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Q: If Medicare is paying for a members nursing facility stay for the max 20 days, does the case management agency need to complete a Level of Care (LOC) for Nursing Facility (NF) for those 20 days or can they hold off on completing an LOC for NF, so at the end of their 20 day stay, the member can still access HCBS services?
A: If Medicare is able to be used for temporary Nursing Facility placements and, if the Nursing Facility is able to bill Medicare for temporary placements, a new LOC Screen would not be needed as it is a temporary placement (please see operational memo 25-027 on temporary therapy placements and terminations). However, if the nursing facility stay is longer than 20 days, an LOC Screen would need to be completed for nursing facility as Medicare will only pay for 20 days. An LTC Notice of Action would also need to be issued for the termination of HCBS.
Q: Can a nursing facility require a new Level of Care (LOC) Screen to be completed before a member is admitted to their facility? In addition, what should an incoming CMA do if the previous CMA does not get the LOC Screen completed for a member transfer and the referral was sent to the previous CMA instead of the incoming CMA?
A: Yes, a Level of Care (LOC) Screen for NF is required prior to the member being admitted to the Nursing Facility. In addition, the discharging nursing facility shall notify the CMA in their designated service area where the NF is located to complete the discharge process, which would include the LOC Screen, when placement into HCBS services is being considered (10 CCR 2505-10 8.7202.c.2.a. Otherwise, CCR 8.7202.M should be followed, and agencies should coordinate who will complete the LOC Screen based on the best interest of the member.
Q: Is the case management agency required to complete a new Level of Care (LOC) Screen if the nursing facility does not take Medicare and needs a new LOC Screen for NF in order to bill for that member's stay, even though financial approval or denial still needs to be obtained?
A: Yes, the case management agency is required to complete the LOC Screen before admission into the NF. The LOC Screen shall not be delayed pending Financial determination. Financial eligibility cannot be determined without a LOC Screen is completed; therefore, an assessment would need to be completed for the NF to bill Medicaid. Please see Section 8.7202.B on “Intake, Screening and Referral” and OM 25-025 for further guidance.
Q: Are there any exceptions to doing a monitoring via email for members who do not communicate verbally and only use an eye-gaze device for communication?
A: At this time, emails are not an approved method of contact for monitoring. All monitoring method options should be explored if the individual is not able to communicate verbally, such as:
1. Natural and paid supports helping to facilitate a virtual monitoring contact by reading device outputs and,
2. Exploring software or alternative communication devices that convert typed text to audible dialogue.
However, if all available methods have been explored and they are not able to communicate verbally or sign, their current assisted communication device does not allow for phone or virtual monitoring, and they do not have a natural or paid support that can facilitate a virtual monitoring- then they would require in-person monitoring for all monitoring contacts.
Q: OM 25-025 instructs Case Managers to reopen the previous Level of Care (LOC) Screen and update the Nursing Facility (NF) in the Additional Program Information section and not to complete a LOC Screen Reassessment for NF to NF transfers. How can we ensure CMAs don't lose record of NF to NF transfers and that streamline is not impacted with this process?
A: Case Managers shall follow the Nursing Facility Initial Enrollment, CSR, NF to NF Transfers, and Service Planning Checklist Job Aid. This includes:
1. Case Managers entering all NF information, including start and end date, in the Care Provider section, maintaining a record of all NFs and,
2. Case Managers reopening and completing the LOC Screen to trigger streamline eligibility and produce a new LOC Certification needed by the new NF.
Q. When a Member transfers from their Case Management Agency's (CMA) Designated Service Area (DSA) to another CMA's DSA, can the primary CMA complete a Member's Level of Care Screen (LOC) Reassessment via telephone if the Member did not notify the CMA of their move and the Reassessment needs to be completed? (Updated 10/22/2025)
A: No-Beginning January 1, 2026, all LOC Screens must be conducted in person as outlined in OM 25-063, which supersedes the temporary allowances in OM 24-008. In addition, both CMA's should follow transfer expectations outlined in §8.7202.M to ensure continuity of service and supports for the Member.
Q. Has any time-tracking been conducted to determine the average amount of time required to complete an Intake/initial Colorado Single Assessment (CSA) vs. CSA for Continued Stay Review (CSR)? Also, are we expected to complete the assessments in the member's homes from beginning to end? (updated 10/22/2025)
A. During the Pilot of the new Assessment and Person-Centered Support Plan process, a time study was conducted to determine the average amount of time necessary to complete these processes. The entire process averaged 4 hours and 25 minutes (this would be commensurate with completing the Level of Care Screen (100.2), Supports Intensity Scale (SIS), instrumental activities of daily living (IADLs), and Service Plan (SP) and broke out as follows:
- Level of Care (LOC) Screen, 28 minutes;
- Required and voluntary questions in the Needs Assessment, 2 hours and 17 minutes; and
- Person-Centered Support Plan, 1 hour and 3 minutes.
The average times varied between populations, and it is anticipated that at the outset, during the learning curve, times may be longer until case managers' navigation skills have improved.
Case managers are required to conduct the LOC Screen in the location where the person currently resides. The Needs Assessment and Person-Centered Support Plan can be conducted in a setting of the member’s choosing and can be completed in one meeting, or in separate sessions, as necessary or desired by the member.
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