MFEI and InterRAI Care Planning FAQs

• What is the MFEI, and why is Kansas adopting it?

  The Medicaid Functional Eligibility Instrument (MFEI) is replacing BASIS to ensure a more standardized, accurate, and person-centered approach to assessing Level of Care (LOC) eligibility for IDD waiver services. LOC evaluations determine whether a person is eligible for the IDD waiver, meaning they meet the functional criteria to receive waiver services. It is a yes/no determination based on the person’s ability to perform activities of daily living (ADLs), behavioral needs, and other support requirements. 

  As the BASIS is deficit-focused and outdated the IDD Modernization Committee strongly recommended this transition. The MFEI, built on the validated interRAI framework, provides a holistic view of an individual’s strengths and needs, ensuring fair and transparent eligibility determinations. 

  Additionally, Kansas cannot implement the new Community Supports Waiver without a validated LOC tool, and the MFEI is necessary to meet that requirement.

• How is the MFEI different from the BASIS?

  The BASIS assessment was deficit-based, focusing primarily on limitations, while the MFEI captures both strengths and needs, providing a more holistic and person-centered evaluation. The BASIS never evolved to reflect modern support models, whereas the MFEI is a standardized tool aligned with national best practices for HCBS quality measures. 

  One other major distinction is that the BASIS combined both LOC determinations and tiering (acuity assessment) into a single tool, while the MFEI is currently focused solely on LOC. LOC determines whether a person qualifies for waiver services, while acuity assessments determine the intensity of support needed and influence funding levels. Kansas is still evaluating whether MFEI data alone will be used for acuity-based rate setting or if additional factors, such as interRAI case-mix modeling, will be incorporated.

• When does the MFEI go live?

  The MFEI will officially replace BASIS for all IDD waiver Level of Care determinations starting July 1, 2025.

• How long does the MFEI take compared to the BASIS?

  The MFEI may take longer initially, but trained CDDO assessors will become more efficient over time. The additional time is justified by the greater accuracy and fairness in eligibility determinations, which will reduce disputes and inconsistencies and provide further downstream efficiencies in the waiver program.

• Does the MFEI require more documentation than the BASIS?

  No. Kansas has reduced documentation burdens under the MFEI. While the assessment is more comprehensive, CDDOs and providers are not required to collect additional paperwork for the MFEI Level of Care determinations. The validated nature of the MFEI allows assessors to rely on participant-reported information and existing records, eliminating the need for providers to gather the documentation level previously required under BASIS.

• The BASIS is required annually for everyone on the IDD waiver. Will this still be true for the MFEI?

  Yes, federal regulations require that LOC evaluations be performed regularly to confirm continued waiver eligibility. However, moving to a standardized, validated tool like the MFEI allows the state to potentially reduce assessment frequency for certain individuals in the future. Kansas will be able to analyze assessment data after going live to determine if less frequent evaluations are appropriate for participants with stable needs.

• Will this change how many assessments I have to participate in?

  No, this change only replaces the LOC evaluation conducted by the CDDO as well as the needs assessment conducted by the MCO. It does not add any additional assessment burdens at this time. The state is working to streamline assessments and reduce duplication where possible, ensuring that necessary evaluations are efficient and focused on individual needs.

• Will this change impact who qualifies for IDD waiver services?

  No. Previous workgroups field-tested the MFEI, and all individuals eligible under BASIS remained eligible under the MFEI. The goal is not to remove services but to ensure a more accurate and standardized approach to determining eligibility.

• Will CDDOs still determine eligibility for the IDD waiver?

  Yes. Currently, CDDOs determine eligibility for the Kansas IDD system before assessing a person’s eligibility for the IDD waiver. If a person is found eligible for the IDD system, the CDDO will complete the MFEI LOC to determine waiver eligibility, just as they previously did with the BASIS. Once a person is determined eligible for the IDD system and the IDD waiver and a waiver slot is available, KDHE determines financial eligibility for the Medicaid (KanCare) program.

• Will the MFEI impact what services I receive?

  No. The MFEI primarily determines waiver LOC eligibility and does not directly impact what services a person qualifies for. Services will continue to be determined through the person-centered planning process with participants, families, TCMs, providers, and MCOs.

• How will MFEI data be utilized?

  MFEI data will provide a more accurate and complete understanding of each participant’s needs, supporting eligibility determinations, service planning, and system-wide improvements. The data will be used in several key ways: 

  • Improving Person-Centered Planning by helping to ensure support plans reflect a participant’s actual strengths, needs, and goals. 

