HomeMy WebLinkAboutResolution No. 2013-63Suggested by: Council Member Molloy
Mayor Porter
Vice -Mayor Marquis
Council Member Bookey
Council Member Boyle
Council Member Gabriel
Council Member Navarre
CITY OF KENAI
RESOLUTION NO. 2013 -63
A RESOLUTION OF THE COUNCIL OF THE CITY OF KENAI, ALASKA, OPPOSING
PROPOSED CHANGES TO REGULATIONS THAT SUBSTANTIALLY DECREASE THE
MEDICAID DAILY SERVICE PAYMENT RATES FOR PRIVATELY OWNED AND
OPERATED ASSISTED LIVING FACILITIES.
WHEREAS, the Kenai City Council has consistently recognized the critical importance
of both independent living facilities and assisted living facilities as the centerpieces of
the long -term care continuum for seniors and their families in Kenai; and,
WHEREAS, seniors desire and require affordable independent living and assisted
living housing and services; and,
WHEREAS, the availability of such housing and services helps curb the attrition of
seniors leaving Kenai after retirement, and generates jobs and revenue in the Kenai
economy for health care providers and for vendors of other services, food and other
supplies; and,
WHEREAS, in 1992, the City of Kenai established the Vintage Pointe Manor as an
independent living facility for senior housing in Kenai, and the City has operated this
independent living facility continuously since then, providing senior housing for
seniors able to live independently; and,
WHEREAS, the City of Kenai does not provide an assisted living facility; and,
WHEREAS, for many years, the Kenai City Council and Administration have supported
the interests and efforts of nonprofit agencies and private developers in studying the
feasibility of developing and operating assisted living facilities in Kenai, in recognition
of the benefits such services will provide to the community; and,
WHEREAS, private developers of assisted living facilities have private capital at risk,
and their projects must be economically viable or such projects will not be developed
or maintained; and,
Resolution No. 2013 -63
Page 2 of 4
WHEREAS, many seniors cannot afford private assisted living rates without
assistance, but can afford to rent units in private assisted living facilities which accept
seniors on the Medicaid home and community -based waiver program; and,
WHEREAS, privately owned assisted living facilities that accept seniors on the
Medicaid home and community -based waiver program must accept the Medicaid daily
payment rates that are paid by the Alaska Department of Health and Social Services
(Department) under the Medicaid home and community -based waiver program for
seniors on Medicaid; and,
WHEREAS, the Medicaid daily payment rates paid by the Department for seniors on
waivers are an important component of revenue considered by private developers in
deciding upon the feasibility of developing an assisted living facility in Kenai as well as
the continued viability of existing facilities; and,
WHEREAS, increases in the Medicaid daily payment rates for assisted living facilities
with 17 or more beds from $144.78 per unit per day (ending June 30, 2011) to
$155.01 per unit per day (ending June 30, 2014) were critically important to the
feasibility and the business plans of developers on the Kenai Peninsula and
throughout the State of Alaska; and,
WHEREAS, the Department's proposal to adopt regulation changes that will decrease
the Medicaid daily payment rates for privately owned and operated assisted living
facilities with 17 or more beds from $155.01 per unit per day to $124.81 per unit per
day beginning July 1, 2014, an approximately 20% reduction in payment rate, equates
to a loss to privately owned facilities of $30.20 per unit per day and losses of
approximately $906.00 per unit per month from existing rates; and,
WHEREAS, the Department's proposal to adopt regulation changes that will decrease
the Medicaid daily payment rates for smaller privately owned facilities and operated
assisted living facilities with 5 or fewer beds from $141.08 per unit per day (ending
June 30, 2014) to $130.00 per unit per day (beginning July, 2014), results in an
approximately 8.5% reduction in payment rate, which equates to a loss to privately
owned facilities of $11.08 per unit per day and losses of approximately $332.40 per
unit per month; and,
WHEREAS, in contrast, the Department proposes to adopt regulation changes for state
