Welfare Watch - May 10, 2009 - Proposed Repeal of Medicaid Targeted Case Management Regulations

The Department of Health and Human Services (HHS) published in the Federal Register a notice that it intends to seek to partially rescind the Medicaid Targeted Case Management (TCM) regulation issued in December, 2007.  Congress placed a moratorium on these regulations in June of 2008.  The TCM regulation restrictive, and some believe the "over enforcement", put our health delivery system to vulnerable citizens in peril. 

Georgia was particularly hard hit as it was targeted as one of the first two states in the nation to "undo and unbundle" its services.  We know in Georgia that as a result of the implementation of the Centers for Medicare and Medicaid Services (CMS) interpretation of these rules, that children with mental health disorders have been adversely affected.  As a result of these rules, services are difficult to obtain, not integrated into their community environments and have put a significant hardship on providers. 

This proposed repeal of the Medicaid TCM regulations would rescind the single case manager requirement; the "integral component" tests that shifted the cost of non-medical programs to our Department of Human Services. The "unbundling" requirement would also be rescinded.  "Unbundling" services in Georgia not only "silo-ed" services, it put them on other farms.   We are happy for this reconsideration by HHS but most of it will come too late for Georgia.  As a result of CMS enforcement of these TCM regulations, most of the integrated services within our Level of Care system were dismantled and separated from the integrated delivery system of Level of Care.

The provision of the Deficit Reduction Act that prohibits foster care from billing Medicaid for the delivery of foster care services such as research gathering, assessing adoption placements, recruiting potential foster care parents, doing home investigations and making placement arrangements will stay in place.   Other legislation is proposed to address these concerns.

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Welfare Watch, an email newsletter of the
Georgia Association of Homes
and Services for Children
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                            Normer Adams, Editor
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