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Advocacy Home and Community Based Long Term Services and Support Overview

Independent Assessment Entity (IAE)

Update: An RFI has been posted by MassHealth (RFI info below). The deadline to Reply to the RFI is June 28.

Request for Responses (RFR) from EOHHS

Recently the Executive Office of Health & Human Services (EOHHS) released an RFR, looking to award a contract to a Single Assessment Entity. This single entity would conduct clinical evaluations for over 240,000 elderly and disabled individuals across Massachusetts covered by a number of Mass Health funded programs which enable these individuals to continue living independently in the community.

Currently, these evaluations are largely conducted by community-based organization such as Aging Service Access Points (ASAPs) and Independent Living Centers (ILCs). The organizations send nurses to the recipients’ homes at least annually to assess their needs for Long Term Services and Supports (LTSS). They also manage the complicated assessments and approval requirements before submitting them to MassHealth Optum for determination of services. Members may then choose to appeal these determinations with support from the assessments of the community-based nurses.

The programs that will be impacted by this change are Adult Foster Care, Group Adult Foster Care, Personal Care Management, Day Habilitation, Adult Day Health, Senior Care Options, PACE, and OneCare. Advocates across the state strongly oppose this move. EOHHS released this RFR without consulting with any of the providers or consumers who currently utilize these services. The intent is to streamline the on-boarding process and lessen the confusion about where to find services.

Massachusetts has long been the beacon for providing a variety of long-term services and supports that are looked at with envy by many in other states. Now, instead of being an innovative leader, Massachusetts is looking to follow what has been implemented in other states like Pennsylvania, New York, North Carolina and several others with disastrous results. Our colleagues in these other states report that wait times and confusion has increased, incorrect information is provided, and in many cases, services are cut. This is an opportunity for a large private equity firm from out of state or a large healthcare system to take over and medicalize what have been consumer directed and consumer choice programs.

Advocates Response

Tell your legislator to tell EOHHS to work with the consumers using these services and the agencies currently providing them to implement truly innovative and lasting change that will have positive impact and resolve the issues. And please Reply to the RFI by June 28.

As advocates, we are not saying there is not room for improvement and simplification. The LTSS structure in Massachusetts is complex and can be confusing to navigate. Often, the complexities are caused by the contractual regulations set by the very agency, EOHHS, that is now looking to remove all clinical services from community bases agencies and to place them in one large potentially for-profit entity. What we are saying is collaborate with the providers who have been working with these programs for years. Invest in your current system of providers to streamline our procedures, as you have streamlined procedures for this new entity in the RFR. Adding yet another entity in the mix will only be more confusing for those we work with. In addition, this will cause many clinical and administrative staff in these community-based agencies to lose their jobs.

The state has been on the forefront of the No Wrong Door approach with Options Counseling and Mass Options, allowing individuals to contact any ILC or ASAP and receive information on the multitude of options available to them. As community-based providers, we know the individuals we work with daily and the services available to them. Do not take away their choice and options with this change.

EOHHS has slowed the process due to the concerns being raised by all the those impacted, but they do intend on moving forward. As advocates we feel this initiative needs to be stopped. We are asking everyone to reach out to their legislators and tell them what a short-sighted move this is. This major change will totally disrupt over 40 years of services Community-based organizations have been providing and will have no impact on the issues EOHHS is trying to solve.

Initial DignityMA response

The Statewide Personal Assistance Coalition writes to express our deep concern and concerted opposition to the multiple proposed changes now being considered to the Personal Care Attendant (PCA) program.

Two weeks ago, Governor Healey’s budget proposal outlined changes to reduce eligibility considerations—likely resulting in over 6000 people losing these much needed supports to remain in their own homes. This week, EOHHS and the OLTSS announced a released RFP to centralize the entire assessment process and utilize a “one size fits all” tool that has yet to be developed.

As Governor Healey moves Massachusetts to become the leader in utilization of technology and AI, the consideration of human beings is slowly being eroded.  The logic of eliminating services which are provided by a largely female and culturally diverse workforce to a wide variety of people with disabilities who are living in their own homes, and then moving all assessments to determine the need for these services to a central provider who will then utilize “virtual reality” and a cookie cutter approval approach seems to fly in the face of all that has been previously accomplished. 

The Personal Care Attendant program is consumer directed. Those seeking assistance have a say in the services they need, how they are received and a responsibility to ensure that their care needs are being met appropriately.  A uniform assessment that will be applied to all LTSS services, then calculated based on algorithms and data equations will lose the efficacy of face to face contact, in the setting of the person who needs the help. 

A centralized assessment provider will then be expected to offer all choices of care to those individuals that they qualify for community services.  Currently there are multiple providers of every service in every town.  There will be increased bias towards certain providers—those that are typically “shinier” and are operated under the umbrella of a for-profit organization—and the smaller programs will be penalized for their lack of marketing panache.

It was suggested that the change to a central assessment provider will be helpful to the PCMs who struggle to hire nurses and will reduce the administrative burden of managing the required documentation. The current program rates do not allow competitive nursing salaries to be offered, and many programs have hired administrative support to navigate not only the complex tracking of documentation, submission for authorization and changes needed throughout the approval year due to status changes—but also the implementation of the EVV program.  Many questions now exist about the role of any central assessment provider—how will they fare better at recruiting nurses to meet the program expectations, who will then provide all options to the consumers, what will the engagement be with remaining PCMs…and how will it be paid for under the state budget that has recently seen great reductions in all lines of human services.  This will likely create another opportunity to erode the human connection and allow virtual assessment processes to occur.  Through any virtual interaction, you cannot grasp the needs of the individual or their true home environment.  You cannot detect that the person’s incontinence has caused skin breakdown, or soaked the chair that they are sitting in.  You cannot smell that the cat’s litter box hasn’t been emptied or that food is rotting in the garbage that they can’t carry out. 

The PCA frequently falls under scrutiny for fraudulent activities, including billing for services not provided. We challenge that this change will call further opportunity for fraudulent approval of services based on people’s ability to fool the assessors—especially when they are likely to never see or speak to the assessor again.

In 2022, the state moved to a centralized fiscal intermediary.  Within a few weeks many stories were shared about PCA workers not being paid, union involvement, system changes and fraud.  The same occurred when the state moved Protective Services referral to a “Central Intake Unit” to manage all incoming referrals of elder abuse, neglect and exploitation.  Both of these changes have caused a significant lack of communication between these operating organizations and the people doing the work. 

The proposal to create a Central Assessment Unit now threaten to undermine the PCA program altogether.

Request for Information from MassHealth

COMMBUYS, Executive Office of Health and Human Services

Independent Assessment Entity Request for Information

MassHealth is exploring whether an Independent Assessment Entity(IAE) can improve the MassHealth member experience by simplifying and streamlining the clinical assessment process for certain long-term services and supports. The IAE would conduct required assessments for personal care attendant services (PCA), Adult Day Health (ADH),Group Adult Foster Care (GAFC), Adult Foster Care (AFC), Day Habilitation, Senior Care Options (SCO), PACE, and One Care.Currently, more than 400 entities administer clinical eligibility assessments and/or rating category assessments for these LTSS programs.

Responses must be submitted electronically. Questions should be answered in order of appearance and numbered according to the RFI question number. Respondents are invited to respond to a subset or all the RFI questions; please respond to as many as you feel are appropriate. The response deadline is June 28, 2024.

Questions regarding COMMBUYS should be directed to the OSD HelpDesk at OSDHelpDesk@mass.gov.