government owned and operated providers that will increase the Medicaid daily
payment rates from $155 per unit per day to $354.55 per unit per day, an increase of
over 200% for state owned and operated facilities; and,
WHEREAS, these substantial decreases in payment rates to privately owned and
operated providers, if adopted, will likely be financially devastating to existing private
providers and discourage any new development; and,
WHEREAS, the decrease in payment rates to private operators coupled with the
increase in rates to state government owned providers creates an unfair competitive
advantage in favor of the state in favor of the state providing the same services that
private industry can and is willing to provide; and,
Resolution No. 2013 -63
Page 3 of 4
WHEREAS, three seniors recently transitioned out of the Vintage Pointe Manor, and
the Kenai Senior Center staff referred two of the seniors to local privately owned
assisted living facilities; and,
WHEREAS, these substantial decreases in payments likely will force private providers
to accept less seniors on Medicaid or to go out of business and close their facilities,
reducing the referral options for Kenai Senior Center staff, potentially eliminating
referrals to local licensed facilities; and,
WHEREAS, these substantial decreases in payment rates to privately owned and
operated providers, if adopted, will harm seniors and their families by the loss of
assisted living facilities, which will limit placement options; the alternatives being
more in -home care and more long -term nursing care in nursing homes, which is more
expensive, or re- location to assisted living facilities far away from Kenai, and even
outside the State of Alaska, defeating this Council's goal of keeping seniors in our
community for the benefit of the community.
NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF KENAI,
ALASKA:
Section 1. That the City of Kenai opposes the Department's proposed regulation
changes that will substantially decrease the Medicaid daily payment
rates for privately owned and operated assisted living facilities in the
State of Alaska.
Section 2. City of Kenai request the Department default to a hold harmless rate as
of July 1, 2013.
Section 3. That a copy of this resolution be sent to Randall Schlapia, Department of
Health and Social Services, Office of Rate Review, 3601 C Street, Suite
978, Anchorage, AK 99503, before the public comment period closes on
October 1, 2013.
Section 4. That copies of this resolution be sent to Governor Sean Parnell, Lt.
Governor Mead Treadwell, Commissioner William Streuer (Department of
Health and Social Services), Senate President Charlie Huggins, Speaker
of the House Mike Chenault, Senator Peter Micciche, Representative Kurt
Olson, and Kenai Borough Mayor Mike Navarre.
Section 5. That this resolution takes effect immediately upon passage
PASSED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA, this 18th day of
September, 2013.
PAT PORTER, MAYOR RY N ARQ IS, VICE MAYOR
Resolution No. 2013 -63
A /
TIM NA�V%ARRRE,,yCO`UN�CIILL MEMBER
/dam S�Y�
BRIAN GABRIEI. COUNCIL MEMBER
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11KIlaye with a Past, C# with a Future"
210 Fidalgo Avenue, Kenai, Alaska 99611 -7794
Telephone: 907 - 283 -7535 / FAX: 907 - 283 -3014
MEMORANDUM
TO: Mayor Porter, Council Members and Student Representative
FROM: Council Member Bob Molloy n
DATE: 09 -11 -13
SUBJECT: Resolution No. 2013 -63
This resolution expresses the City of Kenai's opposition to the Department of Health and
Social Services' ( "Department's ") proposed regulation changes that will substantially
decrease the Medicaid daily payment rates for privately owned and operated assisted
living facilities in the State of Alaska.
The Notice of Proposed Changes in Regulations states that any written comment must be
submitted to Randall Schlapia, Office of Rate Review, 3601 C Street, Suite 978,
Anchorage, AK, 99503 no later than 4:00 p.m. on October 1, 2013. The Notice also
states that:
After the public comment period ends, the Department of Health and Social Services will
either adopt these or other provisions dealing with the same subject, without further
notice, or decide to take no action on them. The language of the final regulations may be
different from that of the proposed regulations. You should comment during the time
allowed if your interests could be affected.
