Another NHTD/TBI Transition Plan
Last week, the Department of Health (DOH) posted a revised draft Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Medicaid waiver transition plan into managed care. DOH has requested comments be submitted before Aug. 24th. Your comments can be submitted electronically to: email@example.com, please copy me on your comments.
LeadingAge New York and our members were involved in an earlier version of a “draft” transition plan to CMS. We had several opportunities to revise the plan before it was to be submitted to CMS, however, with the change in the transition date as a result of this year’s final budget, that transition plan was put on hold. The new date for transition of the waivers to managed care is scheduled for Jan. 2018.
This is the most current transition plan along with the nine attachments. Some areas that are still included in the 21 page document are:
- The background, access to services, including Community First Choice Option (CFCO), some of the services currently being provided by the waivers and not included in CFCO, with CMS approval, may be part of the benefit package. Service Coordination is one of the services that generated an intense discussion of how it could be provided without duplicating care management being provided by the managed care plans.
- The Regional Resource Development Center (RRDC) will continue to have a role in the managed care model in order to access the need for what is referred to as “enhanced benefits.” The current RRDC contract expires at the end of this month and it will probably be extended until a new procurement is processed in 2017. See Attachment Five for the Enhanced Benefits Service Assessment process.
- Please note page 8-9 and Attachment Six, the new transition timeline. According to the transition plan, DOH continues to request 90-day temporary extensions of the existing NHTD waiver until the waiver is eliminated, which is expected to be on June 30, 2018 or until all current NHTD waiver participants are safely and successfully transitioned to managed care plans. The TBI waiver has been granted temporary extensions by CMS to the current application in order for the State to fully respond to CMS´ formal Request for Additional Information (RAI). The extensions have allowed the waiver program to operate while the transition plan is being finalized. DOH’s goal is to obtain CMS approval of this transition plan by Sept. 1, 2017. If CMS approves the transition plan then, effective Oct. 1, 2017, all pending waiver applicants will be contacted by the RRDCs and advised of the opportunity to voluntarily enroll into MLTC/MMC services directly instead of seeking waiver services. Additionally, DOH will close the door and will stop the enrollment of any new waiver service providers and will no longer approve expansion of existing waiver service providers effective Oct. 1, 2017.
- Current NHTD/TBI waiver participants will receive an announcement letter on or about Dec. 1, 2017 indicating that voluntary enrollment of existing waiver participants into a managed care product will be effective statewide Jan. 1, 2018 and that the NHTD/TBI waiver programs will no longer be available effective April 1, 2018.
- The transition plan outlines enrollment after Jan. 2018 which will follow the current enrollment process through the Conflict-Free Evaluation and Enrollment Center (CFEEC) and DOH is proposing a two year continuity of care provision for waiver participants and waiver service providers.
- Continuity of care provisions and rates need to be further analyzed.
- Please note plan readiness on page 16 – 18. See Attachment Nine that provides the basic staff qualifications for the current waiver services that will become part of the benefit plan. Managed care plans will be required to submit an orientation and training plan that ensures all relevant staff receive training including, but not limited to six areas.
LeadingAge NY will continue to analyze the transition plan and seek member's input for comments to DOH before the August deadline.
Contact: Cheryl Udell, firstname.lastname@example.org, 518-867-8871