WAIVER TRANSPORTATION RATE STUDY METHODOLOGY AND ... · 1212 / ©2018 NAVIGANT CONSULTING, INC. ALL...
Transcript of WAIVER TRANSPORTATION RATE STUDY METHODOLOGY AND ... · 1212 / ©2018 NAVIGANT CONSULTING, INC. ALL...
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OCTOBER 23, 2018
WAIVER TRANSPORTATION RATE STUDY
METHODOLOGY AND
RECOMMENDATIONS
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OBJECTIVES
• Summarize the stakeholder feedback received during the Waiver
Transportation Study
• Present the recommendations developed by the Navigant
Consulting team
• Invite your comments and questions during and after this meeting
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ASKING QUESTIONS AND PROVIDING COMMENTS
How to ask questions during the public webinar:
During this presentation you may submit written questions using the “raise your hand”
webinar option and we will respond to them at the end of the presentation
How to ask questions after the public webinar:
• If you have questions or comments you wish to submit after the webinar, please use
the online feedback form at the link below
• The comment period will end on November 6, 2018
• The project website will provide a summary of comments and questions received
Availability of this presentation:
A taped recording of this webinar will be posted on the study website
For more information, visit the project website:
https://public.navigant.com/sites/MNTranspStudy/SitePages/Rate%20Study.asp
To provide comments on the methodology and recommendations, please use
the online form on the project website:
https://navigantmarketing.co1.qualtrics.com/jfe/form/SV_2tbtusYdK25YMAd
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AGENDA
1. Waiver transportation study overview
2. Waiver transportation study methodology
3. Minnesota’s waiver transportation providers
4. Key themes that informed recommendations
5. Rate Study recommendations
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SECTION I: WAIVER
TRANSPORTATION STUDY
OVERVIEW
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MEDICAID HOME AND COMMUNITY-BASED SERVICES
PROGRAMS
What are home and community-based services (HCBS)?
• Services that provide opportunities for aging people and people with disabilities to
receive services in their own homes or communities rather than other potentially isolating
settings
• Examples of services are adult day services, customized living, personal care assistance,
and waiver transportation
How do states use Medicaid to pay for HCBS?
• States must ask special permission from the federal government to use Medicaid funding
to implement HCBS
• This permission is granted in the form of a waiver of federal requirements. As such, these
programs are called “HCBS waiver programs”
• All states offer HCBS waiver programs. These programs vary in terms of the included
services and eligibility
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MEDICAID HOME AND COMMUNITY-BASED SERVICES
PROGRAMS
What agencies or organizations are in charge of HCBS in Minnesota?
• The Minnesota Department of Human Services (DHS) administers HCBS programs
• There are four waiver programs for Minnesotans with disabilities and two programs for
aging Minnesotans where services are available if individuals meet certain eligibility
standards
• Lead agencies deliver the services including county social service agencies, managed
care organizations (MCOs), and tribal agencies
• Managed care organizations are the lead agencies for the Elderly Waiver Program
• Counties and Tribes are the lead agencies for disability waiver programs and the
Alternative Care Program
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HCBS WAIVER PROGRAMS FOR AGING PEOPLE
Waiver Description
Waiver Transportation Recipients and
Expenditures
(State Fiscal Year 2016)
Alternative Care
(AC)
(fee-for-service)
Serves individuals over
age 65 years who are at
risk of nursing home
placement
• 572 recipients
• $298,915 in Medicaid expenditures
• $523 per recipient
Elderly Waiver
(EW)
(fee-for-service
and managed
care)
Serves individuals older
than age 65 who require
the level of care provided
in a nursing facility and