The interests of the City of Kenai regarding the development and operation of privately
owned and operated assisted living housing and services for seniors and their families in
Kenai are affected by the Department's proposed changes to regulations that will
substantially decrease Medicaid payment rates to those facilities. The Kenai City Council
has consistently recognized the critical importance of both independent living facilities
and assisted living facilities as the centerpieces of the long -term care continuum for
seniors and their families in Kenai. Since 1992, the City has provided an independent
living facility for seniors -- Vintage Pointe Manor — but the City does not provide an
assisted living facility.
For many years, the Kenai City Council and Administration have supported the interests
and efforts of nonprofit agencies and private developers in studying the feasibility of
Mayor Porter and City Councilors
09 -11 -13
Page 2 of 2
developing and operating assisted living facilities in Kenai, in recognition of the benefits
such housing and services will provide to the community (such as Frontier Community
Services' past study of a project in Momsen Subdivision, and Charis' Place 2012 -2013
study and development of a 22 bed facility on North Forest Drive, and other potential
projects).
From March 1, 2011 through June 30, 2014, there have been increases in the Medicaid
daily payment rates for assisted living facilities that are privately owned and operated,
referred to as "Non -State Government owned and operated provider," as shown in the
accompanying table. For larger facilities like the new Charis Place (17 or more beds) the
increases were from $144.78 per unit per day (ending June 30, 2011) to $155.01 per unit
per day (ending June 30, 2014). For the smaller smaller privately owned facilities (5 or
fewer beds) the increases were from $131.77 per unit per day (ending June 30, 2011) to
$141.08 per unit per day (ending June 30, 2014). These increases were critically
important to the feasibility and the business plans of developers on the Kenai Peninsula
and throughout the State of Alaska who developed the few new larger facilities that were
developed during this time period, and also to existing providers, including the smaller
smaller privately owned facilities.
Medicaid rates in general are under review for cost containment across - the - board.
However, the Department's proposal will substantially decrease the Medicaid payment
rates to the privately owned and operated providers — by approximately 20% to the larger
facilities and by approximately 8.5% to the smaller privately owned facilities. In
contrast, the Department proposes to adopt regulation changes that will substantially
increase the Medicaid daily payment rates from $155 per unit per day to $354.55 per unit
per day for state government owned and operated providers, an increase of over 200 %.
The rate decreases, if adopted, will be financially devastating to facilities in Kenai, on the
Kenai Peninsula, and in the State of Alaska. Private providers likely will be forced to
accept fewer seniors on Medicaid or to go out of business and close their facilities
altogether, reducing the referral options for Kenai Senior Center staff, and potentially
eliminating availability of local licensed facilities for placements. Seniors and their
families will be harmed by the loss of assisted living facilities, which will limit placement
options. The alternatives are more in -home care and more long -tern nursing care in
nursing homes, which is more expensive, or re- location to assisted living facilities far
away from Kenai, and even outside the State of Alaska, defeating this Council's goal of
keeping seniors in our community for the benefit of the community.
Signature blocks for the Mayor and all Council Members are provided in Resolution No.
2013 -63. Your support of this resolution is respectfully requested.
SNAP210- 2T:RJM Political Assisted Living Rates:RES Memo AL Rates.v2.doc
Department of Health and Social Services
Chart of Personal Care Attendant and Waiver Services Rates
Rebased Rates Effective July 1, 2014 (7 AAC 145.520(h))
The following are Medicaid payment rates for specified Personal Care Attendant and Waiver Services.
This chart does not cover all services reimbursed by Medicaid for Waiver Services. For services not
covered here, the controlling regulation should be consulted (example: Specialized Medical Equipment,
Environmental Modifications, or Specialized Private Duty Nursing).
Waiver Proerams:
Alaskans Living Independently - ALI
Adults with Physical and Developmental Disabilities - APDD
Children with Complex Medical Conditions - CCMC
Intellectual and Developmental Disabilities - IDD
Note: Regulatory payment restrictions such as payment limits, coverage limitations, or mutually
exclusive restrictions are not addressed in this rate chart.
