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LeadingAge NY Comments on CHHA CON Reform Paper

LeadingAge NY recently provided comment on a Department of Health (DOH) position paper which outlines several options for reforming the Certificate of Need (CON) process for Certified Home Health Agencies (CHHAs). It is likely that DOH will issue proposed regulations on this matter later this year.

LeadingAge NY framed its concerns regarding access to home health care by stressing two main points: insufficient reimbursement rates for providers and the workforce shortage. While the CON reform is important in ensuring that need is met and agencies are capable and qualified, these two overarching factors are the main culprit impacting the availability and quality of CHHA services today. LeadingAge NY provided background on both issues and requested support and commitment from the State on both fronts. With regard to specific CON reform, LeadingAge NY supports a need review process and a formula that utilizes Medicaid- and Medicare-eligible enrollees compared to current CHHA caseloads. We also oppose a presumption that need is satisfied if there are at least five CHHAs in a county. LeadingAge NY also advocates for flexibility in designated planning areas, especially in upstate regions, to address areas that are not being adequately served.

You can find LeadingAge NY's comment letter here. Draft regulations will likely be issued soon. Feel free to contact our office with additional feedback so that we can incorporate your suggestions into our next comment letter.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871