LTSS Continuity of Care Period Ends June 30th in Phase 3 Counties
The 180-day continuity of care period for Community Health Choices (CHC) partcipants getting long-term services and supports (LTSS) at home ends on June 30, 2020. After that date, CHC plans can change participants’ LTSS providers and CHC plans can terminate, reduce, or change the type and amount of LTSS partcipants receive. This assumes that the state has lifted the COVID 19 emergency by June 30th. If the state of emergency remains in place on July 1, CHC plans cannot reduce LTSS.
As a reminder, an InterRAI assessment and the person-centered service plan (PCSP) must be completed before a CHC plan can change any home and community-based service. The PCSP is an intensely collaborative process and plan involving the CHC participant, the service coordinator and anyone else the participant wants; a process that identifies the partcipants’ needs, preferences, and goals. The PCSP identifies the type and amount of services to be provided, such as Personal Assistance Services, and includes information about any informal supports (such as unpaid family caregivers) available to help the participant. The participant is supposed to sign the PCSP and receive a copy.
CHC plans are required to send their members written notice of reductions and denials of services and supports. If, after June 30th, a CHC plan acts to reduce, change, or end a participant’s in-home LTSS, the CHC plan must send the member a written notice 10 days before the change takes place. These notices must detail the reasons for the shift. Justifications like “you have been assessed as not needing these services” or “the services are not medically necessary” without any further explanation are insufficient. CHC participants, their family members, or other supports are encouraged to read notices denying or changing services carefully.
Individuals who receive such a notice can appeal the CHC plan’s decision by requesting a grievance. The CHC plan’s written notice will tell the member how to do this. To keep LTSS in place during the appeal process, the member must request a grievance within 10 days of the mail date on the CHC plan’s written notice.
Vigilance from CHC participants, their advocates, and their providers is needed to ensure participants’ needs are met. We strongly encourage CHC participants (or their advocates) to call PHLP’s Helpline at 1-800-274-3258 or email us at email@example.com if they experience issues with the person-centered planning process (including not receiving a copy of the plan), receive a notice that doesn’t give adequate detail, or want advice or help with their appeal. Information about appealing a CHC decision can also be found on PHLP’s website.
PHLP Co-Hosts CHC Information Sessions with PATF
PHLP staff partnered with the Pennsylvania Assistive Technology Foundation (PATF) to deliver an exciting series of information sessions about CHC. Between January and April, PHLP and PATF staff delivered three in-person presentations across the greater Philadelphia area and one statewide webinar. Collectively, the presentations and webinar reached nearly 500 people, including CHC participants and their family members, service providers, and representatives from a wide range of community organizations that serve the CHC population.
PATF is a statewide, non-profit organization that helps individuals with disabilities and older Pennsylvanians acquire assistive technology and services. They provide information and assistance about assistive technology, funding resources, and vendors as well as financial education and low-interest loans to assist with purchasing assistive technology.
The training series, which was supported through a generous grant by the HealthSpark Foundation, combined PHLP’s technical knowledge of Medicaid with PATF’s experience with assistive technology. PHLP and PATF staff covered a broad range of topics related to CHC, including:
- Overview of Medicare and Medicaid
- CHC Basics
- How to get Medicaid Home and Community-Based Services (“Waiver” services)
- CHC Benefits, including Waiver services
- CHC Appeals
A recording and other materials from the webinar are available online through PATF’s CHC Toolkit. PHLP offers both in-person and web-based training on a range of Medicaid topics, including CHC. Organizations interested in hosting PHLP for a training session should contact firstname.lastname@example.org or Request a Training through the PHLP website.