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Program Structure Matters: A State-by-State Look at Consumer-Directed Programs

Exploring CDPAP, CDASS, CEP, and More

January 30, 2025 – In our last blog, we discussed the potential of consumer-directed personal care programs and how they empower participants to manage their care. As consumer direction expands across the country, it’s crucial to understand that how these programs are structured matters and has a significant impact on program success.  

We are excited to see consumer-directed care expand across the country, but what’s best for consumers needs to remain at the forefront when these programs are implemented. In this blog, we will examine specific programs in different states. While these programs share the philosophy of participant autonomy and personalized care, their structures and execution vary significantly. 

Consumer-Directed Programs Across the Country

As we mentioned in our prior blog, we are examining four main consumer-directed programs. The first is New York’s Consumer Directed Personal Assistance Program (CDPAP). This program was established in the 1990s and is a pioneering model that gives Medicaid recipients complete control over their caregiving. Like all consumer-directed programs, participants can hire family members or friends as caregivers, which provides autonomy and allows individuals to receive care from who they want, when, and where they want. It is also particularly valuable for those facing language or cultural barriers, as it allows them to select caregivers who align with their personal needs and preferences. 

The CDPAP program in New York is undergoing a major overhaul as the Department of Health and the Governor are moving towards consolidating the services of about 700 CDPAP providers into a single, co-employer model of fiscal intermediary support.  This change is projected to bring about significant savings to the state, but it is also fraught with considerable risks. As advocates, we are concerned about a variety of aspects of the new program, including:

  1. The proposed format eliminates consumer choice of providers. This has proven to be a stumbling block when other states implement similar programs. In Pennsylvania, for example, the consolidation of Fiscal Intermediaries resulted in over 13,000 consumers leaving the consumer-directed option for the agency option and, in the process, giving up control of their services to a third party.
  2. The selected provider has a long history of infractions and poor services in other states.  The idea that a single provider can support over 250,000 consumers and manage over 350,000 caregivers seems like it will come with many problems. As advocates, we are very concerned about the capacity and risks associated with the suffering of so many vulnerable consumers.
  3. The transition to the new program is very short, resulting in consumers not receiving services and caregivers not getting paid.

Launched in 2002, Colorado’s Consumer-Directed Attendant Support Services (CDASS) is another program that provides participants with unparalleled control. Under this program, consumers work with case managers to determine needs, including homemaker services, personal care, and health maintenance. Under CDASS, consumers can use their Health First Colorado dollars to pay the attendant of their choice rather than a home health or personal care agency. They are responsible for managing their provider. The added flexibility of CDASS enables individuals to manage the services they need to live independently and to participate in the community more fully.

Pennsylvania also offers a program under OLTL’s Home and Community-Based Waiver Services and ACT 150. Pennsylvania’s consumer-directed program allows individuals to employ a personal attendant rather than arranging for a worker through an agency. Employers must meet the income guidelines defined by OLTL’s Medicaid Waiver Services, and like other states, allows consumers to choose the services they need and who will provide them. 

Oregon’s Consumer-Employed Provider Program (CEP) puts an emphasis on emphasizing direct participant oversight of caregiving services. Medicaid recipients can hire, supervise, and terminate caregivers, granting them full authority over their care. Through the program, consumers can get personal care assistance, homemaker services, non-medical transportation, health-related tasks like wound care and insulin injections, and medication and oxygen management. State support is integral to the program’s success, as it handles enrollment, payroll, tax compliance, and legal obligations. Another OR Medicaid program is called the Independent Choices Program (ICP). Through this program, seniors can self-direct their long-term care, including hiring their spouse as a caregiver. One way this program differs from the CEP Program is that the state plays a more minor administrative role. Instead of the state paying caregivers, consumers in this program given receive a monthly cash benefit with which to pay their selected caregivers. 

While these programs all have the same theoretical goal of providing choices to the consumers, it is important choices to consumers; it is important to note that controlling who provides services and what services are provided is not where choice should end. Fiscal intermediaries play a significant role in the administration of these consumer-directed programs and impact their success. When it comes to choice; it also needs to extend to the administration of these programs. 

The Role of Fiscal Intermediaries

A key component of consumer-directed personal care programs is fiscal intermediaries. These organizations play a workers play a significant role in ensuring the success and functionality of consumer-directed programs by handling administrative responsibilities such as enrollment, payroll, tax compliance, and regulatory documentation. This relieves consumers of these burdens while ensuring legal and procedural compliance and that workers are compensated fairly for their time. 

