FAQ HCBS Prevocational and Supported Employment Services
Question Response
General Questions
Is this something new, or has this been in
the works for awhile?
The Rules in ARRC 2471c, and the new HCPS codes and rates, are the
culmination of several years of “systems change” projects involving DHS,
IVRS, and other partners. You may know this effort as “Medicaid
Employment Redesign” which has involved staff and national technical
experts from the ICIE (Iowa Coalition on Integrated Employment), E1st
(Employment First State Leadership Mentor Project), and SELN (State
Employment Leadership Network). This effort has been evolving since
2009, and in earnest since 2012.
Where do I find these Rules?
Please refer to Informational Bulletin 1665 for detailed information including
links to the administrative rules.
https://dhs.iowa.gov/sites/default/files/1665_HCBSPrevocationalandSuppor
tedEmploymentServiceChanges.pdf
How and why was the May 4th date
chosen?
The effective date of May 4, 2016 is purely a function of the administrative
Rules timeline; this date results from the date the Rules were officially filed
It is my understanding that DHS will work
with the MCOs, requiring them to change
contracted work services rates to the new
schedule. If this is not correct, please
advise.
The fee scheduled posted on the IME Fee Schedule website at:
https://dhs.iowa.gov/ime/providers/csrp/fee-schedule has been shared with
the MCOs. The MCOs are in the process of making the changes needed
to implement the new rules.
Will these codes and fees be automatically
given to the three MCO'S, or do we have to
contact the MCO'S and negotiate with
someone to get them added to our
contracts?
See response above. The rates paid by the MCOs are negotiated between
the MCOs and their providers, the IME can not address to the MCOs
reimbursement negotiations. Providers serving FFS members and billing
the IME will be paid at the posted Fee Schedule rate.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Does this rule and fee schedule change
include employment services funded by
habilitation?
Yes. The provider qualifications, service definitions and reimbursement
methodologies and rates are now consistent across the HCBS ID and BI
Waivers and the Habilitation program.
I knew the rules were passed, but I thought
I saw something that said the fees could not
be implemented until CMS approves Iowa's
proposed waiver amendments. Did that
happen?
The department has chosen to implement the changes up[on the effective
date of the administrative rules and will be submitting the state plan
amendment and waiver amendments adopting the changes.
On the first page of the flowchart, near top
left, it says if 24+ and needs career
exploration, apply to IVRS. I know it's kind
of late, so maybe I'm just confused, but I
thought these individuals worked through
waiver? If you could clarify, would be
greatly appreciated! (via IACP email 4/29)
What the box actually says, for both Medicaid members who are in
prevocational already and also those not yet in prevocational, “If the
member is 24+ years old, authorize Career Exploration and assist them to
apply to IVRS. …”
The rules state that the waiver can not pay
for services that are available through VR or
the department of education is a denial
letter required from IVRS or the Dept. of Ed
before Prevocational or Supported
Employment services can be authorized
under the HCBS programs?
Medicaid does not require a denial letter from IVRS or the Dept. of
Education in order for members to access like services through the waivers
or Habilitation.
To meet this requirement the Case Manager, or Care Coordinator
documents in the member's person centered service plan that the reason
that services are not available through IVRS or the school system for
members still in school. This is outlined on Page 65 of the
HCBS Provider Manual.
https://dhs.iowa.gov/sites/default/files/HCBS.pdf
This is also outlined in administrative rule 441 IAC 78.27(10)(f)
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Define commensurate experience
Commensurate experience is defined as: work experience that would equal
to the educational requirement. If a BS is a four year degree then in lieu of
the 4 year degree we would expect to see four years of work related
experience in either organizational or community employment.
What is the IME measuring for outcomes
data related to employment services?
Specific details on data requirements can be found at this link...***LeAnn
can we insert the link to the Access And Quality (ACCQUAL): Report of
Employment. As a general response, MCOs are expected to collect a two-
week period of employment data that occurred in the reporting months of
April and October. MCOs can determine the experience period to be
reported. Data to be collected for members competivevly employed is
hours worked during the reporting period, and hourly wage/earnings.
How often is the case manager and/or care
coordinator to have contact with the
member?
The case manager and/or care coordinator are to have monthly contact
with the member, and monthly contact can be collateral. Face-to-face
contact with the member is to occur quaterly.
Provider Qualifications
Please click on the following
link for a staff qualification
& training requirments tool:
Insert link for table.
