Mortgage Application Rejection Letter by lbg52283

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									   ADAP 101
           Nancy Abraham-Budds,
          ADAP/CHIC Administrator
    Illinois State Department of Health
                & Neal Carnes,
Program Manager of HIV Medical Services
   Indiana State Department of Health
           Presentation Overview
   Client eligibility screening and
    documentation (verifiable and official)
       Public Law 109-415: Ryan White
       State/Territory-specific eligibility criteria
       Policy setting & standardization
       Confidentiality
       HIPAA
   Federal Reports: ADAP Quarterly & RDR
   The hokey-pokey
           Presentation themes
   "Democracy means simply the bludgeoning of
    the people by the people for the people."
    Oscar Wilde
   “If Columbus had an advisory committee he
    would probably still be at the dock.”
    Arthur Goldberg
   “A civil servant is sometimes like a broken
    cannon - it won't work and you can't fire it.”
    George S. Patton
          Client eligibility screening
   Public Law 109-415: Ryan White Treatment
    Modernization Act of 2006 requires covered
    clients/enrollees/patients/PEOPLE to be:
       Living with HIV/AIDS
       Low income
       A State/Territory resident
       “Payer of last resort”
   States/Territories may have unique eligibility
    criteria, e.g. IN requires enrollment in Care
    Documentation (verifiable & official)
   Documentation proves the fundee (YOU)
    validated the enrollee meets established
    criteria for enrollment and you remain
    compliant with the law and program policies
   Two questions: is the document official and
    can it be verified?
       Anyone can say they are HIV positive, make less
        than established poverty threshold, etc but can
        they prove it; what is the documents source and
        can you check it’s validity?
    Documentation (verifiable & official)
   Why is this important?
       If you are audited, and yes HRSA has the right and the
        responsibility to ensure the guidelines set out in the law
        and the criteria specified in the grant are being adhered
        to, then you will need to supply supporting
        documentation to prove valid enrollment
       Fairness is also at play. Why should one client be allowed
        to supply, say a handwritten note stating there are 4
        people in their household thus allowing them a greater
        income threshold yet another client gets only 1 household
        member, thus a lower income threshold?
    Documentation (verifiable & official)
   So what is accepted, not accepted?
       PL 109-415 does not specify what a
        State/Territory can or cannot accept as proof of
        the applicants eligibility – this is left to the State
       In IN we consider “verifiable” and “official” as our
        guide – can we contact the issuing agency to
        prove what is being supplied AND when we say
        official – is it an agency with some regulatory
        oversight and thus lacks a greater degree of
        vested interest
    Documentation (verifiable & official)
   Any questions so far?

   Next we’ll look at specific examples based
    upon PL 109-415 requirements as well as
    State/Territory specific criteria
          HIV status documentation
   What is accepted in your State/Territory?
   Lab reports
       Everybody, no matter their HIV status, has a CD4 count.
        Any number of factors can impact a CD4 count, e.g. too
        much sugar, recent cocaine use, a cold – anything
        requiring an immune response can deflate one’s count
       Viral load – what about those who are positive and
        showing an undetectable viral load
   Example: IN requires a medical provider’s signature
    on a Physician Certification form (part of our
    application) in addition to recent lab results as a
    means of diagnosis along with the provider’s
    contact information (so we can validate)
       Example – “…but he had a HAART pill bottle with him”
    Low Income Status documentation
   Does any State/Territory generate a non-FPL-based
    criteria when determining income?
       We are allowed to set our own threshold, e.g. 150, 200,
        300, 500…% of FPL
   Do you consider gross or adjusted income?
   Household membership is a factor, yet the FPL
    guidelines do not define household – how does your
   Assets: what State/Territories consider assets, such
    as bank accounts, home ownership…? And how do
    you document?
   Example: IN sets threshold at 300%, we consider
    household membership but not assets
     Example: IN Income/Household
    documentation (from our manual)
   Copy of Workforce Development earnings statement dated within 3 months of
    the application date
   Copy of the previous year’s federal or state income tax return,
   Copy of the previous year’s W-2(s),
   Copy of a pay stub dated within 3 months of the application date and showing
    year-to-date earnings (as well as the employer’s name and address),
   Copy of Unemployment Insurance benefits notification letter and the most
    recent check stub (must be dated within 3 months of the application date),
   Copy of current (within 3 months of the application date) Social Security
    benefits notification letter or check,
   Statement, dated within 3 months of the application signature date, from the
    employer (on company letterhead) documenting annual gross employment
    income, must be signed and dated by a company representative with contact
   Food stamps, annuities, pensions, 401(k), rental property, etc payments count
    as income; an official print out from the payer to the payee is required as

