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Fiscal Intermediary Workgroup Completes Work

The agenda of the fourth and final meeting of the Department of Health's (DOH) Consumer Directed Personal Assistance Program (CDPAP) Fiscal Intermediary (FI) Workgroup included a detailed discussion of protections for consumers who transition from one FI to another, followed by a review of the Department’s compilation of all of the workgroup feedback from previous meetings.  DOH had scheduled a longer meeting to ensure sufficient time for a complete transition issue discussion, which was accomplished during the first half of the meeting. The discussion summarizing what DOH had synthesized from all of the prior meetings was disrupted by activists protesting the budget provision that alters how FIs are reimbursed for administrative expenses, making it impossible for the culminating discussion to continue. DOH is requesting that workgroup members review the slides that lay out a summary of feedback provided by the workgroup and submit final comments to the Department by Aug. 23. The slides can be downloaded here.

The workgroup, composed of consumers, FIs, local departments of social services (LDSSs) staff, managed care plans, and provider associations, was charged with helping the State to develop selection and contracting criteria for FIs while also considering other issues, including best practices, quality and reporting requirements. It was convened pursuant to provisions in the 2019-20 State budget that require DOH to implement a procurement process to authorize organizations to provide FI services and is expected to reduce the number of current FIs. DOH anticipates issuing a request for applications (RFA) for FI services in early fall, with decisions released in January 2020.  

The statute also shifts how FI administrative costs are reimbursed, resulting in widespread concern about potential negative impacts on the CDPAS program as well as FI and MLTC plan reimbursement due to potential underfunding.  DOH is working on implementing the reimbursement change separately and has made it clear that funding issues are outside of the scope of the FI workgroup. Managed Care Policy 19.01 issued in July outlines the new reimbursement structure as well as notice and monitoring responsibilities for FIs, plans and Social Services Districts/HRA when a consumer transitions from one FI to another. DOH has posted the templates FIs, plans and districts must use to notify consumers/members of changes.

A key discussion point was whether the procedures and templates that DOH has developed for use when a consumer changes FIs due to the FI closing or reducing service area should be applied when consumers change FIs voluntarily or when an FI leaves a plan’s network. DOH is inclined to require the process be used in all cases. We and other workgroup members have pointed out that the template language is fairly specific and would need to be tailored if used universally. While statute requires plans to supervise the transfer of a member’s records from one FI to another when an FI closes, such a requirement for all voluntary changes may not be warranted. 

Workgroup members expressed concern regarding potential difficulties in meeting the established timelines in cases where large numbers of consumers would be transitioning, pointing out that closing agencies would be reducing staff which could make it challenging for them to field any follow-up communications. DOH indicated that the 45 day notice of closure and client notification timelines were established to help address this and that the Department would monitor and adjust as needed, stressing that Maximus staff will be trained to assist in the process. Although some workgroup members were skeptical that such a process would be possible in all parts of the state, HRA described a success in transitioning clients in a prior FI closing in which HRA took an active role to coordinate all of the entities involved.

We anticipate DOH to collect and review final comments on the workgroup input summary and use the information to guide the development of the request for applications (RFA) for FI services. The RFA is likely to be issued in October, with decisions announced in January 2020. Members with concerns, questions or recommendations regarding the state’s summary of the workgroup’s recommendations are asked to let us know or communicate them directly to DOH no later than Aug. 23, 2019.

LeadingAge NY Contact:  Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841