HARRISBURG ---The Pennsylvania Health Care Association/Center for Assisted Living Management today pledged to work closely with Gov. Tom Wolf as his administration seeks to explore managed long-term care in the commonwealth to assure that the state’s seniors have continued access to high-quality care.
“PHCA supports the governor’s commitment to improve the long-term care system,” said PHCA/CALM CEO Stuart H. Shapiro, M.D. “But, not surprisingly, we have some concerns with the document as drafted. We appreciate the opportunity to comment on the plan and look forward to working collaboratively and constructively as a partner with the administration and entire General Assembly in improving the long-term and post-acute care systems in Pennsylvania.”
PHCA/CALM submitted its formal comments today to the Department of Human Services’ (DHS) Managed Long-Term Services and Supports (MLTSS) Discussion Document.
Although he believes the state’s abbreviated planning period, from July to October, to develop a request for proposal (RFP) is extremely aggressive, Dr. Shapiro said PHCA nonetheless is prepared to move expeditiously into planning for and implementing Phase 1 to help design several small geographically limited projects that are focused on participant outcomes. That means exploring multiple projects that utilize different models of payment, organizational structure, risk and care management.
“We suggest that models not be limited to just those that drive scarce taxpayer dollars to large insurance companies,” Dr. Shapiro said. “We need to test various MLTSS models to determine whether care improvements and savings truly can be expected, and which ones work best for certain populations, before we even consider expanding any programs statewide. For example, provider-driven models such as primary care case management, health homes and Accountable Care Organizations (ACOs) may offer innovations that are as effective for consumers and save the taxpayer money.”
Dr. Shapiro pointed out that the Pennsylvania Long-Term Care Commission (LTCC), on which he served, recommended that the state develop and implement MLTSS as demonstration projects initially and that several different models be tested and proven effective before MLTSS advanced beyond a pilot. For that reason, Dr. Shapiro indicated, any RFP should be limited simply to getting a couple of programs up and running, initially.
“We need to develop Pennsylvania-specific data that show the elderly and disability communities are not hurt by MLTSS and that any program the state implements will actually protect consumers and save the state money before dismantling the current system we have,” Dr. Shapiro said.
Because this proposal represents such a landmark change for long-term care in Pennsylvania, the state must spend the necessary time to design the pilots correctly and evaluate the data thoroughly before moving to statewide implementation. That is why, Dr. Shapiro added: “It is essential that the initial RFP not lock the commonwealth, and other stakeholders, into the future by the decisions being made at the beginning. There is no way we can know today what will be needed in 2018 or 2019.”
Among the suggestions PHCA/CALM made in its submission to DHS:
- Obtain Pennsylvania-specific data to evaluate which programs or models are most effective in ensuring the best outcomes for consumers as well as the optimal cost effectiveness for the commonwealth.
- Study, understand and benefit from programs being implemented in other states. More than 25 states have implemented some form of managed long-term care, yet the states’ systems are very different and have had varying degrees of success in assuring access to care, saving money and managing the long-term care population.
- Take the time to assess whether any segments of Pennsylvania’s population would be better served in an alternative model, or even held out of MLTSS altogether, if the evaluation does not show significant benefits.
- Look carefully at the impact of various Centers for Medicare and Medicaid Services (CMS) programs like bundled payment models to ensure better coordination and outcomes, ACOs and other innovations led by CMS’s Center for Medicare and Medicaid Innovation (CMMI).
- Evaluate and incorporate into Pennsylvania’s program the comprehensive CMS proposed rule that was just released for Medicare and Medicaid managed care. The rule includes a number of protections for consumers and should be studied with the RFP process and examined for benefits in the state’s current system.