choose to reside in the
community
• 5,095 recipients
• $12,075,901 in Medicaid expenditures
• $2,370 per recipient
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HCBS WAIVER PROGRAMS FOR INDIVIDUALS WITH DISABILITIES
DELIVERED BY COUNTIES AND/OR TRIBES
Waiver Description
Waiver Transportation
Recipients and
Expenditures
(State Fiscal Year 2016)
Brain Injury
(BI) Waiver
Serves individuals with a traumatic,
acquired, or degenerative brain injury (BI)
who require the level of care provided in a
nursing facility that provides specialized
services for persons with BI, or who
require the level of care provided in a
neurobehavioral hospital
• 641 recipients
• $1,052,033 Medicaid
expenditures
• $1,641 per recipient
Community
Alternative
Care (CAC)
Waiver
Serves individuals who are chronically ill
and medically fragile who require the level
of care provided in a hospital
• 9 recipients
• $3,658 Medicaid
expenditures
• $406 per recipient
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HCBS WAIVER PROGRAMS FOR INDIVIDUALS WITH DISABILITIES
DELIVERED BY COUNTIES AND/OR TRIBES, CONTINUED
Waiver Description
Waiver Transportation
Recipients and
Expenditures
(State Fiscal Year 2016)
Community Access
for Disability
Inclusion (CADI)
Waiver
Serves individuals with disabilities who
require the level of care provided in a
nursing facility
• 8,446 recipients
• $9,006,953 in Medicaid
expenditures
• $1,066 per recipient
Developmental
Disabilities (DD)
Waiver
Serves individuals with developmental
disabilities or a related condition who
require the level of care provided in an
Intermediate Care Facility for Persons
with Developmental Disabilities
(ICF/DD)
• 1,491 recipients
• $2,250,692 in Medicaid
expenditures
• $1,510 per recipient
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CONTEXT FOR LEGISLATIVE MANDATE FOR
TRANSPORTATION STUDY
• In 2013, the Centers for Medicare and Medicaid Services (CMS) required states,
including Minnesota, to develop standardized service definitions and rates for all
HCBS waiver programs
• In 2014, DHS implemented new statewide HCBS rates
• Waiver transportation was excluded, because DHS did not have a process for
certifying waiver transportation providers as a group
• In 2017, the DHS Long Term Services and Supports Gap Analysis and Olmstead
Subcabinet consumer reports indicated gaps in service related to transportation for
people receiving HCBS waiver program services
• As a result, the Minnesota legislature directed DHS to conduct a study to identify
and recommend the following:
1. Waiver transportation service rate(s)
2. Waiver transportation technical and administrative improvements
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DEFINITION OF WAIVER TRANSPORTATION SERVICES
What are waiver transportation services and why are they important?
• Waiver transportation allows seniors and individuals with disabilities to access
their communities and lead a productive and fulfilled life
• Examples of transportation destinations include:
- Shopping for groceries and household supplies
- Going to work
- Participating and recreational activities
• In State Fiscal year 2016, 16,254 HCBS waiver recipients received waiver
transportation services totaling $24,688,151 in Medicaid expenditures
What are the types of waiver transportation providers?
Types of waiver transportation providers include taxis, van services, public buses
and trains, and volunteer drivers
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DEFINITION OF WAIVER TRANSPORTATION SERVICES
Which transportation services are not included in this study?
• Transportation services that are provided as an essential component of another
Medicaid HCBS service, for example:
- Adult day health care
- Day treatment and habilitation
- Group homes
• Transportation services related to medical care, for example:
- Emergency medical transportation (EMT)
- Non-emergency medical transportation (NEMT) services for recipients to access
doctor’s appointments
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WAIVER TRANSPORTATION PROVIDER ENROLLMENT AND
BILLING
• How are waiver providers enrolled and how do they bill?
