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Full PDF Version - ASPE - U.S. Department of Health and Human ...

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Options for Designing Service Coverage: General Considerations 59circumstances such as (a) out-<strong>of</strong>-home respitecare, <strong>and</strong> (b) room <strong>and</strong> board <strong>of</strong> a live-in caregiver.Federal financial participation is available forroom <strong>and</strong> board provided as part <strong>of</strong> respite carefurnished in a facility that is approved by the state<strong>and</strong> not a private residence. Respite care is availableas a service under HCBS waivers, but not asa distinct service under the state plan. 5The expectation is that individuals will use theirown income <strong>and</strong> resources (e.g., Federal SupplementalSecurity Income [SSI] benefits <strong>and</strong> earningsfrom employment) to meet room <strong>and</strong> boardexpenses. This exclusion can complicate development<strong>of</strong> strategies to support individuals in thehome <strong>and</strong> community. In contrast, room <strong>and</strong>board expenses are Medicaid-reimbursable in aninstitutional setting where individuals receive asignificantly reduced SSI payment ($30/month) asa personal needs allowance.Obligations <strong>of</strong> Other Public Programs. Medicaidis deemed a payer <strong>of</strong> last resort. This means that ifanother public program is obliged to provide aservice to an individual, a state generally may notreplace this funding with Medicaid dollars. Forexample, if two public programs such as Medicare<strong>and</strong> Medicaid cover the same service <strong>and</strong> an individualis eligible for the service in both programs,Medicare must pay first for the service. Medicaidcan only pay once Medicare benefits are exhausted.State Policy Goals <strong>and</strong> ObjectivesFederal policies provide a framework withinwhich states can weigh their options in decidingwhether to <strong>of</strong>fer a service under their Medicaidplan or through an HCBS waiver program. But astate makes its particular coverage choices in light<strong>of</strong> its own policy goals <strong>and</strong> objectives. Five majorfactors need highlighting in this connection.State Budget Impact. States must balance theirbudgets on a regular basis—every year for moststates. This can make a state wary <strong>of</strong> <strong>of</strong>fering servicesunder its statewide Medicaid plan, becauseFederal law prohibits rationing the amount <strong>of</strong>services furnished to individuals or limiting thenumber <strong>of</strong> persons who receive the service underthat plan (as noted in the section on Federal policyconsiderations above).Thus, states are underst<strong>and</strong>ably careful that thecosts <strong>of</strong> <strong>of</strong>fering a service under the state plan notsignificantly exceed available resources, becausethey are uncertain both about how many individualsmight qualify <strong>and</strong> about how much it mightcost to serve each person. One reason many stateshave turned to HCBS waiver programs to exp<strong>and</strong>availability <strong>of</strong> non-institutional long-term careservices is that the amount they will spend in thewaiver context is predictable. This is because astate that <strong>of</strong>fers services under an HCBS waiverprogram is obligated to serve no more than thenumber <strong>of</strong> beneficiaries the state itself establishes.Inclusiveness. While state <strong>of</strong>ficials <strong>and</strong> policymakersmust be concerned about expenditures, itis <strong>of</strong>ten equally important to them that services beavailable to all who require them. This is an argumentagainst providing services through waivers<strong>and</strong> can lead states to cover a particular serviceunder the state plan in order to ensure universalaccess. As discussed below, when deciding whetherto cover a service under the state plan or a waiverprogram or both, states need to carefully considerhow services provided in different programs cancomplement each other in providing people withdisabilities the right service mix <strong>and</strong> amount.Target Populations. Because services <strong>of</strong>feredunder a Medicaid state plan must be provided toall eligible individuals on a comparable basis, itcan be difficult to vary services or service deliveryapproaches based on the needs <strong>of</strong> individualswho have particular impairments <strong>and</strong> specializedneeds. In addition, it is sometimes easier for astate to craft a package <strong>of</strong> services <strong>and</strong> supports tomeet the needs <strong>of</strong> specific groups than to seek aone-size-fits-all state plan coverage design.These considerations frequently lead a state toselect an HCBS waiver program as a vehicle for<strong>of</strong>fering services to defined groups <strong>of</strong> individuals,because the service package can be fine-tuned tomeet their distinct needs.Maintaining a Unified Service Delivery System.While Medicaid is the major funding source forhome <strong>and</strong> community services, it is frequently not

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