Bettina Carroll

Director for Programs and Contract Management

HIV Care Services/Public Health Solutions

September 18, 2012

Background

• April 2011 HRSA implemented Monitoring Standards for RW Part A/B grantees

• Introduction of Eligibility Determination Screening process

• Programs required to assess and maintain documentation of client eligibility including: proof of income-based on EMA-developed criteria proof of residency-within the five boroughs of NYC,

Westchester, Rockland and Putnam counties

Implementation Process• New York City Department of Health and Mental

Hygiene Bureau of HIV/AIDS Prevention and Control (DOHMH/BHIV) issued correspondence to providers (10/31/11 and 12/16/11): Documentation of Proof of ResidencyPolicy overview (including exempt service categories)Process for implementation of processTimeline for implementation of processOverview of acceptable documentation

Implementation Process (cont’d)• JoAnn Hilger, MPH/DOHMH, presented HRSA Monitoring Standards

for Ryan White Part A & B Grantees to the HIVCS CAG on October 26, 2011 Clients will be subject to income eligibility standards starting March 1, 2012 Clients will be required to provide evidence of EMA residency for eligibility

starting March 1, 2012

• HIV Care Services Contractor Newsflash – December 2011 - detailed client eligibility review and documentation process to be initiated as of March 1, 2012

Implementation Process (cont’d)• Amended Contract Scope of Services language with FY 22

contract renewals

• Initiated monitoring of compliance as of March 1, 2012

• Provided technical assistance to programs regarding implementation

• Documented “recommendations” for compliance in site visit reports

• Postponed implementation of compliance actions until September 2012

Site Visit Monitoring of Eligibility Check Compliance

Ninety-seven (97) routine/reimbursable site visits for the applicable service categories were conducted for services delivered in the contract period beginning 3/1/12. Below are the aggregate numbers for programs compliance in checking eligibility.

# of programs that were compliant with conducting

checks

# of programs that were not compliant

with conducting checks

# of programs that were partially compliant with

conducting checks

Income eligibility 37 (38%) 9 (9%) 51 (53%)

Residency eligibility

34 (35%) 9 (9%) 54 (56%)

Issues related to compliance(feedback from providers)

• Client resistance to/fear about providing documentation

• Time consuming process (particularly with “old” clients)

• Difficulty getting documents from homeless clients

• Difficult to obtain copy of documents for clients seen in the home; innovative methods may breach confidentiality

Issues related to compliance(feedback from providers cont’d)

• Unaware of/confused about when requirements for eligibility checks should be implemented

• Unaware of acceptable documentation for eligibility checks

• Transient population (inconsistent attendees)

• Clients forget to bring documentation

Questions from programs regarding documentation of eligibility

• Can e-PACES be used to verify residency and income eligibility?

• Can transportation logs be used for residency documentation?

• If the same documentation is used to establish eligibility in successive years (no status change), is it necessary to re-copy documents?

• Can mail from the program sent to a client’s address be used as proof of residency?

Questions from programs regarding documentation of eligibility (cont’d)• Can a HASA referral letter document residency and

income eligibility?

• Can identification cards for other health insurance, with Medicaid-similar income criteria, be used to document income eligibility?

Best Programs Practices

• Development of a form/checklist of documents needed to enroll clients

• Development of “eligibility documentation” section created in the client record

• Development of Attestation Form detailing required elements as statements; used at point of reassessment

This is to certify that I, _______________________________ can attest that the following has

Changed Not Changed as of _____________ (Date):

Client Home Address No Yes New Information ______________________ Client Household Income No Yes New Information ______________________ Medical Insurance Information No Yes New Information ______________________ ______________________________ _____________________________ Client Signature Staff Signature

Sample Attestation Form: courtesy of HHC Harlem Hospital

Next Steps• HIVCS and DOHMH will review current process and

need to revise the scope amendment to adjust documentation requirements:

Inclusion of additional acceptable documentation Process to collect/reflect documentation

Questions for the CAG• What barriers have you found in implementing the

process?

• How have you addressed these concerns?

• Are there suggestions for eligibility documentation which we have not considered?