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Virtual PACE Proposal

Program Design and MOU

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Virtual PACE Program Design and Memorandum of Understanding

The Memorandum of Understanding (MOU) between DHS and Centers for Medicare and Medicaid Services (CMS) will constitute CMS approval of the DHS demonstration proposal and outline additional program design details.

Revised Memorandum of Understanding (MOU) Submitted to CMS 8/12/13
DHS submitted a revised draft MOU to CMS on August 12, 2013. This draft has been revised based on feedback from stakeholders regarding the April 2013 draft and subsequent negotiation with CMS. The proposed MOU incorporates compromises between the originally-envisioned, fully integrated model and the alignment pathway CMS has subsequently established, to the extent consistent with program objectives. This version is as far as Wisconsin will move from the goal of full integration towards an aligned, but not integrated, model such as the Financial Alignment Demonstrations. Also see the letter to CMS below in the Correspondence section of this page for more information on this proposed MOU submittal.

Wisconsin’s Proposed MOU Submitted August 12, 2013 (PDF, 562 KB)

Memorandum of Understanding (MOU) Public Comments and Revised Draft MOU
DHS received comments from five organizations, and major themes included requests for more detail, questions on and issues with omitted financing and payment sections, and comments on medically necessity definitions and the integrated appeals process. The comments received were from the following entities:

Public comments on the draft MOU and DHS responses are summarized in the following document:

The MOU has been revised in response to some of the comments; the version posted below contains tracked changes showing what was revised. Revisions occur in Section III.E regarding Ombusdman services, Appendix 7 Section IX regarding appeals, and Appendix 7 Section XI regarding Administration and Oversight. DHS submitted this version to CMS on April 23, 2013.

Virtual PACE Draft Memorandum of Understanding (MOU) for Public Comment
The Department of Health Services (DHS) drafted a Wisconsin-specific MOU based on the template issued by CMS, which was modeled after the agreement reached in the Massachusetts demonstration. The MOU is the agreement between the state and CMS for administration of the integrated initiative. The draft proposed here has not yet been approved by CMS and is subject to further review.

The draft MOU was developed from the content in the proposal Wisconsin submitted to CMS for the integrated Virtual Pace demonstration model, with changes to reflect subsequent negotiations between Wisconsin and CMS in some areas of program operations. The public was invited to comment on this draft.

Documents that describe DHS-proposed MOU language:
Shared with Stakeholder Advisory Committee and sent to CMS.

Documents that describe proposed program design details:
Shared with Stakeholder Advisory Committee and CMS for discussion and eventual incorporation into the MOU.

CMS Questions and DHS Responses
CMS questions on Wisconsin’s demonstration proposal and DHS responses will be incorporated into the MOU.


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Last Revised: August 14, 2013