By skyforbes 
[The following (re-posted verbatim) was part of a series of Medicaid compliance-based criticisms of the Kancare RFP (2011) submitted during the Federal open comment period]
Care Coordination must only enhance, not replace, community based case management for HCBS
Kansas must keep the intensive community case management services we have in place, and bolster (read: do not replace) their effectiveness with a high quality Care Coordination program that will ensure access and prevent unnecessary institutionalization. Unfortunately, the KanCare RFP, written documentation, and 1115 Waiver application are unclear how existing case management will interact with this new administrative level of “Care Coordination.”
If Home and Community Based Services (HCBS) are to be moved under managed care, individuals and families who need these services deserve a quality specialty Care Coordination program that strengthens and reinforces (but does not replace) quality community-based Targeted Case Management. Any proposal to implement managed care must have a well designed Care Coordination program in order to address system gaps and barriers, help determine network adequacy of providers, ensure access to needed personal support services and treatments… and comply with state and federal laws. However, Kansas does not do this in its 1115 Waiver application or KanCare RFP.
Kansas must mitigate all potential conflicts in the coordination of services by requiring that KanCare:
· Ensures that individuals can advocate for themselves or have an advocate present in planning meetings.
· Ensures documentation of the choices that individual members have been offered among all qualified providers of direct services.
· Establishes administrative separation between those doing assessments and service planning and those delivering direct services.
· Establishes a consumer council within the each service providing organization to monitor issues of choice.
· Establishes clear, well-known, and easily accessible means for consumers to make complaints and/or appeals to an independent conflict resolution program for assistance regarding concerns about choice, quality, and outcomes.
· Requires all MCOs and contracting organizations to document the number and types of appeals and the decisions regarding complaints and/or appeals.
· Have State quality management staff oversee providers to assure consumer choice and control are not compromised.
· Document consumer experiences with measures that capture the quality of case management services.