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LeadingAge NY Highlights Need for Dedicated Investment in Aging Services in 1115 Waiver Comments

LeadingAge NY submitted written comments on the State's proposed $13.5 billion waiver request, pointing out that the waiver fails to address the needs of older adults and the long term care providers that serve them. Following up on oral comments presented at the Department of Health's (DOH) May 3rd hearing, the written comments noted that the waiver's reliance on advanced value-based payment (VBP) arrangements as the driver of funding will likely result in minimal investment in long term care and services for older adults. Because health coverage for older adults is bifurcated between Medicare and Medicaid, it is challenging to implement VBP arrangements that combine Medicare services and Medicaid long term care services.

Instead, our comments called for targeted investments of waiver funding in initiatives designed for older adults and the providers that serve them, including:

  • Inclusion of area agencies on aging, long term care and aging services providers, and Managed Long Term Care (MLTC) and Program of All-Inclusive Care for the Elderly (PACE) plans in the governance structure of the regional planning entities that drive much of the work under the waiver, known as Health Equity Regional Organizations (HEROs);
  • Inclusion of long term care and aging services providers in social determinants of health (SDH) networks created under the waiver to engage in contracting for social care services with managed care plans;
  • Funding for VBP arrangements tailored for MLTC, PACE programs, and long term care providers, including nursing homes;
  • Investments in innovative value-based models of workforce development and enhanced compensation for long term care staff;
  • Investments in SDH initiatives that are targeted for older adults, do not duplicate or disrupt existing services, and enable MLTC plans and PACE programs to contract with SDH networks on flexible terms that do not require advanced VBP arrangements;
  • A continued focus by the Workforce Investment Organizations (WIOs) on long term care workforce development, an emphasis on career ladders within long term care settings rather than diverting entry-level long term care staff to positions as community health workers, and cross-training of long term care aides to enable work across long term care settings;
  • Support for long term care workforce development initiatives outside of the WIOs, including provider partnerships with high schools, community colleges, and four-year degree programs to build the long term care workforce;
  • Investment in resident assistant or service coordination in affordable senior housing;
  • Investment in the Assisted Living Program as an alternative to nursing home care;
  • Investment in the operating expenses of innovative nursing home models, such as Green House, small house, restorative care, palliative care, and person-centered dementia care; and
  • A modification of the nursing home telehealth investment proposed in the draft waiver to align with needs.

An article summarizing the waiver is available here. A recording of the waiver hearing is available here, and the DOH slides from the hearing are here. LeadingAge NY's statement in the hearing is here.

LeadingAge NY will keep members apprised as waiver discussions progress.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8838