State HCBS eFMAP Workforce Funding Directed to Subset of LHCSAs

As members know, Medicaid Home and Community-Based Services (HCBS) Enhanced Federal Medical Assistance Percentage (eFMAP) funding will soon be flowing to Medicaid HCBS providers as enacted by the federal American Rescue Plan (ARP). The State developed and submitted a spending plan over the summer, which the Centers for Medicare and Medicaid Services (CMS) is reviewing and approving in parts. Last week, the Department of Health (DOH) met with home care providers to review the State’s plan to implement spending of the workforce funds. This funding will be directed to a subset of 250 Licensed Home Care Services Agencies (LHCSAs) that meet a certain revenue threshold in their Managed Long Term Care (MLTC) region. The funding amounts will be provided in the form of directed payments passed through to LHCSAs that engage in the attestation and spending plan process with MLTC plans and the Department. The Department's slide presentation on this plan is available here.

LeadingAge NY has posed several additional important questions and concerns to the Department about this spending process regarding eligible providers and permitted spending:

Workforce challenges are dire and significant across HCBS provider types, and this is a significant amount of funding. Originally, this funding item included several provider types, including Adult Day Health Care programs (ADHCs) and Social Adult Day Care programs (SADCs). Why are they not included?
Nurses are critical to opening and supervising home care cases. Funding should support their hiring and retention. We are hearing this from both MLTC plans and providers. We are worried about the possibility of unmet needs among patients.
Agencies that want to use the money to raise wages or incentivize recruitment (not just retention) should be allowed to do so.
Agencies should also be permitted to use the funds to create agency-based aide training programs, to expand existing training programs, and to pay trainees. We do not believe that DOH has released any information about the work or outcomes of the Workforce Investment Organizations (WIOs), and we are concerned that if funds for training must be funneled through WIOs, they will not be used to train new entrants into the field.
The MLTC rate regions are large geographic regions, some of which are not geographically contiguous (e.g., NE/W, ROS.) Has DOH analyzed the geographic scope of the services delivered by the LHCSAs that are targeted for funding? Are there parts of regions or parts of counties that will not be served by any recipient of funding?
Is the Department planning on providing workforce funding via some other spending mechanism to LHCSAs that fall outside the revenue threshold category? An allocation for these providers would be critical to the populations they serve.
There does not appear to be another eFMAP initiative that would offer funding to support Assisted Living Programs (ALPs), Certified Home Health Agencies (CHHAs), Hospice, or ADHC programs in recruiting and retaining staff. Even a modest allotment for these providers would go a long way. If these providers are excluded from eligibility for funding, they may be unable to compete for staff with LHCSAs, exacerbating access challenges for post-acute care and community-based long term care.
Consumer Directed Personal Assistance Services (CDPAS) Fiscal Intermediaries (FIs) are also mentioned in Section IA of the eFMAP plan, but do not appear to be in the first tranche. Have they been eliminated?

LeadingAge NY posed initial questions to the Department when first learning of this plan, which are available here. LHCSAs that have been targeted for funding will be contacted by the Department soon and invited to a webinar on the funding process. LeadingAge NY will continue to advocate for a broader distribution of the funds and more clarity on this process. There are several other funding streams under the spending plan, and as these are communicated to plans and providers, we will pass along that information.

Please contact our office to communicate concerns or any questions you may have. We will be sure to keep you apprised of any new information we learn about this process.

Contact: Meg Everett, meverett@leadingageny.org, 518-929-9342