To download the public comment, click the link here: 3.26.21.public_comment
March 26, 2021
RE: Public Comment on HCBS settings that require heightened scrutiny
The Association for Indiana Music Therapy (AIMT) is a non-profit organization that strives to provide and encourage continuing education for our members, increase awareness of music therapy to the public and related professions, and increase access to quality music therapy services in Indiana. Music therapy is currently offered in 82 out of the 92 Indiana counties and there are currently over 300 Board-Certified Music Therapists in the state of Indiana.
We appreciate the opportunity to provide input regarding HCBS settings that require heightened scrutiny. AIMT is pleased to see the continued focus at the state level on moving towards person-centered services and planning. Music therapy is inherently person-centered, strengths-based, and very much in line with the settings rule. These attributes of the service are detailed below as well as some recommendations for improvement and best practices.
First, music therapy is designed to support access to the greater community for those that receive the service through skill development including daily living skills, employment skills, social skills, emotional skills, and motor skills as well as setting goals for one’s life through the exploration of a person’s dreams and aspirations.
Secondly, music therapy is provided in many settings throughout the state including homes, clinics, children’s daycares, and other settings that a person may frequent throughout their weekly schedule. Music therapy is available to those outside the Medicaid Waiver mostly in clinics, through telemedicine, in nursing facilities, in hospitals, as well as other settings. Therefore, those on the Medicaid Waivers have the same degree of access as those outside the waiver to music therapy services. When Appendix K expires, AIMT fears that those on the waiver may not be able to access Music Therapy to the same degree if they live in a rural community, lack transportation, have fragile health needs, or cannot access a therapist who speaks their primary language in their community.
Finally, AIMT would like to see more clarity within the waiver applications showing services can and should look different depending on any person’s specific strengths and opportunities for growth, which would emphasize the desire for person-centered services outlined by the settings rule. Our members continue to report confusion from case management and other entities involved with waiver services regarding the service definition of music therapy. Currently the waiver manual states, “One (1) hour of billed therapy service must include a minimum of forty-five (45) minutes of direct patient care/therapy with the balance of the hour spent in related patient services.” The statement is confusing and is at times interpreted as requiring a 75/25 ratio of direct to indirect services, or more often, that music therapy should only consist of hour-long therapy sessions weekly. Both interpretations keep music therapists from being able to provide person-centered services, as the session frequency/length should be based on an individual person’s needs/desires and preparation for a session should also be based on a person’s individual needs/desires. AIMT respectfully requests this language be removed from the waiver applications in order to bring clarity and emphasize that services should always be person-centered and align with the settings rule.
Again, we appreciate the opportunity to provide input and look forward to assisting the state in clarifying definitions, continuing telemedicine options for those receiving the service, and supplying workforce analysis data or meeting to brainstorm improvements to further expand music therapy access and quality in the state of Indiana.
Respectfully Submitted,
Lindsey Wright, MT-BC
Government Relations Chairperson
govrelations@indianamusictherapists.com