• The Centers for Medicare and Medicaid Services requires that all Medicaid HCBS
providers be Medicaid-enrolled. To meet these requirements, DHS created policies
that allow lead agencies to deem a provider as Medicaid-enrolled for the purposes
of waiver transportation services
• The majority of waiver providers enroll with lead agencies and submit invoices (not
in a Medicaid claim format) for payment. Lead agencies then convert this
documentation into Medicaid claims to receive DHS reimbursement
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OVERVIEW OF TRANSPORTATION STUDY
There are two components of the Minnesota waiver transportation study:
1. Rate Study: Identify and recommend service rates for transportation
available under Minnesota’s four disability waiver programs and the Elderly
Waiver and Alternative Care programs
2. Access Study: Identify and recommend technical and administrative
improvements to transportation available to individuals under Minnesota’s
four disability waiver programs and the Elderly Waiver and Alternative Care
programs
Today’s public webinar discusses recommendations
developed as part of the Rate Study
(October 23, 2018 from 1:00 – 3:00 pm)
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DHS ESTABLISHED ADVISORY GROUPS FOR EACH STUDY
• The Department of Human Services convened a Rate Study Advisory Group and an
Access Study Advisory Group to provide input and feedback throughout the study
via monthly meetings
• Members of these two stakeholder advisory groups included representatives for
waiver program consumers, state agencies/organizations, and statewide
associations and providers that influence transportation services
• Rate Advisory Group topics
- Provider cost and wage survey input
- Rate components / assumptions
- Feedback regarding rate recommendations
• Access Advisory Group meeting topics
- Access survey input
- Feedback regarding transportation access barriers and solutions
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SECTION II: WAIVER
TRANSPORTATION STUDY
METHODOLOGY
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STUDY METHODOLOGY
• Navigant developed key
observations and
recommendations from
extensive and comprehensive
research on waiver
transportation issues
• Research included qualitative,
quantitative, and mixed
methods
Recommendations
Quantitative
Mixed Method
Qualitative
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QUALITATIVE RESEARCH
1. Qualitative Research
• Input and guidance from Access and Rate Advisory Groups
• Approximately 90 stakeholder interviews with individuals, groups, and online
email discussions including:
- Consumer organizations: National Alliance on Mental Illness Minnesota,
Governor’s Council on People with Developmental Disabilities and Minnesota
Disability Council
- Lead agencies: Representatives from four counties, seven MCOs covering
services to the elderly waiver participants, and email feedback from tribal agencies
- Minnesota State agency representatives: DHS, MnDOT, Metro Council, University
of Minnesota Humphrey School of Public Affairs
- Providers of transportation services
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QUALITATIVE RESEARCH: CONTINUED
1. Qualitative Research
• Interviews with representatives from nine other state NEMT and HCBS
programs
• Literature and document review:
- Relevant Minnesota transportation-related programs, activities, and published
documents/reports
- Minnesota State statutes, policies and regulations
- National and local emerging transportation initiatives and new technologies
- Studies conducted on Medicaid transportation programs across the country
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MIXED METHOD AND QUANTITATIVE RESEARCH
2. Mixed Method Research
• Navigant contracted with the University of Minnesota Humphrey School of
Public Affairs to develop and conduct an Access Survey directed at
providers of waiver transportation services and focused on understanding
fleet capacity and barriers to providing waiver transportation
3. Quantitative Research
• Navigant conducted a Rate Survey of providers of waiver transportation
services requesting specific information on the costs of providing services
• Navigant reviewed and analyzed two years of fee-for-service Medicaid
claims data (State Fiscal Years 2016 and 2017)
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RATE SURVEY PROCESS
• Navigant developed a cost and wage survey to capture provider
information related to delivering waiver transportation services
• The survey was released through the relevant provider associations on July
17, 2018 and through MN-ITS on July 24, 2018, with an original due of
August 14, 2018
- There were two MN-ITS communications, one to day training and
habilitation (DT&H) and waiver transportation providers, and the other
going to all providers
- An extension was granted through August 17, 2018 to increase survey
responses
• Each survey was reviewed for consistency and completeness
• The results of the cost survey were used to inform the development of the
updated waiver transportation rates
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RATE SURVEY REVIEW PROCESS
Cost Survey is submitted
Navigant reviews
Cost Survey
Questions are sent to Provider (if necessary)
Responses by Provider
are reviewed (if necessary)
Further questions are asked
(if necessary)
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RATE SURVEY RESPONDENT PROFILE
• Surveys were received from:
- 61 providers (this represents approximately 12% of the 491 active and
enrolled waiver transportation and DT&H providers)
- Providers deliver services in 72 out of the 87 Minnesota counties
