WAIVER TRANSPORTATION RATE STUDY METHODOLOGY AND RECOMMENDATIONS

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Domenic Cook
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2 OBJECTIVES Summarize the stakeholder feedback received during the Waiver Transportation Study Present the recommendations developed by the Navigant Consulting team Invite your comments and questions during and after this meeting 2 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

3 ASKING QUESTIONS AND PROVIDING COMMENTS How to ask questions during the public webinar: During this presentation you may submit written questions using the raise your hand webinar option and we will respond to them at the end of the presentation How to ask questions after the public webinar: If you have questions or comments you wish to submit after the webinar, please use the online feedback form at the link below The comment period will end on November 6, 2018 The project website will provide a summary of comments and questions received Availability of this presentation: A taped recording of this webinar will be posted on the study website For more information, visit the project website: To provide comments on the methodology and recommendations, please use the online form on the project website: 3 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

4 AGENDA 1. Waiver transportation study overview 2. Waiver transportation study methodology 3. Minnesota s waiver transportation providers 4. Key themes that informed recommendations 5. Rate Study recommendations 4 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

SECTION I: WAIVER TRANSPORTATION STUDY OVERVIEW 5

6 MEDICAID HOME AND COMMUNITY-BASED SERVICES PROGRAMS What are home and community-based services (HCBS)? Services that provide opportunities for aging people and people with disabilities to receive services in their own homes or communities rather than other potentially isolating settings Examples of services are adult day services, customized living, personal care assistance, and waiver transportation How do states use Medicaid to pay for HCBS? States must ask special permission from the federal government to use Medicaid funding to implement HCBS This permission is granted in the form of a waiver of federal requirements. As such, these programs are called HCBS waiver programs All states offer HCBS waiver programs. These programs vary in terms of the included services and eligibility 6 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

7 MEDICAID HOME AND COMMUNITY-BASED SERVICES PROGRAMS What agencies or organizations are in charge of HCBS in Minnesota? The Minnesota Department of Human Services (DHS) administers HCBS programs There are four waiver programs for Minnesotans with disabilities and two programs for aging Minnesotans where services are available if individuals meet certain eligibility standards Lead agencies deliver the services including county social service agencies, managed care organizations (MCOs), and tribal agencies Managed care organizations are the lead agencies for the Elderly Waiver Program Counties and Tribes are the lead agencies for disability waiver programs and the Alternative Care Program 7 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

8 HCBS WAIVER PROGRAMS FOR AGING PEOPLE Waiver Description Waiver Transportation Recipients and Expenditures (State Fiscal Year 2016) Alternative Care (AC) (fee-for-service) Serves individuals over age 65 years who are at risk of nursing home placement 572 recipients $298,915 in Medicaid expenditures $523 per recipient Elderly Waiver (EW) (fee-for-service and managed care) Serves individuals older than age 65 who require the level of care provided in a nursing facility and choose to reside in the community 5,095 recipients $12,075,901 in Medicaid expenditures $2,370 per recipient 8 / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

9 HCBS WAIVER PROGRAMS FOR INDIVIDUALS WITH DISABILITIES DELIVERED BY COUNTIES AND/OR TRIBES Waiver Description Waiver Transportation Recipients and Expenditures (State Fiscal Year 2016) Brain Injury (BI) Waiver Serves individuals with a traumatic, acquired, or degenerative brain injury (BI) who require the level of care provided in a nursing facility that provides specialized services for persons with BI, or who require the level of care provided in a neurobehavioral hospital 641 recipients $1,052,033 Medicaid expenditures $1,641 per recipient Community Alternative Care (CAC) Waiver Serves individuals who are chronically ill and medically fragile who require the level of care provided in a hospital 9 recipients $3,658 Medicaid expenditures $406 per recipient 9 / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