The new education / experience
requirements for a staff providing Individual
Supported Employment require a Bachelors
degree or commensurate experience,
preferably in human services, sociology,
psychology, education, human resources,
marketing, sales or business. My question
is: would a combination of education and
commensurate experience qualify? For
example an Associate degree and
commensurate experience
Yes, a combination of commensurate experience and education is
acceptable.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
New 01/15/2020
I am enrolled to provide Prevocational
services, can I choose to only deliver
Career Exploration services (T2015 U3)
and not provide tradtional Prevocational
services (T2015) ?
An enrolled Prevocational service provider may choose to only provide
Career Exploration (T2015 U3) and choose not to provide traditional
Prevocaitonal services (T2015). A provider choosing to deliver traditional
Prevocational services (T2015) must also offer Career Exploration (T2015
U3) services to participants.
For individual supported employment (SE)
the rules state “nationally recognized
certification for an employment support
professional (APSE's CESP) and complete
employment specialist training (ACRE
approved training or College of Employment
Services (CES) or similar). ”
For job coach and small group SE the rules
state “nationally recognized certificate of
completion in job training and coaching.”
For direct support pre-voc staff the rules
state “9.5 hours offered through Direct
Course or ACRE approved training."
The employment services training we
currently receive through IACP is called
College of Direct Support through U of IA.
Is Direct Course the same as College of
Direct Support?
Yes the Direct Course/ College of Direct Support - Employment Supports
is the IACP sponsored training and may be used to meet the 9.5 hours
training requirements.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
For Individual SE, the person must hold
nationally recognized certification for an
employment support professional (APSE's
CESP) and complete employment specialist
training (ACRE approved training or College
of Employment Services (CES) or similar).
For the employment specialist training, does
this include both of the following:
• College of Employment Services
(through CDS) course completion for
employment specialist where a person
obtains a certificate of completion for the
online employer development courses.
• IA-APSE (ACRE approved) foundations,
job coach and employer development
For the 9.5 hours of initial training and 4 hours of annual continuing
education, the dept. recognizes the training offered through APSE or IACP;
and for credentialing and certification we recognize any nationally
recognized employment specialist certification for ISE, and for the LT Job
Coaching and Group Employment we recognize the training course offered
through APSE or IACP.
Do current career counselors/job coaches
that are employed by the schools need to
meet the new certification guidelines
Any provider billing the IME or MCOs for Prevocational or SE services must
meet the staff training requirements in rule.
Within Individual Supported Employment
Staff Qualifications – if I have staff currently
working as Job Developers who do not
meet the requirement for a BA or
commensurate experience (4 years) quite
yet, will they be able to work under the new
rules?
Yes, we would expect the staff already in place and working to meet both
requirements within the 24 month time frame.
(1) Individual supported employment: bachelor’s degree or commensurate
experience, preferably in human services, sociology, psychology,
education, human resources, marketing, sales or business. The person
must also hold nationally recognized certification for an employment
support professional (APSE's CESP) and complete employment specialist
training (ACRE approved training or College of Employment Services
(CES) or similar) and must earn this credential within 24 months of hire or
within 24 months of May 4, 2016.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
If an Employment Specialist has their Job
Coaching/Job Development certificate of
completion and has a Bachelor Degree or
commensurate experience, do they still
need the 9.5 hours of employment training
in addition to this if they also do Long Term
Job Coaching?
If the staff person hired to provide Job Coaching services, has their
Certification for Employment Support Professional (CESP) or completed
other nationally recognized certificate of completion in Job Coaching, then
they already exceed the 9.5 hours of training within 6 months of hire
requirement and would be considered to be in compliance with the
requirement.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Where do I find the 9.5 hours of
employment training?
* DirectCourse is available to all Iowa HCBS providers through IACP, r
See directcourse@iowaproviders.org or visit www.iowaproviders.org and
click on “DirectCourse“
* Ameirgroup offers DirectCOurse to its provider network, contact
Amerigroup Provider Relations for addtional information
* Iowa-APSE offers ACRE approved Community Employment Services
Training. See http://www.iowa-apse.org/
* The RELIAS platform contains courses for “Community Employment”
which are equivalent to the courses offered through DirectCourse and
includes such courses as: Customized Job Development, Supplemental
Security Income and Work, People with Disabilities Building Relationships
and Community Membership, Customized Employment, Creating
Community Careers
The Department will accept the RELIAS Continuing Education Platform
courses for Community Employment to meet the 9.5 hours of employment
service training and to meet the 4 hours of annual continuing education
requirement for both Prevocational and Supported Employment services.
