More on the LTHHCP Transition to MLTC

There are two updates:

1. CMS Posted the DRAFT Contract/ Special Terms and Conditions with DOH

During our calls with CMS they have stressed the draft Special Terms and Conditions (STCs) are their contract with DOH. As you read through the STCs it appears most of the document is boilerplate language for the twelve subject areas except for a couple sections that are relevant to the LTHHCP.  The provision for the mandatory enrollment of the LTHHCP patients into Managed Long Term Care (MLTC) and mainstream Medicaid Managed Care (MMC) plans is covered in the STCs of the "Partnership Plan Medicaid Section 1115 Demonstration" under HCBS Expansion Program. The majority of the references are in general terms. CMS has stated the specificity on contracts, continuity of care, etc. will be detailed by the DOH. CMS did say they will be carefully monitoring the implementation of the LTHHCP transition process. We have stressed with concerns that are outlined in our letter to the Commissioner of Health such as, continuity of care, freedom of choice, patient safety, regulatory relief, and spousal impoverishment budgeting. We have pointed out to CMS that a 60-day continuity of care policy similar to what DOH instituted for personal care is insufficient for this nursing home level of care population. We have suggested a more robust provision of 90 days or greater. During the April 11 DOH MLTC Advisory Conference call the continuity of care provision had been changed to 90 days.

2. Continued Clarification on the Transition Process and Timeframes with DOH

We continue to discuss your concerns with key officials at DOH. Our HCBS cabinet thought it was time to go on the "record" with your concerns - please read our letter to the Commissioner of Health. There are still many outstanding contracting and regulatory relief questions to be answered for this to be a smooth, successful and safe transition of care.  

Questions have been raised on the status of the Care Management Administrative Agreements (CMAS). DOH has confirmed there are nine CMAS under review.

DOH stated that announcement letters should be mailed to LTHHCP patients around April 22. It has been clarified by DOH that around April 10 announcement letters were mailed statewide to non-duals. Duals in mandatory counties of NYC, Nassau, Suffolk and Westchester should start receiving the announcement letters around April 22.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871