Requested change for Housing Stabilization Services Approval and Denial Processes

Dear Disability Services Division (DSD) and the Housing Stabilization Services (HSS) Team. We as HSS providers come to you today with a request for help, collaboration, and consideration. We want to thank DHS for initiating a service that is desperately needed in our community. As we all recall, at HSS’s one year anniversary in July of 2021, the program had served 7,203 people throughout the State and this tripled the initial expectations (Stats from minnesota_dhs@public.govdelivery.com , July 21th 2021). This was possible in part through collaboration and partnerships between DHS and services providers. We understand that the service expectations for the upcoming year are high. To attain these expectations, we as providers are requesting some flexibility in the Approval and Denial process.

Current Approvals:

A person’s HSS eligibility start date is the date the approved application is submitted into the Housing Stabilization Services Eligibility Request Form. In the cases of Renewals, the new eligibility start date will align with the end of the previous eligibility span.  If the person is found eligible, services may be billed back to the eligibility start date listed on the approval form.

Renewal Request

If a renewal request is sent in and the request is denied, services provided before the new HSS eligibility start date are not billable even if a future submitted application is approved.

New Request

If a new request is sent and the request is denied, services provided after the submission date are not billable even if a future submitted application is approved. For example, a change of provider was submitted as an initial request and a denial was issued stating that it needed to be sent in as a change of provider request. In this case the individual is eligible for HSS, however the submission was done incorrectly. Due to this current procedure this causes substantial delays in service provision for the individual served.

Proposed Changes

As providers, we are proposing that instead an absolute denial, please change it to pending approval except in cases where the individual does not meet all the eligibility criteria as set forth by the program:

·         Be on Medical Assistance (MA)

·         Be 18 years old or older

·         Be experiencing housing instability

·         Have a documented disability or disabling condition

·         Be assessed to require assistance in Communication, Mobility, Decision-making; or managing challenging behaviors

If the individual meets all 5 criteria, an additional information request letter should be sent to the provider and once the missing information is received or corrected, the approval should be backdated to the date of the original submission. This will ensure a timely service provision and payment assurance to providers.

Potential consequences if this change is not made

1.      Expectations for the program will not be met

2.      Consequences to the people we serve 

a.       For example, imagine receiving a phone call from a homeless individual living in frigid temperatures, requesting HSS services. You collect all needed eligibility documents and send them in to DHS. Now, imagine having to tell this individual that has no income, no shelter, no support system, “by the way, you will have to wait for 4 to 8 weeks before we can begin services.” Then 4 to 6 weeks later, the provider receives a denial letter stating that, “individual is currently receiving services with another provider please re-submitted as change of provider.” You make the necessary changes and re-submit, and it takes about 6 more weeks for approval. In our experience the individual who experienced the example above, their situation deteriorates during this waiting process, and they lose resources that they might have had.

b.      Imagine working with a person served for a while and you both found that perfect place they can call home and the individual’s plan or eligibility ends. As a provider, you tell the individual that their case would have to be put on hold until we get approval from DHS.  Currently, DHS is out 2 to 6 weeks with approvals. In this case, there is a great possibility this person served will go underserved and lose out on this opportunity, they could have called home. In result leaving them in their current unstable housing environment, on the streets, or from one encampment to another.

c.       Imagine getting a call from an individual requesting for services and they tell you my landlord has given them a month to move out. After talking to this person, they checked all the eligibility criteria, but they will have to wait 3 to 4 weeks to begin services.

Proposed solution: Changing the denial to pending approval and back dating the  services start date in case of denial to the date of original submission. This assures   providers that they would be paid once the approval process is complete. In the         meantime, we as providers will be able to help these individuals find and keep their housing.

3.      Consequences to the Providers

a.       For us providers, it is not just about finding housing for some strangers. These people are our neighbors, our family, our friends, and even our co-workers. These relationships that we create with the people we serve makes it extremely difficult to deliver the news that due to the delay of the renewal approval from DHS their case will be put on pause. It is an assumed expectation that providers should assume the risk while we wait on DHS to approve services. But with DHS being out 4-10 weeks, it is a financial strain on providers to work for this duration or more without the hopes of getting paid

b.      Imagine you are a provider, and you have 20 cases, 10 of those cases are up for renewal. You submit all renewal documents on time to DHS. During submission, you missed typed the individuals date of birth, or the Housing plan did not mention that they were on sustaining, or the provider sent it in as initial request as opposed to update on plan, etc. Again, DHS is out 4 to 6 weeks for approvals. You wait for 4 to 6 weeks, and a denial comes through, you fixed the error and resubmit and wait for another 4 to 6 weeks before you finally get an approval.

     i.      Client would have lost leads

    ii.      Reduce staff turnover

Proposed solution: If providers had the option of continuing work with the individual with the expectation that the error can be fixed and resubmitted and approval back dated to the original submission date, will help us providers in serving the purpose for which this service was initiated. We would have avoided staff turnover and the person served would have been connected to the resources needed in the 8 to 12 weeks of waiting.

Conclusion

Change the current denial process to pending approval in cases where people meet all 5 areas of eligibility criteria. Giving providers the opportunity to make changes to the original submission if eligibility is not the main reason for denial would in turn allow providers and persons served to work seamlessly or with minimal interruption on their Housing Stabilization Service. This change would then provide assurance of payment to HSS providers.  Thank you for your consideration and taking the time to look into this matter.