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Another Meeting on the NHTD/TBI Transition to Managed Care

Last week, LeadingAge NY participated in the Department of Health’s (DOH) Phase 2 workgroup meeting on the transition of the Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Medicaid waiver plan into managed care. This follows the release of a “draft” NHTD/TBI transition plan that we commented on in August.

The three major agenda items that were discussed included a revised transition timeline, an update on the UAS-NY, and a summary of common elements DOH received on the “draft” transition plan.

The revised timeline includes:

  • all Phase 2 workgroup meetings;
  • Community First Choice Option (CFCO) moving into managed care in January 2017 (waiver participants will transition to CFCO and managed care at the same time in January 2018);
  • DOH submitting an 1115 waiver amendment in June 2017;
  • CMS approval of the transition plan and release of a new RRDC RFA in September 2017;
  • The end of enrollment of new waiver providers and more in October 2017;
  • Various enrollment notices going out to waiver participants from December 2017 through March 2018; and
  • The beginning of services and the full incorporation of CFCO and previous waiver services into managed care in April 2018.

An update was also provided on the UAS-NY. A national workgroup has been formed to look at the whole tool, and InterRAI is writing a position paper on it. There have been numerous discussions and concerns voiced over several years on the UAS-NY being used with patients who have a cognitive impairment. In addition, IPRO is currently conducting an audit on ten TBI participants from each of the nine RRDCs who scored less than a five on the UAS-NY. DOH is looking at three potential outcomes: can the score be replicated; are there issues not being picked up by the UAS-NY, and is the item specific to the measure; and is it accurate. The Phase 2 workgroup requested that an item be added to the UAS-NY: service-dependent. This is included in the assessment tools of other states, such as Michigan. Service-dependent means that without the services, the participant could regress or fail. Currently, less than 25 percent of the TBI population scores a five or under on a nursing home level of care. This generated much discussion on why the percentage could be decreasing. It was mentioned by many that the issues of access and rates are problematic. Several stakeholders stated that Certified Home Health Agencies (CHHAs) are not conducting the UAS-NY because of the low reimbursement rate.

The last major issue discussed was the brief summary of common elements in the comments DOH received on the “draft” transition plan. DOH has discussed the changing role of the Service Coordinator with CMS. In our comments to DOH, we stated that we do not see any conflict of interest with the plan’s care managers and service coordinators and requested that the term "business relationship" be removed from the transition plan.

The next Phase 2 meeting is scheduled for Tues., Oct. 4th at 10 a.m.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871