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LeadingAge NY Advocates for Collaborative Post-Acute Care Models and Regulatory Reforms

Commenting on proposals submitted to the Department of Health’s (DOH) Post-Acute Care Management Models Work Group, LeadingAge NY asked the Department to support collaborative post-acute care models rather than changing home care licensing regulations to permit hospitals to provide home-based services. The Post-Acute Care Management Models Work Group was convened by the Department in connection with its Regulatory Modernization Initiative. The Work Group’s discussions focused on requests by hospitals for changes in regulations to allow them to provide and receive reimbursement for home-based services. LeadingAge NY was a member of the Work Group and participated in its two meetings. Summaries of the meeting are available here and here. The full text of our comments is available here.

In our comments, LeadingAge NY described the significant stress on the long-term/post-acute care sector as a result of workforce shortages, growing managed care penetration, new payment models, and the failure of government reimbursement to keep pace with rising costs. We also explored some of the potential disadvantages of expanding the ability of hospitals to provide home-based services. In particular, we pointed to the possibility that such an expansion might have a detrimental impact on the state’s home care infrastructure, as hospitals would absorb low-acuity, short-term cases and might threaten the financial viability of certified home health agencies (CHHAs). Meanwhile, a shrinking supply of home care nurses and aides would be attracted by the higher wages that hospitals could offer. In addition, these models could lead to the need to manage additional care transitions as 72-hour hospital-home care cases would be handed off to CHHAs and licensed home care services agencies (LHCSAs) for extended post-acute care and long term care.

LeadingAge NY urged the Department to invest in the long-term/post-acute care sector and provide support for successful collaborative post-acute models. In particular, we requested investment in electronic health records and health information exchange and telehealth modalities. We sought a broad array of regulatory reforms to respond to workforce shortages and new care and payment models. We also renewed our request for funding for service coordination services in affordable senior housing.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124