• Respondents generally provide:
• Respondents provide the following level of services:
• Day training and habilitation services • Occupational training
• Adult day care services • Other disability services
• Public transit • Other private transportation services
• Fixed route services – 26% • Door-through-door – 20%
• Curb-to-curb – 31% • Other assistance – 1%
• Door-to-door – 21%
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SECTION III: EMERGING STATE
AND NATIONAL TRENDS
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EMERGING TRANSPORTATION TRENDS – STATE AND
NATIONAL
Mix-model (fee-for-service, broker and/or managed care organization):
- Fee-based payment in some areas of the state,
- Contracts with transportation coordination companies who coordinate all
transportation services in other areas, and
- Managed Care Organizations
On demand request or ride-hailing services:
- Some states contract with “ride-hailing” companies to provide NEMT services
(e.g. Uber and Lyft)
- Dakota County has a similar pilot project with Lyft for waiver transportation
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EMERGING TRANSPORTATION TRENDS – STATE AND
NATIONAL
1) MCOTA. Vehicle Sharing Among Human Service Providers in Minnesota: Steps to Address Barriers; Sept. 2013
Vehicle Sharing:1
• To increase access to transportation services, organizations are leveraging
vehicle-sharing services to increase coordination of transportation among many
consumers and lower overhead costs
• Definition: there are two types of vehicle-sharing:
- Time Sharing: One or more organizations operating the same vehicle at
different times
- Ride Sharing: Using the vehicle of one organization to provide
transportation for the clients of another organization
• Minnesota has several examples of vehicle sharing between county and city
transportation providers and private human service organizations
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Regional Transportation Coordination Councils or RTCCs:2
• MnDOT, DHS, and other State agencies are working with the Metropolitan
Council and other local governments to create RTCCs throughout 8-10 regions in
the State
• MnDOT approved RTCCs will be funded in 2019 and operational in 2020 or later
• RTCCs will be responsible for coordinating transportation services through a
network of existing public, private, and non-profit transportation providers
• Each RTCC will be composed of residents within each service area with oversight
from the State and local agencies and organizations
EMERGING TRANSPORTATION TRENDS – STATE AND
NATIONAL
2) Coordinate MN Transit, Regional Transportation Coordinating Councils (RTCC’s). Available online: http://www.coordinatemntransit.org/regional/rtccs/
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SECTION IV: KEY THEMES THAT
INFORMED
RECOMMENDATIONS
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CONSISTENT THEMES FROM STAKEHOLDERS
Stakeholder feedback yielded the following themes regarding barriers to access for
waiver transportation. These findings provided context and a solid foundation for
Navigant’s final recommendations.
1. Lead agency authorization and coordination of services takes a lot of time and
could be made more efficient
2. There is a wide variability provider approval requirements and payment policies
across lead agencies
3. Lead agencies and providers could benefit from improved infrastructure support
and centralization of administrative functions
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CONSISTENT THEMES FROM STAKEHOLDERS, CONT’D
4. Vehicle-sharing among transportation providers is limited, if not prohibited due to
liability and other issues. Vehicle sharing could increase the availability and hours
of operation of waiver transportation providers
5. Evaluating the quality and costs of waiver transportation services is challenging
without defined statewide service standards, more detailed utilization and
expenditure reporting capabilities, and a process for uniform tracking of consumer
access and service issues
6. Provider participation is hampered by the widespread perception of an inadequate
and uneven rate structure
The following slide summarizes stakeholder feedback related to theme number six
and is not specific to the stakeholder type providing the feedback.
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STAKEHOLDER FEEDBACK: PERCEIVED INADEQUATE AND
UNEVEN RATE STRUCTURE
• Providers reported that rates do not cover the costs of transportation delivery,
including but not limited to:
- Licensing and compliance with policies and regulations
- Unloaded miles
- Vehicle maintenance
- Cancelled rides
- Driver recruitment and training
- Insurance costs
• There is a large variation between waiver transportation rates and methodologies
across lead agencies
• Current rates established by lead agencies through the market rate do not
consistently account for these specialized services:
o Curb-to-curb = drivers will assist passenger in and out of vehicles only
o Door-to-door = drivers will assist passengers to the entrance of their origin or destination
o Door-through-door = drivers will assist passenger to the inside of their origin or destination
• There is a lack of reimbursement for unloaded miles which discourages volunteer
driver participation
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SECTION V: RATE STUDY
RECOMMENDATIONS
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OBJECTIVES TO GUIDE RECOMMENDATIONS
The following objectives were created to guide the development of the
recommendations and reflect feedback from the Rate and Access Advisory Groups:
1. Advance access and availability of waiver transportation services to all waiver
