Thank You for This Opportunity to Comment to the Health Care Reform Task Force on the Draft

December 6, 2012

TO:Members of the Health Care Reform Task Force

FROM:Patti Cullen, President/CEO, Care Providers of Minnesota

Gayle Kvenvold, President and CEO, Aging Services of Minnesota

RE:Comments on Roadmap to a Healthier Minnesota

Thank you for this opportunity to comment to The Health Care Reform Task Force on the draft Roadmap to a Healthier Minnesota – the Task Force's recommendations to Governor Dayton and the Legislature. The Long Term Care Imperative has submitted comments in the past on recommendations from two of the workgroups: Care Integration and Payment Reform; and Workforce. We are please to note that both Workgroups have incorporated some of our comments and issues we have presented to the Workgroups.

In particular, we are supportive of the inclusion of long term care for integration and coordination in total cost of care contracts; and identifying post acute and community based long term care providers as a targeted provider group, and therefore eligible to receive technical assistance. As we continue to evaluate the ongoing impacts of consolidation in the health care marketplace and their intersection with the long-term care issues of providing access and supports to Medicaid eligible individuals, the inclusion of long-term care in this process is necessary to try to minimize the number of individuals who could be "falling through the cracks."

We encourage the task force to continue to examination the role of each of the payee's in the shared savings approach to help incent the correct placement of individuals receive the right services and the right time in the right place. We would also like to voice our strong support for the integration of Medicare and Medicaid benefits mentioned under strategy element #4. Without a mechanism to recognize savings created across those programs for dually eligible individuals, the full potential of integrated care for that population will not be realized.

Under strategy element #6, we are pleased that the task force has acknowledged the importance of information sharing across provider types, which we believe to be crucial to successful integrated care models. We would note however that the draft does not acknowledge that one of the barriers to this information exchange is financial, and that additional investment in this area will be necessary in order to achieve many of the goals laid out in the Roadmap.

We are supportive of strategy element #7 and are glad to see that the task force recognizes the special challenges faced by small rural providers as they try to transition to an integrated model of care. We are hopeful that the technical assistance described in the recommendations will address some of these challenges, but the role of small rural providers in integrated care will have to be carefully monitored over time to make sure that people throughout the state have access to high quality and cost effective services.

We greatly appreciate the acknowledgement that recruitment and retention of long term care workforce will only happen with an additional investment. It is important to highlight the comment made by Task Force member Dale Thompson about strategy element #11: Attract and Retain the Long Term CareWorkforce – due to federal matches and private pay rate equalization in nursing facilities, a 27 cent state contribution results in a $1.00 wage increases for long term care workers. Long term care providers throughout Minnesota are currently facing significant shortages of direct care workers, particularly nursing assistants and RNs, and the ability to offer more competitive wages and benefits is crucial to addressing this growing problem.

In order for facilities to continue to attract and retain workers, there must be both short term increases as well as a long term payment system established in Minnesota. This system needs to address the enormous gap between the Medicaid allowable expenses and the current state reimbursement. This gap is the primary reason that attracting and retaining workforce is such a challenge for long-term care.

Furthermore, we would like to point out the connection between strategy element #11 and strategy element #28 "Provide affordability and coverage support for adults with incomes between 138%-200% of the Federal Poverty Level". Because of dependence on state funding, the lack of increased state investment, and ongoing gap between expenses and payment, an increasing number of employees in nursing homes fall into the category of those who are lower income, and working. These workers currently find employer offered insurance unaffordable, and fall into this income category. The reasons are varied (less than full time, single parents, etc), but the result is the same. Currently, many of these employees are qualifying for the state program of MinnesotaCare. We encourage you to keep this in mind in the design of the affordability of coverage and support for this income level--the change should not create more working poor being uninsured or underinsured.

Finally, on strategy element #20, we are interested in the concept of Accountable Communities for Health (ACH) and would like to see pilots of this concept take place. The draft strategy element mentions a number of services that an ACH would include, but does not mention “long term care.” We would like to see that included as well, at least as a possibility that could be tested in a pilot, because keeping long-term care separate from other services does not serve full integration of care. Also, under strategy element #24 (performance measurement for total cost of care), we want to emphasize that the quality measures for this purpose should be designed not to add to the reporting burden of providers, many of whom already report significant amounts of quality data to various state and federal entities.