Michigan Department of HHS warns against the inappropriate use of assessment tools for people with disabilities

Thomas Renwick, the Director of the Michigan Bureau of Community Based Services, has sent a warning to agencies that fund and provide services to people with developmental and other disabilities: Assessment tools that are inappropriately and arbitrarily used to restrict needed services, supplant Medicaid “medical necessity” criteria, and to achieve budget reductions are not allowable by the Michigan Behavioral Health and Developmental Disabilities Administration (BHDDA).

“Please be advised that any assessment or screening tool, including those required by the Department, cannot be utilized…as an arbitrary means for identifying the amount, scope or duration of services that an individual will receive. While such assessments can certainly help inform the person-centered planning process, it is the person-centered planning process and medical necessity criteria that determine the amount, scope and duration of services. With regards to determining medical necessity, I am not aware that any of the assessments or tools in use or proposed for use have any normed or research supported basis for determining an individual’s medical necessity for services and supports. [emphasis added.] It also bears reminding that the PIHP [the regional agency that administers funding of CMH services] is obligated to ensure that medically necessary supports, services or treatment are sufficient in amount, scope and duration to reasonably achieve their purpose.”

Provider networks must also ensure that individuals are provided proper notice of their rights if they are not satisfied with the outcome of their person-centered planning process.

See also Michigan guidance on the use of the Supports Intensity Scale, an assessment tool that the BHHDD encourages with the consent of the individual but advises that it should not be tied to medical necessity criteria and the authorization of services.