the Mittineague Blog

I am sending this from one of my email addresses to another. Please feel free to respond to either of them. But ….

** Please Note ** that this email is being sent "Carbon Copy" to several addresses in addition to yours. If you reply to this email, do not include any information you don't want others to see. Please be mindful of privacy concerns, use ******** in place of names and be careful with any information that may identify an individual.

******** – WestMass ElderCare,
I apologize for taking so long to get back to you, *******'s dad passed away the day after your last visit to the house so things have been a bit exceptional to say the least.

Anyway, I have finally found some time to look into the recent AFC regulations. I had mentioned that the ADL – IADL items didn't look right. I am familiar with the definitions found in 130 CMR 422.410 (PCA)

422.410: Activities of Daily Living and Instrumental Activities of Daily Living

(A) Activities of Daily Living (ADLs). Activities of daily living include the following:
(1) mobility: physically assisting a member who has a mobility impairment that prevents unassisted transferring, walking, or use of prescribed durable medical equipment;
(2) assistance with medications or other health-related needs: physically assisting a member to take medications prescribed by a physician that otherwise would be self-administered;
(3) bathing/grooming: physically assisting a member with basic care such as bathing, personal hygiene, and grooming skills;
(4) dressing or undressing: physically assisting a member to dress or undress;
(5) passive range-of-motion exercises: physically assisting a member to perform range-of motion exercises;
(6) eating: physically assisting a member to eat. This can include assistance with tubefeeding and special nutritional and dietary needs; and
(7) toileting: physically assisting a member with bowel and bladder needs.

(B) Instrumental Activities of Daily Living (IADLs). Instrumental activities of daily living include the following:
(1) household services: physically assisting with household management tasks that are incidental to the care of the member, including laundry, shopping, and housekeeping;
(2) meal preparation and clean-up: physically assisting a member to prepare meals;
(3) transportation: accompanying the member to medical providers; and
(4) special needs: assisting the member with:
(a) the care and maintenance of wheelchairs and adaptive devices;
(b) completing the paperwork required for receiving personal care services; and
(c) other special needs approved by the MassHealth agency as being instrumental to the health care of the member.

But after finding MassHealth Transmittal Letter AFC-11, I see that it uses different definitions. i.e. 130 CMR 408.402

Activities of Daily Living (ADLs) – fundamental personal-care tasks that are performed as part of an individual's routine of self-care. ADLs include, but are not limited to, eating, toileting, dressing, bathing, transferring, and ambulation.
…….
Instrumental Activities of Daily Living (IADLs) – activities related to independent living that are incidental to the care of the member and that include, but are not limited to, household-management tasks, laundry, shopping, housekeeping, meal preparation and cleanup, transportation (accompanying the member to medical providers and other appointments), care and maintenance of wheelchairs and adaptive devices, medication management and any paperwork required for receiving prescribed medications within the AFC setting, or any other medical need determined by the AFC provider as being instrumental to the health care and general well-being of the member.

I don't see the logic of having varying definitions, but I imagine they serve some purpose.

First, I must again emphasize my feelings about anything that runs counter to keeping things the "least restrictive". It has taken a long time for ******** to become but only a little less suspicious, resentful, and fearful of the "State", and I am concerned that any knowledge of this requirement might prove to be a setback to, if not permanently undo, this slight progress.

The fact that AFC-11 states "The regulations incorporate new standards that are consistent with other MassHealth-covered community-based services." is a most welcome change after years of being grossly under-compensated without a single COLA. But I was unable to find online the "Rates of Payment" changes. I know Senator Buoniconti was working on increasing the caregiver payment last March, but I could not find the new amount or when it begins. Are the new rates going to be consistent with the "Caring Homes" rate of $50 per day or with PCA, HHA, SHCA etc. services? Also, I see that AFC-11 has an effective date of February 1, 2007 but as I received the old rate for February I am a bit confused as to when the changes are actually supposed to go into effect.

Normally, as a matter of principle, I would be opposed to the imposition of any additional workload that is solely administrative in nature. True, form completion should only amount to 1 to 2 quarters of a hour daily, but as the majority of what I do is already uncompensated, part of me feels that unless the new payment rate is truly consistent with what other care providers receive, or at least the minimum wage, that the increase should be applied to the deficit. Even so, a rate of $50 per day should be enough to allow me to get off of low income assistance, so I can justify the time spent filling out the form by the fact that at least some of that time would have been spent filling out LI assistance forms instead. It will be as nice not getting below the FPL as it will be to not be getting less than ********'s supplemental payment. In my opinion this change is long overdue.

As for the form itself, I do have a few problems with it. The second page, that deals with behavior, is something that I can not do as it would be unethical. As I am a certified Clinical Laboratory Scientist I know that it would not be right even as an Allied Health professional to "play psycho-socio-ologist" even though I do have some educational familiarity with behavioral science and extensive experience limited to my particular situation. It is one thing to act on experience and instinct, entirely another to create a permanent record. I am however, confident that I would be able to learn and pass any examination required to become qualified, if the "clinical experience" doesn't need to include a range of settings. If you are aware of any at-home or online routes to certification, please let me know. Alternatively, as progress in behavioral changes occurs so slowly, daily recording seems unnecessary. I really don't see a need to alter the current strategy of monthly updates to professionals that are qualified to make and record an assessment (that would be the two of you).

The first page, which deals with the ADLs and IADLs, does not have any areas for recording time blocks. If there is going to be a difference between "active care" and "on call" rates, this will be a problem. However, if the new payment rate truly is consistent with what other care providers that have been filling out forms in the past are receiving, then I will have absolutely no problem with devising some manner of time sheet to record 15 minute blocks if needed. Even so, any form that is as visually demanding will be a problem until I receive the new payment rate and am able to update my eyeglasses. The prescription that my parents paid for is no longer adequate, and I have needed to adjust by budgeting my "close work" time so as to avoid getting eye-strain headaches.

To summarize my questions
1. What is the new caregiver payment rate?
2. When do the changes that relate to me go into effect?
3. Do you know of any way I could become qualified to record daily psycho-socio assessments?
4. If the new caregiver payment rates are "consistent with other MassHealth-covered community-based services", e.g. PCA, HHA SHCA, is recording care activity in 15 minute blocks of time the standard needed in order to receive full payment for services provided?
Or, if they are consistent with the "Caring Homes" rate, to your knowledge is time logging then unnecessary?

Thanks, ********