DOH Convenes Second Meeting of ALP Need Methodology Workgroup
The Department of Health (DOH) convened the second meeting of the Assisted Living Program (ALP) Need Methodology Workgroup on Nov. 7th. LeadingAge NY staff and member representative Rick Mills, Executive Director of Housing at Loretto, participated in the meeting, along with other stakeholders.
DOH presented this PowerPoint during the meeting, and the discussion focused largely on what data sources the Department could utilize in developing a need methodology formula for the ALP in the future. LeadingAge NY noted that any formula or approach must be flexible enough to be easily updated to reflect the most current picture of need for a community. We noted that the nursing home need methodology did not easily allow for this, and we should learn from those experiences. Below is a summary of the discussion, with particular issues where member input is requested in italics.
The Department was interested in looking at data regarding people living in the community enrolled in Medicaid and receiving home and community-based services (HCBS). The Department felt as though some meaningful data could be obtained that could inform this process. It was noted that eMedNY or other state databases may have information regarding this population.
DOH was particularly interested in learning about the ALP average length of stay and age. There was debate about adding these fields to the ALP Quarterly Statistical Information Report (QSIR); however, stakeholders noted that this information could probably be determined from eMedNY. The Department is interested in learning where people come from when entering the ALP and is wondering if this could be useful in measuring potential need. Stakeholders also suggested contacting the county NY Connects for data about people accessing services.
DOH asked if there is a link between people being enrolled in managed long term care (MLTC) and needing the ALP. It was discussed that the ALP is a good option for some people living in the community who are receiving a great deal of HCBS. The ALP can offer a more cost-effective option that could also alleviate some of the loneliness that some seniors experience in the community. At the same time, it was noted that not everyone is coming to the ALP already enrolled in managed care or MLTC. We welcome member input on what might be learned from enrollment in MLTC and need for the ALP.
There was again debate about whether New York City should be a single planning area. The Department seems disinclined to approach New York City in this way. LeadingAge NY suggested that we bear in mind that people move from county to county, especially given public transportation. Thus, whatever planning area designation we use must also consider the adjoining counties and other factors in the region that affect where people live and travel to. We welcome member input on how New York City should be approached as a planning area.
The group once again discussed occupancy threshold, should that be a factor for determining future need. Stakeholders reinforced that ALP providers do not budget for an operational capacity of 100 percent given the transitions that occur with the population. In addition, there are various other factors that impact regional occupancy, and thus a threshold for the indication of need of 85 percent occupancy is felt to be too high; 80 percent was felt to be a better threshold. It was noted that other factors should always be considered when looking at an occupancy threshold for a planning area. One example was that transitional adult homes that recently converted to ALP may have a lower occupancy as they transition to serving a different population. It was also noted that newer ALPs that received grants or can offer private rooms will often be more popular to the public. Lastly, it was noted once again that poor-performing providers can bring down a region’s overall occupancy, creating the perception that need does not exist.
DOH asked if we should look at the ratio of population to bed availability. LeadingAge NY also suggested looking at data regarding living alone as an indicator of being more likely to need support. DOH welcomes other ideas about how to anticipate what population will need ALP services; we welcome member input on this issue.
DOH indicated interest in the development of a formal waitlist process to understand how many people are waiting for services and what they do when they are on the waitlist. There was some sentiment that this can be a quickly changing process, and the data may not be overly useful. We welcome member input on whether waitlists for the ALP would be feasible or useful.
There was significant discussion about how workforce should factor into the need methodology. DOH wants to be able to grow the system and grow the workforce in a way that does not undermine existing providers. The Department suggested that we look at the just-published Licensed Home Care Services Agency (LHCSA) proposed regulations for need (see pg. 6), where they have suggested a way in which new applicants must demonstrate where they will obtain their workforce. Member input is invited on how to meaningfully incorporate workforce into any need methodology.
The Department expressed the desire to strike a balance in attempting to forecast need, assess the impact of this forecast, and then be able to adjust. They indicated the importance of also being able to note when a region is saturated and asked how we might be able to analyze the sustainability of the providers. The Department wants to promote healthy competition that may promote quality and offer choice but avoid oversaturation of a particular market. We welcome member input on how best to foster growth but avoid oversaturation of any market.
The Department asked if cultural competence should be considered in the ALP need methodology; we welcome member input on this issue.
While DOH could not discuss the current Request for Applications (RFA) that has a deadline of Nov. 14th, it was recommended that they look at it and the most recent ALP expansion opportunity to see if there is anything that can be learned from those processes that can inform this process. In addition, it was noted that the parameters of the current RFA were so limiting that it excluded many interested, good applicants. It was also suggested by one stakeholder that DOH invest capital funds into all ALPs to allow them to update their buildings, rather than the current opportunity that provides grant funds to a small number of buildings.
One stakeholder suggested that the Department allow existing ALPs to expand their capacity by a certain percentage if full, with a waitlist. This is a concept that was discussed in the first meeting, with DOH exploring what quality criteria might be required.
The workgroup will meet next in January. In the interim, DOH is interested in additional data sources that could help indicate, measure, or predict need. The group has also been asked to better define the criteria that we would argue might provide an exception to any specific formula. Member input on these issues is extremely useful, so please let us know your thoughts, questions, or concerns on any of the above issues.
Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828