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Transition Plan for Home and Community-Based Services Rule Available for Public Comment

The Department of Health (DOH) issued its revised Home and Community-Based Services (HCBS) Final Rule Statewide Transition Plan (STP) for public comment on the Medicaid Redesign Team website. This is New York’s plan regarding how it will transition into compliance with the federal HCBS rule by March of 2019. The plan can be found here. DOH will be accepting public comment until the close of business on Fri., Aug. 19th.

By way of background, the federal rule outlines the requirements for home and community-based services provided under Medicaid waivers, which includes services provided under managed care and managed long term care (MLTC) in New York. Given the mass enrollment of Medicaid-eligible people into managed care and MLTC, the impact is broad. The rule highlights principles such as consumer autonomy and choice and person centered planning. The rule also outlines requirements of the environments in which those services are provided.

You’ll see that the transition plan is a lengthy document; however, it is broken down into sections, and we urge members to review any sections that pertain to your service area. LeadingAge NY is currently analyzing the plan and will be providing comment. We encourage members to consider doing the same.

LeadingAge and LeadingAge NY have been following this rule closely over the years, and have been actively engaged in advocacy at every step. Click here to learn more about our most recent conversation with CMS about these issues, and here for an overview of our meeting with DOH and the Governor’s Office. LeadingAge NY was one of five organizations that submitted comment on New York’s initial transition plan to CMS. It is critical that more voices representing services for the aging are heard as the process unfolds, to ensure that the rule is implemented in a way that takes the unique needs and preferences of that population into consideration. For that reason, we urge members to consider making comment.

There is guidance about the rule available on the CMS website. There are aspects of the guidance that LeadingAge NY continues to seek clarification on, and we anticipate additional written guidance in the future. Members are encouraged to contact us with any questions about the rule or the public comment opportunity.

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