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DOH Clarifies 7/26 Guidance on Resumption of Assessments  

The state Department of Health (DOH) this afternoon sent an e-mail to health plans and associations clarifying an earlier guidance (on July 26) that had rescinded certain emergency measures for physician orders and assessments.

DOH’s July 26 guidance had raised numerous issues and concerns that HCA and partner associations discussed with DOH in a meeting yesterday, prompting today’s clarification.

A PDF of today’s e-mail clarification is here. It states the following:

  • Personal Assistant Annual Health Assessments: All personal assistants may continue working until September 30, 2021 while they have their annual health assessment scheduled and completed, even if the due date of the assessment is after July 26, 2021 (i.e., the effective date of the guidance). “If the annual health assessment is not completed by September 30, 2021, the personal assistant would have to discontinue working until it has been completed per regulations.”
  • Resumption of face-to-face reassessments: Managed care plans and local departments of social services (LDSSs) may continue to use telehealth or telephonic community health assessments (CHAs) until August 13, 2021 “in order to accommodate a previously scheduled telehealth or telephonic CHA, or to transition assessor staff scheduling.” Use of this modality should also be documented.
  • Handling Patient Refusal of In-person Assessments: Plans and LDSSs “should make reasonable efforts to complete periodic reassessments” per the schedule outlined in the July 26 guidance. “If an enrollee refuses the periodic reassessment, the refusal should be noted in the enrollee’s case file as services continue.”

Over a month ago, when DOH initially raised the topic of resuming Uniform Assessment System (UAS) assessments, HCA requested ample lead time, as well as flexibility to maintain telehealth as an option for UAS. HCA’s survey of our MLTC/PACE members confirmed these as priorities, which HCA relayed to DOH.

DOH announced at our meeting yesterday that it would provide a brief extension of UAS allowing the telehealth option. While HCA and others sought a more reasonable lead-in period, DOH explained that factors related to its planned implementation of the Independent Assessor initiative had constrained the amount of extension that the Department could provide.

HCA and others had also requested official notice of the changes discussed in today’s e-mail, such as through a Dear Administrator Letter (DAL); however, DOH indicated that a DAL revision could not be accomplished within the timeframe of the UAS extension.

HCA continues to press the Department for an extension of various emergency-era waivers and flexibilities, along with accommodations to assist providers and plans in the transition. We will continue to keep the membership informed of these critical developments.