Situation Report | September 19, 2022
As the state Department of Health (DOH) posted the slides from its September 12th webinar on the Home Care Worker Minimum Wage Guidance (MLTC Home Care Minimum Wage Guidance (ny.gov), HCA continued to advocate for adequate funding in managed long term care (MLTC) plan premiums and rates to providers to support the increased wages.
HCA has strongly disagreed with DOH’s intention to cast this rate increase into the plan-provider rate negotiation process. As the new wage is a statewide government-mandate, HCA continues to maintain that the rate funding should be distinctly provided and demarcated to the health plans and, in turn, through the health plans to the providers. And, funding to any plan or provider proved deficient from the state should be reconciled to cost.
HCA also continues to argue the necessity of financial support for wage increases for non-Medicaid hours that aides provide (i.e. Medicare, private pay, EISEP, etc.).
HCA has informed DOH about the very predictable confusion among plans and providers that has been created by the department’s approach to implementation. This includes the severe challenges being seeing in the contract amendment process where, to date, very few amendments have even been able to be circulated between plans and providers, let alone put into place despite the October 1 effective date of the $2 wage increase.
DOH’s posted September 12 webinar also touched on the following:
- Negotiated rates will vary based on several factors: experience; location; book of business; travel; quality; fringe benefits; worker recruitment and retention; and projected overtime.
- Some contracts may already exceed wage requirements and, therefore, necessitate less of an increase while some may fall further below wage requirements and necessitate more of an increase.
- The amount built into the plans’ premiums for the wage increase varies by risk and utilization. An example:
- Example 1: If region average utilization is assumed at 100 hours per member per month and a plans risk score is .9700 then a plan is funded at $27.90 (NYC Region) for 97 hours per member per month
- Example 2: If region average utilization is assumed at 100 hours per member per month and a plans risk score is 1.2000 then a plan is funded at $27.90 for 120 hours per member per month
- Plans or providers with questions are directed to email addresses at DOH.
The HCA Board met late last week to discuss priority areas for home care, hospice and MLTC, with major focus on the wage mandate funding. HCA has reached out again today directly to the Governor’s office on the implementation problems generated by the DOH approach, and pressing for solutions to meet the needs of the workers, agencies and plans.