March 23, 2016

Jetta Whittaker

Division of Senior and Disability Services

Box 110680

Juneau, AK 99811

Dear Ms. Whittaker,

AADD, the Alaska Association on Developmental Disabilities, is the professional association representing the voice of thirty providers offering services in Alaska to individuals who experience intellectual and developmental disabilities. We are grateful for this opportunity to address public comment to the Proposed Changes to Regulations 7 AAC 130.220 concerning Medicaid Coverage: Home and Community Based Waiver Services. Provider Certification that relates to Conflict Free Care Coordination.

AADD is very grateful to the Division of Senior and Disabilities for working diligently with the Center for Medicaid Services (CMS) to inform them fully of the grave difficulties of offering conflict free care coordination as defined by CMS in rural and remote areas. We are pleased to see these regulations, inclusive of a possible exceptions, released for comment prior to the deadline for full implementation. We are aware that all of us wish there had been a more extended timeline for Alaska to meet these requirements. Again AADD is very pleased that rural exceptions will be allowed in some locations.

The top priority for AADD is the availability of culturally competent and locally available care coordinators in rural and remote areas of Alaska. The implementation of non-urban exceptions through these regulations is tied to the definition of “insufficient to meet the needs”. We encourage SDS to incorporate a strong preference for locally provided care coordination services in policy, wherever possible and preferred by the family/individual. Being able to access a local care coordinator is particularly important in light of the language and cultural differences in many of our rural and remote communities. In addition, being knowledgeable about local resources and natural supports is very important in smaller communities, where a limited workforce make it more difficult to hire and retain paid supports. Knowledge of the culture, language and local resources would not be strengths of a large organization offering statewide care coordination services. We encourage exceptions to be offered in communities or hubs with agencies who can hire and supervise local care coordinators.

The basic content of the regulations would be clearer if the title could mention Conflict Free Care Coordination. It would clarify the regulations if the language “non-urban geographic areas” was included earlier on Page 1. We suggest: Page 1, (a) read ”The department will certify a provider agency as either a provider of one or more community-based waiver services under (1) and (3) or a provider of care coordination services under (2) unless the department grants an exceptionin a specified non-urban geographic areaunder (i) of this section:”The recommended addition is bolded.

It would also serve the readability of the regulations if that same language was added to Page 2 (j) in the new subsection. With this recommendation (j) would read“(j) the department may grant an exception to a provider in a specified non-urban geographic area under (a)”…The recommended addition is bolded.

We note that on page 3 of the regulations, (k) states that the provider agency will be approved for an exception for three years. This three year re-certification is at odds with the current two year re-certification requirement for agencies offering home and community-based waiver services. In a time of fiscal crisis and reduced staff resources at the state, the mandate of “doing less with less” would be well applied. A three year re-certification cycle for waiver services would reduce the provider burden and cost as well as the work load of state staff.The new provider enrollment fee of $554 for each provider at certification or re-certification is burdensome for small providers. We encourage the department to require re-certification on a three year cycle instead of the current two years.

Again, AADD would like to thank the Division for their persistent work with CMS resulting in Alaska’s ability to grant exceptions in specific non-urban areas to allow more consistent, culturally appropriate and community based care coordination. And we thank you for this opportunity to comment on the regulations.


Lizette Stiehr

Executive Director, AADD