General components:
1. Departments responsible for MFTP should gather statistical information as to the percentage of skilled nursing facility (SNF) patients who could reside in community based care settings.
The state should conduct entrance interviews for all patients admitted to SNFs previously on IHSS to determine who have custodial care needs that could be met in community based care settings.
2. Departments responsible for MFTP should conduct local market analysis as to costs of residential care facilities for the elderly (RCFEs) vs. medi-cal reimbursed SNFs to determine approximate medi-cal costs savings for each patient who transfer to community based care settings.
3. Agencies responsible for developing MFTP should be free of institutional bias and recognize many patients end up in SNFs because they are low-income and because medi-cal does not currently for any other 24-hour care settings.
4. MFTP should not be a proprietary exercise by the Department of Health Services but should accommodate significant consumer stakeholder input and expertise by state departments currently responsible for the frail and disabled populations: e.g. the Department of Aging and Community Care Licensing.
5. MFTP should be cost efficient and designed so that medi-cal cost savings could be used to offset expenses associated with measures that involve new medi-cal dollars (e.g. nursing home diversion, aging in place).
6. Since the CMS 2007 MFTP grant specifically limits RCFE provider participation to settings with fewer than 4 beds, provisions should be made for California to submit to CMS an additional RCFE medi-cal waiver to allow participation by RCFEs that usually are licensed to accept 4-6 residents.
RCFE components:
1. MFTP should not use as a component for patients willing to transfer to residential care facilities for the elderly (RCFEs) the Assisted Living Waiver Pilot Program (ALWPP) which is opposed by many senior advocacy groups in the state including the American Parkinsons Association, the California Alzheimers Association, the Grey Panthers, the California Congress of Seniors, etc as well as by, Dion Aroner, author of the ALWPP’s enabling legislation (1999, AB 499).
2. RCFEs should not be converted to mini-nursing homes for SNF patients with custodial care needs wanting to transfer to these settings. Onerous new standards should not be imposed on RCFE providers willing to accept MFTP patients with identical care needs as current RCFE residents.
3. MFTP should be designed to allow easy participation by all RCFE providers including small (4-6) providers that have high staffing and frequently provide care for patients with wheelchairs or with dementia who could wander in cities (e.g. Los Angeles) where most large RCFEs are not licensed to accommodate this type of patient.
4. MFTP should only require RCFEs have nurses for participants with care conditions currently prohibited (g-tubes, i.v's, tracheotomies, ventilators, etc.) in RCFE settings.
5. MFTP should not create any unfunded mandates. For RCFEs willing to accept MFTP eligible patients, medi-cal reimbursement should incorporate a tiered base rate for custodial care and a supplemental payment for nursing expenses associated with patients who require these services. Should total patient expenses exceed total reimbursement (medi-cal and patient's SSI contribution), RCFE providers are not obligated to retain MFTP patients.
6. MFTP should take into consideration local market conditions and not mandate private rooms when share rooms are more affordable to state coffers and when many private paid RCFE residents do not enjoy this luxury.
7. MFTP participants should be allowed to use their medi-cal dollars to seek out shared or private rooms in the marketplace and not be restricted to only non-profit or low cost providers.
8. MFTP should incorporate sensible aging in place measures that do not obligate the state to upgrade RCFE residents in shared rooms to private rooms once they run out of money.
9. MFTP should be designed to facilitate participation by a large number of RCFE providers and provide maximum consumer choice. MFTP should not create unnecessary provider bottlenecks that would eliminate consumer choice.
10. Once fair, tiered reimbursement rates based on local market conditions have been developed, all RCFEs should be notified directly about MFTP and invited to participate.
11. All Olmstead public policy, including MFTP, should be transparent, open and allow for significant stakeholder contribution.
Suggestions for Rapid, Low-Cost Nursing Home Transition (according to the method used in Texas)
1. Send medi-cal SNF residents and their families’ letters informing them of nursing home transition options.
2. Send letters to all RCFE providers encouraging them to participate with nursing home transition.
3. Use existing state social workers/case managers to interview and determine eligibility of interested candidates.
4. Provide a list of community based care options for MFTP eligible patients who want to move home or to a community based care setting.
5. Provide state funding for one-time moving expense assistance.
6. Provide incentives for small RCFE providers to cater to specific populations (e.g. younger disabled people who cannot return home would most likely appreciate living in community based settings with peers of more or less of the same age).
7. Use existing state resources, e.g. Community Care Licensing, to monitor the status of patients who go to RCFEs who have only custodial care needs.
8. Work with the disabled rights advocacy groups to devise the best methods to allow MFTP patients to transfer back to their own home.
