Private Duty Nursing (PDN) Emergency Rule

The Medical Services Board (MSB) met this late last week to consider an emergency rule for Medicaid members who utilize Private Duty Nursing (PDN) who have extraordinary medical needs that require more than the current 16 hour/day to exceed that limit with approval. Under the emergency rule, adult members may now receive up to 23 hours if deemed medically necessary.

During the meeting, HHAC's Advocacy Team member Eliza Schultz, testified, along with others, that this is a good first step to increasing access for patients, but that HHAC is anxious about implementation. We suggested that the rule remove reference to the 16-hour cap all together and simply state that members are allowed up to 23 hours if necessary. We also brought up our serious concerns with Kepro. Adult PDN services must still receive prior authorization through Kepro and are starting to see denials and shortened hours like we saw in the pediatric space. It seems disjointed that on one hand HCPF is looking to increase access, while their UM provider is denying these same services.

Some Board members seems interested in exploring these concerns and has asked HCPF to return at the next MSB meeting to discuss implementation of this rule in more depth.

The MSB approved the emergency rule with one dissenting vote (because of the implementation concerns). We will continue to engage with HCPF on issues with Kepro and will plan to engage at the next MSB meeting.

Full Approved Rule Attached.