Case Management Redesign FAQs
NEW!!!! Added May 12, 2023
Who are the Board Members who are serving on the PASA Future subcommittee?
From Imagine!’s Governing Board, Chris Dewhurst, Marie Gambon, Rebecca Rose, Walt Pounds, and from the Imagine! Foundation Board of Directors, Brad Bickham and Jessie Thompson. Our Imagine! Governing Board of Directors President, Don Brown, and Vice President, Jodie Gilbert are also attending on a regular basis to support this ongoing work.
What’s the purpose of the subcommittee?
They are an advisory group to the executive team members whose job it is to think about the ways that Imagine! can separate case management and direct services that are least disruptive to clients and staff. A smaller group of Board members like this can dive more deeply into some of the details about services that are relevant to the work underway because they are able to dedicate regular time to the work. Over the summer the subcommittee will learn more about other PASAs, demands for direct services and where there are gaps still to be filled for clients on the part of PASAs. The goal of the subcommittee is to be prepared to review, advise on and present to the rest of the Board of Directors the specific ways that Imagine! can stand strong and sustainably as a PASA on its own and without the larger structure of today that provides administrative structure and support.
What is the timeline for the mandated separation of Imagine!’s case management operations and our direct services organization?
The timeline is still to be determined and is largely connected to the transition date that HCPF will establish for the transition of the case management agency (CMA) once they announce who those CMAs will be. Announcements are due in June of 2023. Change management plans for agencies who will be awarded the CMA for a particular service area are due to HCPF by July 15. We expect to know what our transition date will be sometime in mid-summer.
How is Imagine!’s IT department getting ready for the future changes especially since with the mandated separation of case management operations and direct services IT cannot look like it does today, one central IT department supporting both parts of the organization?
For the last several months, the IT department at Developmental Disabilities Resource Center, the CCB in Jefferson County, has been short an IT Director. DDRC was looking for an immediate solution and given the changes coming in our system, asked if Kevin Harding could step in as acting IT Director. This seemed like the perfect opportunity to see if a business support unit from one CCB could combine with another to provide services to multiple organizations. We’re happy to say that so far, the experiment seems to be working. While there hasn’t been a lot of cross team support, that’s about to change. Imagine!’s Carla Rapp will be working with a member of DDRC’s IT team, Chris Dowd, to project manage an Electronic Visit Verification (EVV) implementation at DDRC. In addition, members of DDRC’s team will be assisting Imagine!’s Micah Rountree as we roll out Microsoft upgrades. We hope this cooperation can be a model for other support departments like the business office and human resources as we navigate the case management redesign waters.
What is a PASA and why are we referring to our direct services as such going forward?
The Program Approved Service Agency (PASA) is the name HCPF assigns to services for people with IDD that go through an approval process with the State of CO. There are hundreds of PASAs in CO and as Imagine! we have been authorized to offer services to those on waivers or to clients who pay directly for their services. As the separation of case management operations and direct services takes place prior to June 30, 2024, our work is to “stand up” our direct services as a full PASA that will compete and complement IDD services delivery to clients across the state.
Why haven’t we heard much about the work going on in direct services?
We have been proceeding with “business as usual” on the direct services side of Imagine! while we made changes to the structure and to some programs to strengthen them for the future. We also have had to address emergent situations, like the one that brought about a decision to close the group home residential services in the Charles Family SmartHome, throughout this past year. Our intent has always been to stabilize as much as possible after the COVID years and the leadership changes that happened over the past three years. Updates on these day-to-day service realities has been delivered through the usual mechanisms of emails, town hall meetings, the Digest, and ongoing meetings within work teams. Our CEO has also spent a number of months learning in depth from other PASAs throughout the State, speaking with their leaders, understanding the array of services being offered statewide and especially in our Boulder and Broomfield counties and surroundings, understanding how other CCBs are separating the case management and service areas of their organizations, and visiting programs and services.
What is the specific work to separate and “stand up” the Imagine! PASA?
The good news is that because the case management operations will be separating to join with ACMI’s case management operations to form a new entity, a lot of “work” – especially all the legal and official type things – for the PASA is already done. For example, direct services as the PASA keep the very special name of Imagine!. And the details about registering with the State of CO, tax exemption status, and the like? Same as today.
What else has to be done?
