LeadingAge NY Provides Input to the Department of Health on LHCSA Need Methodology

LeadingAge NY submitted comments on the Department of Health’s (DOH) Request for Information (RFI) on their efforts to develop a need methodology for the establishment of Licensed Home Care Services Agencies (LHCSAs). A member-comprised LHCSA need workgroup developed our base positions for the comment, and LeadingAge NY staff worked with the Home Care Association of New York State and New York State Association of Health Care Providers to build upon those positions.

Among other positions, the comment letter recommends that a workgroup be established to deliberate and advise DOH in greater depth and detail on the questions posed by the RFI and on implementation of the new process. The letter addresses planning area establishment; factors to determine need; quality measures for consideration; exceptions and exemptions to the need methodology; special considerations for licensure; and more. The three groups advocate for a full exemption from the need process for existing LHCSAs that would like to add branches or services and a relaxed need process for existing LHCSAs adding new service areas. We also advocate for an exemption to the need methodology for Continuing Care Retirement Communities (CCRCs) that want to establish a LHCSA to serve their contract holders. We emphasized that the use of detailed criteria in the application and review process should not be applied in ways that add layers, administrative burdens, costs, or time delays to providers or the Department. The LHCSA Certificate of Need (CON) process should, to the maximal extent, be as efficient, timely, and seamless as possible for all concerned.

To read our comment letter, click here.

The requirement to establish a LHCSA need methodology was set forth in the 2018-19 State Budget. This process will move forward over the coming year, and we will keep members up to date. Thank you to members who contributed their time and expertise to develop our position.

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