Situation Report | November 16, 2020
HCA, Managed Long Term Care (MLTC) plan members (including HCA Board Member MLTCs) and managed care association colleagues met with state Department of Health (DOH) officials again last week to outline concerns and recommendations regarding DOH’s implementation of the Independent Assessor (IA) role in MLTC and Medicaid home care. Colleagues at Manatt Phelps hosted the virtual meeting.
The IA requirement was adopted in the April 2020 budget as an initiative of the Executive, carving out the assessment function from the MLTC/provider context and vesting it within an independent agent. This includes start of care, changes in status, and reauthorizing reassessments.
HCA raised fundamental concerns with this programmatic change, impacting what we see as an integral component of care. With IA adopted, HCA has provided input to DOH for shaping implementation in the most workable process possible. DOH has been very open to industry input, inviting mutual work on this issue with HCA, MLTC members and fellow MLTC representatives.
A major focus of this most recent meeting was the process for review of the high-hour cases (patients requiring 12-plus hours per day), the respective roles of the physician panels created to accompany the IA function, and the roles of the IA, MLTCs and providers. DOH offered proposals to streamline the panel review, and the associations and member plans are further evaluating them.
HCA emphasized the need for flexibility so that MLTCs/providers can respond timely and quickly to changes in a patient’s status. This includes changes that would put patients immediately into the “high service hour” status warranting direct action by plans and providers, and where a wait for panel review could not be risked — such as an abrupt change in a caregiver’s availability or a health status change that triggers an immediate increase in hours. There was general agreement that these circumstances should be considered in the further panel and IA planning.
HCA similarly called for MLTC/provider procedural flexibility in its work with the IA itself. This includes times when MLTCs or providers are compelled to act promptly to a patient’s changing needs and cannot await the IA’s reassessment. DOH’s own quality metrics for hospitalizations, ER use, falls prevention and more all rely on timely MLTC/provider intervention and the ability for plans and providers to respond flexibly.
HCA will continue to provide updates to the membership as the process — and HCA’s advocacy — continues to usher new developments.