There is important work that has started with a subcommittee comprised of some Board members from Imagine!’s Board of Directors and some from Imagine!’s Foundation Board members to serve in an advisory capacity to help us look at each program’s strengths and opportunities for growth. The PASA Future Subcommittee has met twice so far and will continue to meet regularly every other week through the summer. They will help Imagine!’s leaders develop models to ensure the PASA can separate in a way that has financial viability, leadership strength and the ability to survive and thrive without being part of a much bigger organization, like today, where expenses and support functions can be shared more widely. Of great importance to the subcommittee and to all of us is honoring our strong legacy of service, preserving much needed services and the high quality always associated with Imagine!, and ensuring as seamless transitions as possible for clients and staff into the newly defined world of the PASA as one of many in the State. Well, as the best, we hope!
What about support functions like HR, IT, and financial/business office?
These are such critical areas of our current day operations. And we must ensure that both the CMA and the PASA have access to high quality services. We do not currently have any details to share on this work, although the leaders of each area are looking at how they can optimize their service models and researching how some of the other CCBs are approaching these same questions. We will provide future updates on this part of our ongoing work.
When will the RFP be posted to the website?
The RFP we submitted to HCPF was a document that was almost 300 pages long, filled with proprietary information about ACMI and Imagine!, and meant only to be seen by HCPF. It is not something we are currently able to share publically. You are encouraged to reach out to HCPF for more information about the RFPs they received.
Will non-waiver programs remain under the management of the Case Management Agency (CMA) when the process is completed and awards are made?
Per HCPF, State-general funded programs, such as FSSP and the State Supported Living Services (SLS) Program, will remain under newly appointed CMAs once those decisions are made in the spring. As of this response, we are planning to manage other non-waiver programs, not funded by the State General Funds, as we do today, under the leadership of the newly formed case management agency (CMA) as determined by HCPF at the time awards are made this spring.
How will the CMRD affect the support our son with an intellectual disability son is receiving today?
Imagine!’s goal throughout this process is to minimize disruptions in services and to ensure that we do all we can to continue our mission of creating a world of opportunity for all abilities. A reminder that the State of Colorado and the State of Colorado and the state’s Department of Healthcare Policy and Financing (HCPF) are directing this process. Therefore, we are unable to answer specific questions about the future of individual services until we have more information from HCPF.
How will various departments, services, and the CMA be housed in Imagine!’s buildings?
We don't know yet just how we will divide our campus assets when we develop and finalize our plans for separating services and case management. There will be communication as we clarify these details.
Will individuals on the Children’s Home and Community Based Waiver (CHCBS) still be served by Imagine! or ACMI folks?
The CHCBS waiver is included in the waivers that will be served by the new Case Management Agency, so assuming Imagine! and ACMI are awarded the contract we would continue to serve children on that waiver.
Last week, Imagine!’s Director of Client Relations and Kristen Lundy, Assistant Director of Client Relations, met with the Imagine! Case Management team to answer questions about CMRD. Below are some of their responses.
Is there going to be competition for this catchment area?
We won’t know for sure until the list of bidders is posted, which we expect sometime after March 1. Will Case Managers have to learn all 10 waivers? We are in discussion with another CCB who currently manages the IDD/SEP contracts together already who is experimenting with mixed caseloads right now. From this vantage point, we would not expect one single person to be a Case Manager for 10 waivers. It is a great opportunity, though, for people who want to expand their knowledge to dip into the non IDD field. Just a reminder, though, that post award we will work to become one agency bringing together experience and expertise in all waivers, serving all ages and all disabilities. We have no doubt we will figure out how to provide quality case management efficiently AND any needed specializations among case managers.
Will ACMI be moving in with us?
We will be one combined agency headquartered at one of the current buildings on the Imagine! campus, most likely 1400 Dixon Avenue given the layout which does allow us to optimize desk sharing options. We will be looking for creative and innovative ways to use our space and meet all needs. As noted in a different FAQ recently, there are still some decisions to be made at Imagine! on how we will divide our assets, including the use of our current buildings.
Is ACMI going to get rid of their building?
ACMI currently rents space at 1455 Dixon Avenue. We do not anticipate needing that footprint to house our new, combined case management agency, but that has not been determined yet.
What happens with IT, PR, HR and the business office if we can’t share with the PASA anymore?
The PASA must have its own administrative services once we make the split. ACMI and Imagine! have different models currently that deliver these services which each offer particular advantages. As we work to become the new combined Case Management Agency (CMA), we are also looking at a number of best practices for creative solutions to help us manage costs and optimize efficiencies.
Will we have a new name?
Yes! The new CMS entity will have a new name that ideally identifies us as the newly combined entity that joins and optimizes all of Imagine!s and ACMI’s decades of case management experience and expertise. Imagine!’s services (the PASA side) will retain the Imagine! name after the CMA and PASA entities are split.
Will we have a new logo?
There are so many acronyms around here. Is there a list somewhere that explains some of these, especially for those of us who are new to CMRD?
