A: Enrollment updates can be found on the DOH website:
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1 ENROLLMENT Q1: Please clarify how many Nassau/Suffolk members remain on Guildnet and Elderplan rosters as of June 1, 2017, and provide monthly updates until the transition is complete. A: Enrollment updates can be found on the DOH website: Q2: Please clarify timing and implementation approach of auto assignment of remaining Guildnet/Elderplan members that have not transferred, if applicable. A: There is no auto assignment at this time. COMMUNICATION/MESSAGING: Q3: Has there been any written communication to transitioning members to let them know they will not lose services if they do not pick a plan by June 1? A: Yes, DOH has provided written communication to all affected GuildNet members clarifying they are not required to transfer to a new plan by June 1 st and will continue to receive services from GuildNet until a transfer can be completed to a new plan. Q4: Are those being advised to select FIDA also being notified that there is no continuity of care provision if member then opts out of FIDA and returns to MLTC? A: NYMC is informing members of all options and is NOT advising to select FIDA. When the GuildNet or Elderplan member calls NYMC, FIDA is identified as one of the MLTC plan options. If FIDA is selected then the consumer is transferred to the FIDA call center representative for more detailed information on the process to transfer to a FIDA plan. POLICY Q5: Plans may have only capacity to assess existing members and may not have capacity to assess an influx of potential new members. What should plans communicate to potential new LI members? A: DOH understands and appreciates the capacity issues that have been created by these transfers. The message to potential new members should be an affirmative one - that the plan is working to schedule an assessment as soon as possible. Q6: Will DOH give plans access to member UASs conducted prior to effective date, including any assessment done on behalf of the plan? A: Plans are currently able to see previous UASs via UASNY system.
2 Q7: Can DOH confirm whether MLTC plans seeking to withdraw from a service area must maintain their members services until those members enroll in a new plan. A: Before approval is given, all Plans seeking to leave a service area would have to maintain members services until the members transfer to a new plan. Q8: How is DOH determining the membership in question? Plans are finding that other ElderPlan/GuildNet members are on their Plan that the State isn t questioning. A: DOH is just looking at Nassau, Suffolk and Westchester members for GuildNet and Suffolk members for Elderplan. Any members not included within that scope at this time on the confirmation sheets files provided by DOH should be added and noted when sent back to DOH for validation. Q9: Will DOH perform an analysis of the overall network capacity for Nassau and Suffolk? A: DOH is monitoring network capacity on an ongoing basis. Q10: If the required timeframe of 30 days to assess a potential member is exceeded by an MLTCP, due to the temporary increase in the demand for assessments in certain areas that cannot be accommodated by the current MLTCP UAS Nursing staff within the allotted timeframe, will the MLTCP be subject to a penalty? A: DOH understands and appreciates the capacity issues that have been created by these transfers. DOH will strongly consider the conditions created by the current service area reduction activities in Nassau, Suffolk, and Westchester counties by GuildNet and Elderplan when determining whether any action is appropriate for non-compliance with assessment timeframe requirements for enrollees and potential enrollees. Q11: Although the letter included a June 1 transition date, it did not explicitly detail the process for the selection and transition to an alternate MLTC, and offer contingencies in the event that the date could not be met. As such, MLTC members are concerned whether they will have enough time to make their selection and go through the assessment process. This has been intensifying since March when the announcement was first made. What is DOH s direction on the timeframes and how has DOH been monitoring progress of the transition? A: DOH has informed GuildNet and Elderplan that they must continue to provide services to their respective members until their members transfer to another plan. Q12: Members are being advised that they can file a Fair Hearing after enrolling if their hours are cut. This is producing additional administrative burden on plans enrolling these transitioned MLTC members. What is DOH guidance on how to address? A: According to Medicaid regulations, members can file a Fair Hearing if, after enrollment, the plan decreases the initially authorized number of hours or the member requests an increase in hours and the plan denies the request. Q13: What is DOH guidance to the service area reduction MLTCs and Maximus with respect to advising transitioning members about selection of FIDA? Transitioning members are reporting that making the
