Commonwealth Coordinated Care (CCC) Update

May Enrollment Figures.  As reported previously, the Department of Medical Assistance Services (DMAS) has passively enrolled dual eligibles in Wythe County, Staunton, and the Northern Virginia localities of Loudoun County, Arlington County, Alexandria, and Falls Church for effective coverage July 1, 2015.  Additionally, it appears that a substantial number of nursing facility dual eligibles were determined eligible for the CCC program across the demonstration regions who had previously not been eligible for the program (at least as a nursing facility resident).  It is not yet clear as to why this increase in the eligible population occurred (particularly outside of Northern Virginia) – we have inquired with DMAS as to their understanding of what caused the increase, but we have not yet received their response.

Specifically, the CCC program added 1,013 to the nursing facility eligible population (May compared to April), of which 970 have been enrolled into the program (846 auto-enrolled; 124 opted-in).  Northern Virginia added 404 CCC nursing facility residents (some or all of which would be explained by the additional four localities); the Roanoke region added 168 (some explained by the addition of Wythe County); and, the Charlottesville region added 95 (some explained by the addition of Staunton).  However, Tidewater also saw an increase (130) as did Central (173), with no locality expansions to explain the increase.  Of the 303 additional enrollees in Tidewater and Central VA combined, 85 of them opted-in on their own, so the remaining 218 appear to be newly eligible for the program.  Again, we have inquired with DMAS as to a reason for such an increase in the eligible population.

As with each of the expansions of auto-enrollment that have occurred since the CCC program’s inception, it is after the initial enrollment that the recipients begin to opt-out of the program.  If the most recent expansion is typical, we will likely see a decline in enrollment relative to the May figures as recipients determine their best option.  We reiterate that CCC enrollment is an individual beneficiary’s decision.  To the extent an individual seeks guidance from their care team at a facility, we recommend you stick to program facts and refer the individual to the State Ombudsman (800-552-3402) or other entity for further guidance.

Future Direction of Managed Long Term Care.   VHCA staff and members continue to meet with DMAS and the Medicare/Medicaid Plans (MMPs) to address shortcomings with the CCC program.  This week, VHCA staff and members of the Board met with Secretary Hazel to discuss concerns with the CCC program, in light of the changes DMAS has proposed.  Specifically, DMAS has proposed requiring participation of the CCC-eligible population on the Medicaid side.  In other words, while participation with a MMP cannot be mandated on the Medicare side, DMAS has announced intentions to mandate participation with the MMP on the Medicaid side.  Cindi Jones, DMAS Director has stated that their goal is to mandate Medicaid for CCC-eligibles no earlier than July 1, 2016.  

DMAS further articulated their plan to extend the Medicaid-only program to the remainder of the state (the regions not in the CCC demonstration) as well as the remaining long term care populations except for the Intellectual Disability waiver and Developmental Disability waiver recipients, meaning non-dual long term care recipients in the demonstration regions; and, duals and non-duals in the other areas of the State.  DMAS has not yet articulated a timeline for this second phase, but it would be after the mandatory Medicaid coverage in the existing CCC program.

DMAS has invited VHCA to be a part of the planning process for this change, which we appreciate, but we have already articulated our concern that current shortcomings of the program must be corrected prior to any further expansion, particularly one made by removing a beneficiaries choice of participation in the program.  As far as the second phase of the DMAS-announced plans, we have articulated concern with the managed care model generally, and advocated for flexibility in the model, given the shortcomings identified under CCC.  Obviously, there will be significant discussions over the next several months to determine VHCA’s stance on these announcements going forward.