California Alzheimers Association Letter Regarding ALWPP

July 16, 2004

Kim Belshé, Secretary
California Health and Human Services Agency
1600 9th Street, Room 460
Sacramento, CA 95814

Dear Ms. Belshé:

On behalf of the 500,000 Californians living with Alzheimer’s and their families, I’m writing to express our serious concerns over the design of the Medicaid waiver proposal for the Assisted Living Pilot Project.

Aside from the exceedingly long time the Department of Health Services has taken to prepare the waiver proposal since the passage of AB 499 four years ago, our understanding of the guidelines for the pilot is that they would negate most of the objectives of the bill and its proponents, which included the Alzheimer's Association.

The intent of the bill was to evaluate assisting low-income Californians in accessing assisted living services when their needs do not warrant nursing home care but are unable to continue living in their own home. This is the case for a number of persons suffering from Alzheimer's and other dementia disorders. Many require close supervision and a high degree of assistance with daily living activities but do not require nursing care. The trend towards families choosing assisted living facilities for their family member with dementia is evidenced by the authority for these facilities to provide a safe environment through the use of secure perimeter and egress devices. It's further indicated by the fact the Department of Social Services has promulgated dementia regulations requiring that all assisted living facilities that accept residents with dementia must meet standards making them dementia capable.

One of the purposes of AB 499 was not only to increase residential options for persons who can no longer remain in their own home but also to lower costs to the State, since nursing home costs usually exceed what Medi-Cal would have to pay for someone to be in an assisted living facility. While assisted living facilities would offer the State a more cost effective Medi-Cal option for the growing number of Californians who suffer from dementia, the guidelines of the pilot would exclude most of the facilities that care for persons with dementia from participating in the pilot.

The criteria in the waiver proposal disallow facilities with shared rooms and bathrooms and require kitchenettes in each residential unit. This would so limit the facilities who could participate that it is unlikely to accomplish the pilot’s goal.

We understand the waiver is nearing completion for submission and are perplexed that those involved in drafting the proposal have ignored the unanimous voices of consumers and the California Assisted Living Association to include criteria which will ensure a representative sample of facilities are evaluated in the pilot. Regrettably staff has not taken the input from those who are most familiar with the nature and scope of assisted living facilities, including the Department of Social Services, which regulates these facilities.

If the waiver is submitted as drafted, all the years of waiting will be for naught and the State will miss an opportunity to test a more cost effective level of care for persons with Alzheimer's who are Medi-Cal eligible. We urge you to have staff revise the proposal before it is submitted to CMS.

Sincerely,

Jackie Wynne McGrath