   How do these meet the verifiable/official guidelines?
   These are also comprise what is accepted for recertification
        Example: IN Residency
    documentation (from our manual)
   Copy of a valid – not expired, suspended, revoked, etc – Indiana Driver’s
    License, State Identification (ID) card, or an official BMV Driver Record
   Copies of utility bills or a print out from the utility company for the 12
    consecutive months (one from each month) prior to the application date,
   Copies of cancelled rent checks/mortgage payments or a print out from the
    property management/mortgage company for the 12 consecutive months
    (one from each month) prior to the application date,
   Copy of Indiana Full Year Resident Income Tax return from the most recent
    tax year,
   Postmarked medical bills or mail documenting 12 consecutive months of
    Indiana residency (one from each month), or
   Notarized letter from HIV Care Coordinator attesting to 365 days of
    continuous Indiana residency and citing chronic homelessness.

   Note on notary public: an officer who can administer oaths and statutory
    declarations, witness and authenticate documents, and perform certain
    other acts depending on the jurisdiction – check with your State/Territory to
    verify a notary public’s capacity when determining if you will or will not
    accept a notarized letter.
   These also compromise what is accepted for recertification
      Example: IN “Payer of last resort”
   IN requires all applicants to apply for Medicaid prior to their Ryan White
    Part B application – we do not wait for their denial, yet accept a Medicaid
    Application Verification form (unique to IN) to be signed and dated by a
    Medicaid Rep and submitted w/ their app
   Our database interchanges w/ Medicaid’s and we are notified when one
    of our enrollees is Medicaid enrolled/eligible
   We also require all applicants offered a private/employer-based insurance
    program to select this coverage as their primary. In cases where the
    policy is substandard we offer “wrap around coverage”
   We also reserve the right to request the applicant/enrollee have a unique
    form be signed by an employer representative stating the client is not
    eligible for healthcare coverage – this can be verified and we do
   All Medicare Part A and B eligible enrollees must elect this coverage – if
    they are not eligible for Part D we offer “wrap around” to pick up their
    pharmaceutical coverage – Medicare card must be submitted with
    app/recertification paperwork
   We also require a private insurance rejection letter for applicants based
    on our high-risk insurance pool’s policy
    Example: Care Coordination (CC)
   Indiana HIV Medical Services requires all
    enrollees be enrolled in a State-sanctioned
    CC site – what unique criteria does your
    State/Territory apply?
   IN documents CC enrollment via the
    application and recertification process – these
    documents must come from one of our
    funded sites, signed and dated by the client’s
    Care Coordinator
               Criteria v policies
   Many States/Territories adjust/set policies on-
    going; keep in mind that your location has
    submitted a grant application specifying the
    criteria you are considering for eligibility. If
    you want to make a change/adjustment you
    need to report them to HRSA and get
    approval prior to the adjustment
   Consider: how do you plan to document this
    clarification/new policy?
   If you are clarifying a policy it should relate to
    one of your established criteria…
    Example: IN’s Incarceration Policy
   On August 30, 2007 IN issued a policy
    clarification regarding enrollee’s who find
    themselves incarcerated during enrollment.
    The new policy stipulates those in a State or
    Federal facility are no longer eligible due to
    State and Federal law granting them access
    to healthcare coverage, re: “Payer of last
    resort.” Those in county facilities remain
    eligible for 90 days (a premium cycle) given
    they have someone who can get them meds
   What are standards?
   How does your program standardize its
      Manual/program guidelines…

