Update on Guidance Rescinding Telehealth/Telephonic Assessments for Authorization of Medicaid CBLTSS
The Department of Health (DOH) issued guidance last week requiring an immediate move to in-person assessments for authorization of Medicaid Community-Based Long-Term Services and Supports (CBLTSS). In response to pushback from Managed Long Term Care (MLTC) plans, DOH has moved the compliance date to Aug. 13th. They also clarified some questions regarding members who may refuse in-person assessments.
Clarifications include the following:
- In order to accommodate a previously scheduled telehealth or telephonic Community Health Assessment (CHA), or to transition assessor staff scheduling, Medicaid Managed Care Plans (MMCPs) and Local Departments of Social Services (LDSSs) may continue to use telehealth or telephonic CHAs until Aug. 13, 2021 and should continue to document in the CHA when assessments are conducted via these modalities. After Aug. 13, 2021, MMCPs or LDSSs will not be permitted to conduct further telehealth or telephonic CHAs, and a “hybrid” approach of in-person and telehealth/telephonic CHAs will not be permitted.
- MMCPs and LDSSs should make reasonable efforts to complete periodic reassessments per the schedule detailed in the guidance. If an enrollee refuses the periodic reassessment, the refusal should be noted in the enrollee’s case file as services continue. The Department will provide future guidance on the timing of resumption of regular rules relating to reassessment refusals.
- The program rules requiring a CHA to begin provision of CBLTSS in the Medicaid program, and when applicable enrollment into an MLTC plan, have not changed.
Meeting discussion clarified that individuals entering MLTC may not be admitted if they refuse an in-person initial assessment. DOH's rationale is that if they are willing to allow personal care services (PCS) in the home, they should be willing to have a nurse provide an in-person assessment.
DOH explained that the move to in-person assessments is to facilitate a DOH study to see if in-person and telehealth assessments are on par with one another. The study is being carried out in preparation for the new Independent Assessor process, which is scheduled to be initiated on Oct. 1st. LeadingAge NY is currently looking into what DOH will specifically roll out on that start date.
The guidance calls for reassessments to be carried out in stages, with the first batch to be completed by Sept. 30th. DOH asks that plans communicate any difficulty in getting this done. They are willing to work with plans to facilitate compliance.
Please feel free to contact LeadingAge NY with any questions or concerns. We will keep members updated on the Independent Assessor rollout as well.
Contact: Karen Lipson, klipson@leadingageny.org, or Meg Everett, meverett@leadingageny.org. Both can be reached at 518-867-8383.