10 HCBS WAIVER PROGRAMS FOR INDIVIDUALS WITH DISABILITIES DELIVERED BY COUNTIES AND/OR TRIBES, CONTINUED Waiver Description Waiver Transportation Recipients and Expenditures (State Fiscal Year 2016) Community Access for Disability Inclusion (CADI) Waiver Serves individuals with disabilities who require the level of care provided in a nursing facility 8,446 recipients $9,006,953 in Medicaid expenditures $1,066 per recipient Developmental Disabilities (DD) Waiver Serves individuals with developmental disabilities or a related condition who require the level of care provided in an Intermediate Care Facility for Persons with Developmental Disabilities (ICF/DD) 1,491 recipients $2,250,692 in Medicaid expenditures $1,510 per recipient 10 / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

11 CONTEXT FOR LEGISLATIVE MANDATE FOR TRANSPORTATION STUDY In 2013, the Centers for Medicare and Medicaid Services (CMS) required states, including Minnesota, to develop standardized service definitions and rates for all HCBS waiver programs In 2014, DHS implemented new statewide HCBS rates Waiver transportation was excluded, because DHS did not have a process for certifying waiver transportation providers as a group In 2017, the DHS Long Term Services and Supports Gap Analysis and Olmstead Subcabinet consumer reports indicated gaps in service related to transportation for people receiving HCBS waiver program services As a result, the Minnesota legislature directed DHS to conduct a study to identify and recommend the following: 1. Waiver transportation service rate(s) 2. Waiver transportation technical and administrative improvements 11 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

12 DEFINITION OF WAIVER TRANSPORTATION SERVICES What are waiver transportation services and why are they important? Waiver transportation allows seniors and individuals with disabilities to access their communities and lead a productive and fulfilled life Examples of transportation destinations include: - Shopping for groceries and household supplies - Going to work - Participating and recreational activities In State Fiscal year 2016, 16,254 HCBS waiver recipients received waiver transportation services totaling $24,688,151 in Medicaid expenditures What are the types of waiver transportation providers? Types of waiver transportation providers include taxis, van services, public buses and trains, and volunteer drivers 12 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

13 DEFINITION OF WAIVER TRANSPORTATION SERVICES Which transportation services are not included in this study? Transportation services that are provided as an essential component of another Medicaid HCBS service, for example: - Adult day health care - Day treatment and habilitation - Group homes Transportation services related to medical care, for example: - Emergency medical transportation (EMT) - Non-emergency medical transportation (NEMT) services for recipients to access doctor s appointments 13 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

14 WAIVER TRANSPORTATION PROVIDER ENROLLMENT AND BILLING How are waiver providers enrolled and how do they bill? The Centers for Medicare and Medicaid Services requires that all Medicaid HCBS providers be Medicaid-enrolled. To meet these requirements, DHS created policies that allow lead agencies to deem a provider as Medicaid-enrolled for the purposes of waiver transportation services The majority of waiver providers enroll with lead agencies and submit invoices (not in a Medicaid claim format) for payment. Lead agencies then convert this documentation into Medicaid claims to receive DHS reimbursement 14 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

15 OVERVIEW OF TRANSPORTATION STUDY There are two components of the Minnesota waiver transportation study: 1. Rate Study: Identify and recommend service rates for transportation available under Minnesota s four disability waiver programs and the Elderly Waiver and Alternative Care programs 2. Access Study: Identify and recommend technical and administrative improvements to transportation available to individuals under Minnesota s four disability waiver programs and the Elderly Waiver and Alternative Care programs Today s public webinar discusses recommendations developed as part of the Rate Study (October 23, 2018 from 1:00 3:00 pm) 15 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

16 DHS ESTABLISHED ADVISORY GROUPS FOR EACH STUDY The Department of Human Services convened a Rate Study Advisory Group and an Access Study Advisory Group to provide input and feedback throughout the study via monthly meetings Members of these two stakeholder advisory groups included representatives for waiver program consumers, state agencies/organizations, and statewide associations and providers that influence transportation services Rate Advisory Group topics - Provider cost and wage survey input - Rate components / assumptions - Feedback regarding rate recommendations Access Advisory Group meeting topics - Access survey input - Feedback regarding transportation access barriers and solutions 16 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

