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LeadingAge NY Testifies on Nursing Home Bed Need Methodology

In testimony delivered last week to a Public Health and Health Planning Council (PHHPC) committee and the Department of Health (DOH), LeadingAge New York provided data on nursing home occupancy, capacity and length of stay trends. We also discussed current system reform initiatives that could affect nursing home utilization, and raised several policy issues that should be addressed in discussions on the nursing home bed need methodology.

DOH is required to update the existing need methodology, which expires at the end of 2016. The Sept. 24, 2015 meeting of the PHHPC’s Planning Committee included an opening discussion on the current methodology and possible revisions. DOH believes that the current methodology has over-estimated the actual need for nursing home beds, and reportedly has sought to require reductions in beds in cases when existing operators are selling or renovating their facilities.

The Planning Committee is seeking input from various stakeholders on possible revisions to the need methodology, including but not limited to:

·         Suitability of the existing 97% occupancy threshold: The existing regulations provide that even if the methodology shows unmet need in a planning area, if the average occupancy in the area is less than 97 percent, it is assumed that there is no need for additional beds;

·         Planning areas to be used:  Currently, the methodology relies on the county as the planning area for need, except that the five boroughs of NYC are considered a single planning area, as are the two counties of Long Island. The Committee seeks input on whether the planning area should always be a county or should be a multi-county region (e.g., NYC, Long Island); and whether DSRIP Performing Provider System service areas should be considered; and  

·         The effect of short-stays:  The impact of short stays of <100 days on admissions and occupancy is not currently considered in the methodology.

Among the findings we reported in our testimony were the following: 

·         Statewide nursing home occupancy declined modestly from 94 percent to 93.4 percent during the period 2011-2015 (year-to-date).     

·         Since 2010, 3,246 nursing home beds have been taken off line in the State due to nursing home closures. Another 905 beds have been reduced in facilities that remain in operation, for a total bed reduction of 4,151 beds or 3.5 percent of total system capacity. 

·         Statewide, the total number of short-stay episodes (100 days or less) increased by 4 percent between 2011 and 2014, while the average length of stay in these episodes modestly increased by 3.2 percent to 28.3 days. 

LeadingAge NY cited the following factors as likely to affect future nursing home demand: (1) demographic changes; (2) mandatory Medicaid managed care; (3) value-based payment;  (4) delivery system realignment; and (5) expansion of assisted living and other alternatives.

An archived webcast of the Planning Committee meeting is available here by clicking on “Public Health and Health Planning Council Committee Day, September 24, 2015.”  For your reference, the current bed need estimates by county are posted here and the relevant regulations (10 NYCRR 709.3) are posted here.

LeadingAge NY will be discussing the need methodology with its Cabinets in the coming months, and formulating recommendations for the Planning Committee and DOH. Please contact us if you have any questions or comments.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866