DOH Postponing Independent Assessor Implementation, Plus Other Updates from Monthly MLTC Meeting  

Situation Report | September 14, 2020

The state Department of Health (DOH) says it is postponing its scheduled October 1, 2020 implementation date for an Independent Assessor (IA) to perform assessments for services under Managed Long Term Care (MLTC). 

No firm date was given for the new implementation timeline, but it could be postponed as far as January 2021 or later. 

The announcement was made during the September 10 monthly DOH meeting with Managed Long Term Care (MLTC) plans, Managed Care Organizations (MCOs), and member organizations.

At the meeting, it was suggested that the postponement stems from multiple factors and complexities, including issues raised by HCA and others.

As extensively reported to the membership, the IA concept was adopted with virtually no public or industry vetting during the swift implementation of Executive-recommended health care provisions in the state budget that was negotiated and passed at the height of the pandemic. 

In particular, HCA has emphasized to the Department the fragmentation that would be created by this IA structure as currently conceived — a structure that segregates the core assessment function apart from its current place in the MLTC-provider care planning, management and service delivery system.

These concerns have escalated with DOH thus far not permitting a dynamic role for MLTCs or providers to communicate differences of judgment or assessment that may vary from the IA’s determinations over a patient’s abilities, risk areas, service needs, or other clinical presentation. 

Effectively, aside from strict “factual” differences — e.g., stroke impairment left-side versus stroke impairment right-side, or amputation of the foot versus the hand — MLTCs and providers would not be allowed any systematic interaction with the IA for reconsideration of assessments results. IA assessments on start or reauthorizations of care would govern. Even change-of-status reassessments would fall under the exclusive decision-making authority of the IA.

Moreover, these concerns unleash a host of other major problems, which is why HCA continues to urge changes in the IA implementation.

The DOH postponement is, therefore, a very welcomed development in relation to the IA, which we believe should be rescinded in this form altogether.

Other MLTC Meeting Updates

Last week’s meeting with DOH yielded other important updates, including new rate enhancements for private duty nursing services to medically fragile children (see related story here).

During the meeting, DOH also provided important updates on the following additional areas with links to meeting materials below.