More Details on the Transition of the LTHHCP to MLTC

During the April 11 DOH MLTC Implementation Advisory Group call, the majority of information presented was on the transition of Long Term Home Health Care Program (LTHHCP) patients into mandatory managed long term care. Critical information shared includes:

• Confirming the Federal approval of the amendments to the LTHHCP 1915c waiver which will close the “front door” to LTHHCP Medicaid admissions and begin sweeping everyone into managed care in mandatory counties - NYC, Westchester, Nassau and Suffolk. The intent is to close the door effective June 1, 2013.
• CMS approval was granted for April 1, 2013, however, full implementation will not occur until sometime around June 2013. 
• LTHHCP patients will probably receive announcement letters in the mandatory counties next week - around April 22.
• The first mandatory enrollment letters are slated to be mailed around mid-May. The LTHHCP patients will be given 60 days to decide on a MLTC plan or join another 1915 (c) waiver. On the call it was stressed these letters will go out slowly, over the course of three or four months.
• Documentation on the projected timelines and relevant material will be posted shortly on the MRT website under MRT #90.
• DOH stressed the principle guiding criteria will be participant choice. LeadingAge NY has been advocating with the CMS central office in Baltimore and NY regional office in New York stressing “choice” and “continuity of care.” Interesting to note that our position on 90 days or more of Continuity of Care (CoC) policy that we discussed with CMS has now been incorporated. This is a change in policy from the March 18 webinar on the Transition of Dual and Non-Dual Eligible LTHHCP Participants to MLTCs/MMC. We advocated that the CoC policy should be longer because of the vulnerability of this population. 
• DOH clarified that per a directive from CMS the options for enrolling in other 1915 (c) waiver programs must offered. It was stressed during the call that there must be choice and the Plan of Care (PoC) must be person-driven and not insurance plan-driven. This again has been part of our advocacy with CMS. DOH acknowledged that individuals cannot be mandated into a particular LTC program, but must have choice of available programs. 
• The LTHHCP is required to share the PoC with the MLTCs and cooperate with the transition in the best interests of the patient. 
• It will be the LTHHCPs responsibility to be checking with eMedNY to confirm plan selections and assignments.
• It will be the responsibility of the LTHHCPs contracting with LHCSAs for personal care to notify LHCSA contractors which MLTC the LTHHCP patient has enrolled in.
• The Special Terms and Conditions (STCs) are not finalized between the DOH and CMS.   

DOH responded to several questions which include:

• Total mandatory MLTC enrollment thru March 2013: New York City, 43,076; Nassau, 235; Suffolk, 133; Westchester 198. Mailings were sent to 2,329 "long term" CHHA patients and 276 have enrolled into MLTC plans.
• Front door to services – in mandatory counties for private duty nursing the door is still open (about 200 clients), adult day health care and long term CHHA cases there is no real front door, so DOH has started mailing to that population and that population will be swept in overtime.
• DOH wanted to remind everyone to maximize Medicare and that Medicaid was the payer of last resort.
• There continues to be systems and coding problems with hospice patients and providers.
• LHCSA and LTHHCP relationship – the question was raised how the LHCSA will be notified from the LTHHCP when the case goes to contract with MLTC. DOH restated it is the LTHHCP's responsibility to notify the LHCSA.
• Contracting issues including Care Management Agreement Services (CMAS) between the MLTC and LTHHCP are still problematic. DOH shared that the hold up for CMAS is due to DOH review. They want to ensure that the process is understood.

Providers shared with the DOH that there are ongoing and major obstacles to partnerships between MLTCs and LTHHCPs.

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