The Department intends to promulgate rules to formalize the change as
noted below.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
7.25(9) Supported employment habilitation
(1) Individual supported employment:
bachelor’s degree or commensurate
experience, preferably in human services,
sociology, psychology, education, human
resources, marketing, sales or business.
The person must also hold nationally
recognized certification for an employment
support professional (APSE's CESP) and
complete employment specialist training
(ACRE approved training or College of
Employment Services (CES) or similar) and
must earn this credential within 24 months
of hire or within 24 months of May 4, 2016.
Clarification: The person providing Individual Supported Employment
services has 24 months from the date of hire to meet the educational
requirements and earn the Employment Support Professional certification.
(2) Long-term job coaching: associate
degree, or high school diploma or
equivalent and 6 months’ relevant
experience. A person providing direct
support shall, within 6 months of hire or
within 6 months of May 4, 2016, complete at
least 9.5 hours of employment services
training as offered through DirectCourse or
through ACRE approved training. The
person must also hold or obtain, within 24
months of hire, or within 24 months of May
4, 2016, nationally recognized certificate of
completion in job training and coaching.
Clarification: The person providing Long-Term Job Coaching services has
24 months from the date of hire to meet the educational requirements and
complete the APSE or DirectCourse Job Coach training courses.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
(3) Small-group supported employment:
associate degree, or high school diploma or
equivalent and 6 months’ relevant
experience. A person providing direct
support shall, within 6 months of hire or
within 6 months of May 4, 2016, complete at
least 9.5 hours of employment services
training as offered through DirectCourse or
through ACRE approved training. The
person must also hold or obtain, within 24
months of hire, or within 24 months of May
4, 2016, nationally recognized certificate of
completion in job training and coaching.
Clarification: The person providing Long-Term Job Coaching services has
24 months from the date of hire to meet the educational requirements and
complete the APSE or DirectCourse job coaching or job development
training courses.
Prevocational Services
An individual age 24 and above does NOT have to be referred to IVRS for
Career Exploration. Of course, if the person wants to work and would
need/benefit from IVRS services (which consist of employment services,
including Career Exploration), they can always be referred to IVRS. IVRS
does not have any age minimum or maximum, a person just needs to be
able to – and expresses a desire - to WORK.
Are Resume writing and interview skills that
may previously been taught as a group in
pre voc still able to be done that way under
the new rules, or is it something now that
needs to be done more individually under
supported employment?
Prevocational services includes teaching skills related to obtaining
employment which would include resume writing and interviewing skills
training.
If a person has started pre voc with one
provider and then switches to another
provider, does the clock start over for
prevocational timing
The time is tied to the person and their service plan not the provider, so it
would not start over if the member switches providers
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
If a person has a Master’s in Vocational
Rehabilitation, do they still have to take the
APSE test or can they appeal or be
grandfathered in
The person would have to be able to demonstrate that their MVR provides
the same curriculum as the national certification.
If we have job coaches who were APSE
certified in job coaching and job
development last year, are they
“grandfathered” in as meeting the
requirement of the 9.5 hours (and go to the
4 hours annually) or do they have to start
with the 9.5 hours effective May 4th?
Re: 77.25(9) Supported employment habilitation
(2) Long-term job coaching: associate degree, or high school diploma or
equivalent and 6 months’ relevant experience. A person providing direct
support shall, within 6 months of hire or within 6 months of May 4, 2016,
complete at least 9.5 hours of employment services training as offered
through DirectCourse or through the ACRE certified training program. The
person must also hold or obtain, within 24 months of hire, nationally
recognized certification in job training and coaching.
If staff are currently working and have completed the APSE certification
prior to the new rules being implemented, we would consider the 9.5
hours of training to be met.
Prevocational -
Career Exploration
Does the 34 hours of Career Exploration
run concurrent with the 90 days in pre-voc,
or is it 34 hours plus 90 days?
For members enrolled in Prevocational services on or before May 04, 2016
the 90 day clock starts after the member has completed the 34 hours of
Career Exploration services by having a written career plan. The 34 hours
of Career Exploration service may be authorized concurrently with
Prevocational hourly services and occurs over a 90 day period of time. The
90 day period may occur at anytime during the 24 month period.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Since Career Exploration is at a different
rate than pre-voc, how will it be billed
separately?
