DOH Webinar Reviews SADC Site Evaluation Tool
On Sept. 16th, the Department of Health (DOH) presented a webinar for Managed Long Term Care (MLTC) plans during which Department staff walked through a Social Adult Day Care (SADC) site evaluation tool. The tool and accompanying guide are designed to assist MLTC plans in conducting initial and annual SADC site evaluations that verify that the site is compliant with state and federal requirements, including the Home and Community-Based Services (HCBS) Settings Final Rule. The tool and guide were posted in late August on the MLTC Policies page of the Medicaid Redesign Team (MRT) 90 section of the DOH website under Policy 21.05. Plans may begin using it immediately. DOH indicated that the webinar and slides will be posted there as well.
While DOH stresses that use of the tool is not mandatory, those who use alternative instruments must ensure that they check and document all of the information that is contained on the DOH tool when conducting site evaluations.
The tool is an Excel workbook with nine sections (tabs) that can be expanded to accommodate additional staff and member checklists. It is intended to be used at initial contract as well as for annual site visits. Most sections are comprised of a series of Yes/No questions with fields for comments as well as space to describe remediation activities for responses indicating non-compliance. All fields and tabs in the tool are required unless otherwise stated, and plans should maintain the completed tools and any accompanying documentation for seven years and be prepared to provide copies to regulatory agencies as needed.
In response to a question regarding what documents DOH would recommend that plans obtain and keep, staff indicated that best practice may be to keep a copy of the certificate of occupancy and perhaps notification to local fire division, and to keep those with the copy of the tool. If remediation is involved, it would be good practice to keep evidence/documentation that the issue was resolved with the tool. If facing specific questions, please contact MLTCSurvey@health.ny.gov.
If a plan has a contract with a site, but has no members at the site, the review should be treated the same as for a new provider, showing that the program will be able to meet all the requirements once it starts receiving members. For SADC sites serving members, the requirement is that 10 percent of the plan’s members attending the site be included in the review.
The evaluation tools are not submitted to DOH, but are kept for records, with plans being prepared to produce them as required. The Department does intend to do additional surveys focused on this issue in the future, so plans will want to make sure to have them all completed and on file. Note that this tool is specifically for SADC, not Adult Day Health Care (ADHC). There are other requirements that apply to ADHC, but the focus of the discussion was exclusively on SADC.
In response to questions regarding remediation, DOH indicated that they have no set time for a SADC site to remedy non-compliance and that the plan should be working with the site to ensure that they are coming into compliance and setting a reasonable timeframe for remediation. Plans should use their own experiences of going through corrective action plans when thinking of elements to include when working with SADC: address the issue, ensure that it does not reoccur, obtain and keep evidence that it was remediated.
Under the HCBS standard, Programs of All-Inclusive Care for the Elderly (PACE organizations) are not required to follow through with the compliance activity. DOH reports that some PACE organizations have reached out regarding specific SADC sites and are willing to collaborate and use these tools. So, while they are outside of the required compliance activities, the option is there for PACE organizations to participate in the process if they so choose.
Plans have recently been notified about which compliance category applies to each of their SADC providers based on self-assessment surveys as well as the required action applicable to each category. While MLTC plans have been responsible for ensuring SADC compliance, the expanded process required by the tool seems extensive. Please let us know if you have comments or are encountering difficulties with the process.
LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841