The Status of the Department of Health and Human Services' Compliance With Requirements To Establish a Data Collection Plan for the Medicaid Home and Community Care Waiver

GAO was requested to determine the status and nature of the data collection plan being developed by the Department of Health and Human Services as required under the Home and Community-Based Service provisions of the Omnibus Reconciliation Act of 1981. The legislation authorizes the Secretary of Health and Human Services to waive current Medicaid requirements so that States can submit a plan to provide coverage to Medicaid patients for a broad range of home and community-based services.

GAO met with Health Care Financing Administration (HCFA) officials to assess the status of the plan which is presently in draft form. The data are to be provided annually by the States and will form the basis for the annual impact monitoring report on the waiver program. The outline of the proposed plan does not include a description of how an unduplicated count of recipients will be determined. Without this explanation, there was no way to assess how much confidence could be placed in the numbers. Also, standard definitions were not provided for the new services covered under the waiver, and without standardization, States could report expenditures under one service category which would be classified as a different service in another State. Even if problems are resolved, the information available will be restricted to total expenditures for services within States and to total individual participants in the waiver by prior status. This will severely limit the kinds of information HCFA will be able to report to Congress on how the waiver program is operating. The plan will not provide information on how or if people are shifting service use, the nature of the kinds and packages of services being provided, or how long they are being provided. HCFA staff stated that providing this information would require a data collection system that would be person-based. While no approved version of the data collection plan exists, four States have been approved for the waiver and have provided assurances that they will provide data once the plan is implemented.