Barclay Damon
Barclay Damon

Legal Alert

Medicaid Health Homes Application Deadline Approaching; Mandatory Letter of Intent Due by September 1, 2011

The New York State Department of Health (DOH) has imposed new deadlines for those entities that want to apply for approval as a Medicaid Health Home. The application deadlines will be strictly enforced and will not be extended. The purpose of the Health Home initiative is to create networks of providers capable of providing coordinated, comprehensive medical and behavioral health care to chronically ill patients through care coordination with the ultimate goal of reducing hospitalization and emergency room visits. The following is a brief description of the application timing and requirements and a general overview of (i) eligible Health Home applicants, (ii) the patient population served by Health Homes, (iii) the services that a Health Home applicant needs to show it is capable of providing, and (iv) the types of network partners DOH will be looking for in a Health Home.

Application Timing and Requirements

Prospective applicants must submit a Letter of Intent (LOI) by close of business on September 1, 2011. There is no set form for the LOI but it must be a Word document and it must be e-mailed to DOH at the designated e-mail address by September 1st. Applications of those applicants that did not timely file a LOI will not be considered. The LOI needs to include a preliminary list of proposed Health Home network partners, the proposed service area and initial capacity. The DOH’s website contains additional information concerning the contents of the LOI which can be found at http://www.health.ny.gov/health_care/medicaid/program/medicaid_health_homes/.

The Health Home application must be received by DOH by close of business on October 3, 2011. An online version of the application can be found at the above-referenced webpage. The applicant is required to provide comprehensive and detailed information regarding the applicant’s ability to provide the required services and the identity of those network partners that will assist the applicant in providing such services. Implementation will begin November 1, 2011 in the larger urban areas focusing on patients with high acuity rates that are currently the least connected with existing primary care programs.

Eligible Health Home Applicants

Although the potential universe of eligible Health Home providers is very broad, DOH has made it clear that only those applicants that can clearly demonstrate the ability to provide all required services through a network of contracted service providers will be considered as a Health Home provider. The applicant will be the single entity that enters into a contract with the State to provide Health Home services, will be responsible for service performance and will be the entity that receives payments. The Health Home provider will enter into service contracts as needed with specific service providers. The list of eligible Health Home providers includes hospitals, managed care plans, community health centers, home health agencies, clinical practices, medical/mental/chemical dependency treatment clinics, primary care practitioner practices and “any other Medicaid enrolled entity that meets the State’s Health Home requirements.” As referenced above, it is the view of DOH that no single entity by itself could qualify as a Health Home, thus requiring the applicant to demonstrate that it will have agreements in place with specific providers to provide all required services.

Patient Population

Under the applicable statutes, a “health home” is a designated provider (or team of providers) selected by an eligible individual with chronic conditions to provide Health Home services. An “eligible individual with chronic conditions” is defined as an individual who (i) is Medicaid eligible, (ii) has at least two chronic conditions, (iii) has one chronic condition and is at risk of having a second, or (iv) has one serious and persistent mental health condition. A chronic condition is defined as (i) a mental health condition, (ii) a substance abuse disorder, (iii) asthma/diabetes/heart disease/hypertension/obesity, or (iv) HIV/AIDS.

Health Home Service Requirements

The core services to be provided by a Health Home generally include (i) comprehensive care management, (ii) care coordination and health promotion, (iii) transitional care with follow-up, (iv) patient and family support, (v) referral to community and social support services, and (vi) use of information technology to link services.

A Health Home applicant must also show that it can provide (i) post critical event care coordination and services, (ii) language access/translation capability, (iii) 24/7 telephone access care manager, (iv) crises intervention, (v) links to acute and outpatient medical, mental health and substance abuse services, (vi) links to community based social support services — including housing, and (vii) beneficiary consent for program enrollment and for sharing patient information and treatment.

Network Partners

DOH requires that an applicant demonstrate that it has strong medical, behavioral and social service community provider connections. At the time of application, the applicant must attest that it has contractual agreements (or other agreements as practicable) in place with organizations that can provide all of the required services. The LOI must provide a preliminary list of its proposed Health Home partners, including direct care providers, Targeted Case Management, COBRA (Community Follow-Up Program), Managed Addiction Treatment Services and Chronic Illness Demonstration Project programs, as well as community based organizations.

During the time between the receipt of LOIs and the October 3, 2011 application deadline, DOH will analyze the data collected from the LOIs to perform patient matching and will attempt to match applicants with other applicants in designated service areas and match applicants with specific service providers to form networks, controlled by a single entity, that fits its Health Home service model. It is expected that this process will also continue after applications are received.

Those entities that wish to be considered as a Health Home provider must, if they have not done so already, immediately reach out to prospective service providers to construct a service network that can be shown to be able to provide the required services. Those entities that wish to become a part of a Health Home network by contracting with a Health Home service provider should be making inquiries with potential Health Home providers in an effort to join a network.  

Should you need assistance in these matters, please contact a member of the Firm’s Health Care and Human Services Practice Area at (518) 434-2163.