Transitioning from the LTHHCP to MLTC
LeadingAge NY has been advocating for regulatory relief, flexibility and clarification on issues related to the transition of Long Term Home Health Care Program (LTHHCP) patients to Managed Long Term Care (MLTC). We continue our strong advocacy with DOH on these issues and presented testimony at the first Home and Community Based Care Work Group on Friday, June 21. Our advocacy has become even more critical as LTHHCP patients begin to be transitioned in counties designated for mandatory enrollment effective Monday, July 1.
In seeking clarification on assessment requirements during the transitions, the DOH OASIS Education Coordinator responded to our question as follows:
Question - Is an OASIS discharge assessment and a SOC OASIS comprehensive assessment required when transitioning a patient from LTHHCP (Medicaid Episodic Payment) to a Medicaid Managed Long Term Care Plan and the LTHHCP provider will continue to provide services to the patient?
Answer - A discharge OASIS and SOC OASIS assessment is not a CMS requirement in this situation since the patient is not actually being discharged from the home care agency and admitted to another home care agency AND the payor source is not changing to Medicare FFS which would require a new SOC. In this case, the agency must follow the direction of the payor (MLTC). If the payor requires a new SOC, then the Discharge is needed and a new SOC would be accepted in the system. If the payor does not require a SOC, then the agency continues on the 60 day recert cycle and would change the payor source as appropriate when the recertification OASIS is due.
For related Federal CMS guidance on these issues, please click here.
From the CMS Q&As: Q35 - The patient's payer source changes from Medicare to Medicaid or private pay (or vice versa). The initial SOC/OASIS data collection was completed. Does a new SOC need to be completed at the time of the change in payer source?
A35 - Different states, different payers, and different agencies have had varying responses to payer change situations, so we usually find it most effective to ask, “Does the new payer require a new SOC?" HHAs usually are able to work their way through what they need to do if they answer this question. If the new payer source requires a new SOC (Medicare is one that DOES require a new SOC), then it is recommended that the patient be discharged from the previous pay source and re-assessed under the new pay source, i.e., a new SOC comprehensive assessment. The agency does not have to re-admit the patient in the sense that it would normally admit a new patient (and all the paperwork that entails a new admission). If the payer source DOES NOT require a new SOC, then the schedule for updating the comprehensive assessment continues based on the original SOC date. The HHA simply indicates that the pay source has changed at M0150. OASIS data collection and submission would continue for a Medicare/Medicaid patient changed to another pay source until the patient was discharged. Because the episode began with Medicare or Medicaid as a payer, the episode continues to be for a Medicare/Medicaid patient.
Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871