Yes, we have a link to a comprehensive list of acronyms here.
In addition, The State of Colorado’s Office of Community Living (OCL) has created this Acronym Glossary.
Will people in services or employees have an opportunity to weigh in on the RFP decision-making process with HCPF?
We are not privy to the actual process of selection as HCPF will not discuss the RFP process specifically with case management agencies, but anyone is free to attend the general stakeholder engagement sessions where HCPF opens the floor for questions and discussions on a variety of CMRD related questions.
What happens to the Imagine! Foundation? Will they serve the CCB or the PASA?
It is likely all fundraising activities will be associated with the PASA in the Imagine! world post-CMRD implementation, although there are many considerations yet to be made. At the moment, our attorney is reviewing all of our legal entities, including the Foundation, reading through Articles of Incorporation and Bylaws to understand any particular legal considerations that must be taken into account as we plan the future. Stay tuned as we learn more and continue to study the possibilities.
Will Imagine! Case Management staff be able to view responses to the RFP?
We are deferring on responding to this question for the moment since we are still learning about the RFP process. We understand it to be a very competitive and proprietary process so undoubtedly there will be a level of care in sharing some of the specific responses pre-submission. There will be a collaborative process in preparing and vetting our responses to ensure accuracy, of course, but what that looks like right now is hard to define. Stay tuned for more information regarding all things RFP as we learn more.
When can Imagine! program managers begin meeting with the leadership team at ACMI?
The process is soon to include Case Management leadership from both agencies who will help define the work ahead and levels of engagement likely prior to submission of the RFP. Timelines for submission, post submission, and pre-implementation (assuming we win the RFP award) will be drawn up over the coming weeks and will include plans for engagement and ongoing communication.
If Imagine! were awarded the contract to serve as the CMA for our catchment area, would the number of people Imagine! currently serves increase?
Yes, this is very likely. Since the catchment area will be larger, and the number of waivers serviced by the CMA would increase, the number of people served by Imagine! would increase as well. HCPF has published projections for the number of people who will be served in each catchment area, you can access that information here.
How will the distribution of Mill Levy dollars look post-CMRD?
Boulder County controls how Mill Levy dollars are distributed. We are in discussion with the County, of course, about how their thinking is emerging regarding the future state of things with the changes being brought about separating case management agencies from PASAs. They do not have anything definitive regarding this topic, but commit to continue funding the IDD community with mill levy dollars. For mill levy funding for the calendar year 2023, we will be having the first of what is likely to be a few meetings with Boulder County in November regarding their priorities for the coming year and what format they are planning to use for our submission request. There have been no specific discussions on the various programs or positions currently funded partially by those mill levy dollars, only the overall topic.
Are there limits on how many regions an agency can bid on the RFP for?
The Colorado Department of Healthcare Policy and Financing (HCPF) has not specified a limit to how many “catchment areas” an entity can bid for. A reminder that HCPF has defined the new catchment areas for implementation of CMRD, and you can find the information memo released by HCPF and the map here. HCPF has further reiterated just in the past week that the bidding is “an open competitive process that will result in the Department selecting offerors ‘whose proposal is determined in writing to be the most advantageous to the state…'" (C.R.S. §24-103-203(7)). HCPF said additionally that “this competitive process encourages proposals from all agency types and will result in the Department conducting a comprehensive, thorough, complete and impartial evaluation of each proposal received."
Is that state providing support to Imagine! to help prepare for the post-CMRD world?
Not currently. At one point, the Colorado Department of Healthcare Policy and Financing (HCPF) had a contract with Health Management Associates (HMA) to provide coaching on the transition process during this critical time in the history of services for people with IDD in Colorado. On October 12, 2022, HCPF sent a message to CCBs, CEPs and private case management agencies, including Imagine!, saying the Department “has made the decision to pause the work being conducted by HMA effective October 15, 2022 and will resume that work after the RFP proposal submission deadline has concluded on approximately March 1, 2023. The Department will be sending out additional communication regarding the current work underway with HMA in the coming weeks.” There were no additional explanations offered in that communication. What it means from a practical standpoint is that the work we had been doing with our transition coach on assignment from Heath Management Associates (HMA) is suspended until after the RFP submission period has passed. We will keep you posted on any additional information from HCPF as it is made available.
How does CMRD impact Imagine!?
Currently, Imagine! provides both service coordination (case management) and direct services. After July 2024, we will no longer be able to do this. There must be a complete separation.
