Newsletter June 2024
Behavioral Health
Todd Lewicki, PhD, LMSW, MBA
Chief Behavioral Health Officer
C-Waiver Applications are Open for Public Comment
In 1983, Congress added section 1915(c) to the Social Security Act. This is when Home and Community-Based Services (HCBS) were first available to eligible individuals. This addition to the Social Security Act gave Michigan the option to get a waiver of the Medicaid rules that govern institutional care. HCBS services became a Medicaid State Plan option in 2005. The Social Security Act section 1915(c) waiver program permits Michigan to furnish an array of home and community-based services that are designed to meet the needs of individuals who prefer to get long-term supports and services in their home and/or community and not in an institutional setting. Broadly, state programs must meet the following HCBS waiver program basics:
- Demonstrate that waiver services will not cost more than providing these same services in an institution.
- Ensure the protection of individuals’ health and welfare.
- Provide adequate and reasonable provider standards to meet the needs of the target population.
- Ensure that services follow an individualized and person-centered plan of care.
HCBS serve different targeted groups, including individuals with intellectual and/or developmental disabilities (children and adults), severe emotional disturbance (children/youth and families), and severe mental illness (adults). C-Waiver applications to the Centers for Medicare and Medicaid Services (CMS) are updated and renewed every five years, with the current C-Waivers set to expire on September 30, 2024. Michigan operates three 1915(c) waiver, or “C-Waiver” programs, which include:
- Habilitation Supports Waiver (HSW) - supports individuals of any age in the community by enrolling them into the program with services designed to help keep them out of an institutional setting.
- Children's Waiver Program (CWP) - enables individuals with developmental disabilities under the age of 18 who have significant needs and who meet the CWP eligibility requirements to live free of an institutional setting with their parents or legal guardians and to fully participate in their communities.
- Waiver for Children with Serious Emotional Disturbance (SEDW) - provides HCBS to children, youth, and young adults under age 21 who have significant mental health needs and who meet the SEDW eligibility requirements to live in their home and community instead of receiving hospital level of care.
The Michigan Department of Health and Human Services (MDHHS) will be submitting renewal applications for these three C-Waivers and each renewal application summarizes a list of changes and modifications included in the applications that can be reviewed and commented upon. A copy of each proposed renewal application can be found here: https://www.michigan.gov/mdhhs/keep-mi-healthy/mentalhealth/mentalhealth/medwaivers. Anyone interested in requesting a written copy of the C-Waiver renewal applications and/or who wish to offer comments can send an email to MSADraftPolicy@michigan.gov or submit a request in writing to: MDHHS/Behavioral and Physical Health and Aging Services Administration, Program Policy Division, PO Box 30479, Lansing MI 48909-7979.
For further information or questions, please contact Todd @ Todd.Lewicki@midstatehealthnetwork.org.