Support HCA’s Article VII amendments for service sustainability, access and workforce; reject budget provisions that would jeopardize programs; and leverage public health/savings opportunities obtainable through home care and hospice.
The Governor’s 30-day budget amendments deliver new, compromising cuts to home care and MLTC. These cuts further drive into the red a system that over half-a-million New Yorkers and their families depend upon.
HCA has responded with a mark-up of the Article VII budget bill. We ask the Legislature to adopt our proposals in each house.
These are sensible changes, mindful of the state’s fiscal challenges while endeavoring to stabilize the state’s Medicaid home care program, its patients, its workforce and the infrastructure that supports them.
Eliminate Harmful Budget Proposals that Have No Savings or Cost-Benefit
Our markups target budget provisions that impose outsized costs or operational burdens to providers – for instance, a wholly unnecessary requirement that thousands of home health aides obtain a national provider identifier number (NPI). This requirement is seemingly heedless of the fact that all home care providers and ordering physicians must already register for and maintain an NPI, and that all aides must already be registered in a statewide database and undergo a criminal history record check process, among other supervision and integrity measures, including the imminent requirement for electronic visit verification.
Another example is the Governor’s proposed wholesale carve-out of transportation services from MLTC coverage – a service line essential to coordination and service access for the complex and chronically ill populations served by MLTC plans and their provider networks. See, for instance, the compelling facts provided by Nascentia Health’s MLTC, which covers 48 counties, underscoring why we are asking the Legislature to strike this carve-out provision, or at least preserve transportation as an MLTC-selected option.
HCA’s State of the Industry report cites official cost report data portraying the extremely challenged financial status of home and community based care in New York State due to state/governmental underfunding. This harsh financial environment has manifested two recent MLTC plan closures while forcing NYC’s second-biggest Certified Home Health Agency (CHHA) into major layoffs and retrenchment of services.
Our proposals include an immediately needed cost-of-living adjustment in state-set home care rates, which hasn’t occurred in ten years. In that time, fee-for-service home care has actually dwindled to a small fraction of all Medicaid home care service volume; thus, a fee-for-service rate increase, as we have proposed, would levy a marginal cost impact on the state’s balance sheet. However, such a rate increase would have an exponential benefit for home care. Why? Because fee-for-service Medicaid home care rates are often used as a benchmark rate for Medicare Advantage, commercial insurers and other Medicaid payors, much of it outside Medicaid’s direct cost responsibility.
The extremely variable rate situation that currently exists – including underpayments at 50% to 70% below provider cost in some payor categories – needs a specific methodological fix like this one.
For purposes of stability, the state has provided benchmarking within other areas of the Medicaid service system. Congruently, HCA’s language directs the Commissioner of Health to establish a minimum benchmark that home care rates must at least meet.
Our markup also seeks to address needed transparency in the state’s MLTC rates, by ensuring that actuarially sound rates are provided to MLTCs and network providers for their services, including for wages and labor compliance. Financial data suggests that the state is not meeting this commitment. Our language strengthens existing requirements for actuarial soundness. It also seeks timely and streamlined payment to MLTCs and providers, so that new mandates are adequately calculated and included in the rates prior to imposition.
Our other proposals are simply the right thing to do for public health while leveraging opportunities for new state savings. They add home care and hospice to the Executive’s proposal for preventable hospitalization strategies, and they further incorporate home care into state policies and programs for improving primary care, public health and prevention through priority intervention areas such as health care disparities, sepsis, asthma, falls, mental health, diabetes, and others.
We also offer language to help address the state’s home care workforce crisis, as reported elsewhere in this month’s Capitol Report. (See related stories.)
Our team is happy to brief you further on any of our proposals, and we urge you to voice strong support for HCA’s Article VII amendments in discussions with health, finance and house leadership as budget negotiations continue.