Major industry input needed to try to make implementation workable
Situation Report | July 27, 2020
State Department of Health (DOH) officials briefed Managed Long Term Care (MLTC) plans and state associations this past week on implementation of some of the major Medicaid home care changes adopted in the April budget.
In advance of these briefings, HCA conducted meetings with our MLTC member plans and providers on the changes, further cultivating and coordinating analyses and prospective recommendations for input and advocacy.
Of particular concern is the budget action that shifts to an “Independent Assessor” for personal care, Consumer Directed Personal Assistance Program (CDPAP) services, and MLTC. It poses enormous dislocation of basic professional, care-delivery and operation functions for MLTCs and providers. Beyond the contradictory separation of assessment from service delivery and care management functions, this new structure lacks a role for interaction, questioning or opportunity for modification of the assessment by the MLTC or provider.
The Independent Assessor will not only perform the eligibility and admission/start-of-care assessment that forms the basis of the plan of care, but the assessor will also be responsible for reassessment and/or revisions triggered based on feedback of changes in the patient’s status, yielding still further concerns about the impact of this process on timely and necessary patient care.
The state has selected Maximus — the current conflict-free assessment agent for enrollment in the MLTC program — to act as the new Independent Assessor.
HCA will be intensifying our work with the provider and MLTC membership to shape and recommend procedures for making this as workable a process as possible. A legislative remedy may ultimately be necessary.
Along with the independent assessment, other major changes include:
- New functional thresholds for Medicaid home care eligibility requiring assistance in more than two activities of daily living (or, for individuals with Alzheimer’s Disease and dementia, assistance with more than one activity).
- Imposition of a 30-month lookback on financial transfers prior to granting eligibility for Medicaid home care.
- MLTC enrollment caps and withholds.
- Fair hearing reforms.
- Wage parity enforcement.
DOH briefs associations and plans on rate calculations
Along with the programmatic briefings, DOH and its contracted actuary (Deloitte) conducted a separate briefing for MLTCs and associations on the status of MLTC rate adjustments and reconciliations, as well as the elements of premium rate calculations for this fiscal year. Especially troubling are reductions in the care management and administrative components of the reimbursement. These are based on disputable forecasts that will further drive funds to perilously inadequate levels.
HCA will be doing everything possible to try to ameliorate the problems presented by this fiscal and program barrage under way.