Recommendations Made on NH Bed Need Methodology
During a March 30th meeting of the Public Health and Health Planning Council (PHHPC) Planning Committee, the Department of Health (DOH) recommended revisions to the nursing home bed need methodology. The existing need methodology is set to expire at the end of 2016.
In a presentation to the Committee, DOH made the following recommendations:
1. The methodology should be revised and applied for a five-year period (i.e., update the planning target year from 2016 to 2021). This is intended to allow sufficient time to assess the impact of initiatives such as care management and DSRIP, particularly the intersection of these reforms and the long term care system. Data would be collected and presented annually to PHHPC.
2. The base year data and usage rates would be revised. The population and usage statistics would be updated to 2014, the most recent data available. The methodology would begin to look at the recent trend of nursing home usage rates (rather than use a snapshot), and no longer blend the planning area bed estimate with statewide figures. These changes will likely make the bed need estimates more closely reflect each county’s experience.
3. The planning areas would be revised. Currently, each county is a planning unit (except for New York City and Long Island, each of which is a single planning area). The methodology would be revised to treat counties (including each county within New York City and Long Island) as a starting point, but allow flexibility in redefining the planning area for a particular application based on factors such as population density and travel time.
4. A new approach would be used on adjustments to account for persons who access nursing homes in different counties. The current methodology uses a universal migration adjustment, which produces some anomalies in county-level need estimates. DOH is recommending applying a regional migration adjustment in areas where it is deemed appropriate.
5. The methodology would include a revised occupancy rate threshold. Currently, if the overall occupancy rate in a planning area is less than 97 percent, it is assumed that there is no unmet need and DOH determines whether to decertify beds in connection with a renovation or ownership transfer application. The 97 percent threshold would be retained for net new beds, but a lower threshold of 95 percent would be applied in renovation and change in ownership applications.
DOH believes that the current methodology has over-estimated the actual need for nursing home beds, and has sought to require reductions in beds in cases when existing operators are selling or renovating their facilities. LeadingAge New York called for not applying any occupancy threshold to renovation projects, citing this policy as having had a chilling effect on needed facility updates. We also urged DOH to issue a new request for proposals under the nursing home voluntary rightsizing program, which allows facilities to temporarily decertify beds or permanently convert beds to another service line.
An archived webcast of the Planning Committee meeting is available here by clicking on “Public Health and Health Planning Council's Health Planning Committee Meeting, March 30, 2016.” For your reference, the current bed need estimates by county are posted here and the relevant regulations (10 NYCRR 709.3) are posted here.
The Planning Committee agreed that DOH’s recommendations should be reported to the full PHHPC at its April 14th meeting. LeadingAge NY will be discussing the need methodology with its Nursing Facility Cabinet in coming weeks, and welcomes member feedback on the DOH recommendations.
Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866