  • Allowing CDDOs to monitor service delivery, ensure appropriate placements, and track various trends in participant needs at a local level. 

  • Giving providers insight into a participant’s support needs when receiving referrals, allowing them to plan more effectively. 

  • Helping Kansas identify trends in service utilization and acuity levels, supporting future rate methodology development, waiver changes and provider network adequacy. 

  • Allowing the state to identify participants who may be a good fit for the CSW, ensuring they receive services that align with their needs while also helping manage waiver capacity and reduce waiting lists. 

  MFEI data will be a valuable tool for improving service and support coordination, funding accuracy, and long-term system planning, benefiting participants, providers, and policymakers alike.

• What happens if a participant’s needs increase?

  If a participant’s support needs increase, providers can apply for additional funding through an enhanced funding process or negotiated rate adjustments with MCOs. MCOs are expected to ensure adequate provider networks and can still authorize additional funding support on a case-by-case basis.

• How will rates change for new waiver entrants vs existing participants?

  New waiver participants will have acuity-based rates determined using a new methodology starting July 1, 2025. Existing participants will keep their current rates until July 1, 2026, or when unbundling occurs, whichever comes later. This transition period allows time for rate adjustments and fiscal impact analysis.

• How will rates and tier placement be determined?

  Kansas has not yet finalized whether rates will be determined solely from MFEI data or if an interRAI case-mix system used by MCOs will also play a role. A comprehensive rate study is underway to ensure rates accurately reflect costs and participant needs. 

  Similarly, the state has not yet determined whether tier scoring will remain with CDDOs or transition to MCOs. Still, any new tiering process will be based on standardized, rules-based methodologies rather than discretionary decision-making. The goal is to ensure that funding aligns with actual support needs transparently and equitably.

• How does this change impact the MCOs?

  To provide a more standardized approach to assessing for participant needs, MCOs will transition to using the interRAI suite of care planning tools on 7/1/25. Many MFEI questions overlap with interRAI assessment, creating an opportunity to streamline the needs assessment process and reduce redundancy. KDADS is working with the MCOs to ensure assessments are not duplicated unnecessarily, balancing the need for accurate evaluations with efficiency in care planning.

• If the state elects to leverage the MCOs in any new acuity rate system, wouldn’t that be a conflict of interest?

  MCOs would not be determining tiers arbitrarily—they would be applying a standardized, rules-based case-mix algorithm that uses the MFEI data collected by CDDOs, ensuring that tiering decisions are based on validated assessment data, collected by an independent assessor, rather than subjective judgment. 

  While some have raised concerns that MCOs may have an incentive to assign lower tiers to save costs, they are contractually required to maintain an adequate provider network and ensure participants receive the services they need. If reimbursement rates are set too low and providers exit the network, MCOs fail to meet their contractual obligations, risking corrective action and financial penalties from the state. Additionally, Kansas would oversee audit tiering decisions, ensuring that assignments reflect participant needs rather than financial considerations. 

  Unlike in some provider-driven models, where the same entity conducts the assessment and provides the services, MCOs do not directly provide waiver services. This removes the financial incentive for over-identifying needs or assigning higher rates, which has been a concern under the current BASIS system. CMS has established guidelines requiring transparency and state oversight in managed care needs assessments. As long as Kansas ensures a standardized, rules-based tiering system with state oversight, MCOs conducting case-mix modeling would not violate federal conflict of interest standards. 

  That said, Kansas recognizes the historical distrust toward MCOs in the IDD system, which is why any new tiering model will not be implemented without stakeholder buy-in and will be based on objective rules-driven methodologies.

• Why do the MCOs need to be involved at all?

  MCOs play a critical role in ensuring an adequate provider network and developing individualized service plans for waiver participants—a responsibility that was explicitly given to them when Kansas transitioned to Medicaid managed care over a decade ago. 

  Managed care exists to create efficiency and accountability in LTSS delivery. MCOs are contractually required to maintain an adequate provider network and ensure that waiver participants have timely access to services that align with their needs. Thus far, without standardized tools like the interRAI, MCOs have been left to make service planning decisions using different internal methodologies, creating inconsistency and inequities across the system. Additionally, Kansas has a licensing agreement with interRAI, which is what the MFEI was built off of. As part of that agreement, Kansas must implement the full interRAI suite for needs assessment, which requires MCOs to play a role in service planning. 

  Ultimately, MCOs need to be held accountable for ensuring access to services, but they also need standardized tools to effectively manage the network. The MFEI and interRAI provide the structure to ensure that participant needs drive funding decisions rather than subjective or inconsistent methodologies.