Public Notice and Input

Prior to submission of this waiver application, Illinois had an extensive process for public input and dialogue. Our public notice and input process was consistent with the requirements outlined in 42 CFR Part 431 Subpart G. It should also be noted that many of the provisions included in this proposal grew out of the ongoing health reform dialogue in the state (including numerous opportunities for public input) as outlined in Section I of this proposal, including the Alliance for Health and the Governor’s Health Reform Implementation Council.

Public Website

The State developed a website for the Path to Transformation waiver, which is accessible on the state’s

page includes a copy of the waiver concept paper, waiver drafts, slide decks from stakeholder meetings, attendance lists from stakeholder meetings, and instructions (with links) on how to submit comments on the concept paper and waiver drafts.

A copy of the waiver concept paper was posted on the state’s website on November 7 and also distributed via e-mail to dozens of stakeholders. The State received written comments from 94

organizations and individual stakeholders on the concept paper. Comments were grouped by topic and summarized for review by state staff and consultants.

A draft of the waiver proposal was posted on the state’s website on January and also distributed via e-mail to stakeholders. The State received written comments from 85 organizations and individuals on the draft waiver proposal. Comments were grouped by topic and summarized for review by state staff and consultants.

Stakeholder Meetings

The state held three large group stakeholder meetings to discuss waiver concepts and solicit input from stakeholders. Each stakeholder meeting was held more than once, and in-person, phone and video options were provided to maximize accessibility. The dates and primary topics of the waiver stakeholder meetings are listed below:

October 18: Waiver kick-off meeting; waiver goals and timeline

November 14 (two sessions): Consolidation of 1915(c) waivers under 1115; concept paper discussion

January 9/10 (two sessions): Consolidation of 1915(c) waivers under 1115; discussion of draft waiver

In addition to the large group stakeholder meetings, state staff and our consultants met individually with dozens of stakeholder groups and advocates, including, but not limited to the following. Please see Appendix E for a complete list of stakeholder meetings.

 Illinois Primary Care Association

 Illinois Hospital Association

 Illinois Human Services Commission

 AARP

 Illinois Health Care Association

 SEIU Healthcare Illinois/Indiana

 Illinois Association of Community Care

 Illinois Association of Rehabilitation Facilities

 Illinois Association of Area Agencies on Aging

 Illinois Council on Developmental Disabilities

Finally, our waiver consultant team met regularly with all interested state agencies, including the Medicaid agency (Department of Healthcare and Family Services) and the agencies with responsibility for the current 1915(c) (Department on Aging, Department of Human Services). Cross-agency briefings on the waiver were held on December 9, December 16, December 23, December 30 and February 5.

Legislative Briefings and Hearing

Key legislative staff members were briefed on the waiver on multiple occasions by the governor’s office and agency leadership. In addition, several legislative hearings on the waiver were held, including:

 House Human Services/ House Human Services Appropriation Committee -- December 18, 2013

 House Human Services/House Human Services Appropriation Committee – January 22, 2014

 House Human Services/House Human Services Appropriation Committee – February 25, 2014

Public Notice of Waiver Application

A public notice of the waiver application was published in the Illinois Register on February 7, 2014, allowing for a 30-day comment period. The waiver application was also posted on the state’s website for public comment. Additional public stakeholder meetings were held on February 14 (Springfield) and February 20 (Chicago), in compliance with federal regulations. More than 70 individuals and

organizations provided written comments during this public notice period. While many of the comments were beyond the scope of the waiver or were already addressed in the waiver, additional refinements were made to the waiver based on public comments. In addition, many helpful comments were received and will be catalogued to inform the waiver implementation process and future discussions with CMS regarding the waiver. There were several recurring themes in the comments received, which are summarized below:

 Most commenters were supportive of the waiver, but had additional ideas for provisions they wanted to see included in the waiver or ideas on how waiver provisions should be implemented

 Several commenters wanted to see more detail included in the waiver application itself and were uncomfortable with the amount of detail that must be worked out in the waiver terms and conditions and implementation plan.

 Several commenters sought the restoration of adult dental care under the waiver.

Pathways 1 and 2

 Several organization expressed concern that the public private partnerships articulated in the Cook County DSRIP proposal and the proposal to incentivize collaboration between health care delivery systems and Regional Public Health Hubs constituted a privatization of services. This is not the intent of the waiver and we have tried to clarify the language.

Pathway 3

 There was support from several organization to add Primary Care Residency Expansion (PCRE) programs to the Teaching Health Center (THC) program provision. The State is interested in further exploring this idea with CMS.

Pathway 4

 Several organizations were concerned about provisions to incentivize smaller (i.e., 4-bed) CILAs.

The State believes this language is consistent with our overall goals and has not changed the language in the waiver.

 Several organizations recommended expanding the definition of “personal assistant” to included community activities. The State is currently reviewing this recommendation for cost and impact and will raise with CMS if we determines we can both afford it and it improves quality.

 Several individuals and organizations recommended including peer support services in the waiver. These services are already included in the waiver.

 We received several comments expressing concern about the proposed waiver of certain cost sharing provisions. We believe the concern is related to amisunderstanding of the intent of this waiver. However, the state will follow up with stakeholders and may modify this request pending those discussions.