FASI Assessment

CMS requires all states with Medicaid HCBS waiver programs to assess participants initially and annually to determine if individuals require an institutional level of care. CMS must approve the assessment procedures and criteria used.

Although CMS has approved the assessments currently used in Wyoming, the current institutional level of care assessments being used are inconsistently administered across waiver populations and leave the state vulnerable to CMS compliance findings.  

The Long Term 101 and 104 (LT-101 and LT-104) assessments are homegrown assessments developed by the Wyoming Department of Health and are currently used to determine institutional level of care for skilled nursing facilities (SNFs) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID), respectively.  These assessments are not standardized and have not been validated.

• • • The LT-101 assessment is administered by Public Health Nurses and measures activities of daily living (ADLs) and instrumental activities of daily living (IADLs).  This assessment typically takes 45 -90 minutes to complete and is given to individuals who apply for or receive services on the Community Choices Waiver, who have an acquired brain injury and apply for or receive services on the Comprehensive or Supports (DD) Waivers, or who apply for or receive other non-waiver services.
    • The LT-104 assessment, developed in 1999, assesses the supervision and functional needs of individuals applying for or receiving DD Waiver services or services at the Wyoming Life Resource Center – Wyoming’s only intermediate care facility for individuals with intellectual and developmental disabilities (ICF/IID). Although the Division makes the final determination on participant eligibility, the LT-104 is currently administered by the individual’s case manager, potentially creating a conflict of interest. It takes approximately five minutes to complete.
  • The continued use of these assessments makes the State of Wyoming vulnerable to federal compliance violations, including but not limited to under-serving eligible populations, serving populations that do not meet eligibility requirements, and violating conflict of interest requirements.

We have teamed up with the Wyoming Institute for Disabilities (WIND) to create and carry out a thorough study of the FASI. This project is quite extensive and will be launched in phases.

Phase I – Pilot Project – Adults in all HCBS Waivers

• WIND will use the FASI on about 400 participants from June 2023 to August 2024.
• WIND will check the data and create a final data sheet by January 2025. 

Phase II – Pilot Project – Children in DD Waivers

• WIND will use the FASI on about 400 participants from August 2023 to October 2024. 
• WIND will check the data and make a final data sheet by January 2025. 

Phase III – Nursing home residents not in Waivers

• WIND will compare current LT101 assessment results with FASI measures to calculate scores. WIND will conduct evaluation assessments on around 100 nursing home residents between June 2023 and November 2023.
• WIND will check the data and create a final data sheet by February 2024. 

Phase IV – Exploration of assessment as a resource allocation tool

• If the FASI is suitable for deciding ICF/IID and SNF level of care, we will expand the project to learn how the FASI can update the current methodology used to calculate individual budget amounts for participants on the Comprehensive Waiver.

If you are part of the Comprehensive, Supports, or Community Choices Waiver program, you might be chosen to take part in the FASI pilot project. If you are selected, a representative from the Wyoming Institute for Disabilities (WIND) will get in touch with you to schedule a meeting at a time that works for you. During this meeting, which will likely take around an hour, you will be asked questions about:

• Taking care of yourself
• Getting around and moving
• Using a wheelchair
• Activities like bathing, dressing, getting out of bed, using the restroom, and eating
• Essential activities like cooking, cleaning, getting around, doing laundry, and managing money
• Your living situation, available support, and help from caregivers

WIND will study all the data collected during the pilot, compare it to current assessment results, analyze results, and provide the Division with a final report and recommendation about how the FASI could affect participant eligibility if adopted.

The purpose of the pilot project is not to make requirements stricter for current waiver program participants. Instead, it’s meant to help the Division decide if the FASI assessment works well for determining institutional level of care for Wyoming’s  HCBS waiver program participants.

Formal feedback sessions will be offered throughout the project.  Dates, times, and participation information will be shared as it becomes available. If you would like to provide written feedback or have questions, please email wdh-fasi@wyo.gov.

May 31, 2023 Stakeholder Education and Feedback Session

Recorded Presentation  |  Slide Deck

Want more information?

Centers for Medicare and Medicaid Services – FASI Webpage

FASI Flyer for Case Managers