LeadingAge NY Meets with New HCBS Staff at DOH

LeadingAge NY and other home care and hospice association partners met with Home and Community-Based Services (HCBS) staff of the Department of Health (DOH) last week in the first of its new quarterly meetings with the Department since its recent reorganization, which includes the new Office of Aging and Long-Term Care (OALTC). An OALTC organizational chart is available here.

The group discussed a new Dear Administrator Letter (DAL) and corresponding form that now requires hospice providers to report all unrelated services their patients are receiving to ensure that no double billing is occurring, a requirement that mirrors Centers for Medicare and Medicaid Services (CMS) requirements. The reporting will be a significant burden on providers. Hospice providers would need to go to extensive lengths to comply with the guidance. Additionally, it would further complicate accessing hospice, a service that is severely underutilized in New York compared to other states in the country.

The guidance requires hospice providers to know the full range of services a patient is receiving, an unreasonable task. The Department seems open to revisiting the guidance. Providers will likely ask the Department to table and revise the guidance until it is operational.

The Department provided a status update on the licensed home care services agency (LHCSA) application process, which opened this fall. Documents related to the application process and amendments to licenses can be found here. So far, the Department has received 24 applications, with most being changes in ownership. Some hiccups in the application process involve lack of information on what a rebuttal might address; incomplete applications, including lack of certified public accountant (CPA) sign-off for financial feasibility; and lack of Schedule 2D documents regarding out-of-state affiliations.

Usually the process takes four months, but these omissions and lack of Department staff have been contributing to longer review and approval times.

Providers inquired about reducing or eliminating the certified home health agency (CHHA), LHCSA, and hospice Health Emergency Response Data System (HERDS) reporting. Seon Davis of the Department stated that providers would receive a response soon on this issue. Providers urged that if it is not eliminated, it must be revised to remove unnecessary questions.

The need methodology is required for certain new LHCSA licenses, and the Department plans to survey agencies to obtain a revised patient count per county every six months. Providers can reach out with questions to homecareliccert@health.ny.gov.

Lastly, the LHCSA Statistical Report and registration process has been delayed and will be announced shortly. The Department expects agencies to complete a short form before the end of the year for registration, and agencies will have 60 days to complete the Statistical Report.

Members should feel free to contact Meg Everett with questions or concerns.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871