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New Guidance for FMSAs on CDS Employer Orientations

Date: 04/07/22

Texas Health and Human Services (HHS) has provided new guidance regarding Financial Management Services Agency (FMSA) requirements for providing Consumer Directed Services (CDS) employer orientations under the CDS option. This guidance is applicable to Superior HealthPlan Medicaid (STAR, STAR Health, STAR Kids, STAR+PLUS), CHIP and Superior HealthPlan STAR+PLUS Medicare-Medicaid Plan (MMP).

On March 20, 2020, HHS announced FMSAs should suspend in-person CDS employer orientations due to the Public Health Emergency (PHE) caused by the ongoing risks of COVID-19. On November 18, 2021, HHS announced that the policy to allow FMSAs to conduct CDS orientations virtually (using audio-visual platforms), or in-person, would become permanent effective February 1, 2022. See original notice: Financial Management Services Agencies Should Suspend Face-to-Face Activities

Please note the following additional clarifications from HHS posted in Information Letter 2021-54 - COVID-19 Guidance for FMSAs and CDS Employers:

  • HHS clarified that effective February 1, 2022, audio-only CDS orientations are no longer permitted.
  • On March 29, 2022, HHS clarified that, for purposes of CDS requirements in 40 TAC Chapter 41 only, “face-to-face” includes both in-person orientations and virtual orientations conducted using synchronous audio-visual platforms.
  • FMSAs are not required to provide in-person orientation visits for all CDS employers whose initial orientation was conducted virtually or by telephone from March 20, 2020 through January 31, 2022.
    • For all CDS employers whose initial orientation was conducted virtually or by telephone from March 20, 2020 through January 31, 2022, the FMSA must provide the CDS employer an in-person orientation, if the CDS employer requests an in-person orientation.