3 FIDA selection has allowed them to expedite enrollment into another plan, and that they will be likely be returning to MLTC in a short time period. A: DOH has not furnished guidance regarding this; however, FIDA remains an option for all MLTC members in FIDA regions. Q14: How is DOH monitoring that transitioning members are receiving the appropriate level of education with respect to choosing FIDA as an alternative to Original Medicare or a Medicare Advantage plan? How are we ensuring that transitioning members who may have retirement plan health coverage are not inadvertently being enrolled in FIDA? A: DOH is unable to monitor members free choices into Medicare products. DOH is working with NYMC on an ongoing basis to ensure that transitioning members receive clear education on plan options. Members are not referred to FIDA unless an interest in FIDA is expressed. Q15: While the Department is considering whether to implement a 90-day continuity of care requirement, how should MLTC plans proceed with applying any continuity of care? Additionally, what instruction has been given to the ALJs regarding the Department s position? A: As of the issuance of this guidance, the Department has not issued a 90-day transitional care requirement for these members. The Department will be reaching out to ALJs with training regarding this service area reduction in Nassau, Suffolk, and Westchester counties. RISK SCORES Q16: Each month, can DOH release to each new health plan the proposed member-level risk scores of the newly transitioned LI members for comparison to the current risk scores? A: Yes, this will be included on validation sheets sent by DOH. Q17: Is the Department still intending to recalculate the MLTC Plans risks scores as of July 1 and October 1 to include the new member cohort? A: Yes, the Department will update risk scores with new transferred members for July 1 and October 1. Additional updates will be added if necessary. Q18: Will the risk score for these members be updated or is a member shift between plans? A: The risk score will be updated for the July update. Q19: Please clarify the specific methodology for adjusting plan risk scores effective 7/1/2017 and 10/1/2017. DOH states the adjustment will be retroactive to the member s enrollment date. Please clarify how DOH will pay plan s retroactively to enrollment date if the risk score is adjusted effective July, 1,2017 and October 1,2017. A: The risk score will be adjusted to account for members back to their original effective date. DOH is currently in the process of developing a calculation method for this with Mercer.
4 Q20: How often will the rates be updated via risk score change, and will rate updates be retroactive? Please provide any available details regarding the process to review risk scores off-cycle to ensure there is an accurate/timely snapshot of plan membership. A: The Department will update risk scores with new members for July 1 and October 1. Additional updates will be added if necessary. The risk score will be calculated retroactive to the new members start date. Actual payment rates will not be retroactive, as the risk score should reflect the additional months for the member. RATE SETTING Q21: Would you consider splitting Region 1 into two separate regions, one for NYC (and possibly Westchester) and one for Nassau and Suffolk? The market dynamics are different. A: DOH believes that cost report data, encounter data and risk scores will appropriately reflect the LI population in the calculation of rates. Q22: Given the substantial variance in risk and cost, how is DOH distinguishing between community and NHT and how will the plan identify the cases? A: Plans will receive monthly files to verify whether a member is community or NH. Q23: How soon after the July 1 and October 1 rate recalculation does the Department anticipate providing the actual rate adjustment? A: Rate calculations will be expedited and loaded as soon as DOB approval is obtained. Q24: DOH has indicated that it would consider making plans whole for Guildnet / Elderplan transfers in the event the risk score adjustment does not cover the cost of these members. How/when will DOH determine when a payment adjustment is warranted? How will this be funded? Will there be a premium reduction to fund these payments? A: DOH is discussing possible methods for this with Mercer. Q25: Will you consider other factors beyond risk score to calculate the cost of high cost/need patients such as number of HHA hours? A: Risk score will be utilized to address rate adjustments. DOH is discussing other possible methods for making plans whole with Mercer.
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