Prevocational and Career Exploration have two separate procedure codes
which will be authorized in the members service plan. Prevocational hourly
procedure code is T2015 and the Career Exploration procedure code is
T2015 U3. The U3 modifier is used to differentiate between the two
services.
How is career exploration different from
individual supported employment?
Currently our employment coordinator
provides services that include employment
preparation, planning, and support.
The differences in the two services is the expected outcome of the service.
Career exploration is intended to develop a career plan that can then be
utilized to identify the ongoing supports that a person may need to obtain
and maintain employment.
“Career exploration,” also referred to as “career planning,” means a person-
centered, comprehensive employment planning and support service that
provides assistance for waiver program participants to obtain, maintain or
advance in competitive employment or self-employment. Career exploration
is a focused, time-limited service engaging a participant in identifying a
career direction and developing a plan for achieving competitive, integrated
employment at or above the state’s minimum wage. The outcome of this
service is documentation of the participant’s stated career objective and a
career plan used to guide individual employment support.
“Supported employment” means the ongoing supports to participants who,
because of their disabilities, need intensive ongoing support to obtain and
maintain an individual job in competitive or customized employment, or self-
employment, in an integrated work setting in the general workforce at or
above the state’s minimum wage or at or above the customary wage and
level of benefits paid by the employer for the same or similar work
performed by individuals without disabilities. The outcome of this service is
sustained paid employment at or above the minimum wage in an integrated
setting in the general workforce in a job that meets personal and career
goals. Supported employment services can be provided through many
different service models.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Is career exploration part of pre-voc or
individual supported employment, or both?
Career Exploration is a Prevocational service and may also be an activity
through Individual Supported Employment for those folks not choosing to
participate in the Career Exploration service through a Prevocational
service provider.
Members served in our pre-voc program are
typically served from 8:15 A.M. to 1:45
P.M. Can we include their half hour lunch
time in our billable hours since they are in
the program during that time?
Meal time support is not considered a prevocational service and is
therefore not billable time.
Can we bill for services that help individuals
with volunteer opportunities? In 78.27(9)
page 8 it says it is part of pre-voc but on
page 9 it is excluded. This seems to be
conflicting information.
A member may participate in volunteer opportunities that provide work
experiences during Prevocational services; however that does not include
support for members volunteering in for-profit organizations and
businesses other than for-profit organizations, or businesses that have
formal volunteer programs in place (e.g., hospitals, nursing homes), and
support for members volunteering to benefit the service provider.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Currently we have to reach 4.25 hours to bill
a unit for a day. If a client leaves early for
any reason, we do not get to bill for a partial
day. Under the new hourly rates, will we
have to reach a threshold for hours in a day
to bill or could we bill for one hour in a day?
- Is there any rounding for the hour? Our
clients are typically scheduled 5.5 or 6.5
hours in a day. Can you bill partial units? If
so, what is the break down, half or quarter
hours for example. Is there any rounding?
If a client trains 3 hours and 39 minutes for
example, do we round down to 30 minutes,
round up to 40, not get paid for that time at
all because it didn’t reach a full hour?
Hourly services should be rounded as follows:
• Add all the minutes provided for a day
• When the total minutes for the day is less than 60, round up to one (1)
whole unit
• When the total minutes for the day is more than 60, divide the total by 60
to get the number of hours for the day. This should be rounded to the
nearest whole unit, by rounding down for 1-30 minutes, and rounding up for
31-59 minutes
Individual Supported
Employment
Please clarify that the unit of service for
Individual Supported Employment.
The unit of service for Individual Supported Employment is an hour.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Providers authorized for Job Development (JD) in March 2016 were able to
bill for the JD at the time the services were authorized in the members
service plan. Those providers should have already gotten paid in April for
JD services to assist the member to obtain a job. The unit of service for
the $955.00 payment under the old model is a job the member holds for 30
days, and even though the provider gets paid up front, the outcome is the
member obtaining a job and holding the job for 30 days.
If the member was authorized for JD and after May 4, 2016 the member
still has not obtained a job, the SE-JD provider will need to provide the
service documentation for the JD services provided to the member to
evidence the provider’s efforts and activities related to assisting the
member to obtain a job before Individual Supported Employment may be
authorized. This is due to the provider already receiving payment to "obtain
a job" .
