Public records request filed seeking transparency on decision-making methodology, assessment training, quality assurance, and implementation problems
The Arc of Indiana supports the Indiana Family and Social Services Administration’s (FSSA) decision to pause adverse level-of-care determinations resulting from InterRAI assessments and take corrective action in response to concerns about how assessments have been conducted. InterRAI is the new assessment tool implemented earlier this year as part of the process to determine if people meet the level-of-care requirements for Medicaid waiver services.
The pause follows months of concerns raised by individuals with disabilities, families, case managers, providers, and advocates about the assessment’s implementation and individuals facing the loss of critical home and community-based services.
The Arc has repeatedly raised these concerns with FSSA and sought additional information about the assessment process. While FSSA is now taking important steps to address assessment administration, significant questions remain unanswered.
The Arc is submitting a request under Indiana’s Access to Public Records Act seeking records on how Indiana implemented InterRAI, how assessment information is used to make eligibility decisions, assessor training and oversight, quality assurance, implementation problems, and outcomes under the new process.
Read the Public Records Request
“FSSA’s decision to pause adverse determinations and reassess individuals who may have been affected is an important step,” said Kim Dodson, CEO of The Arc of Indiana. “We have raised concerns about inconsistent assessments, inadequate training, changes to the process, and poor communication with individuals and families. We appreciate that FSSA is responding to some of those concerns. Now we need to make sure the problems are fully corrected and understand how the information collected through InterRAI is actually being used to determine eligibility.”
The Arc has taken steps to better understand the assessment, including meeting with InterRAI fellows familiar with how the intellectual disability assessment was developed and is intended to be used.
“What we have learned suggests that the tool itself is not the fundamental problem. The concern is how Indiana has implemented and used it.” Dodson said. “InterRAI is intended to be a comprehensive, person-centered assessment that considers information from multiple sources, individual circumstances, observations, and professional judgment. Many of the assessment experiences individuals and families have shared with The Arc do not reflect that approach.
“FSSA has informed The Arc that individuals with adverse determinations currently in the appeal process will have those determinations retracted and receive new assessments. The State has also identified additional individuals who will be reassessed because of concerns with how their assessments were conducted. Those reassessments will be conducted by mentors or other specially trained assessors, with the individual’s assigned case manager participating in the process.
The Arc strongly supports this approach and believes specially trained, experienced assessors should be used for InterRAI assessments going forward.
“This is a sophisticated assessment that can have enormous consequences for an individual,” Dodson said. “It should be conducted by people who know the instrument, understand how it is intended to be administered, and have demonstrated proficiency in using it. The individual’s case manager, family members, and guardians should also be meaningfully involved to provide important information about the person’s abilities, needs, and supports.”
While these corrective actions address important concerns about how assessments are conducted, serious questions remain about how assessment information is used to determine eligibility.
InterRAI does not determine who qualifies for Indiana’s Medicaid waivers. Indiana does. FSSA has mapped information collected through InterRAI to Indiana’s level-of-care criteria and uses that methodology to make eligibility determinations. The Arc is seeking greater transparency about that process.
“People with intellectual and developmental disabilities have a broad range of abilities and support needs,” Dodson said. “We need to understand what assessment information matters, how it is weighted, what criteria or thresholds are used, and how the methodology was developed and tested. We must have confidence that the process accurately identifies everyone who meets Indiana’s level-of-care requirements, not only people with the most significant or readily apparent disabilities.”
The Arc’s public records request seeks information about that decision-making methodology, along with records concerning assessment training, quality assurance, implementation problems, and outcomes.
“We appreciate the steps FSSA is taking to correct problems with how assessments have been conducted,” Dodson said. “Now we need the same level of clarity about the other half of the process: how the information collected through InterRAI becomes an eligibility decision. Hoosiers with disabilities and their families deserve confidence that assessments are conducted correctly and that the information they produce is being used fairly and accurately to determine eligibility.