18 STUDY METHODOLOGY Navigant developed key observations and recommendations from extensive and comprehensive research on waiver transportation issues Research included qualitative, quantitative, and mixed methods Mixed Method Qualitative Quantitative Recommendations 18 / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

19 QUALITATIVE RESEARCH 1. Qualitative Research Input and guidance from Access and Rate Advisory Groups Approximately 90 stakeholder interviews with individuals, groups, and online discussions including: - Consumer organizations: National Alliance on Mental Illness Minnesota, Governor s Council on People with Developmental Disabilities and Minnesota Disability Council - Lead agencies: Representatives from four counties, seven MCOs covering services to the elderly waiver participants, and feedback from tribal agencies - Minnesota State agency representatives: DHS, MnDOT, Metro Council, University of Minnesota Humphrey School of Public Affairs - Providers of transportation services 19 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

20 QUALITATIVE RESEARCH: CONTINUED 1. Qualitative Research Interviews with representatives from nine other state NEMT and HCBS programs Literature and document review: - Relevant Minnesota transportation-related programs, activities, and published documents/reports - Minnesota State statutes, policies and regulations - National and local emerging transportation initiatives and new technologies - Studies conducted on Medicaid transportation programs across the country 20 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

21 MIXED METHOD AND QUANTITATIVE RESEARCH 2. Mixed Method Research Navigant contracted with the University of Minnesota Humphrey School of Public Affairs to develop and conduct an Access Survey directed at providers of waiver transportation services and focused on understanding fleet capacity and barriers to providing waiver transportation 3. Quantitative Research Navigant conducted a Rate Survey of providers of waiver transportation services requesting specific information on the costs of providing services Navigant reviewed and analyzed two years of fee-for-service Medicaid claims data (State Fiscal Years 2016 and 2017) 21 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

22 RATE SURVEY PROCESS Navigant developed a cost and wage survey to capture provider information related to delivering waiver transportation services The survey was released through the relevant provider associations on July 17, 2018 and through MN-ITS on July 24, 2018, with an original due of August 14, There were two MN-ITS communications, one to day training and habilitation (DT&H) and waiver transportation providers, and the other going to all providers - An extension was granted through August 17, 2018 to increase survey responses Each survey was reviewed for consistency and completeness The results of the cost survey were used to inform the development of the updated waiver transportation rates 22 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

23 RATE SURVEY REVIEW PROCESS Cost Survey is submitted Further questions are asked (if necessary) Navigant reviews Cost Survey Responses by Provider are reviewed (if necessary) Questions are sent to Provider (if necessary) 23 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

24 RATE SURVEY RESPONDENT PROFILE Surveys were received from: - 61 providers (this represents approximately 12% of the 491 active and enrolled waiver transportation and DT&H providers) - Providers deliver services in 72 out of the 87 Minnesota counties Respondents generally provide: Day training and habilitation services Occupational training Adult day care services Other disability services Public transit Other private transportation services Respondents provide the following level of services: Fixed route services 26% Door-through-door 20% Curb-to-curb 31% Other assistance 1% Door-to-door 21% 24 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

26 EMERGING TRANSPORTATION TRENDS STATE AND NATIONAL Mix-model (fee-for-service, broker and/or managed care organization): - Fee-based payment in some areas of the state, - Contracts with transportation coordination companies who coordinate all transportation services in other areas, and - Managed Care Organizations On demand request or ride-hailing services: - Some states contract with ride-hailing companies to provide NEMT services (e.g. Uber and Lyft) - Dakota County has a similar pilot project with Lyft for waiver transportation 26 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