If the service documentation provided for JD shows that reasonable efforts
have been made and the individual still did not obtain a job, it would be
reasonable to authorize Individual Supported Employment to continue to
assist the member to obtain employment. If the provider cannot provide
documentation of the JD activities or the documentation does not support
the JD reimbursement already received, then authorization for ISE with
that specific SE provider would not be appropriate. In these type of
circumstances where the member still needs the services but the provider
could not demonstrate the necessary outcomes, it would be most
appropriate to locate a SE provider who may be better equipped to support
the member in their job search activities.
Initial Job Coaching 90 days to stabilization may be provided as part of the
Individual Supported Employment service or as a Long Term Job Coaching
service.
Case Managers have been questioning our
request for the Individual Supported
employment service that we have
requested, some saying that they would
need something to justify the need for this
service, since the lump sum was just issued
in March. • If we
don’t get the Individual SE for Job
Development we won’t be able to bill for any
indirect supports which started May 4.
• The old codes are gone, the lump
sum is no longer a Medicaid service – we
need to be authorized for a service that
exists
• If someone were to get a job, the
initial job coaching has to be covered under
the Initial Supported Employment, which we
wouldn’t have if they don’t authorize it.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Could you clarify the CMS definition &
activity #16 “Systematic instruction and
support during initial on-the-job training
including initial on-the-job training to
stabilization” as it relates to Individual
Employment
Systematic instruction and support during initial on-the-job training
including initial on-the-job training to stabilization” as it relates to Individual
Employment allows for the Employment Specialist to continue to work with
the member on the job while they stabilize in their job and have a “warm
handoff” to the LT Job Coach. It would work the same if they were
receiving “stabilization support” from IVRS with a “warm hand off” to the
Medicaid HCBS LT Job Coach.
With Individual Supported Employment
services authorized at a max of 40 units
initially and a possible 20 additional per
year, can you clarify when a member’s year
re-sets? I would assume it’s at annual
planning.
The member may access up to 60 units per 12 calendar months which
would generally coincide with the member's annual service plan
authorization. i.e. If the member accessed 60 units of ISE between May
2017 and August 2017, the member could beauthorized to access another
60 units of service between May 2018 and August 2018.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Where does job coaching from placement
to stabilization fall in this matrix? From the
information in the webinar and explanatory
handouts, I get the understanding that it
should fall under Individual Supported
Employment T2018 until stabilization is
reached. Is that correct? Or will it be under
Long Term Job Coaching
(updated 7/22/2016) Initial on the job training to stabilization may occur
either through Inducual Supported Employment if the annual limit on the
number of units has not been met otherwise this will occur as Long Term
Job Coaching Activity.
78.27(10) Supported employment services
(2) Expected outcome of service. The expected outcome of this service is
sustained employment,
or self-employment, paid at or above the minimum wage or the customary
wage and level of benefits
paid by an employer, in an integrated setting in the general workforce, in a
job that meets personal and
career goals. Successful transition to long-term job coaching, if needed, is
also an expected outcome of
this service. An expected outcome of supported self-employment is that the
member earns income that
is equal to or exceeds the average income for the chosen business within a
reasonable period of time.
(4) Individual employment strategies include but are not limited to:
customized employment, individual placement and support, and supported
self-employment.
Service activities are individualized and may include any combination of the
following:
20. Initial on-the-job training to stabilization activity
Long Term Job Coaching
If we job coach someone a total of 9 hours
a month which would be tier 3, but let’s say
that they call in the last day. This situation
would put one in a different tier. Do we bill a
different tier or do we lose out on the
number of hours we job coached?
The Tier is based on the average hours worked over the course of a
calendar month. The member remains in Tier 3 (H2025 U5) for the entire
month. If the average hours over the course of the month fall below the 9
hour threshold and that is the new “ average” for the person then the Tier
would be changed to Tier 2 for the following month. The provider would bill
for the Tier authorized for the current month and would then bill at the new
Tier for the following month.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Does an individual need to have a formal
goal in place for the provider is only doing
one contact per month under Long-Term
Job Coaching?
ID Waiver 441 IAC 83.61(1) & BI Waiver441 IAC 83.82(1)
Yes,the member must have a formal goal documented in their service plan
to sustain or maintain employment in order to receive the long-term job
coaching. There must be justification in the service plan for any service
being received.
