HCA continued to advocate for fairness in the eligibility determination process for the Quality Incentive Vital Access Provider Pool (QIVAPP) program by sending a joint letter with other associations to State Medicaid Director Jason Helgerson, with copies to the state Department of Health (DOH) Commissioner, Administration officials, and legislative officials.
The letter, signed by HCA, the New York State Association of Health Care Providers (HCP) and LeadingAge NY, took issue with DOH’s most recent interpretation of provider eligibility criteria for participation in QIVAPP, as reflected in its April 29, 2015 QIVAPP Webinar Frequently Asked Questions (FAQs) document. The letter also addresses the future use of the QIVAPP program as a means to assist home care providers in meeting rising costs stemming from the Home Care Worker Wage Parity Law of 2010 and other ongoing mandates.
As covered in many past editions of ASAP, DOH changed the original health benefit requirement outlined in the April 23, 2014 Dear Administrator Letter wherein an agency must provide comprehensive health insurance coverage to its employees. The change, outlined in an April 29 Frequently Asked Questions document, states: “a minimum of 30% of a provider’s total workforce must be enrolled in the health benefit” in order for the provider to qualify for QIVAPP funding.
HCA has consistently pointed out that this new policy penalizes home care providers who offer comprehensive health coverage but whose workers may choose not to participate in the provider’s health benefit because they access these benefits through other means or elect to receive a higher wage rather than obtain health coverage. We have argued that these agencies are incurring similar costs as those agencies whose workers opt for health insurance because under the state wage parity law, they still have to provide cash or other benefits for aides who don’t choose the health benefit.
In the letter, HCA and the other associations request that DOH retract its April 29 reinterpretation of the health benefit eligibility standard. Additionally, we ask DOH to identify a long term strategy outside of QIVAPP for investing additional funds into the home care system to support wage parity and other increased employer costs.
We further call upon the Department to establish a work group of associations, providers and plans to discuss adequate reimbursement for all counties impacted by wage parity and other mandates, and advocate that home care providers must be reimbursed at an established sufficient amount and Managed Long Term Care Plan premium rates must be set at levels that are adequate to permit plans to meet or exceed this rate.
The letter is at https://hca-nys.org/wp-content/uploads/2015/05/JointQIVAPletter52215.pdf.
For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.