Using Medicaid to Cover Services for Elderly Persons in Residential Care Settings: State Policy Maker and Stakeholder Views in Six States

APPENDIX D. NORTH CAROLINA



TABLE OF CONTENTS

I. OVERVIEW OF LONG TERM CARE SYSTEM
Nursing Homes
Waiver Program
Personal Care Option
Long Term Care Programs Funded with State Revenues Only
II. RESIDENTIAL CARE SETTINGS
Background
Multi-Unit Assisted Housing with Services
Adult Care Homes
III. SUMMARY OF INTERVIEWS
General Comments About the State's Residential Care System
General Comments on Medicaid's Role in Residential Care Settings
Licensing and Regulatory Requirements
Admission and Retention Requirements, and Aging in Place
Service Rates
Suggested Changes to Improve the Medicaid-Funded Residential Care System
Future Plans
Recommendations for Other States
SOURCES
Publications
Websites
Formal and Informal Interviews
ENDNOTES


The information in this appendix is presented in three major sections:

Because the information in the first two sections is intended to serve as a reference, some information is presented under more than one heading to reduce the need for readers to refer back to other sections for relevant information.

Unless otherwise cited in endnotes, all information presented here was obtained from the sources listed at the end. Supplemental Security Income levels, the federal poverty level, federal spousal protection provisions, state supplemental payments, and state reimbursement rates are for 2003, unless otherwise noted.


I. OVERVIEW OF LONG TERM CARE SYSTEM

Nursing Homes

North Carolina has had a Certificate of Need (CON) Program for nursing homes since 1981. Consequently, compared to other states, they have a lower number of nursing home beds per person age 65+ than the national average: 3.8 percent compared to 4.2 percent. The current occupancy rate is 87.9 percent compared to the national average of 82.9 percent.1

Financial Criteria2

Spousal Protections

Family Supplementation

In nursing homes, families can pay the difference in cost between a semi-private and private room for a Medicaid beneficiary only if the beneficiary has been a private pay resident of the nursing home and has spent down to Medicaid eligibility.

Level of Care Criteria

To receive Medicaid coverage of nursing home care, a physician must certify that an individual needs eight hours of licensed nursing care (RN or LPN) per day, either direct care or oversight.

Waiver Program

The state's waiver program for elderly persons is called the Community Alternatives Program for Disabled Adults (CAP/DA). Only persons residing in their own or another's home can receive waiver services because North Carolina licensing rules do not permit any residential care settings to serve persons who need a nursing home level of care. Due to a nursing home bed shortage and other factors, some people who meet the state's nursing home level of care criteria do in fact reside in adult care homes. They are not eligible for waiver services but can receive some nursing care through Medicare or Medicaid Home Health services".

Financial Criteria

Spousal Protections

Family Supplementation

Any monetary resources provided to a waiver client are considered income and are counted in determining Medicaid eligibility. Medicaid waiver clients can not be served in residential care settings, so family supplementation to pay the cost of a private room is not an issue in the waiver program.

Level of Care Criteria

Waiver applicants have to meet the same level of care criteria as nursing home applicants. To receive Medicaid coverage of nursing home care, a physician must certify that an individual needs 8 hours of licensed nursing care (RN or LPN) per day, either direct care or oversight.

Personal Care Option

In the 1980's, the state added personal care services to the Medicaid State Plan. At that time, only Medicaid-eligible persons residing in their own homes could be eligible for personal care services. Personal care in people's homes includes assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs), and is capped at 80 hours a month. Between July 2000 and June 2001, 23,661 people received Medicaid personal care in their own homes.

In 1995, the state expanded the settings in which care could be provided to adult care homes. In adult care homes, personal assistance includes assistance with ADLs and medications. Assistance with meal preparation, housekeeping, laundry, and money management is covered under the room and board payment. To be eligible for Medicaid covered personal care services, individuals must first meet Medicaid's financial eligibility criteria. However, these criteria differ for individuals in their own home and individuals in adult care homes.

Financial Criteria For Individuals Living in Their Own Homes

Spousal Protections

No income and asset protections are provided for the spouses of persons receiving personal care services in their own homes. When spouses live together in a home, a spouse's income is counted in determining whether a person meets the income eligibility standard, according to SSI policy.