Can an individual use long-term job
coaching to help them get their driver's
license and/or other transporation supports?
Job coaching must be directly tied to the member maintaining their
employment or advancing in employment. If having a driver's license is
directly related to the member maintaining their employment because it is a
requirement for the job then that would be appropriate to assist the
member in obtaining their driver's license, however if the member isn't
required to drive for their job, then it would not be a billable service and
would be more appropriately provided under an SCL/HBH service.
Transportation of the member during LT Job Coaching services is billable
when it is designed to assist the member with retaining individual
employment.
Is long term job coaching a long term
service?
Long-term job coaching services are designed to assist the member with
learning and retaining individual employment, resulting in workplace
integration, and which allows for the reduction of long-term job coaching
over time. Services are individualized, and service plans are adjusted as
support needs change. The LTJC service should be provided in such a way
that the member is able to fade the number of hours of service over time as
the member builds indpendence and natural supports in the workplace.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
If a member is receiving long term job
coaching supports at a particular tier level,
but due to various circumstances, was not
provided that particular level of support
(either less or more), how is the
employment provider to bill? Do you bill as
approved, vs. the tier level of support that
was actually provided?
Long-term job coaching services should be billed as approved or
authorized. If circumstances occur outside of the provider's control, for
example these circumstances might include, a decrease in work hours due
to an illness or hospitalization, or it might be an increase in hours due to the
availability of seasonal work, these are considered short-term occurances
and that the level of support will remain the same. Submit billing for the tier
approved, ensuring that you documentation/case note(s) reflect what was
occuring for the member that impacted their work hours, and therefore level
of job coaching supports. If it is expected that the member will need a new
level of support, a new tier level should be requested.
Medicaid HCBS Employment Services rule
changes going into effect May 4, 2016.
Part of the rules now say that transportation
to and from job sites can be bundled into
the supported employment time and thus,
billed under the supported employment
code and rate. I just want to clarify that this
is just an option. If we want to continue
providing the transportation under T2003
HCBS Waiver Transportation and billing as
a per trip service, we are allowed to do so
as long as there is authorization for it,
correct
The Supported Employment services; Individual Supported Employment ,
Group Employment and Long Term Job Coaching include transportation of
the member during service hours. Community transportation options (such
as driving oneself, carpools, public transportation, being transported by co-
workers, families, volunteers, etc.) shall be attempted before the service
provider provides transportation.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Updated 01/21/21
How do I determine the total hours of Long
Term Job Coaching that I provided over the
course of a month?
LTJC is billed for one unit of service per month with the exception of Tier 5
for those members requiring more than 26 hours of staff support on the job
each month which is an hourly unit of service.
LTJC Tiers 1-4 are a monthly unit of service
To determine the total hours of LTJC provided during a month, the
provider::
• Documents the exact start and stop time for each service encounter and
totals the exact time spent on the encounter on the service note. For
example if the service start time is 10:30 am and the service end time is
3:35pm the provider records 5 hours and 5 minutes for total time spent for
that date of service. Rounding of time is not applicable to monthly units of
service.
• The total time spent for each date of service provided over the course of a
month is totaled at the end of the month to determine the amount of hours
of service provided for the month.
Transportation
Will these codes and fees be automatically
given to the three MCO'S, or do we have to
negotiate with the MCO'S to get them
added to our contracts?
The fee scheduled posted on the IME Fee Schedule website at:
https://dhs.iowa.gov/ime/providers/csrp/fee-schedule has been shared with
the MCOs. The MCOs are in the process of making the changes needed
to implement the new rules.
Procedure Codes and
Rates
How were the rates arrived at? Our
prevocational hourly rates are better than
this now.
The new rules comply with CMS’s employment guidance and settings rules,
and national technical experts helped us with a rate development model
that incentivizes staff development for supported employment. We
honored recommendations from our ad-hoc 2013 workgroup of providers,
family members, and funders, and ultimately had to build rates that allowed
the Medicaid budget for employment services to meet cost neutrality.
Our floor rate for Prevocational Hourly is
higher than the fee schedule. Will floor
rates be honored?
