Permanently Placed Nursing Home Residents and MLTC Enrollment
The Department of Health (DOH) reports that implementation of the provision in the recently enacted state budget that limits Managed Long Term Care (MLTC) enrollment to three months after a nursing home resident has been deemed permanently placed will begin when the current discussions with the Centers for Medicare and Medicaid Services (CMS) are complete. DOH had signaled that nursing home residents not enrolled in MLTC would no longer be required to join a plan starting in early May. At this point, the date of this change is not known, and plans and providers should continue to follow the rules and procedures in place prior to April 1st until notified by DOH.
The enacted budget limits Single Capitated MLTC Plan enrollment to three months for permanent nursing home residents. This change does not impact Programs of All-Inclusive Care for the Elderly (PACE), Fully Integrated Duals Advantage (FIDA), Medicaid Advantage Plus (MAP), or Mainstream Medicaid Managed Care. DOH envisions implementing the transition in a three-prong approach, subject to CMS approvals:
- Starting on a date to be announced by DOH, dually eligible Medicaid beneficiaries who are not enrolled in MLTC and who are “permanently placed” will not be required to enroll into MLTC and will be covered by fee-for-service (FFS) Medicaid from the start;
- Medicaid beneficiaries who are enrolled in MLTC and permanently entering a nursing home will remain enrolled in MLTC for the first three months, then disenroll and revert to FFS;
- Those enrolled in MLTC who were permanently placed prior to April 1, 2018 will revert to FFS beginning in July 2018, pending approval of the technical amendment to the 1115 Medicaid Waiver that the State has submitted to CMS. DOH expects such transfers to begin in July, but to possibly be staged over the course of several months.
The change would not alter the MLTC nursing home benefit for temporary nursing home stays or the need for providers and plans to assist residents desiring to return to the community to do so.
In late April, MLTC enrollees received a letter from the State that contained some incorrect information regarding the upcoming change that created some confusion. DOH intends to send a clarification letter shortly.
DOH has reactivated the advisory group that assisted in transitioning the nursing home benefit into MLTC, and meetings to discuss the details of the new transition have begun. LeadingAge NY is represented on the group, and we invite plan and provider members to share any concerns with us and DOH so that they can be addressed as quickly as possible. The DOH notice addressing the letters sent to enrollees is copied below. The Department has agreed to share information being sent to MLTC enrollees on this topic with plans and providers prior to their issuance.
Contact: Darius Kirstein, firstname.lastname@example.org, 518-867-8841
DOH Notice sent May 8th:
This is to inform you that some Managed Long Term Care enrollees received a notification from the New York State Department of Health that contained incorrect information. The letter contained information indicating that the MLTC enrollees would have a change in nursing home benefits on May 26, 2018. Please note that enrollees should disregard that letter, as MLTC nursing home benefits will remain unchanged at this time. The Department will be sending a clarification to those enrollees in the next few weeks to apologize and retract the information, and will provide contact information for any questions.
Further, please note that the mandated enrollment of newly identified permanently placed dual eligible individuals into MLTC partial capitation plans will continue until further notice from the Department.