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Liberty Resources Voices Concerns Over Proposed NCQA Standards for CIL Accreditation on Case Management for Individuals Receiving Long Term Services and Support

It is imperative that organizations such as NCQA work collaboratively with CILs should they shape policies that impact the work we do.

Dear Community Stakeholders,

With the continued rollout of Medicaid funded Managed Long Term Services and Supports (MLTSS), states and programs across the nation are redefining how quality is measured. As a result of these changes, the National Committee for Quality Assurance (NCQA) has put forth proposed standards for accreditation on Case Management for Individuals Receiving Long Term Services and Support. We at Liberty Resources, Inc. (LRI), the Center for Independent Living (CIL) in Philadelphia, do not agree with the standards put forth by NCQA. These standards could impose medically based measurements on CILs as we develop working partnerships with Managed Care Organizations accredited by NCQA HEDIS standards. For MLTSS, it is imperative that states focus on “quality of life” measurements for participants residing in a community setting.

The CILs were conceived in response to a medically based social framework that did not understand choice and independence for Consumers with disabilities. Utilizing a social model based on Consumer Driven Choice and Independent Living Philosophies, CILs provide core services and connect Consumers to available resources in their community. At LRI, we pride ourselves on our advocacy and Nursing Home Transition services. With twenty-five years of experience providing services and advocating for Consumers with disabilities, we would like to provide measurement recommendations for consideration. 

Goal Measurement

The mission of the Center is to assist Consumers in attaining their goals of choice and independence. We are concerned that the accreditation standards put forth by NCQA do not recognize the nuanced needs of Consumers in how they define personal independence and choice. We do not believe there should be standardized measurements for independence and choice. A Consumer’s definition of independence and choice varies from Consumer to Consumer. For example, independence for John may mean to live at home with her mother while independence for Jane may mean living alone in his own apartment. So, who is more independent than who? Independence and choice are goals that yield different Consumer outcomes.

These Consumer outcomes impact outcome measurements for the CIL. For example, goal achievement time frames varies from Consumer to Consumer. These time frames can range anywhere from six months to five years. If it takes a Consumer longer to achieve the same goal than another Consumer, the Center continues to provide quality services to meet the Consumer where they are and works with the Consumer towards their goal. We do not define goal achievement successes on standardized time frames. Standardized time frames for goal achievement negatively penalizes Consumers and the Center. It is contrary to the established analysis of each Consumer on an individualized basis. Additionally, it shifts the focus from the Consumer deciding services to services being provided by standardized recommendations. Accreditation efforts must recognize these nuances in defining goals and goal achievement.

Outcome Measurements

Consumer specific outcomes as mentioned above are nuanced and should not be standardized. This does not mean that it is impossible to measure if a Consumer’s goal has been achieved. Rather than utilizing standardized quantitative measurements, we recommend that qualitative methods be used in measuring goal achievement. Qualitative methods are intensive and outcomes can be measured through one-on-one interviews with Consumers or through focus groups using objective criteria. Individualized analysis of a Consumer’s needs and quality of life measures are consistent with decades of accommodation analysis made under the Rehabilitation Act of 1973 and the American with Disabilities Act. Qualitative methods support the Independent Living philosophy of a CIL. It is the Consumer who defines services and what their desired outcome is. The success and outcomes of a CIL is therefore defined and driven by the Consumers they serve not numbers they must achieve.

Staff Measurements

To ensure that medical standards do not encroach on CIL values, the Center firmly believes in peer supported services. Oftentimes, Staff with disabilities serve Consumers with disabilities. This is an intrinsic value and requirement of CILs as we are federally mandated to ensure that 51% of our Staff are Individuals with disabilities. This may mean that some Staff at the Center do not have educational credentialing requirements but nevertheless possess a wealth of knowledge based on their work experience as an Individual living with their disability. At the Center, we do not embrace the notion that a lack of educational credentials should exclude Staff from providing services in which they have lived experience in navigating and/or advocating. We recommend that life experience be added to the NCQA credentialing requirements with as much weight as educational credentials.

Should job prerequisites be based on educational credentials, employment opportunities to Individuals with disabilities would drop. Currently in Pennsylvania with the rollout of Managed Long Term Service and Supports, we have taken action to prevent this from happening to Service Coordination.

In closing, we recommend that NCQA continue additional collaboration with a variety of CILs should it want to provide accreditation standards for measuring CILs. At the Center we have explored utilizing measurement standards put forth by the Council on Quality and Leadership (CQL). The standards are in line with Independent Living Philosophies and understand the intricacies of service delivery to Consumers with disabilities. We recognize the move towards accreditation as MLTSS expands and we invite NCQA to better understand and collaborate with the disability community.

We encourage other CILs and stakeholders to provide their input on the NCQA proposed standards. The proposed standards can be found on the NCQA website (PDF).

See also: more information on why NCQA proposed accreditation standards for CILs

Although the deadline for public comment has passed, your concerns on the accreditation standards can still be voiced. It is imperative that organizations such as NCQA work collaboratively with CILs should they shape policies that impact the work we do. As we prepare for Managed Care in Pennsylvania, we remain ever vigilant of, “Nothing about us, without us.”

Sincerely,

Mang Shaper

Director of Quality Management

Liberty Resources, Inc.

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