Community Health Choices Waiver MLTSS Advisory Subcommittee April
Community Health. Choices Waiver MLTSS Advisory Subcommittee April 6, 2016 Virginia Brown, OLTL 11/6/2020 1
Current LTSS System • Five home and community-based waivers serving discreet target populations • Some individuals receive physical health benefits through Health. Choices, others do not • Individuals residing in nursing facilities carved out of Health. Choices • Very little coordination of LTSS and Medicaid/Medicare benefits 11/6/2020 2
CHC Waivers v Medicaid – Concurrent 1915 (b) and 1915 (c) Waivers • 1915 (b) waiver allows for the use of managed care in the Medicaid program through MCOs and makes the program mandatory for eligible participants to receive services. • 1915 (c) waiver allows the provision of home and communitybased services to people who would otherwise need institutional care. v Medicare – Section 1859 • Allows Medicare Advantage plans to create specialty plans targeted to special needs individuals, including those who are dually enrolled in Medicare and Medicaid. Under this authority, states can use their D-SNP contracts (MIPPA agreements) to link Medicare services to Medicaid MLTSS programs. 11/6/2020 3
CHC 1915(b) Waiver v Medicaid – Section 1915 (b) Waiver Main Application • Requests authority for Pennsylvania to mandate participants in CHC to obtain services through MCO’s. • Waiver participants in the CHC regions may only receive services through the CHC-MCO. v Populations included in the 1915(b) Waiver Application • Adults age 21 or older who require Medicaid LTSS (whether in the community or in private or county nursing facilities) because they need the level of care provided by a nursing facility. • Dual eligibles age 21 or older whether or not they need or receive LTSS. 11/6/2020 4
CHC 1915(c) Waiver • The 1915(c) waiver allows for the delivery of Long-Term Services and Supports (LTSS) in the home and community. • During the three-year phased implementation of Community Health. Choices (CHC), Pennsylvania will operate a 1915(c) CHC waiver in CHC regions, while continuing to operate existing 1915(c) waivers in fee-for-service regions. • The OBRA waiver will continue to operate across the state o individuals who are currently in the OBRA waiver who will not qualify for CHC o 18 through 20 year olds who require certain LTSS that are not offered through the Medicaid State Plan. 11/6/2020 5
CHC 1915(c) Waiver • HCBS Settings Final Rule o States that had existing 1915(c) HCBS waivers in March 2014 have until March 2019 to bring them into full compliance with the federal 2014 HCBS regulation. New HCBS waivers adopted after March 2014 must comply with the regulation immediately. o CHC waiver-specific transition plan will be included in the CHC 1915(c) application. o CHC-MCOs are responsible for ensuring compliance with OLTL policies related to the HCBS Final Rule. 11/6/2020 6
CHC 1915(c) Waiver Ø The COMMCARE Waiver has been selected as the vehicle for CHC. COMMCARE is the Waiver for Individuals with Traumatic Brain Injury (TBI) for the following reasons: • It is the smallest OLTL waiver, with the fewest people to transition. • The Nursing Facility level-of-care eligibility criteria aligns with CHC and other OLTL waivers, easing transition (immediate reassessments not necessary). • Similar to Independence waiver, which can serve as transitional waiver for COMMCARE participants. • Expiration date allows for a longer transition period than other existing waivers. Ø As part of this transition, two services will need to be added to Independence to make the packages equivalent: Residential Habilitation and Structured Day Habilitation. The transitions involved in this change should be seamless to program participants. 11/6/2020 7
Starting 1/1/2017 OLTL Waivers Available • • CHC OBRA • • Aging Attendant Care Independence OBRA
Starting 1/1/2018 OLTL Waivers Available • • CHC OBRA Aging Attendant Care Independence OBRA
Starting 1/1/2019 OLTL Waivers Available • • CHC OBRA
Timeline • April 2, 2016 – amendments published in PA Bulletin. Notification will also be distributed to DHS stakeholders. • April 23, 2016 – 1915(b)/(c) waiver application published in PA Bulletin and distributed to DHS stakeholders • May 1, 2016 – Deadline for public comment on amendments • May 23, 2016 – Deadline for public comment on CHC waivers • June 30, 2016 – Draft CHC waiver applications submitted to CMS to begin approval process • January 1, 2017 – Anticipated effective date for CHC waivers 11/6/2020 11
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