Financial Criteria For Individuals Living in Adult Care Homes

Spousal Protections

No income and asset protections are provided for the spouses of persons receiving personal care services in residential care settings. The income of spouses of adult care home residents is not counted in determining eligibility for Special Assistance.

Service Criteria

To be eligible for residence in an adult care home, a physician must certify that an individual needs the supervision and personal care provided by the Adult Care Home.

Family Supplementation

Family supplementation to pay for private rooms is currently not permitted in adult care homes or other residential care settings, but the state is considering allowing it. State provider associations are working with the North Carolina General Assembly to develop a bill.

Long Term Care Programs Funded with State Revenues Only

North Carolina combines some state funds with Older Americans Act funds into a program called the Home and Community Care Block grant that is distributed to the counties based on an intrastate formula.


II. RESIDENTIAL CARE SETTINGS

Background

For the past several decades, North Carolina has depended heavily on domiciliary care to meet the long term care needs of its population.7 Domiciliary care was a term North Carolina used to define three types of residential care settings: Homes for the Aged (also called Adult Care Homes), Family Care Homes, and Group Homes for Adults with Developmental Disabilities. These homes are licensed by the Department of Human Resources' Division of Facility Services and monitored by county Departments of Social Services staff.

Domiciliary homes were defined in statute as any facility, by whatever name it is called, that provides residential care for aged or under 65 disabled persons whose principal need is a home that provides the supervision and personal care appropriate to their age or disability.

Prior to 1995 when the state began paying for some personal care in these homes through the Medicaid program, domiciliary care was solely privately purchased. However a significant amount of the payments to residential care settings was publicly subsidized through the federal SSI program and the state's SSI supplement, called Special Assistance.

Persons eligible for SSI who live in domiciliary care homes are eligible for Special Assistance. Each month they receive a check, which is paid to the home. Monthly benefits for the combined SSI and Special Assistance benefit are established by the North Carolina General Assembly as the "rate" for domiciliary home care. Prior to the use of Medicaid to pay for some personal care in these homes, this rate covered room and board and custodial care provided by the home.

Introduction of Medicaid Personal Care Services in Adult Care Homes

In the late 1980's to mid-1990's advocates for elderly persons urged the state to address perceived quality of care problems in adult care homes. In particular, their concerns focused on the retention of persons requiring a nursing home level of care in these homes, who not receiving appropriate or adequate services. During the same period, the development of a new model of residential care--market-rate assisted living--had become widespread throughout the state. Advocates also urged the state to provide this new care model to elderly persons who needed services in a residential care setting.

The state convened a domiciliary care team that met for 18 months and consulted with a number of experts to assist in the development of new residential care policy. In 1994, the state commissioned a study of North Carolina Domiciliary Care Home Residents.8 The study found that residents in domiciliary care homes in North Carolina had significant levels of impairment, with nearly two-thirds having moderate to severe cognitive impairment. Comparisons to domiciliary care home residents in ten other states showed that the North Carolina domiciliary home residents had much higher levels of ADL impairment, cognitive impairment, and incontinence.

These findings were a major impetus for the policy decision to use Medicaid to pay for additional personal care in domiciliary homes. Other important factors included pressure from advocates to increase the amount of care provided in these homes, pressure from providers for higher payments, and U.S. Congressional discussions about block granting the Medicaid program. In response to the latter, many in the state felt it would be advantageous to draw as much Medicaid money as possible before the program was block granted.

By using Medicaid to pay for these services, the state's domiciliary care team developed a budget neutral strategy that would increase the amount of personal care provided in adult care homes and provide case management to oversee residents with heavy care needs. The state reduced the Special Assistance payment and used the savings as the state match for the new federal funding.

Because the State was concerned about the cost of the new benefit, it established three fixed reimbursement levels for personal care in domiciliary care homes--basic and two enhanced levels--to be determined by a case manager.

The Revision of Domiciliary Care Home Licensing Rules

In 1995, considerable debate occurred in the North Carolina General Assembly about the definition of the term "assisted living." On one side were those who believed the term should only be used by facilities that provided the new model of assisted living, which offered private rooms and individualized service packages. On the other side were those concerned that a segment of the domiciliary care industry would be negatively affected if it could not also call itself assisted living. The latter group convinced the North Carolina General Assembly to define an assisted living residence to mean:

"any group housing and services program for two or more unrelated adults, by whatever name it is called, that makes available, at a minimum, one meal a day and housekeeping services, and provides personal care services directly or through a formal written agreement with one or more licensed home care or hospice agencies. The Department of Human Resources may allow nursing service exceptions on a case-by-case basis. Settings may include self-contained apartment units or single or shared room units with private or common baths."

