CMS Issues ICF/MR Clarifying Memo on “Client Right to Manage Financial Affairs and Money Management Training”

CMS issued the letter on July 10th. ANCOR offered comments prior to the letter publication and many suggestions were incorporated. The letter puts the assessment and determination for the need for formal money management programs in the hands of the interdisciplinary team (IDT). Providers who are cited will want to have this letter handy – as long as their IDTs review the comprehensive functional assessment (CFA) and discuss the need for a formal program for each client (who is the chronological age to utilize money) and document their reasoning when there is no formal objective. If the surveyors find that the CFA and the individual’s skills (and age) support the need for a formal program, and there is not one, they can cite a deficiency during the survey process.

ANCOR suggestions incorporated into the letter:
· Added the use of the “formal objective” vs. just saying money management program
· Changed several “must be” to “is” to show that the standard regarding use of CFA continues and is not new
· Softened what must be included in the assessment from dictating - “Assessment findings should include at a minimum:” and changed it to “Assessment findings to be considered by the team include skills that can be cross-utilized in training programs such as:”
· Took out the use of the work “transferable” but changed it to “cross-utilized”.
· Added that the CFA must be reviewed at least annually, but did leave in that the annual review “should always include an update to the CFA and take into consideration any changes in the individual’s circumstances since the last IDT.”