Therefore, Imagine! has made the following decisions:
- Imagine!’s Direct Services, which includes Residential Services, Employment Services, School Age Services, Adult Community Services, Mental and Behavioral Health Services, Imagine!'s Social Enterprise, and Family Recruited Employee Services, will take the name Imagine! and serve as a Program Approved Service Agency (PASA).
- Imagine! will respond to the Request for Proposal (RFP) from Colorado to serve as the Case Management Agency (CMA) for our catchment area (catchment area is the geographical area of service).
- If Imagine! is awarded the contract to serve as the CMA for our catchment area, the CMA will take on a new name and provide case management services to individuals who have intellectual or developmental disabilities (IDD) on the following waivers: Developmental Disabilities waiver, Supported Living Services waiver, Children’s Extensive Support waiver, as well as for individuals on the following waivers: Brain Injury waiver, Community Mental Health Supports waiver, Elderly, Blind and Disabled waiver, Spinal Cord Injury waiver, Children’s Home and Community Services waiver, and Children with Life Limiting Illness waiver.
If Imagine! is awarded the contract to serve as the CMA for our catchment area, our organization is likely to resemble the visualization below post-CMRD:
What steps are Imagine! taking in preparation for responding to the RFP to serve as the CMA?
Imagine! is currently (as of Oct. 11, 2022) engaging in due diligence for how best to respond to the RFP, including:
- Exploring potential partnerships
- Vetting viability of options through legal, financial, cultural lenses
Are there any details to share regarding where Imagine! Early Intervention (EI) services and coordination components will land with the future given the mandate to separate Case Management services from PASA services?
EI is under the direction of the Colorado Department of Early Childhood (CDEC -a newly created department in Colorado) and not Health Care Policy & Financing (HCPF) and Medicaid waivers, so how we plan for the future of EI is not dictated by the CMRD conflict-free mandate as defined in Colorado.
With Case Management Redesign and the changes coming in 2023, is Imagine! still posting and hiring for new positions?
Yes, our new job posting and hiring is “full speed ahead.” We continue to grow – especially focusing on new Direct Care – DSP – positions to meet the needs of our community. Over the past six months (May – Oct. 2022), we have grown by nearly 50 new staff!
Q: What is Case Management Redesign (CMRD)?
A: Case Management Redesign refers to several initiatives that will help make accessing long-term services and supports (LTSS) easier by changing case management agencies to serve all Home and Community-Based Service (HCBS) waivers so people have one place to go, making sure there are the right number of case management agencies in Colorado, and increasing the quality of case management services.
Q: Why is CMRD happening?
A: Single Entry Points (SEPs), Community Centered Boards (CCBs), and private Case Management Agencies currently provide case management for individuals with disabilities in the Colorado Department of Health Care Policy and Financing’s (the Department) ten HCBS waiver programs, with each serving different waiver programs.
In addition to case management services, many Case Management Agencies (CMAs) also provide direct services to program recipients, creating a conflict of interest which is no longer allowable by the Centers for Medicare and Medicaid Services (CMS).
Individuals who are seeking or receiving LTSS often qualify for multiple programs and end up navigating between systems that are siloed by program, making the system difficult for members.
CMRD is intended to simplify access and remove silos so members will be able to more easily navigate and find the right programs and services that work for them. It will require one case management agency to provide case management services for all waiver programs in each catchment area that is awarded by the Department through a competitive procurement process.
Further, these changes will meet the federal Conflict-Free Case Management requirement and allow the Department to ensure quality case management services for members across the state.
Q: Why is CMRD happening NOW?
A: In 2014, CMS, the Department’s federal partner, released the requirements for the “HCBS Settings Final Rule.” It included many requirements for providers to make changes to their processes to increase person-centeredness.
This rule also included a requirement for case management agencies to be “conflict free,” which means that they cannot provide services to the same person they are providing case management services to.â€¯Colorado must come into compliance with these rules by July 1, 2024.
Q: What if we don’t implement CMRD?
A: If Colorado does not come into compliance with conflict free case management, the risk is losing federal funding, which is 50% of the budget for home and community-based services. This would be detrimental to people in Colorado being able to access these vital services in the future.
Q: What does “conflict free” mean?
A: Conflict free means a case management agency will not provide both case management services and direct services to an individual, because this creates a conflict of interest.
CMS defines conflict free case management as: “Providers of HCBS for the individual, or those who have an interest in or are employed by a provider of HCBS for the individual must not provide case management or develop the person-centered service plan, except when the State demonstrates that the only willing and qualified entity to provide case management and/or develop person-centered service plans in a geographic area also provides HCBS. In these cases, the State must devise conflict of interest protections including separation of entity and provider functions within provider entities, which must be approved by CMS.”
Q: Will there be exceptions to conflict free case management?