participants, regardless of program type, participant’s abilities, or geographic
location
2. Support an increase in appropriate and cost-effective person-centered delivery
of transportation, including an on demand (“demand request”) response option
3. Maximize use of cost-effective pre-existing community capacity for
transportation
4. Adjust the current reimbursement structure to support the delivery of quality
services to meet identified individual needs
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RATE APPROACHES TO ADDRESS DIFFERENT TYPES OF
TRANSPORTATION PROVIDERS
• Per Trip
- Build-up approach that incorporates wages, miles, vehicle costs, administrative
overhead, and other factors to determine a standardized per trip rate
• Public Transit (contracted through lead agencies)
- Advertised per trip rate
- Ability to purchase monthly/annual pass at discount
• On-demand (contracted through lead agencies)
- Negotiated or market rates with on-demand transportation service
• Per Mile (Volunteers)
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PER TRIP: RATE METHODOLOGY
• Analysis is built from the ground up
• Recognizes the costs of specific services
• Assumptions can be derived from provider, state, or industry standard data
• Employs assumptions of:
- Wages – hourly wages
- Employee related expenses – costs related to employee taxes and benefits
- Client absences – time related to missed appointments
- Program plan support – non-service delivery time (meetings, documentation, and
other activities to support the service)
- Vehicle programming and supports – support costs related to providing the
service
- Administrative overhead – costs related to an organization’s overhead and
operations
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PER TRIP: RATE METHODOLOGY BENEFITS
• Transparency
- Models contain the factors and values that drive the final rate
• Ability to include policy objectives
- Examples could include improving direct care staff salaries or benefits or
incentivizing increased access to services
• Efficiency in maintaining rates
- Models can be easily scaled and adjusted for inflation or specific cost factors
• Alignment with similar services
- Assumptions from similar services can be aligned to create consistent policy
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PER TRIP: WAIVER TRANSPORTATION (WAGES)
• Wages – accounts for hourly wages for program employees providing the
service directly to the individual
• Cost survey results
- Median wage: $13.30
• Preliminary recommendation for wage: blend of two occupational
classifications based off of 2017 Bureau of Labor Statistics Wage Data3
- 60% - Personal and Home Care Aides: $11.78
- 40% - Bus Drivers, School or Special Client: $16.42
- Total recommended wage: $13.64
• Using BLS wages will allow for more frequent rate adjustments as data is
published annually
3 Minnesota statewide median value
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PER TRIP: WAIVER TRANSPORTATION (EMPLOYEE RELATED
EXPENSES)
• Employee Related Expenses (ERE) – accounts for employee taxes,
benefits, and insurance as a percent of employee salaries and wages
• Cost survey results
- Median ERE: 21.9%
• Preliminary recommendation for ERE
- Use the ERE that is incorporated into the Disability Waiver Rate System (DWRS)
of 23.6% as this is similar to the cost survey results
• Using the DWRS value will create consistent methods across waivers and
allow for easier updates in the future
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PER TRIP: WAIVER TRANSPORTATION (CLIENT ABSENCES)
• Client Absences – accounts for consumer “no-shows” for scheduled pick-up
(scheduled service where the individual does not use the transportation
service)
• Cost survey results
- Median Absence Factor : 3.69%
• Preliminary recommendation for Absence Factor
- Use the Absence Factor that is incorporated into the Disability Waiver Rate
System (DWRS) of 3.9% as this is similar to the cost survey results
• Using the DWRS value will create consistent methods across waivers and
allow for easier updates in the future
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PER TRIP: WAIVER TRANSPORTATION (PROGRAM PLAN
SUPPORT)
• Program plan support – accounts for time that program staff must spend on
non-reimbursable activities as a percent of employee salaries and wages
• Cost survey results
- Median Program Plan Support Factor : 16.7%
• Preliminary recommendation for Program Plan Support Factor
- Use the program plan support factor that is incorporated into the Disability Waiver
Rate System (DWRS) of 15.5% as this is similar to the cost survey results
• Using the DWRS value will create consistent methods across waivers and
allow for easier updates in the future
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PER TRIP: WAIVER TRANSPORTATION (VEHICLE
PROGRAMMING AND SUPPORTS)
• Vehicle programming and supports – accounts for expenses tied to
supporting the delivery of the transportation services (for example, fuel,
vehicle, tires, licensing fees, insurance, maintenance, and other expenses) as
a percent of employee salaries and wages
• Cost survey results
- Median Vehicle Programming and Supports Factor : 23.10%
• Preliminary recommendation for Vehicle Programming and Supports Factor
- Use the median Vehicle Programming and Supports Factor of 23.10%
- Calculated as the ratio of total vehicle-related program/support costs to direct
worker costs. We expect that this ratio will be higher than we would see in other
services because there are likely higher program costs for the numerator and
fewer direct care workers to establish the denominator.