27 EMERGING TRANSPORTATION TRENDS STATE AND NATIONAL Vehicle Sharing: 1 To increase access to transportation services, organizations are leveraging vehicle-sharing services to increase coordination of transportation among many consumers and lower overhead costs Definition: there are two types of vehicle-sharing: - Time Sharing: One or more organizations operating the same vehicle at different times - Ride Sharing: Using the vehicle of one organization to provide transportation for the clients of another organization Minnesota has several examples of vehicle sharing between county and city transportation providers and private human service organizations 1) MCOTA. Vehicle Sharing Among Human Service Providers in Minnesota: Steps to Address Barriers; Sept / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

28 EMERGING TRANSPORTATION TRENDS STATE AND NATIONAL Regional Transportation Coordination Councils or RTCCs: 2 MnDOT, DHS, and other State agencies are working with the Metropolitan Council and other local governments to create RTCCs throughout 8-10 regions in the State MnDOT approved RTCCs will be funded in 2019 and operational in 2020 or later RTCCs will be responsible for coordinating transportation services through a network of existing public, private, and non-profit transportation providers Each RTCC will be composed of residents within each service area with oversight from the State and local agencies and organizations 2) Coordinate MN Transit, Regional Transportation Coordinating Councils (RTCC s). Available online: 28 / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

30 CONSISTENT THEMES FROM STAKEHOLDERS Stakeholder feedback yielded the following themes regarding barriers to access for waiver transportation. These findings provided context and a solid foundation for Navigant s final recommendations. 1. Lead agency authorization and coordination of services takes a lot of time and could be made more efficient 2. There is a wide variability provider approval requirements and payment policies across lead agencies 3. Lead agencies and providers could benefit from improved infrastructure support and centralization of administrative functions 30 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

31 CONSISTENT THEMES FROM STAKEHOLDERS, CONT D 4. Vehicle-sharing among transportation providers is limited, if not prohibited due to liability and other issues. Vehicle sharing could increase the availability and hours of operation of waiver transportation providers 5. Evaluating the quality and costs of waiver transportation services is challenging without defined statewide service standards, more detailed utilization and expenditure reporting capabilities, and a process for uniform tracking of consumer access and service issues 6. Provider participation is hampered by the widespread perception of an inadequate and uneven rate structure The following slide summarizes stakeholder feedback related to theme number six and is not specific to the stakeholder type providing the feedback. 31 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

32 STAKEHOLDER FEEDBACK: PERCEIVED INADEQUATE AND UNEVEN RATE STRUCTURE Providers reported that rates do not cover the costs of transportation delivery, including but not limited to: - Licensing and compliance with policies and regulations - Unloaded miles - Vehicle maintenance - Cancelled rides - Driver recruitment and training - Insurance costs There is a large variation between waiver transportation rates and methodologies across lead agencies Current rates established by lead agencies through the market rate do not consistently account for these specialized services: o Curb-to-curb = drivers will assist passenger in and out of vehicles only o Door-to-door = drivers will assist passengers to the entrance of their origin or destination o Door-through-door = drivers will assist passenger to the inside of their origin or destination There is a lack of reimbursement for unloaded miles which discourages volunteer driver participation 32 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

34 OBJECTIVES TO GUIDE RECOMMENDATIONS The following objectives were created to guide the development of the recommendations and reflect feedback from the Rate and Access Advisory Groups: 1. Advance access and availability of waiver transportation services to all waiver participants, regardless of program type, participant s abilities, or geographic location 2. Support an increase in appropriate and cost-effective person-centered delivery of transportation, including an on demand ( demand request ) response option 3. Maximize use of cost-effective pre-existing community capacity for transportation 4. Adjust the current reimbursement structure to support the delivery of quality services to meet identified individual needs 34 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

35 RATE APPROACHES TO ADDRESS DIFFERENT TYPES OF TRANSPORTATION PROVIDERS Per Trip - Build-up approach that incorporates wages, miles, vehicle costs, administrative overhead, and other factors to determine a standardized per trip rate Public Transit (contracted through lead agencies) - Advertised per trip rate - Ability to purchase monthly/annual pass at discount On-demand (contracted through lead agencies) - Negotiated or market rates with on-demand transportation service Per Mile (Volunteers) 35 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

