive Care for the Elderly.) The ADRC also completes the Client Assessment, Referral and Evaluation (CARE) assessment for individuals entering a nursing facility.
Based on the principle of “No Wrong Door (NWD),” the RFP issued last month was written to better serve the aging and disabled populations by creating a one-stop shop regardless of disability for:
- The statewide call center
- Information, referral and assistance
- Choice counseling
- Community transition opportunities
- Functional eligibility determination
The NWD approach will make it easier for individuals with dual disabilities to get a comprehensive picture of the community and Medicaid services available to them and increase personal choice. Currently individuals have to access this information at different locations based on a single, specific disability. These include:
- Intellectual/Developmental Disability (I/DD): Community Developmental Disability Organization (CDDO)
- Physical Disability (PD), Frail Elderly (FE), and Traumatic Brain Injury (TBI): ADRC
- Severe Emotional Disturbance (SED)/Behavioral Health: Community Mental Health Center (CMHC)
- Technology Assisted (TA): Children's Resource Connection
- Autism: KDADS or KVC Health Systems
The NWD ADRC approach is a more efficient way of linking individuals with community resources across disability groups.
Under the current system, community resource providers must coordinate with a variety of entities to fully inform individuals about all of the resources available to them. Through the NWD approach community organizations can coordinate with one entity, the ADRC, and touch all affected disability populations.
The RFP directly addresses consumer, provider and legislative suggestions that KDADS develop a way to make the current system less confusing for those who need information about the services available.
- A common criticism from participants, providers and the Legislature is that access to services is unnecessarily complicated and thus creates a barrier to entry. As a result many individuals throw up their hands because they cannot figure out where to go for services or assistance. The NWD ADRC changes this by allowing any individual seeking community or Medicaid services to contact one place, the ADRC, and obtain the information they need. This will be particularly beneficial for those with co-occurring behavioral health and a physical or developmental disability, and for their families.
- In the RFP process, bidders have the opportunity to provide the required ADRC information and assessment service but can also show how they could provide additional services that make their bid more attractive. The competitive bidding process means bidders will seek to demonstrate how they would provide the highest degree of customer service.
An example similar to this example is the value-added benefits provided by the Managed Care Organizations (MCOs) to attract KanCare beneficiaries. These additional benefits are offered competitively by the MCOs and enjoyed by KanCare beneficiaries. The value-added benefits drive innovation and customer service. Examples of the kinds of value-added benefits the ADRCs could offer include:
- Employment assistance
- Medicaid application assistance
- Information and/or access to community resources specific to the geographic region
- Other services determined beneficial by the bidder
The RFP will place the state in a better strategic positon to meet upcoming CMS managed-care rule changes while increasing flexibility and improving services.
- The new managed care rule requires the ADRCs to perform the duties and responsibilities of an "enrollment broker" as defined by CFR 438.10, CFR 438.71 and CFR 438.810. The enrollment broker would provide Medicaid/KanCare enrollment support/assistance. The RFP allows bidders to provide innovative proposals to meet these requirements. This is a requirement the state must meet to comply with CMS managed-care rule requirements. The state also believes it will help the most vulnerable through the Medicaid enrollment process.
- In transitioning to a NWD ADRC approach the state opens up revenue sources to fund the ADRC system. Under new federal rules, states that transition to a truly NWD ADRC approach are in line for additional federal funding to pay for it.
The design of the state's current point-of-entry system for Medicaid waiver services may have some inherent conflict of interest issues. The best example if this is the CDDO system. Currently, only CDDOs assess functional eligibility for individuals who need services under the I/DD waiver. In many areas of the state the CDDO also provides IDD services. KDADS believes when Kansas renews the IDD waiver, CMS will require this process to substantially change and require CDDOS to either perform functional eligibility assessments or provide I/DD services -- but not both because of the inherent conflict of interest. This RFP provides an option to meet this requirement while sustaining the ability of the CDDO to continue to deliver services to the I/DD population.
The agency asks that legislators, KanCare participants and the public listen carefully to critiques of this RFP because the current system has created some interests that are averse to any change, regardless of whether that change would benefit future wavier service beneficiaries. Already some are claiming that the RFP is some kind of stealth creation of an integrated waiver system, which is a misinterpretation of both its intent and its substance.
The RFP has nothing to do with the integration of services. Waiver integration, as proposed in 2015 by the Kansas Department for Health and Environment, dealt with specific home- and community-based services delivered under the seven Medicaid waivers, and would have allowed waiver beneficiaries to receive certain services regardless of the waiver in which they were enrolled. It did not address assessment of applicants for services under the various waivers as the RFP does. The two proposals – waiver integration and the RFP for NWD ADRC services – deal with two entirely separate areas of the Medicaid waivers. Attempts to conflate the two areas are unfortunate and misleading.
The RFP also calls for the Aging and Disability Resource Centers to be combined into four “catchment areas” or regions, but with multiple points of contact within each region. Instead of contracting with one Area Agency on Aging for the entire state, under the RFP there could be four separate contracts.
The regional approach to the NWD ADRC outlined in the RFP allows for regional needs to be addressed. Not all regions in the state have the same populations, needs and capabilities. By creating a regional system, the state has the flexibility to award contracts to match regional needs with appropriate kinds of vital information about the Medicaid waivers.
I know this is a long and detailed email. Please let me know if you have any questions or concerns.
Secretary, Kansas Department for Aging and Disability Services