   Why is it important to set standards?
      Is it legal/fair to grant one set of standards
       to one person/group over another?
   Allowance for exceptions? What is the basis?
    How do you document these exceptions? …
   PL 109-415, Sec. 304. states, “…the entity
    (meaning the State/Territory or other funded
    agency) agrees to ensure that information
    regarding the receipt of early intervention services
    pursuant to the grant is maintained confidentiality
    in a manner not inconsistent with applicable law.”
    It goes on to state, “…in testing an individual for
    HIV/AIDS, the applicant (your agency) will test an
    individual only after the individual confirms that the
    decision of the individual with respect to undergoing
    such testing is voluntarily made.”
   Upon application and recertification the client signs,
    dates and receives a copy of IN’s Certification of
    Understanding, which states, “I understand that my
    records are protected under the state law (16-41-8-
    1) relating to confidentiality of medical or
    epidemiological information involving a
    communicable disease (410 IAC 1-2.1) and/or
    under the federal regulations governing
    confidentiality of alcohol and drug use Patient
    Records, 42 CFR Part 2, and cannot be disclosed to
    any other entity except those referenced herein
    without my written consent.”
 Know your enrollees and your agencies'
  rights and responsibilities in light of
  what is law (State/Territorial & Federal)
  as well as any internal policies
 Furthermore, we have an ethical (some
  would even say moral) responsibility to
  protect our enrollees
   For those of us who are insurance-based or operate
    some portion of our program paying insurance-
    related costs, HIPAA is in play
   HIPAA is not a CONFIDENTIALITY law, it is an
    insurance portability law with confidentiality clauses
    of which HIPAA-covered programs must verify
    enrollee identity or requesting parties capacity prior
    to disclosing personal health information (PHI)
   When PHI can be disclosed: payment, treatment
    and/or program operations
                Back to Nancy
   Decision Tree
   Pricing

   I’ll be back in after these important topics to
    cover federal reports
                Federal Reports
   There are two primary federal reports: the
    ADAP Quarterly Report & the Ryan White
    HIV/AIDS Program Data Report (RDR,
    formerly the CADR)
   ADAP Quarterly is due:
       July 31 (April-June 30)
       October 31 (July 1-September 30
       January 31 (October 1-December 31)
       April 30 (January 1-March 31)
   RDR is due March 24 by 6 pm EST
        ADAP Quarter Report (AQR)
   Required of all Part B funded grantees
   Cover page (auto populated)
   Section 1: Quarterly Submission, made up of:
       Aggregated client, criteria, program limitation,
        funding, expenditure and ARV/OI/Hep B & C
        utilization data
   Section 2: Annual Submission (due on the July
    31st submission) made up of:
       ADAP funding & formulary, eligibility requirement
        and cost savings aggregate data
        ADAP Quarter Report (AQR)
   Primary changes in the 2008 version:
       Hispanic/Latino ADAP clients reported distinctly
       Regimen differentiation (1-2, 3-4, more than 4)
       Set formulary of medications reporting on and
        reporting on previous quarter not two quarters
       Cost-savings per client accounting for rebates, etc
      Ryan White HIV/AIDS Program
           Data Report (RDR)
   Required of all Part A, B, C and D grantees
   Reporting on previous calendar year data
   Section 1: Grantee information – contact,
    functionality & funding
   Section 2: aggregate clients served data
   Section 3: core & support service data
   Section 4: counseling & testing data
   Section 5: outpatient/ambulatory medical provider
   Section 6: Part C & D (only) data
   Section 7: health insurance programs data
      Ryan White HIV/AIDS Program
           Data Report (RDR)
   Primary changes in the works:


    (Lord, God, Buddha, Isis, the Spirits, Mom…
                  Help Us ALL!)
    Coordinated Statement of Need &
          Comprehensive Plan
   Statewide Statement is due Jan 5, 2009
       Combined statement of need – coordination of
        services across all Parts – regarding all Part
        grantees within your State/Territory
       Another way to look at this is the barriers
   Comp Plan is due Feb 1, 2009
       (basically the same thing as the Statement but in
        a unique document)
       What you’re going to do about the barriers
           Contact Information
Neal Carnes
Program Manager, HIV Medical Services
Indiana State Department of Health
2 N Meridian St, 6-C
Indianapolis, IN 46204
317-233-7450 (Direct)
37, 5’8”, 165 lbs of pure muscle, brown hair, blue
  eyes, great sense of humor, fabulous family, love
  kids (from a distance) and looking
     Thank you

And now for the
  hokey pokey

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