A: Yes, the Department will create a process for exceptions to conflict free case management in areas where the approved case management agency is also the only willing and qualified provider in a catchment area to ensure access to services and supports statewide.
Q: How will CMRD benefit members?
A: Currently, SEPs provide case management services for individuals on the following waivers: Brain Injury waiver, Community Mental Health Supports waiver, Elderly, Blind and Disabled waiver, Spinal Cord Injury waiver, Children’s Home and Community Services waiver, and Children with Life Limiting Illness waiver. The CCBs provide case management services to members who have intellectual or developmental disabilities (IDD) on the following waivers: Developmental Disabilities waiver, Supported Living Services waiver, Children’s Extensive Support waiver, and Children’s Habilitation Residential Program waiver. Private Case Management agencies provide case management services to people on the Children’s Home and Community Based Services waiver.
Individuals seeking or receiving long term services and supports often qualify for multiple programs and end up navigating systems that are siloed by program. Case Management Redesign will create a simplified system where there is one place to go in each catchment area for case management for all waivers. Case Management Redesign will create consistency in the quality, accountability and stability of the case management services people receive across the state. It will allow the Department to provide oversight and support to ensure high performing case management system statewide.
Q: Will members still have a choice of agency?
A: Members will receive case management services from the agency that holds the contract in their catchment area. Case Management Agencies will have a process for members to request a new case manager if they are not a good fit.
Exceptions will be made if a person moves across catchment area boundaries and wants to continue being served by their previous agency. The process for this portability allowance and exception is still being formulated and will likely differ by catchment area. (Updated 8/25/22)
Q: What if I want to keep being served by my current agency but they don’t get awarded the contract?â€¯
A: In the event there is a transition, the department works closely with both incoming and outgoing agencies to ensure there is very minimal impact on members. In our experience, the majority of staff transition to the new agency, and individuals are able to retain their case manager if they so choose.
Q: What will the impact be if a person moves from being served by a SEP or CCB to being served by a case management agency?
A: The impact on members should be minimal if a transition does occur in your area. Most of the transition process will be business processes, contracts, materials, and files which are done “behind the scenes.” The Department works with both incoming and outgoing agencies to ensure a smooth transition for members. Members can expect to experience outreach and communication regarding a change in their case management agency from both the Department and the awarded case management agency.
During previous transitions between agencies, case management staff experience and expertise are highly valued and new agencies seek to retain case managers whenever possible. Unless case managers choose to leave, members can expect to continue with their current case manager through transitions whenever that is possible.
Q: How are catchment areas decided?
A: The Department hired a contractor to analyze data, caseloads, the numbers of assessments and support plans, and to look at geographical issues resulting in catchment area recommendations.
Stakeholders provided feedback on the proposed maps and the contractor adjusted recommendations to the Department based on webinar feedback and survey responses.
Final catchment areas (the areas that the new case management agencies will service) were decided based on feedback in November 2021.
Q: Will contracts for Case Management go to the lowest bidder through the RFP process?
A: No. The rates for case management are set for all administrative and targeted activities. The RFP process will not evaluate costs but will evaluate best fit to serve the specific catchment area each agency applies for.
Q: How will CMRD impact Children’s-Home and Community Based Services (CHCBS)?
A: CHCBS members will continue to receive In Home Support Services (IHSS) and case management services. The Department will align CHCBS case management with the other waiver case management to meet efforts to simplify and streamline the current siloed system. All case management agencies will be required to evolve with the changes required in Colorado's system, but the Department is working closely with CMAs to support the retention of staff into the future case management system. (Updated 8/25/22)
Q: How will CMRD impact CCBs and mill levy?
A: The definition of CCBs will be amended but will ensure the continuity of local mill levy dollars as it pertains to HCBS recipients to be shared with local CMAs. The Department, CCBs and CMAs will ensure that case managers are informed, educated and trained on all resources available to HCBS individuals in their catchment areas.
Q: How will CMRD impact providers or available services for members?
A: Providers will continue providing the same direct services per rule and regulation. Providers will be notified of any changes in case management agency in each catchment area via provider bulletin, Department communication and communication from local case management agencies.
Q: What is the Department doing to ensure stability among case managers at current CCBs and SEPs?
A: The Department is aware of the uncertainty and anxiety that can be created with this level of change. Department leadership meets with CCB and SEP leadership groups on a monthly basis to discuss ways to support agencies and their staff through this transition. The Department has approval to utilize American Rescue Plan Act (ARPA) funds to identify strategies to address these important concerns in our case management system. This work will be ongoing between now and July 2024. Check out the ARPA website for more information about this project! (Updated 8/25/22)