ALP Conflict-Free Case Management Conversation with DOH Continues

LeadingAge NY met again with the Department of Health (DOH) to continue the ongoing discussion regarding the federal Home and Community-Based Services (HCBS) Settings Rule and the implications for the Assisted Living Program (ALP) in New York. The Centers for Medicare and Medicaid Services (CMS) is requiring an independent party to provide case management to ALP residents that is separate from the ALP provider. Click here for background on this issue and to access previous member webinars on this issue.

LeadingAge NY stressed the importance of articulating very clearly the roles and responsibilities for both the third party case manager and the ALP. Upon our latest discussion, the Department indicated that this entity may need to determine level of care and ensure choice of services. The entity would also develop a person-centered care plan regarding the individual’s Medicaid long-term services and supports. LeadingAge NY noted that ALP residents’ needs are largely met by the ALP, and therefore the plan would be fairly limited. At present, the Department seems to be leaning away from health homes as a possible provider because they do not have nurses. LeadingAge NY also highlighted that some providers currently have relationships with Institutional Special Needs Plans and wanted to ensure that those relationships were not disrupted.

Ultimately, it seems that a specific plan has not yet been determined, and details regarding the roles and responsibilities of the ALP and third party case manager remain somewhat murky. We will continue to work with our partners at LeadingAge National to learn more about what has been done in other states and get input from our members to provide to DOH on this process.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828