Tuesday, April 3, 2012

Michigan's Plan for Dual Eligibles: Comment on Self-Determination, Opting-out, and Physical Health Care

Self-determination and available service settings for people with DD

Currently, Self-determination is an option under state guidelines. It is an approach to serving people with DD (and others in the CMH system) that allows for individualized budgets and gives the person the ability to hire and fire service providers. While self-determination has been an innovative and useful approach for many people with DD, it is not the only or best approach for providing appropriate services for all people with DD, especially those with more extensive needs who may be safer, happier, and better served in congregate licensed settings.

In addition, under services provided by the plan, there is no mention in the proposal of Adult Foster Care homes in community settings that provide services for people who need a high level of care.

Will these settings continue to be available? Will day programs continue to be available for people with DD? Will self-determination continue to be optional, available to those who want to pursue this approach to providing services?

Penalties for opting out

There needs to be a fuller explanation of the services that will not be available to people who decide to opt out of the Dual Eligibles plan.

What are “enhanced dental and vision” services that will not be offered to people opting out? The ramifications of a decision to opt out needs to be fully understood by Medicaid and Medicare beneficiaries. Penalizing people who make that choice needs to be justified.

Physical Health Care

The ICOs will manage the provision of physical health needs of dual eligibles in the mental health system. The plan (page 17) says that ICOs may provide other physical health services at the option of the ICO, such as expanded dental services, vision services, and hearing aids, and are strongly encouraged to do so.

Does this mean that people with developmental disabilities will only receive these services depending on where they live and whether the ICO wants to offer these services rather than based on need?

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