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PER TRIP: WAIVER TRANSPORTATION (ADMINISTRATION
FACTOR)
• Administration (admin) factor – accounts for administration expenses to
program employee salaries, wages and benefits (for example, administrative
salaries, IT costs, and office supplies) as a percent of employee salaries and
wages
• Cost survey results
- Median Administration Factor : 20.8%
• Preliminary recommendation for Administration Factor
- Use the admin factor that is incorporated into the Disability Waiver Rate System
(DWRS) of 23.0% as this is similar to the cost survey results
• Using the DWRS value will create consistent methods across waivers and
allow for easier updates in the future
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PER TRIP CALCULATION
• Cost survey results and DWRS factors are represented as a percent of
wages plus employee related expenses
Total Staff Compensation = Wages * ERE Factor
Total cost per day =
Total Staff Compensation * Absence Factor
Total Staff Compensation * Program Plan Support Factor
Total Staff Compensation * Vehicle Programming and Supports Factor
Total Staff Compensation * Admin Factor
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PER TRIP CALCULATION (CONTINUED)
• To convert total cost per day to a per trip value: need to determine
a reasonable estimate of the number of trips that can be provided
during an 8 hour shift.
• Established Mileage Bands to account for the range of distances
traveled when delivering waiver transportation services
• Proposed mileage bands
- 0-9 miles
- 10-19 miles
- 20-39 miles
- 40-59 miles
- Greater than 60 miles
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PER TRIP CALCULATION (CONTINUED)
• Single occupant rate per trip
- Divide total cost per day by the maximum number of trips per day within
each mileage band, to arrive at a single occupant rate per trip
➢ 270 miles per day (6.76 billable hours per day * 40 miles per hour)
➢ Divided by the highest mile value within the mileage band
➢ Divided by two to determine number of one-way trips
➢ Multiplied by 1.5 to assume half of return trips are empty vehicles
• Proposed trips per day for each mileage band
• Apply add-on component for assisting passengers to enter and exit
the vehicle for multi-passenger trips
– 0-9 miles = 23 trips
– 10-19 miles = 11 trips
– 20-39 miles = 5 trips
– 40-59 miles = 3 trips
– Greater than 60 miles = 3 trips
/ ©2017 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED47 / ©2018 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED47
RATE CHANGES FOR FUTURE CONSIDERATION
• New rates will be implemented in 2021
- DHS must assess the impact the rate changes have on access to services and
providers
• Advisory group members identified the following rate recommendations,
which will be revisited after the initial rate changes have been implemented
and monitored:
- Adjust payment rates to account for high demand and low availability
times (for example, weekends and evening hours)
- Adjust payment rates based upon the type of vehicle and modifications
/ ©2017 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED48 / ©2018 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED48
ASKING QUESTIONS AND PROVIDING COMMENTS
How to ask questions during the public webinar:
During this presentation you may submit written questions using the “raise your hand”
webinar option and we will respond to them at the end of the presentation
How to ask questions after the public webinar:
• If you have questions or comments you wish to submit after the webinar, please use
the online feedback form at the link below
• The comment period will end on November 6, 2018
• The project website will provide a summary of comments and questions received
Availability of this presentation:
A taped recording of this webinar will be posted on the study website
For more information, visit the project website:
https://public.navigant.com/sites/MNTranspStudy/SitePages/Rate%20Study.asp
To provide comments on the methodology and recommendations, please use
the online form on the project website:
https://navigantmarketing.co1.qualtrics.com/jfe/form/SV_2tbtusYdK25YMAd
/ ©2017 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED49
CONTACT INFORMATION:
ANDREA PEDERSON, DIRECTOR AT NAVIGANT
BETSY WALTON, DIRECTOR AT NAVIGANT
DENNIS FINNEGAN, ASSOCIATE DIRECTOR AT NAVIGANT
FRANK DOUMA, STATE AND LOCAL POLICY PROGRAM DIRECTOR
HUBERT H. HUMPHREY SCHOOL OF PUBLIC AFFAIRS
UNIVERSITY OF MINNESOTA
GWYN VOLK, DIRECTOR AT NAVIGANT