36 PER TRIP: RATE METHODOLOGY Analysis is built from the ground up Recognizes the costs of specific services Assumptions can be derived from provider, state, or industry standard data Employs assumptions of: - Wages hourly wages - Employee related expenses costs related to employee taxes and benefits - Client absences time related to missed appointments - Program plan support non-service delivery time (meetings, documentation, and other activities to support the service) - Vehicle programming and supports support costs related to providing the service - Administrative overhead costs related to an organization s overhead and operations 36 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

37 PER TRIP: RATE METHODOLOGY BENEFITS Transparency - Models contain the factors and values that drive the final rate Ability to include policy objectives - Examples could include improving direct care staff salaries or benefits or incentivizing increased access to services Efficiency in maintaining rates - Models can be easily scaled and adjusted for inflation or specific cost factors Alignment with similar services - Assumptions from similar services can be aligned to create consistent policy 37 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

38 PER TRIP: WAIVER TRANSPORTATION (WAGES) Wages accounts for hourly wages for program employees providing the service directly to the individual Cost survey results - Median wage: $13.30 Preliminary recommendation for wage: blend of two occupational classifications based off of 2017 Bureau of Labor Statistics Wage Data 3-60% - Personal and Home Care Aides: $ % - Bus Drivers, School or Special Client: $ Total recommended wage: $13.64 Using BLS wages will allow for more frequent rate adjustments as data is published annually 3 Minnesota statewide median value 38 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

39 PER TRIP: WAIVER TRANSPORTATION (EMPLOYEE RELATED EXPENSES) Employee Related Expenses (ERE) accounts for employee taxes, benefits, and insurance as a percent of employee salaries and wages Cost survey results - Median ERE: 21.9% Preliminary recommendation for ERE - Use the ERE that is incorporated into the Disability Waiver Rate System (DWRS) of 23.6% as this is similar to the cost survey results Using the DWRS value will create consistent methods across waivers and allow for easier updates in the future 39 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

40 PER TRIP: WAIVER TRANSPORTATION (CLIENT ABSENCES) Client Absences accounts for consumer no-shows for scheduled pick-up (scheduled service where the individual does not use the transportation service) Cost survey results - Median Absence Factor : 3.69% Preliminary recommendation for Absence Factor - Use the Absence Factor that is incorporated into the Disability Waiver Rate System (DWRS) of 3.9% as this is similar to the cost survey results Using the DWRS value will create consistent methods across waivers and allow for easier updates in the future 40 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

41 PER TRIP: WAIVER TRANSPORTATION (PROGRAM PLAN SUPPORT) Program plan support accounts for time that program staff must spend on non-reimbursable activities as a percent of employee salaries and wages Cost survey results - Median Program Plan Support Factor : 16.7% Preliminary recommendation for Program Plan Support Factor - Use the program plan support factor that is incorporated into the Disability Waiver Rate System (DWRS) of 15.5% as this is similar to the cost survey results Using the DWRS value will create consistent methods across waivers and allow for easier updates in the future 41 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

42 PER TRIP: WAIVER TRANSPORTATION (VEHICLE PROGRAMMING AND SUPPORTS) Vehicle programming and supports accounts for expenses tied to supporting the delivery of the transportation services (for example, fuel, vehicle, tires, licensing fees, insurance, maintenance, and other expenses) as a percent of employee salaries and wages Cost survey results - Median Vehicle Programming and Supports Factor : 23.10% Preliminary recommendation for Vehicle Programming and Supports Factor - Use the median Vehicle Programming and Supports Factor of 23.10% - Calculated as the ratio of total vehicle-related program/support costs to direct worker costs. We expect that this ratio will be higher than we would see in other services because there are likely higher program costs for the numerator and fewer direct care workers to establish the denominator. 42 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