Personal Care Assistance Services - 7 AAC 145.500
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
Personal Care -
Agency
Per 15 Minute
$5.64
T1019
N/A
Personal Care -
Consumer Directed
Per 15 Minute
$5.64
T1019 U3
N/A
Care Coordination - 7 AAC 130.240
Service
Service Unit and
Service Rate
Procedure Code
Waiver Program
Limit
Case Management
Per Month
$228.85
T2022
ALI, APDD,
CCMC, IDD
Screening
One Initial
$85.85
T1023
ALI, APDD,
(one additional as
CCMC
approved)
Plan of Care
One Annual
$364.73
T2024 U2
ALI, APDD,
—Development
CCMC, IDD
August 16, 2013 Page 1 of 6
Rebased rates effective July 1, 2014 (7 AAC 145.520(h))
Nursing Oversight and Care Management — 7 AAC 130.235
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
Oversight and Care
Per 15 minute —
$354.55
T2031 CG
ALI, APDD
Management
local (service
$74.63
T1016 CG
CCMC, IDD
ALI, APDD
within 200 miles
of provider)
Per day
$130.54
T2031 US
Oversight and Care
Per 15 minute —
Management
non -local
$138.50
T1016 TN
CCMC, IDD
ALI, APDD
(recipient greater
Per day
$351.50
T2031 TG
ALI, APDD
than 200 miles
from provider)
Note: Non -local (greater than 200 miles) means the provider must travel to the recipient in excess of 200
miles.
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer beds
$354.55
T2031 CG
ALI, APDD
RSL
Acuity Add -on **
per EIN*
Per day
$130.00
T2031 UR
ALI, APDD
RSL - 6 to 16 beds per
EIN*
Per day
$130.54
T2031 US
ALI, APDD
RSL - 17 or more beds
per EIN*
Per day
$124.81
T2031
ALI, APDD
RSL
Per day
$351.50
T2031 TG
ALI, APDD
Acuity Add -on **
*EIN is the provider's Employer Identification Number as issued by the Internal Revenue Service. The
provider's residential assisted living beds must be added to determine the total.
** 7 AAC 130.267 requires that the recipient receive dedicated 1 to 1 staffing care 24 hours per day.
Residential Supported Living (RSL) — 7 AAC 130.255 - State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL
Per day
$354.55
T2031 CG
ALI, APDD
RSL
Acuity Add -on **
Per day
$351.50
T2031 TG
ALI, APDD
** 7 AAC 130.267 requires that the recipient receive dedicated 1 to 1 staffing care 24 hours per day.
August 16, 2013 Dr E, c� Page 2 of 6
Lp in�3 Arvbg � r1C-)-l1KCLjZ
LAW
PROPOSED Rate Changes July 1, 2014
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer
Per day
$130.00
T2031 UR
OA, APD
beds per EIN**
RSL - 6 to 16 beds
Per day
$130.54
T2031 US
OA, APD
per EIN**
RSL - 17 or more
Per day
$124.81
T2031
OA, APD
beds per EIN**
RSL
Per day
$351.50
T2031 TG
OA, APD
Acuity Add -on * **
Effective Dates of Service July 1, 2013 — June 30, 2014
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer
Per day
$141.08
T2031 UR
OA, APD
beds per EIN**
RSL - 6 to 16 beds
Per day
$145.24
T2031 US
OA, APD
er EIN **
RSL - 17 or more
Per day
$155.01
T2031
OA, APD
beds per EIN**
RSL
Per day
$342.59
T2031 TG
OA, APD
Acuity Add -on * **
Effective Dates of Service July 1, 2012 —June 30, 2013
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer
Per day
$138.04
T2031 UR
OA, APD
beds per EIN**
RSL - 6 to 16 beds
Per day
$142.11
T2031 US
OA, APD
per EIN**
RSL - 17 or more
Per day
$151.67
T2031
OA, APD
beds per EIN**
RSL
Per day
$335.22
T2031 TG
OA, APD
Acuity Add -on * **
Effective Dates of Service July 1, 2011— June 30, 2012
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer
Per day
$134.67
T2031 UR
OA, APD
beds per EIN**
RSL - 6 to 16 beds
Per day
$138.64
T2031 US
OA, APD
erEIN* *
RSL - 17 or more
Per day
$147.97
T2031
OA, APD
beds per EIN**
RSL
Per day
$327.04
T2031 TG
OA, APD
Acuity Add -on * **
Effective Dates of Service March 1, 2011— June 30, 2011
