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New DOH Guidance on Post-Acute Care Collaboration

The Department of Health (DOH) has issued new guidance that authorizes and encourages health care provider collaboration initiatives to streamline and improve post-acute care. The Dec. 19th Dear Administrator Letter (DAL) was issued pursuant to the Hospital-Homecare-Physician Collaboration Law enacted in 2015. Recommended collaboration initiatives include, but are not limited to, integrated or collaborative care and care management, care transitions, prevention, house calls, telehealth, bundled payments, and initiatives to avoid ER and hospital readmissions.

To accomplish the goals of the initiative, DOH is providing approved provider collaboration initiatives with regulatory and procedural flexibility, including allowing for streamlining or waiving of regulations relating to home care services to improve patient access, better health outcomes, and cost effectiveness. Some collaborations may require regulatory waivers or specific policy changes for certain activities, while others may not.

LeadingAge NY participated in DOH's Post-Acute Care Management Work Group and successfully advocated for inclusion of providers across the long-term/post-acute care (LTPAC) continuum in the initiative. By statute, collaboratives include hospitals, nursing homes, physician practices, and home care agencies, including Certified Home Health Agencies (CHHAs), Licensed Home Care Services Agencies (LHCSAs), and Long Term Home Health Care Programs (LTHHCPs). The DAL clarifies that adult day health care programs, hospice programs, and LHCSAs associated with Assisted Living Programs (ALPs) may also participate in these collaboratives. The guidance also requires that collaboratives delivering services in the home must include a home care agency, a requirement supported by LeadingAge NY.

All proposed projects are required to receive prior approval from DOH. It is only necessary to submit a request for a waiver if collaborative arrangements would be impeded by state regulation, policy, or procedure.

Questions relating to the DAL and requests for waivers should be directed in writing to Mark.Kissinger@health.ny.gov.

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