DOH Convenes Meeting Regarding ALP Transition to Managed Care
LeadingAge NY and other stakeholders met with the Department of Health (DOH) on Sept. 15, 2016 to plan for the eventual transition of the Assisted Living Program (ALP) into managed care and managed long term care (MLTC). A variety of issues were discussed, and several questions were raised. To date, no clear decisions have been made.
We again discussed how to transition the ALP program and population into managed care and MLTC. One member suggested using a pilot to begin with voluntary enrollment, before transitioning the larger population. We reiterated the ALP’s need for a phased-in approach to be sensitive to their administrative capacity. Plan representatives pointed to the manner in which the MLTC reimbursement would be structured to guide the phase-in approach.
We also discussed the network adequacy provision; if we are to require that plans contract with ALPs, they must provide consumer choice in each county. Choice is described as providing two or more options to the consumer; however, 11 counties do not have an ALP in them, and some have one provider. DOH noted that the network adequacy provision is a challenge in those counties where there is only one provider; the provider must then work with the plan. It was noted that the approach to contracting with specialty nursing homes may provide an avenue to address the situation. Others noted that it pointed to the need for an expansion of the ALP program.
The ALP as a Bundle of Services
There was discussion regarding whether the ALP services would be a bundle or package of services, versus the plan being able to contract for any of the services within the ALP package. There seemed to be a preference for approaching the ALP as a bundle, as this is how it has operated and how it is uniquely set apart from a situation in which an adult care facility (ACF) resident accesses licensed home care services agency (LHCSA) services.
One member noted that retaining residents longer with additional wrap-around support from the plan could be beneficial. DOH noted that the retention standards do not change by virtue of this transition.
There was discussion regarding care management responsibilities. DOH questioned whether plans should have the ability to approve or disapprove a level of service, including hours of a particular service within the ALP. It was felt that this level of management was not needed in the ALP. Rather, it was suggested that DOH and the plans approach the ALP as they have the nursing home; the service provider is responsible for providing the package of services at the level that the resident needs that day. There seems to be a need for greater clarification regarding the roles and responsibilities for each party.
Federal Home and Community Based Settings Rule Compliance
We discussed consumer choice and that, in compliance with the federal home and community based settings rule, the consumer will have chosen the ALP package of services, which includes the LHCSA that comprises the ALP. If a resident comes from the community into the ALP, that may mean that they have to give up their current LHCSA. Consumer choice is a key principle of the rule.
There was also discussion of rate protection, and arguments were made for various time frames, both short and long. LeadingAge NY provided an update on the work we are doing to help facilitate a rate update for the ALP prior to the transition. In addition, we discussed the work DOH is doing to gather necessary data to ensure that the ALP has access to funds dedicated to help Medicaid providers pay for the minimum wage mandate.
HARP and the ALP
Lastly, a question was raised about whether people in the ALP would be in HARP, a managed care product for those with mental illness and behavioral health needs, or if they should be disenrolled. This question will be considered further.
At the conclusion of the meeting, DOH indicated that they may draft a policy for the ALP transition and have stakeholders comment. The group will be meeting monthly for the next few months, and LeadingAge NY will continue to participate and contribute to the discussion on behalf of our membership.
Contact: Diane Darbyshire, firstname.lastname@example.org, 518-867-8828