Common Elements of Comments: NHTD/TBI Transition Plan Waiver Services to Managed Care

September, 14 2016

The Transition to Managed Care

  • Waiver participants are a discreet population and should not be integrated into managed care

Service Coordination and Care Management

  • Define scope and nature of Service Coordination
  • Conflict of Interest as related to Service Coordination and Care Management
  • Specify scope, frequency, and intensity of services to be included in MLTC/MMC/CFCO
  • Streamline administration of services
  • Clarify service approval process
  • Home visits should be an option in the transition plan
  • Transportation


  • UAS – findings of current examinations of the tool should be included in the plan and a system for reassessment for those determined ineligible should be established
  • UAS and individuals with cognitive deficits

Stakeholder Workgroups

  • Convening Transition Workgroup meetings
  • Stakeholder involvement – mailings, publish public comments, local meetings


  • Access to services/RRDC and MLTC administrative processes
  • CFCO’s impact on waiver services
  • Clarification of the eligibility for CFCO
  • Definition of IADLs/PCA Scope
  • Cueing and Supervision under the CDPAP
  • Exceeding soft limits due to medical necessity
  • Referrals and Needs and Service Assessments
  • Network Capacity and Plan Readiness
  • Notification Requirements
  • Information on implementation of CFCO should be made available to providers, managed care plans & consumers
  • HCSS vs. supervision and cueing/personal care
  • Recommends expanding the definitions and limitations of CTS, personal care (i.e. supervision and/or cueing) and IADLs


  • Capitated payments
  • Cost of community based care vs. institutionalization
  • Overtime rule for homecare workers


  • Housing/risk of institutionalization after the transition

Regional Resource Development Centers (RRDC's)

  • Timeline for awarding contracts to the RRDCs
  • Maintaining RRDCs’ role
  • RRDCs given a “consultative role” & are limited in their ability to advocate
  • RRDC assessment process

MLTC/MMC Referral and Services

  • Referral process
  • Auto-assignment process into MLTC/MMC products
  • Person Centered Planning under Managed Care/Conflict Free SC & Care Management
  • Not enough detail on scope of waiver services offered through MLTC
  • Strongly supports the two-year continuity of care provision
  • Dual eligible & spenddown requirements as related to access to services
  • Requests an eligibility crosswalk for MMC/MLTC/CFCO/FIDA and NHTD/TBI Waivers
  • Notification should be sent to service providers of a participant changing MLTC plans

HCBS Regulation Requirements

  • SDP settings and heightened scrutiny process


  • Need for brain injury training for staff
  • Educating managed care plans
  • Training for staff

Participant Rights and Protections

  • Protections for current participants
  • Participants’ rights and appeals process
  • Monitoring, tracking and investigations of instances of neglect and abuse
  • Monitoring and tracking system for participant outcomes after transition into MLTC/MMC

Provider Qualifications

  • Grandfathering of SC, ILST, PBIS, CIC & SDP staff/agencies
  • ILST qualifications in the most recent Provider Qualifications Chart is more stringent & requests it be modified


  • Contracts with MLTC & MMC plans
  • Existing and new providers of CFCO services during and after the two-year continuity of care period
  • Process of current waiver participants’ transition into MLTC and eligibility requirements


  • Face-to-face visits every 6 months with the SC and/or case manager is too long
  • Questions regarding 6 month reassessment of service needs, conflict free evaluation and enrollment centers, training/qualifications of care managers and cost to MCOs

Out of State Placements

  • Transitioning out-of-state institutionalized individuals back to NY