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LeadingAge NY Calls for Investment in Long Term Care and Aging Services at Medicaid Waiver Forum

LeadingAge NY called for a renewed emphasis on long term care and aging services at the annual public forum on New York's 1115 Waiver last week. The forum provided an opportunity for stakeholders to provide feedback on the existing 1115 Waiver, known as the Medicaid Redesign Team (MRT) Waiver, as well as the proposed New York Health Equity Reform (NYHER) amendment.

LeadingAge NY noted the growing population of older adults in New York State and the shrinking percentage of working-age adults to care for them and highlighted the lack of investment in long term care and aging services under the prior MRT Waiver and its companion Delivery System Reform Incentive Payment (DSRIP) program. Only 1.4 percent of DSRIP funds were invested in long term care. It also pointed out that gains in access to home and community-based services under the Managed Long Term Care (MLTC) program are currently threatened by workforce shortages, flawed rate-setting policies for MLTC, and the recently launched Independent Assessment process.

LeadingAge NY urged the State to avoid repeating the same mistakes under the new proposed NYHER amendment submitted in early September. It pointed out that the NYHER amendment, which would invest $13.5 billion over five years in the State's health care delivery system and social care networks, appears to once again bypass older adults and the providers that serve them. LeadingAge NY reiterated its concerns, previously expressed in comments on the amendment concept paper and draft waiver amendment, that the majority of the funds under the amendment flow through advanced Value-Based Payment (VBP) arrangements. These arrangements typically do not cover populations dually eligible for Medicare and Medicaid and typically do not benefit long term care and aging services providers. In fact, the Department of Health (DOH) has stopped supporting VBP for the partially capitated MLTC plans that enroll the vast majority of New York's older adults receiving long term care services covered by Medicaid.

Specifically, the amendment would create regional planning entities, known as Health Equity Regional Organizations (HEROs), to develop regional plans to advance health equity and address the needs of vulnerable populations through VBP. The amendment would also support the creation of Social Determinants of Health Networks (SDHNs), networks of community-based organizations that enter into value-based contracts with managed care plans to address the social care needs of enrolled members. Funds flowing through the waiver would be allocated as follows:

  • Health Equity Focused Redesign: $8.7 billion, including:
    • $6.8 billion for Advanced VBP Models;
    • $1.2 billion for HEROs and SDHNs;
    • $748 million for criminal justice-involved populations;
  • Transitional Housing: $1.6 billion (to be distributed through a pool consisting of proceeds of VBP arrangements and waiver dollars);
  • System Redesign and Workforce: $3 billion, including:
    • $1.5 billion for a COVID-19 unwind pool for financially distressed hospitals and nursing homes to be distributed through managed care organizations via VBP arrangements;
    • $1.5 billion for workforce funding to be distributed to Workforce Investment Organizations (WIOs), which would have an expanded role in workforce development across the health care continuum;
  • Digital Health and Telehealth: $300 million to be distributed through an Equitable Virtual Access Fund for development of virtual health infrastructure by safety net providers.

In its remarks, LeadingAge NY encouraged DOH to work with the association and its members to develop VBP arrangements tailored for providers that serve a dually eligible population.

The slides and a recording of the forum will be posted here. The proposed waiver amendment is here, and new Frequently Asked Questions (FAQs) are here.

LeadingAge NY will be submitting comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed amendment. Comments are due on Oct. 19th and can be submitted here. Members are encouraged to share their ideas and their comments with Karen Lipson at klipson@leadingageny.org.

Contact: Karen Lipson, klipson@leadingageny.org