The rates paid by the MCOs are negotiated between the MCOs and their
providers, the IME can not address to the MCOs reimbursement
negotiations. Providers serving FFS members and billing the IME will be
paid at the posted Fee Schedule rate.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
We offer some group supported
employment. For the ID waiver, we
currently bill using code H2023 for group
supported employment (no modifier). For
Habilitation we bill using code H2023 UC
(with a modifier). Thus, we are using
slightly different billing codes depending on
the payer. On the new rate sheet, there is
no differentiation between the
codes/modifiers for ID waiver and for
Habilitation. Is it right, that we are to use
the same codes/modifiers regardless if
waiver or habilitation?
The procedure codes and Level II Modifiers are the same regardless of
which program the service is provided under. The department will be able
to identify which program the services were delivered under by the
members waiver or Habilitation enrollment and the billing provider's
number.
Where are the prior authorization
requirements for employment services?
Please refer to Informational Letter 1665 for the prior authorization process
for Fee-For-Service (FFS) members.
https://dhs.iowa.gov/sites/default/files/1665_HCBSPrevocationalandSuppor
tedEmploymentServiceChanges.pdf
Prior authorization requirements for LTSS are in the MCO provider
manuals:
Amerigroup
https://providers.amerigroup.com/Public%20Documents/!AIA_ProviderMan
ual.pdf
AmeriHealth Caritas
http://becomeaprovider.amerihealthcaritas.com/pdf/iowa/provider-
manual.pdf
United Healthcare
http://www.uhccommunityplan.com/content/dam/communityplan/healthcare
professionals/provider-
adminmanual/IA_UnitedHealthcare_Provider_Manual.pdf
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Prior Authorization of
Prevocational and SE
services
What is the expected time frame for service
plan authorization for employment services?
FFS Service plan authorization must occur within 7 days from the request
when all necessary information has been provided to the Medical
Services reviewer, and 3 days if it needs to be expedited. MCO Service
plan authorization must occur within 7 days from the request when all
necessary information has been provided to CBCM/IHH to be reviewed by
utilization management, and 3 days if it is an emergent need. Sometimes
you need a speedy review, let's say someone is offered a job on Thursday
to start Monday. This is an example of an emergent need.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
With move away from outcome payment in
what was Job/Employer Development, how
will the transition work to this new billing
format? – Specifically, if I’ve been working
for several months with a person to obtain a
job and happen to find success shortly after
May 4, is there any way to collect for the
work we did prior to the rule change, or will I
only be able to bill the few hours provided
between 5/4 and the date the job was
obtained?
Providers were able to bill for the job development at the time the services
were authorized in the members service plan. For Job Development
services authorized and claimed prior to May 4, 2016, providers should
have billed for those services. If not, then the provider would need to claim
the service for a date prior to May 4, 2016.
If the provider has been reimbursed for Job Development and if the
member still has not obtained a job, the provider will be asked to provide
the documentation supporting their efforts to justify authorization of
Individual Supported Employment. If the documentation evidences
reasonable efforts towards helping the member obtain a job, it would then
be justified to authorize Individual Supported Employment.
(updated 7/22/2016) Individual Supported Employment may be authorized
for up to 40 hours/ units per year initially and an additional 20 hours/ units
within that year if they continue to need individual employment to obtain a
job and stabilize a that job. Individual SE is prior authorized and limited to:
Procedure Code: T2018 Initial authorization: $65.47 per hour
Not to exceed 40 hourly units
Extended authorization: $65.47 per hour
Not to exceed 20 hourly units
( updated 07/22/16)
One initial and, if necessary, one extended authorization permitted per year
not to exceed a total of 60 hourly units per year (updated 7/22/16)
Total monthly cost for all supported employment services not to exceed
$3,029.00, per month
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Claims and Billing
Our organization is in the process of
phasing out prevocational services, with a
targeted end date of June 30, 2016. Our
current program offers prevocational
services in an segregated facility setting.
The new rules indicated that prevocational
services must be offered in an integrated
community setting. Will we need to
accelerate the closure of the segregated
facility based prevocational program?
The requirements for a home and community based services to be
delivered in community based settings are not new requirements. As part
of the statewide transition, the state as well as providers must evaluate the
experiences of members participating in services in terms of their
participation and access to the community during service delivery.
The state is required to be in full compliance with the CMS HCBS Settings
requirements by March 17, 2019 at the latest. The state submitted an
updated statewide settings transition plan (STP) to CMS on April 1, 2016.
