It’s been awhile since I’ve written anything here about the Disability Waiver Rate System (DWRS) or related topics, but I’ve started to get some questions from providers about the Competitive Workforce Factor (CWF) distribution report requirements, so I thought I would provide some information.
First, a little background. When the legislation that included the CWF passed in 2019, it included some broad language about a distribution report that providers would have to prepare by December 31, 2020. At that time, the Minnesota Department of Human Services (DHS) advised that guidance would be provided in early 2020 to give providers the information needed in a timely manner. Well, something else happened in early 2020 known as a global pandemic, and timelines got a little messed up. But, on July 29, DHS released a bulletin with more specific information about the distribution reports.
First, it’s important to remember that the intended audience for these reports is the direct support staff employed by each provider organization, and the staff must have access to the reports for at least one calendar year. Providers must also make their reports available to DHS upon request; DHS will notify providers if their report is selected for review. DHS does NOT say that they will review a certain number of reports, and it is not clear what would trigger a review. My sense from conversations with DHS Disability Services Division staff is that they are not intending to systematically review reports unless questions or concerns are raised about them. But that is not an official DHS position.
Which providers must create distribution reports? Any provider that received revenue in 2020 through DWRS framework services that included the CWF. Providers that received revenue for customized living and/or 24-hour customized living as the ONLY framework services are exempted.
What should a distribution report include? There are 3 elements that must be included.
First, a description of the CWF in language that makes sense to the direct support staff. (DHS provides suggested language on their website, but providers may use their own).
Second, the report should include an estimated dollar amount from the CWF for services expected to be delivered in 2021. This is important: not actual CWF dollars received in 2020, but an estimate for 2021. Rate exceptions are excluded from this estimate.
Third, the report has to describe the SPECIFIC ways in which the revenue will be used by the provider organization. Some examples of how revenues may be used include maintaining or increasing direct support wages and/or benefits, or actions taken by the provider to support direct care workers during COVID-19 disruptions. It is possible that the changes outlined in this section may have been implemented prior to the release of the report (i.e., earlier in 2020).
Who can I contact if I have questions? The DHS rates email box is always a good place to go with questions on issues like this. They are generally pretty responsive. Or, you can direct general questions to me and I will answer as best I can or try to find an answer.
There are a few other items to note. Earlier this week, DHS released the DWRS component value rates for 2021. They can be found here. A few highlights:
- New services and service names from Waiver Reimagine are reflected
- Hourly wages are now shown as base rate plus new rate with CWF
- Asleep wages for direct support are increased from $10.00 to $10.08 in corporate residential settings, and from $3.60 to $3.63 for family residential settings
Work on the Waiver Reimagine waiver reconfiguration project is continuing, and DHS is holding some virtual events to gather feedback from stakeholders. More information is available on the Waiver Reimagine webpage.
In 2019, ARRM supported passage of a study and legislative report on value-based payment models. Work on this study by DHS was also pushed back due to COVID-19, but DHS will be sending a survey to stakeholders any time and holding feedback sessions over the next 45 days or so. We will be including information on this in our regular emails when we receive it. Also, our Alternative Payment Model Workgroup will be leading an educational session as part of the virtual Business and Finance Forum on November 17. We hope this will be an affordable and accessible opportunity for many of you to learn more about this topic.
-- Ken Bence, Director of Research, Analysis and Policy