In response to the Hurricane Helene natural disaster in September 2024, the Centers for Medicare & Medicaid Services (CMS) approved several flexibilities to the Innovations waiver to support members to remain safe in their communities. These flexibilities are effective Sept. 26, 2024, through June 30, 2025.
To support Innovations waiver members, families, and health plans in sunsetting these flexibilities, this document outlines the end of each flexibility effective July 1, 2025.
| Appendix K Hurricane Helene Flexibilities | Will this flexibility change? Yes/No | July 1, 2025, Implementation Guidance |
|---|---|---|
| Plan of Care | ||
| Annual reassessments of level of care that exceed the 60-day approval requirement beginning on Sept. 25, 2024, will remain open and services will continue for three months to allow sufficient time for the care manager/care coordinator to complete the annual reassessment paperwork. Additional time may be awarded on a case-by-case basis when conditions from Hurricane Helene impedes this process. Annual reassessments of level of care may be postponed by 90 days to allow sufficient time to complete the annual reassessment and accompanying paperwork. | Yes | Effective July 1, 2025, no level of care redetermination extensions will be allowed. If this flexibility was utilized and the waiver member is outside of the 90-day time frame, a redetermination must be completed. |
| Allow Supports Intensity Scale (SIS) assessment/reassessment to be waived. | Yes | Effective July 1, 2025, no SIS assessments/reassessments will be waived. If the waiver member has not completed a SIS assessment, one must be scheduled by June 30, 2025. |
| Allow utilization review of Individual Support Plans (ISP) and/or revised ISPs to be reviewed and approved (if the request meets medical necessity) retroactively to Sept. 25, 2024, for beneficiaries impacted by Hurricane Helene. | Yes | Effective July 1, 2025, ISP’s will not be reviewed/approved retroactively. |
| Allow Utilization Review and approval of ISPs with care manager/care coordinator signature only. If QP (provider agency) is not able to sign the plan. The care manager or care coordinator should make best efforts to coordinate with QP (telephonically or virtually) to review ISP updates. | Yes | Effective July 1, 2025, all signatures as required (per Clinical Coverage Policy 8P) must be included on the ISP. |
| Services/Service Providers | ||
| Allow beneficiaries to receive fewer than one service per month during this amendment without being subject to discharge. | Yes | Effective July 1, 2025, beneficiaries must receive more than one waiver service monthly. |
| Waive in person face-to-face monthly/quarterly care manager monitoring requirements with the beneficiary, when the beneficiary is not physically accessible. In these cases, virtual and telephonic monitoring will be conducted in accordance with Health Insurance Portability and Accountability Act (HIPAA) requirements. | Yes | Effective July 1, 2025, monthly and quarterly care coordination meetings shall occur face to face. |
| Temporarily include retainer payments to address emergency related issues. | Yes | Effective July 1, 2025, retainer payments will no longer be available. |
| Allow a change in Day Support Group to Day Supports Individual without a change in the Individuals Support Plan (ISP) or prior authorization for waiver beneficiaries impacted by Hurricane Helene. The ISP should be updated as soon as the provider is able to meet with the Waiver beneficiary telephonically or virtually. | Yes | Effective July 1, 2025, a change in the ISP or prior authorization is needed to change Day Support Group to Day Support Individuals. |
| Allow Residential Supports in place of Community Living and Supports, when an individual requires out of home placement, and a Relative as Direct Support Provider or Employer of Record (EOR) is not providing services. Allow service transition without a change in the Individual Support plan or prior authorization for Waiver individuals impacted by Hurricane Helene. The ISP should be updated as soon as the provider is able to meet with the Waiver member/family telephonically or virtually. | Yes | Effective July 1, 2025, Residential Supports may not be used in place of Community Living and Supports. Any changes to services will require an ISP change and prior authorization. |
| Allow replacement or repair of existing home and vehicle modifications damaged by Hurricane Helene when cost of repair or replacement will exceed the Innovations waiver limit. | Yes | Effective July 1, 2025, replacement or repairs of existing home and vehicle modifications must align with the Innovations waiver limit. |
| Allow relatives or Employer of Records who live in the home of the waiver beneficiary (current waiver only allows for Community Living and Supports) to provide Supported Employment and Supported Living for individuals impacted by Hurricane Helene. This should only be used for cases when the direct support staff is impacted by Hurricane Helene and not able to provide services. | Yes | Effective July 1, 2025, Employers of Record may not provide any waiver services. Relatives residing in the home may only provide Community Living and Support per the waiver requirements. |
| Waive staff training requirements within 90 days of employment, if staff training is unable to be obtained during the state of emergency. | Yes | Effective July 1, 2025, staff training requirements will not be waived. |
| Waive training requirements for existing staff for 90 days to continue providing services, if staff is unable to obtain training during the state of emergency. | Yes | Effective July 1, 2025, staff training requirements will not be waived. |
Contact
Questions or comments related to this notice may be directed to iddlisteningsessions@dhhs.nc.gov.