You can view the Statewide Transition Plan (STP) at
http://dhs.iowa.gov/ime/about/initiatives/HCBS
Question as it relates to T2018 and H2025:
for Habilitation and Waiver Services. Can
staff document all their time that is involved
for the client receiving SE services. (noting
that it cannot all be on behalf of)
Can staff document on all of the following
time as billable time: Staff drove to meet
client a job site and provided job coaching
services and drove back to where they were
before they started working with the client.
Staff completed some documentation while
with client.The following could not be billed
for. Once staff returned to the office they
completed documentation on the prior job
coaching activity.
Individual Supported Employment activities on behalf of does not include
documenting those activities. However the provider may bill for any
activities completed on behalf of the member which are directly related to
the member obtaining or maintaining employment.
If the Employment Specialist drove to the job site to meet with the employer
the drive time without the member present is included in the ISE rate and is
not separately billable, but the time spent meeting with the employer on
behalf of the member is billable time.
The time spent driving to the job site without the member in the vehicle is
not billable time Transporting the member for the purposes of the job such
as transporting the member from home to the job site and from the job site
to home or to another job site is billable time. Staff time spent driving to get
to where the member is located is the cost of doing business and is
included in the ISE and LTJC rates.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
Settings
Who is going to develop jobs and do job
coaching for the high school students
referred to VR? Will VR or school staff do
it? Or does VR just refer to the provider
and regulate/fund?
When the IEP student is still in high school, the job coaching is considered
to be an instructional component of the IEP which is the responsibility of
the school, if this need is a result of the student’s disability. The school can
either provide these services themselves or they can contract with another
entity (i.e. a CRP) to provide the services. IVRS has agreed to cover the
costs of the job development, per the Moan between IVRS and the DE. Any
time these services are considered, a team meeting will be held to assure
the team is on board with this decision. If a school chooses to purchase
services through a CRP, IVRS can provide guidance if the school needs
this, however, it is ultimately up to the school as the purchaser of those
services.
Iowa Vocational
Rehabilitation Services
(IVRS)
What is being done to inform and develop
employers for the students leaving the
school under VR?
IVRS has a counselor assigned to every high school in Iowa who is
charged with facilitating and/or providing transition services to eligible or
potentially eligible candidates of IVRS. The primary goal of IVRS staff is to
help a job candidate obtain, regain or maintain employment so staff are
always making contacts within their communities with employers, as well as
developing new ones. Additionally, for any IVRS job candidate who
requires Supported Employment Services, IVRS staff contract with CRP
partners that provide SES in order to contract out for these services.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
What are IVRS Employment Services?
Just to fund or do the services include job
development and placement by VR? If they
rely only on providers there will be quite a
long waiting list.
There are 14 different employment services that IVRS staff are able to
contract for on behalf of an IVRS job candidate from CRP partners that
have a contract with IVRS for employment services. Each of these 14
different employment services are explained in full detail in the Menu of
Services Manual on the IVRS website:
http://www.ivrs.iowa.gov/partners/CRPpage.html
As mentioned in answering question 6, IVRS staff contract out for
Supported Employment Services which includes Job Development. IVRS
also contracts out for most of the other 14 employment services, however
some services such as Job Shadowing Assessment, Transportation
Training, Job Seeking Skills Training, Career Exploration and Non-
Supported Job Coaching may be provided by IVRS staff. Each
employment service that IVRS staff contract for through a community
provider is determined on a case-by-case basis depending on the specific
needs presented by an IVRS job candidate.
We have a work experience program for
high school students prior to their
graduating from school. We have no
contract with the schools and we receive no
funding. School staff come here with their
students and supervise them and we pay
the students for their time at work. This is
totally unrelated to Medicaid. Can the
districts continue this?
The final regulations of the WIOA legislation have not been released, but
our current understanding of this legislation is that schools are not allowed
to contract with CRPs to directly provide transition services to students into
segregated programs. Schools are allowed to contract with CRPs for all
services within an integrated community setting that are not sub-minimum
wage. The key in this is that the work is integrated and meets the
integration definition, most specifically that co-workers are not disabled and
it is located in a business in the community
What obligations do Regions have for this
service structure and these rates, with
regard to contracting with providers, and
can Regions wait until the July 2017
contracting period to implement this
structure and these rates?
Regions are not obligated to adopt Medicaid service design or
reimbursement.
DHS, IME, Policy Unit 01/21/2021
FAQ HCBS Prevocational and Supported Employment Services
DHS, IME, Policy Unit 01/21/2021
