Commonwealth Coordinated Care Update

Member facilities located in the Tidewater area of the Commonwealth are reporting the receipt of letters addressed to their residents announcing that they will soon be enrolled in one of three Medicare-Medicaid Plans (MMPs) and that their long term care services and supports will transfer to the Commonwealth Coordinated Care (CCC) program effective July 1, 2014.  The receipt of these passive enrollment 60-day letters is raising a number of questions from VHCA member facilities as they struggle with how to respond to questions from their residents.

The enrollee’s decision to change MMPs or opt-out of the CCC rests with them or their authorized representative.  We have communicated to DMAS that nursing facilities often assist residents in an informal capacity when they have no family or other legally recognized individual to act on their behalf.  Additionally, there are times when individuals within provider organizations are appointed as guardians to legally act on behalf of residents who are no longer able to make decisions due to cognitive deficiencies.  All providers, including nursing facilities, need to understand what role they can play in discussing beneficiary participation in the CCC with their patients and residents.

In a written request this week to staff of the Centers for Medicare & Medicaid Services’ Medicare-Medicaid Coordination Office, VHCA requested that CMS work with the Virginia Department of Medical Assistance Services (DMAS) to quickly develop effective and practical guidance for nursing facilities so that they can safely and appropriately respond to questions from residents and their advocates about their CCC participation options.  We asked that this guidance include illustrations and examples to give providers the clarity needed to address this important issue.  In the request, we expressed concerns that absent any involvement on the part of nursing facility staff, the right and option to change Medicare-Medicaid Plans or to opt-out of the CCC will effectively be removed for a large portion of our resident populations – beneficiaries with impaired cognitive function and limited or no family involvement.  We have received a response indicating that CMS and DMAS will schedule a conference call with providers and VHCA to better understand the issue before developing the requested guidance.

As reported in last week’s CareConnection, meetings between the MMPs, DMAS and nursing facility representatives are continuing.  These meetings are intended to provide an opportunity for the three MMPs to identify common approaches to a range of operational issues within nursing facilities.  Last week, discussions with the three MMPs produced a common approach related to authorization and reauthorizations requirements related to nursing facility admissions for both skilled and long stay services.  These processes have been finalized and documented and are now posted on the DMAS website.  Additionally, DMAS has indicated that this same information will be communicated to all providers and MMPs via an upcoming Medicaid Memo.

Discussions are ongoing with respect to a number of care coordination-related issues.  A key issue that remains under discussion with the three MMPs focuses on performance and quality measurement under the CCC.  DMAS recently provided VHCA with a matrix reflecting performance measures that may impact nursing facilities.  According to DMAS, these measures are not expected to play a major role in the relationship between nursing facilities and MMPs in 2014 but will likely receive significant attention beginning in 2015.  As reported in an April CareConnection article, VHCA members are encouraged to participate in claims testing with all three MMPs.  Members are reminded that the product and outcome of the workgroup meetings discussed above will be reflected in modifications to all three MMP Provider Manuals.  

Within the next week, we anticipate the announcement of several VHCA-sponsored education and training opportunities for members as preparations continue for the launch of the Commonwealth Coordinated Care program.