MLTC Nursing Home Benefit Change to Be Implemented May 1st
The Department of Health (DOH) has confirmed that the new target date for long-term nursing home stay (LTNHS) residents to disenroll from partially capitated Managed Long Term Care (MLTC) plans is May 1, 2020. The original intent had been to disenroll individuals outside of New York City (NYC) on March 1st and those in NYC on April 1st.
While DOH is working with plans to ensure that the appropriate members are disenrolled, nursing homes should be prepared to assist residents to understand the various notices that they may receive as part of the process. These may come from the resident’s plan, DOH, or from “Medicaid Choice,” the State’s Medicaid managed care enrollment broker. It is important to reassure residents that for most, the change is a background payment methodology change that will not impact their care or their Medicaid eligibility. DOH indicated that all residents set for initial batch disenrollment do have institutional Medicaid in place, but homes should monitor that going forward.
Following the batch disenrollment process that will be coordinated by DOH, going forward, disenrollments of residents meeting the three-month threshold will be initiated by individual plans. While we expect DOH to provide further guidance to nursing homes regarding the process, the change will require providers to:
- Monitor to make sure that any individuals actively working toward discharge are not inadvertently disenrolled from MLTC
- Ensure that they notify the district/New York City Human Resources Administration (HRA) and the resident’s plan within 48 hours of an individual determined to be in a LTNHS
- Continue to assist residents to understand the three-month limitation and related notices that they may receive
- Check rosters and eligibility systems to ensure that they are able to bill Medicaid fee-for-service (FFS) for residents being disenrolled from MLTC and to identify potential problems quickly
- Communicate with plans that directly collect Net Available Monthly Income (NAMI) payments to ensure that NAMI is paid to the appropriate entity when a member is disenrolled.
Please keep in mind that this change does NOT “carve out” the nursing home benefit from MLTC, but rather limits the partially capitated MLTC plan nursing home benefit to three months for individuals who are designated as long-stay residents. The terminology used by DOH in describing the population impacted by the change is now “Long Term Nursing Home Stay” and no longer “permanent placement.” Unless seeking to return to the community, LTNHS members will be disenrolled from partially capitated MLTC plans and revert to FFS Medicaid after a three-month period. The three-month clock begins on the first day of the month following the date on which the individual is designated to be in a LTNHS. These changes do not apply to residents who may be in a Program of All-Inclusive Care for the Elderly (PACE) or a Medicaid Advantage Plus (MAP) plan.
We will provide additional information as it becomes available, but please let us know if you have questions or concerns.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841