While all the programs we mentioned above have the same overall goals, when looking at major state programs, success rates tend to be higher in programs where participants can choose their budgetary intermediary. Let’s examine how fiscal intermediaries are handled in significant state programs and why they matter. 

While it’s yet to be seen how of an impact this will have on NY CDPAP, we’ve already seen how this plays out several times. Oregon’s CEP program assigned over 45,000 consumers to a single fiscal intermediary, and the program has been having issues. A report by Oregon’s Secretary of State’s Audits Division found and problems with the program oversight and implementation and that due to these inadequacies of the program, consumers may experience increased risk to health and well‐being. Pennsylvania is yet another cautionary tale. Under Pennsylvania’s Consumer-Directed program, consumers went from having 36 fiscal intermediaries to choose from to having one. And the results? The program dropped from 22,000 consumers to 8,000, and from serving 50% of the total population receiving services to only 7%. 

Why is that? It’s because choice matters from the top to the bottom. While establishing a single fiscal intermediary can streamline administrative processes in theory, it doesn’t always address individual preferences. In addition, it creates a monopoly on the administration of these programs. Without competition, FIs are not properly incentivized to do their best because consumers have no choice but to deal with them. Beyond the added hassle of increased enrollment periods and lack of specialization offered by fiscal intermediaries, the real issue is when caregivers or consumers get so frustrated that they drop out of the program altogether.  

The good news is that there is a model we can follow. Colorado’s CDASS emphasizes participant choice in fiscal intermediaries. Participants can select from two approved fiscal intermediaries incentivized by the healthy competition to do their best. What have the results been here? The program has continued to thrive. They’ve seen FIs get innovative, which has led to accelerated enrollment (less than 3 days), and caregivers can get paid daily now. By making it easy for workers to be in the program and ensuring administrative needs are met efficiently, the CDASS is proving to be a standout model for autonomy and effective resource management.

One of the most significant benefits of these programs is that consumers can also choose what services are provided. These programs typically offer a range of valuable services and support to eligible individuals, including personal care services like bathing, grooming, dressing, and more. In addition, they provide assistance with activities of daily living like nutrition, mobility, medication management, and more. We know these programs are working as studies have shown that care recipients in these types of programs reported higher satisfaction with their care and experienced fewer unmet needs compared to those receiving traditional agency-directed services.

For caregivers, especially family members, these programs offer the chance to provide meaningful support while being compensated fairly. The mutual trust and familiarity between the caregiver and care recipient often lead to better outcomes and higher satisfaction.

Healthcare payers also see advantages, including reduced hospitalizations and institutional care costs. Programs like these ensure that individuals are more satisfied with their care, which can translate into better compliance with care plans and improved health outcomes. These programs can also help mitigate caregiver shortages by enabling participants to tap into personal networks for support.

Advocates Perspective

Consumer-directed personal care programs exemplify the power of choice in healthcare. And while it’s great to see more programs springing up, we’ve seen the way each state approaches program design matters. And what we’ve found is that the ability to choose a fiscal intermediary significantly enhances participant satisfaction and program success. States like Colorado demonstrate how offering choice in fiscal intermediaries can foster trust and improve outcomes. In contrast, programs with more limited options are seeing consumers drop from the program, and other issues arise. This underscores the importance of tailoring program structures to align with care autonomy and participant-driven care principles. For participants, these programs are more than just a means of receiving care; they’re a pathway to dignity, independence, and self-determination, and it’s essential that we continue to advocate for consumer choice. 

Onward!

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About the Author

Fady Sahhar brings over 30 years of senior management experience working with major multinational companies including Sara Lee, Mobil Oil, Tenneco Packaging, Pactiv, Progressive Insurance, Transitions Optical, PPG Industries and Essilor (France).

His corporate responsibilities included new product development, strategic planning, marketing management, and global sales. He has developed a number of global communications networks, launched products in over 45 countries, and managed a number of branded patented products.

About the Co-Author

Mandy Sahhar provides experience in digital marketing, event management, and business development. Her background has allowed her to get in on the ground floor of marketing efforts including website design, content marketing, and trade show planning. Through her modern approach, she focuses on bringing businesses into the new digital age of marketing through unique approaches and focused content creation. With a passion for communications, she can bring a fresh perspective to an ever-changing industry. Mandy has an MBA with a marketing concentration from Canisius College.