Residential Supported Living (RSL) — 7 AAC 130.255 - Non- State Government owned and operated
provider
Service
Service Unit
Service Rate
Procedure Code
Waiver Program
RSL - 5 or fewer
Per day
$131.77
T2031 UR
OA, APD
beds per EIN **
RSL - 6 to 16 beds
Per day
$135.66
T2031 US
OA, APD
er EIN**
RSL - 17 or more
Per day
$144.78
T2031
OA, APD
beds per EIN**
RSL
Per day
$320.00
T2031 TG
OA, APD
Acuity Add -on * **
Pre 2011 Cost Rate Method
htto: / /medicaidalaska.com/ Downloads /Providers/TrainingMaterials Assisted Living Facility Waiver Pr
esentation 2011.odf
2007 Rate Methodology
http: / /dhss.alaska.gov /dsds /Documents /docs /AK HCBS initial pdf
Riverside Assisted Living Soldotna, Inc.
390 Lovers Lane
Soldotna, AK 99669
AI . 5 PRFM
ASSISIEO IJVING
RMng Me to fie Fafttsr
September 18, 2013
Robert J. Molloy, Council Members
Kenai City Council
Kenai, Alaska
RE: City of Kenai Resolution No. 2013 -63
Mr. Molloy and Council Members:
l8 vJI
`ilG1.
:5�`.
We wish to acknowledge and collaborate on the comments submitted to you by the ALAA (Assisted
Living Association of Alaska), as well as make a few observations respective to Riverside Assisted Living's
projected services in Kenai.
We are writing this letter in support of your Resolution No. 2013 -63, which supports the assisted living
industry, its residents and families, as well as this fine community. The privately owned and operated
assisted living homes are a remarkably effective tool in the short-term as well as long -term planning and
implementation of affordable care "as the centerpiece of the care continuum for seniors and their
families in the community." However, it is vitally important that the newly proposed DHSS (Department
of Health & Social Services) changes to Medicaid coverage and payment regulations specific to home
and community -based waiver services, rates and personal care services... not be enacted.
We believe that the disparity between governmentally owned and operated and privately owned and
operated facilities, is simply too prohibitive. To increase the payment rate to governmentally owned
facilities (such as the 6 large Pioneer Homes statewide) by over 200% while lowering the rate for 17+
bed privately owned facilities (like Riverside) by 20 %, is discriminatory, wrong, and demonstrates poor
financial oversight of those governmentally owned facilities. For Riverside, this equates to a loss of
$510 /day per 17 beds. At normal occupancies, these reductions would create substantial revenue
losses. The lost income isn't "extra" money; running a quality assisted living home is not cheap. The
private assisted living industry has financially suffered greatly over the past decade due to inadequate
rate structures for Medicaid, and has lost some good homes across the state to voluntary closure
because of it.
The passing of the proposed DHSS Medicaid rate changes would serve to remove private capital and
projects from the area. These facilities, together with the services they bring with them, are crucial for
the growth and continuance of an economically secure base. We desire for our seniors and those in
need of services to be able to continue to live in this community and have available services necessary
for a high quality of life. Many small -to- midsized Alaskan communities (like Kenai) struggle with the
historical attrition of retirees (to Anchorage or out of state). These services are vital to stemming that
tide of demographical attrition among seniors and the associated economical losses. The currently
proposed DHSS rate changes and regulations jeopardize those efforts.
