LeadingAge NY Recommends Revisions to Person-Centered Service Planning Guidelines

LeadingAge NY has submitted comments on draft guidelines ("the Guidelines") proposed by the Department of Health (DOH) on Person-Centered Service Planning (PCSP). The Guidelines apply to service planning for home and community-based services (HCBS) conducted by all Medicaid managed care plans (including managed long term care (MLTC), Programs of All-Inclusive Care for the Elderly (PACE), Fully Integrated Duals Advantage (FIDA), and Medicaid Advantage Plus (MAP) plans) and local departments of social services (LDSSs). They are driven by federal regulations governing HCBS delivered under section 1915(c) waivers, Community First Choice Option (CFCO), and other HCBS authorities. In addition, the State's waiver under section 1115(c) of the Social Security Act incorporates general language requiring PCSP.

LeadingAge NY's comments focused on four themes:

• The Guidelines are overbroad and should be targeted to each program and population individually;
• The Guidelines exceed the requirements of the federal regulations and the MLTC contract and impose new administrative requirements simultaneous with a cut in the administrative component of MLTC rates of approximately $40 million;
• The conflict of interest requirements in the Guidelines are ambiguous and risk disrupting established care management and provider relationships; and
• The conflict of interest requirements are inconsistent with the Department's efforts to promote two-sided risk arrangements between MLTC plans and providers. 

LeadingAge NY will apprise members of developments in PCSP as discussions with the Department progress.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124