Why is case management in the Home and Community Based Waiver (HCBW) programs listed as a health care service when it was earlier listed as non-health care?
DHS is considering case management to be a health care service whenever Medicaid funds it. This applies across all programs using Medicaid funding, including “card services”, HCBW and Child Welfare. This is consistent with a federal interpretation that for HIPAA purposes case management is health care in the Medicaid program. Case management in HCBW was earlier listed as non-health care because most services that are managed in a HCBW case are non-health care and because case management has traditionally been considered in social programs to not be a medical service. After further analysis, however, we now place greater emphasis on the importance of consistency within the Medicaid program and with the federal interpretation. Considering case management to be health care for HCBW should have minimal local impact. Many if not most counties provide case management with in-house staff. These staff would have to comply with the Privacy Rule, but will often be in organizational units that ar
