Managed Care Policy and Planning Meeting Highlights
The Managed Long Term Care (MLTC) portion of the September Medicaid Managed Care Policy and Planning Meeting offered participants an opportunity to learn about the role the State hopes health care providers and plans will play in promoting the state's Paid Family Leave Act. The presentation was followed by the MLTC Update that included an announcement that the Assisted Living Program (ALP) benefit would not be added to the MLTC benefit package for at least two years. Highlights of the meeting are summarized below. The MLTC Update slides are available here.
Enrollment. MLTC enrollment continues to grow by an average of 2,200 members each month. The August increase of 1,411 was the lowest monthly change of 2018 so far but followed the year’s largest increase of 3,367 in July. Partially capitated plans represent the bulk of the growth, increasing by 8 percent this calendar year and 14 percent in the last 12 months. Medicaid Advantage Plus (MAP) plans and the Fully Integrated Duals Advantage Plan serving individuals with Intellectual and Developmental Disabilities (FIDA IDD) are seeing large growth, Programs of All-Inclusive Care for the Elderly (PACE) participation remains relatively stable, and FIDA enrollment continues to decline. There are 212,736 members being served by partially capitated plans, with MAP plans reporting enrollment of 11,459.
The Department of Health (DOH) provided some new data showing referral sources for the evaluations that the Conflict Free Evaluation and Enrollment Center has performed during the last 12 months by quarter. The most common referrals are from home care agencies and represent about 25 percent of all referrals. Health plans account for 16-19 percent of referrals, a similar percentage as family/friends/neighbors. Doctors and hospitals account for 11-12 percent.
Enacted Budget Update. On Aug. 20th, DOH issued guidance to partially capitated plans on implementing the state budget provision that sets caps on the number of Licensed Home Care Services Agencies (LHCSAs) in their provider networks. The Department expects to see the required reductions when plans submit their October network filings. DOH reminded that the guidance outlines the exceptions process, noting that no plans have requested an exception yet. There is no intention to issue a template or sample member notification letter for contract terminations, with DOH believing this to be a brief and straightforward notice that plans should already be using.
Although the DOH position continues to be that members of an Independent Practice Association (IPA) would be counted separately, they indicated that they would be open to further discussion if providers did form IPAs (for reasons other than to circumvent the limit). DOH also indicated that they believe that the statutory requirement to reduce networks supersedes contract termination provisions and should not thwart compliance with the provision.
The Department recognizes that membership fluctuates during the year, so plans may add LHCSAs at any time if needed, but should be in compliance based on current enrollment. DOH promised to review plan notices and exception requests quickly and is developing an FAQ document and possibly a webinar on the limitation as well.
There is little new information on other state budget item implementation. The waiver amendment for the 12-month lock-in provision is under review with the Centers for Medicare and Medicaid Services (CMS), and DOH is working with Maximus to implement the “authorization vs. utilization” provision and expecting to issue guidance to plans this month.
Community First Choice Option (CFCO). DOH reported that they had held CFCO meetings with both plans and local social services districts and requested that any comments on the disseminated draft documents be submitted as quickly as possible. A summary of the Aug. 29th CFCO meeting with plans is available here. The Department is working on rates and rate codes, determining how those services that are currently being provided through waiver programs or FIDA are being provided and billed now with the intention of emulating existing practice and filling in gaps as needed.
Although DOH indicated at the outset of the discussion that they were not expecting to delay implementation, participants voiced strong concern that there is insufficient time to complete what needs to be done in advance of a Jan. 1st start date and that there is insufficient information for plans to make some of the key preparations that are required. DOH requested more information on specific barriers that would thwart January implementation, while participants suggested that DOH provide a timeline when key information and documents would be made available to allow plans to review feasibility.
Other Issues. The State has informed CMS that they will not be adding the Assisted Living Program (ALP) benefit into managed care at this time. The most recent plan had been to add the benefit starting in October of this year. This will delay the carve-in for at least two years, at which time DOH may revisit the issue.
The minimum wage guidance and FAQ documents can now be accessed on a dedicated minimum wage web page on the DOH site here. DOH recommends that minimum wage contract amendments for Jan. 1, 2019 be completed by Nov. 1st and has scheduled a webinar for plans and home care providers on Sept. 28th.
DOH reminded plans that are participating in the Workforce Investment Program (WIP) that reports for the Q1 reporting period that ended on June 30th should be submitted as soon as possible to MLTCWorkforce@health.ny.gov. The Q2 reports for the quarter ending on Sept. 30th are due at the end of October. DOH has scheduled a WIP Learning Series that will focus on best practices and allow Workforce Investment Organizations (WIOs) and plans to learn what others are doing. The first session will be on Sept. 28th from 10 am to 2 pm.
Finally, DOH is seeking information on downstate home care and personal care worker shortages to identify pockets of need and provide data that would clarify frequent anecdotal information. Plans with data that would provide insight on this issue are asked to contact DOH.
LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841