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ALP Transition to Managed Care Pushed Back to 2017

LeadingAge NY and other stakeholders met with the Department of Health (DOH) on Oct. 14, 2016 to plan for the eventual transition of the Assisted Living Program (ALP) into mainstream managed care and managed long term care (MLTC).

DOH announced an official change in the target date for the transition of the ALP benefit and population into mainstream managed care and MLTC. The target date had been Dec. 1, 2016; however, the Department has decided to move the date back to July 1, 2017. It was noted that the group will have to make some key decisions by the end of this calendar year to be able to implement the transition by that time. Some stakeholders felt that this date is too ambitious; however, the Department is not receptive to a further delay at this time.

The Department is reportedly still open to discussions about how best to approach the transition timing, but is unable to phase individuals in at the time of the assessment. DOH is proposing that all ALP residents and those entering the ALP transition into mainstream managed care and MLTC on July 1, 2017 in New York City and Oct. 1, 2017 in the remaining counties. There was a recommendation that another way to allow a more gradual phase-in would be to bring new admissions into mainstream managed care and MLTC first, and then bring existing residents in 6 months later, which the Department is considering.

The Department proposed rate protection for a two-year period (i.e., requiring managed care plans to pay ALPs at least the benchmark or Medicaid fee-for-service rate). Rate protection would begin from the transition date, which as proposed would be July 1st for NYC and Oct. 1st for the rest of the state. The discussion of rate protection led to a conversation about how to calculate "benchmark rates." It became clear that it will be challenging to determine exactly how to establish benchmark rates, and further, the plans would find it extremely difficult to continue to pay the ALP in the way in which they are currently paid. The systems do not support being able to pay a per-person, RUG-specific rate to each facility. There was discussion about establishing a county benchmark rate and establishing a mechanism to identify a case-mix adjusted rate (i.e., similar to nursing home Medicaid rates) moving forward. This issue will require further analysis and discussion.

Unfortunately, the Department also indicated that there will be no additional funds for any rate increases in the upcoming state budget. LeadingAge NY has been working with the Department on the potential for an ALP Medicaid rate update to a more current base year, which would bring the rate up for all ALPs. In addition, we have proposed a Medicaid rate add-on for people with dementia in the ALP, a modest investment which could result in significant Medicaid savings. The issue and opportunity were discussed briefly during the meeting. We will continue to work on these issues; however, they will likely have to be addressed in the budget process if no increases are allotted in the Executive Budget proposal. It should be noted that the Department is still reviewing the ALP minimum wage survey responses and working on a methodology to distribute funding through the Medicaid rates to help pay for the minimum wage.

The Department does intend to have the ALP be a provider with which mainstream managed care and MLTC plans must contract. We again had conversations about network adequacy, with some discussion about flexibility in those counties where there is no ALP availability or a choice of ALPs.

We will be meeting with the Department again next month to continue these important conversations. Meanwhile, we will be discussing these issues with our members to get input and direction.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828