State Presents Webinar Regarding Quality Measurement Access Rule
(Nov. 26, 2024) On Nov. 20th, Raina Josberger, Director, Center for Applied Research and Evaluation, Office of Health Services Quality and Analytics, NYS Department of Health (DOH), presented a webinar regarding DOH's efforts to implement the Quality Measurement Access Rule as required by the Centers for Medicare and Medicaid Services (CMS). The federal Access Rule was designed to enhance access to home and community-based services (HCBS) and standardize quality for recipients of HCBS Medicaid. It applies to participants in Medicaid fee-for-service and Medicaid managed care and applies to the 1915 (c), (i), (j), and (k) waivers, as well as the 1115 waiver. The webinar slides are available here.
The goal of the Access Rule is to measure quality across programs, improve it, promote health equity, and allow CMS to compare states. There are several quality measures listed on slide 5, but DOH will only be implementing a process to measure Long-Term Services and Supports (LTSS)-1 and 2. DOH stated that CMS will be implementing Items 6, 7, and 8 on the State's behalf, though did not share more information on that part of the initiative. Measures 1 and 2 relate to the patient comprehensive assessment and plan of care and their updates. They will obtain this data from a sample of beneficiaries. It is unclear how large the required sample size is for this project.
DOH has opted to do an early roll-out of the process and will report 2024 data in 2025 to prepare for the actual required Quality Measure Set items collected for 2025 and reported in the fall of 2026. The data collection will take place every two years.
DOH will use contractor IPRO to do this work. Comprehensive assessments and plans of care/person-centered care plans will be required to be sent through secure file transfer to IPRO for data extraction.
IPRO will then conduct an HCBS experience of care survey. It is up to the HCBS participant whether or not they want to participate. DOH asks that Assisted Living Programs (ALPs) be aware of this process and share this information so that everyone is aware of the project and potential participation.
It seems that providers have a limited role in implementing and carrying out this requirement. DOH shared that they will be presenting this to local departments of social services (LDSSs) and Managed Long Term Care (MLTC) plans. They will also include this in a Medicaid Update soon. LeadingAge NY does not believe that they will share this presentation with licensed home care services agencies (LHCSAs), adult day health care (ADHC) programs, social adult day care (SADC) programs, or other providers. It is likely that ALPs were specifically presented to because their provider setting is a residence, and the contractor will be reaching out to participants.
They ask all HCBS providers, including ALP partners, to provide information about the survey to Medicaid beneficiaries, encourage participation, and confirm legitimacy of IPRO when they connect.
The timeline for this initiative is immediate, with letters being mailed to participants in late December, surveyor training in early January, actual outreach around Jan. 13th, with survey completion by March 24th.
DOH stated that the outreach to beneficiaries will be based on phone numbers in participant Medicaid datasheets, not necessarily the ALP office. The Department communicated that there would be no surprise visits to ALPs. If this is the case, then it would make sense that ALP offices may get calls. There will likely be no Dear Administrator Letter (DAL) on this initiative.
This quality survey process will impact HCBS Medicaid beneficiaries served by many provider types. We will be sure to share additional information as it is provided by the Department.
Contacts: Meg Everett, meverett@leadingageny.org, 518-867-8871 and Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828