As you are aware, Riverside has purchased land, submitted and received entitlement authorizations, and
made preparations for expansion of its KPB services to Kenai. Based on the proposed DHSS rate changes
to Medicaid... we would not be able to continue our development in good financial faith with such
drastic measures in play. In order for tens of millions of dollars of private capital to flow into these
various projects, investors need to be assured that future rate structures will not be radically changed
from year to year. Alaska's 50+ population is growing (as elsewhere) and the infrastructure needed to
meet the needs of the coming baby boomer senior services dilemma will be a challenge. While
Riverside and those involved in the assisted living industry are very cognizant of budget cutting
measures, any proposal needs to accurately capture the true costs of providing the services needed at
the level of care required, and then adequately funding those costs.
We believe that it would be in the best interest of all concerned to extend the hold harmless period for
all rates until June 30, 2014. This would signify that all providers would operate at the hold harmless
rates of July 1, 2013 until July 1, 2014, yet continue to search for ways to adequately base new rates that
would support this vital industry.
Riverside appreciates all the time and effort that has been put into objectively analyzing and
consequently opposing these proposed rate changes ... that would serve, if it becomes law, to cripple and
devastate not only this industry, but we believe the community as a whole.
Please feel free to contact me if you have questions, comments, or concerns.
Respectfully,
Cory Castagneto
Riverside Assisted Living
ccastaaneto CoDrlye rsideassisted I ivi n¢. co m
ASSISTED ea
Kenai Peninsula Branch
2030 Muldoon Rd
Anchorage, AK 99504
September 17, 2013
Robert J. Molloy, Council Member
Kenai City Council
Kenai, Alaska
RE: City of Kenai Resolution No. 2013 -63
Mr. Molloy:
We are writing this letter in support of your Resolution No. 2013 -63, which supports the assisted living
industry, its residents and families, as well as this fine community. The privately owned and operated
assisted living homes are a remarkably effective tool in the short-term as well as long -term planning and
implementation of affordable care "as the centerpiece of the continuum for seniors and their families in
the community." However, it is vitally important that the new proposed changes to the Medicaid
coverage and payment regulations specific to home and community -based waiver services, rates, and
personal care services not be enacted.
We believe that the disparity between governmentally owned and operated and privately owned and
operated facilities is simply too prohibitive. To increase the rate of a governmentally owned facility by
over 200% while lowering the rate for privately owned facilities by 7.8% to 20% (depending on the size
of the home) just seems wrong. There are those assisted living homes in this area that would lose over a
quarter million dollars a year with the enactment of these regulations and the cuts to their present rates
(that's over $70.12 per day on a 10 bed home). The lost income isn't "extra" money; running an assisted
living home properly isn't cheap. The private assisted living industry has financially suffered greatly over
the past decade, and we have lost some good homes across the state to voluntary closure because of it.
The passing of the proposed Medicaid changes would serve to remove private capital and projects from
the area. These facilities together with the services they bring with them are crucial for the growth and
continuance of an economically secure base. We desire for our seniors and those in need of services to
be able to continue to live in this community and have available services necessary for a high quality of
life. The currently proposed regulations jeopardize that.
While the association and those involved in the assisted living industry are very cognizant of budget
cutting measures, any proposal needs to adequately and accurately capture the costs of providing the
services needed at the level of care required.
We believe that it would be in the best interest of all concerned to extend the hold harmless period for
all rates until June 30, 2014. This would signify that all providers would operate at the hold harmless
rates of July 1, 2013 until July 1, 2014, yet continue to search for ways to adequately base new rates that
would support this vital industry.
The association appreciates all the time and effort that has been put into this critical issue that would
serve, if it becomes law, to cripple and devastate not only the industry but we believe the community as
a whole.
Please feel free to contact me directly if you have questions, comments, or concerns.
Respectfully,
Sherry Mettler, Consultant
(907) 242 -5282
smrk@ak.net