LRS comments on proposed prior authorization process for IO waiver
The Ohio Legal Rights Service (LRS) submitted comments on a proposed new rule establishing standards and procedures for the prior authorization process under the Individual Options (IO) waiver. In its comments to the Ohio Department of Developmental Disabilities (DODD), LRS expressed its continued concern that the Ohio Developmental Disabilities Profile (DDP) and the prior authorization process are being used to impose an individual cap on expenditures under the IO waiver, even though the Centers for Medicare & Medicaid Services approved an aggregate cap. Also of continued concern is the financial disincentive for county boards of developmental disabilities to support clients with high needs which results in conflicted decision-making on the DDP and lack of support for needed services in the prior authorization process. This lack of uniformity and denial of services places people at risk of institutionalization, which violates Title II of the Americans with Disabilities Act.
Other comments made by LRS included the need for the prior authorization process to be less complicated and confusing. The process should be structured in a way that is simplified and that eliminates unnecessary burdens on people enrolled on the waiver and their families. LRS also recommended that the county board should communicate in written notice the type of documentation required to submit a request for prior authorization, but at the same time extensive documentation should not be required. Another point made was that the process should be made in such a way that people should not have to endure needless delays to receive the services they need, particularly in emergency situations. LRS also stated that the proposed rule should aim to ensure the Individual Service Plan (ISP) revision process is initiated in a timely manner so that requests for prior authorization can be submitted far enough in advance to ensure continuity of services.
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