43 PER TRIP: WAIVER TRANSPORTATION (ADMINISTRATION FACTOR) Administration (admin) factor accounts for administration expenses to program employee salaries, wages and benefits (for example, administrative salaries, IT costs, and office supplies) as a percent of employee salaries and wages Cost survey results - Median Administration Factor : 20.8% Preliminary recommendation for Administration Factor - Use the admin factor that is incorporated into the Disability Waiver Rate System (DWRS) of 23.0% as this is similar to the cost survey results Using the DWRS value will create consistent methods across waivers and allow for easier updates in the future 43 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

44 PER TRIP CALCULATION Cost survey results and DWRS factors are represented as a percent of wages plus employee related expenses Total Staff Compensation = Wages * ERE Factor Total cost per day = Total Staff Compensation * Absence Factor Total Staff Compensation * Program Plan Support Factor Total Staff Compensation * Vehicle Programming and Supports Factor Total Staff Compensation * Admin Factor 44 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

45 PER TRIP CALCULATION (CONTINUED) To convert total cost per day to a per trip value: need to determine a reasonable estimate of the number of trips that can be provided during an 8 hour shift. Established Mileage Bands to account for the range of distances traveled when delivering waiver transportation services Proposed mileage bands miles miles miles miles - Greater than 60 miles 45 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

46 PER TRIP CALCULATION (CONTINUED) Single occupant rate per trip - Divide total cost per day by the maximum number of trips per day within each mileage band, to arrive at a single occupant rate per trip 270 miles per day (6.76 billable hours per day * 40 miles per hour) Divided by the highest mile value within the mileage band Divided by two to determine number of one-way trips Multiplied by 1.5 to assume half of return trips are empty vehicles Proposed trips per day for each mileage band 0-9 miles = 23 trips miles = 11 trips miles = 5 trips miles = 3 trips Greater than 60 miles = 3 trips Apply add-on component for assisting passengers to enter and exit the vehicle for multi-passenger trips 46 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

47 RATE CHANGES FOR FUTURE CONSIDERATION New rates will be implemented in DHS must assess the impact the rate changes have on access to services and providers Advisory group members identified the following rate recommendations, which will be revisited after the initial rate changes have been implemented and monitored: - Adjust payment rates to account for high demand and low availability times (for example, weekends and evening hours) - Adjust payment rates based upon the type of vehicle and modifications 47 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

48 ASKING QUESTIONS AND PROVIDING COMMENTS How to ask questions during the public webinar: During this presentation you may submit written questions using the raise your hand webinar option and we will respond to them at the end of the presentation How to ask questions after the public webinar: If you have questions or comments you wish to submit after the webinar, please use the online feedback form at the link below The comment period will end on November 6, 2018 The project website will provide a summary of comments and questions received Availability of this presentation: A taped recording of this webinar will be posted on the study website For more information, visit the project website: To provide comments on the methodology and recommendations, please use the online form on the project website: 48 / / NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

49 CONTACT INFORMATION: ANDREA PEDERSON, DIRECTOR AT NAVIGANT BETSY WALTON, DIRECTOR AT NAVIGANT DENNIS FINNEGAN, ASSOCIATE DIRECTOR AT NAVIGANT FRANK DOUMA, STATE AND LOCAL POLICY PROGRAM DIRECTOR HUBERT H. HUMPHREY SCHOOL OF PUBLIC AFFAIRS UNIVERSITY OF MINNESOTA GWYN VOLK, DIRECTOR AT NAVIGANT 49 / 2017 NAVIGANT CONSULTING, INC. ALL RIGHTS RESERVED

Disability Waivers Rate System

Disability Waivers Rate System This document is made available electronically by the Minnesota Legislative Reference Library as part of an ongoing digital archiving project. http://www.leg.state.mn.us/lrl/lrl.asp Disability Waivers