Proposal Presented for the Master Plan for Aging (#6)
Disclaimer
Throughout the MPA process, more than 100 proposals were developed thanks in particular to thousands of hours of work by external stakeholders and members of the public. These proposals and the MPA Council commentary are being submitted to the Governor and shared with policymakers and the public to inform policymaking. These proposals represent a starting point for discussion. Further discussion is necessary between relevant state agencies and stakeholders to both refine these proposals and assess which may be appropriate to adopt and implement.
Summary
Recommendation to provide a flexible approach to nursing home capital improvements by a combination of updates to existing regulatory requirements and metrics. The proposal also includes an evaluation of industry interest in developing specialty care units, and a statement of principle regarding grant program utilization.
Justification
Nursing homes, ACFs, and ALRs are heavily reliant on Medicaid and congregate level 3 SSI/SSP reimbursement to sustain operations and maintain physical plants, and existing capital reimbursements may be difficult to access and include limits. Facilities face inadequate financial support for necessary renovations to improve the quality of life and care for residents. Approval of updated reimbursement costs, a reduction in equity contribution from facilities, and the creation of a new reimbursement methodology would make long-term care facility capital improvements more flexible and would improve reimbursement for cost of care.
Full Proposal
Provide a flexible approach to nursing home capital improvements by:
- Removing long-standing 25% equity contribution requirement for nursing home capital projects and lowering that contribution to 10% which aligns with all other Article 28 projects and recognizes fiscal constraints for the nursing home providers.
- Direct DOH, in consultation with subject matter experts, to review and create an updated construction costs reimbursement cap methodology. The cost reimbursement cap was last updated in 2007. The Department could create a permanent methodology to update these caps in a way that appropriately reflects health care cost inflation.
- Update the decades old regional nursing home need methodology. In addition to updating the methodology based on current occupancy rates and population statistics, the updated need methodology would consider other factors including regional workforce statistics, public transportation availability, community design and zoning that enhances proximity and access to public spaces, services and other amenities and distances between other nursing homes in a geographical area. Since long-term care needs do not exist in a vacuum, any new nursing home need methodology must be done in conjunction with updating the need methodologies for other long-term care facility and service types, including the demand for and availability of home care, hospice care, adult care and assisted living facilities. Consider long-term care needs as a whole and not as individual spokes in the long-term care continuum.
- Require the Department to issue a request for information/solicitation of interest for nursing homes interested in establishing specialty care units, which will recognize and address the problem of discharging patients in need of skilled nursing home care that require additional behavioral health intervention and difficult to serve patients.
- Amend Public Health Law to account for Department approved capital cost expenses which will impact resident quality of care.
- Prioritize long-term care providers in grant programs.
MPA Council Commentary
Component 3 is categorized as near-term. Components 1, 2, 4, 5, and 6 are categorized as long-term. Implementation steps for components 1, 2 and 4 may include a continued review of Certificate of Need (CON) methodologies to ensure existing processes align with industry needs to maximize quality of care. Changes to Component 2 should take into consideration the availability of other capital funding for nursing homes (e.g., Statewide Health Care Facility Transformation grants). Component 6 is currently being implemented in part at the federal level. Modifications to Medicaid reimbursement methodologies as included in this proposal could have significant fiscal implications for the State and would need to be reviewed in the context of the annual budget process and subject to the availability of resources.