VHCA Calls for CCC Improvements Prior to Any Expansion of Managed Medicaid LTC

The Virginia Health Care Associations (VHCA) cautions that expanding the managed Medicaid long term services and supports (MLTSS) program, including nursing facility services, should not proceed prior to the successful resolution of the many issues within the existing Commonwealth Coordinated Care (CCC) program, the association advised in comments submitted to the Department of Medical Assistance Services (DMAS) on June 16.

VHCA submitted its comments in response to a request for them from DMAS as it announced plans for a two-phase expansion of MLTSS requiring participation of the CCC-eligible population on the Medicaid side.  (Participation with a Medicaid Managed Plan (MMP) cannot be mandated on the Medicare side.) Cindi Jones, DMAS Director has stated that the agency intends to mandate Medicaid for CCC-eligibles no earlier than July 1, 2016. 

DMAS has also articulated its 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.  DMAS has not yet provided timeline for this second phase, but it would be after the mandatory Medicaid coverage in the existing CCC program, possibly by July 2017.

In the comments to DMAS, VHCA acknowledged the that collaboration among DMAS, the managed care plans, and the nursing facility providers has been integral in the identification and potential resolution of issues experienced in the CCC program.  VHCA noted that member facilities have not seen a meaningful impact of care coordination under the CCC for nursing facility patients and residents and that we appreciate the inclusion of nursing facility input into the process of better understanding and defining the role of the care coordinator.

VHCA raised several issues about the MLTSS program goals and potential for flexibility to bridge the differences between conflicting Medicare and Medicaid program rules and policies.  VHCA also provided specific comments on questions DMAS posed about expanding the program.  While it remains to be seen whether these comments will help shape the direction of the program, VHCA will continue to press for inclusion of the many important tenants of any care model including nursing facility residents outlined in the comments.  To read VHCA’s comments in their entirety, click here.