The legislature specifically recognized three types of assisted living residences: Adult Care Homes, group homes for persons with developmental disabilities, and Multi-Unit Assisted Housing with Services. Because the new law defined assisted living to include group housing for two or more individuals, Family Care Homes that serve two to six individuals were also included in the new definition of assisted living, and must meet the same licensing and regulatory requirements.

In response to nursing home industry concerns that adult care homes would be turned into intermediate care facilities and would admit the light care residents that were served in nursing homes, the regulations covering assisted living specify that persons with certain medical conditions, such as ventilator dependency, or individuals requiring continuous licensed nursing care, can never be served in these facilities, except when a physician certifies that appropriate care can be provided on a temporary basis to meet the resident's needs and prevent unnecessary relocation.

One commonality in two types of assisted living--adult care homes and group homes for persons with developmental disabilities--is the ability to provide protective oversight and services to meet unscheduled needs on a 24 hour basis. In contrast, Multi-Unit Housing with Services facilities are not permitted to serve residents who require assistance at night. Multi-Unit Housing with Services facilities may call themselves assisted living, but they are not required to be licensed under the assisted living rules; they only have to register with the state.

In 1997, a moratorium was placed on assisted living facilities for three years, and in 2001, a Certificate of Need program was enacted. Continuing Care Retirement Communities are exempt because they are contractually required to provide whatever level of care is needed.

Multi-Unit Assisted Housing with Services

Multi-Unit Housing with Services is a new type of residential care setting named by the 1995 legislation. However, it is more a housing model than a service model. The model was included in the legislation at the request of developers who were interested in a limited service model that did not have to be licensed or highly regulated, but could, nonetheless, be marketed as assisted living.

Because Multi-Unit Housing with Services facilities cannot have in-house personal assistance staff, they do not have to be licensed; they have only to register with the state. Although North Carolina statute defines assisted living as group housing with services that, at a minimum, include one meal a day, housekeeping, and personal care services, Multi-Unit Housing with Services facilities are required to provide protective oversight and social services only. They may choose to provide additional services such as meals and housekeeping, and they may arrange for hands-on personal care and nursing services provided by an outside agency.

Multi-Unit Housing with Services provide private residences--studios and one or two bedroom apartments with private baths and full kitchens or kitchenettes. Persons who live in Multi-Unit Housing with Services are considered to be legal tenants who live in their own rented units.

Persons living in Multi-Unit Housing with Services facilities could theoretically become eligible to receive Medicaid personal care or waiver services in this setting. However, persons who meet Medicaid's financial eligibility rules (those with incomes no higher than 100 percent of the federal poverty level or who spend down to eligibility) are unlikely to be able to afford the rent in these facilities. While some Multi-Unit Housing with Services facilities may set rents on a sliding scale, some facilities charge as much as $1500 a month as their base rate, which does not include any personal care services.

Adult Care Homes

There are three types of Adult Care Homes, all of which are licensed as assisted living facilities:

The remainder of this section will focus solely on the adult care homes licensed to serve seven or more residents.

Physical Plant Requirements

Room and Board

The state limits the amount of room and board charges only for SSI/SA recipients, an amount determined annually by the North Carolina General Assembly. Facilities are free to charge private pay residents a market rate.

Services

Service Rates

The rates are based on the size of facility. In facilities with 1 to 30 residents, the basic daily rate is $14.71, which pays for one hour of personal care. In facilities with 31 or more residents, the basic rate is $16.11 per day. The enhanced rates are per diem add-ons to the basic rate and are the same for both sizes of facilities. Enhanced daily rates are provided when a resident needs assistance with: ambulation (+ $2.64); toileting (+ $3.69); eating (+ $10.33); eating and toileting (+ $13.18).

Admission, Retention, and Discharge Criteria, and Aging in Place

Several respondents believe that the same reasons for inappropriate placement apply in 2003.


III. SUMMARY OF INTERVIEWS

In addition to consulting with 9 state staff and policy makers regarding the technical details of the state's programs, we also interviewed four of them. In addition, we interviewed 9 stakeholders, including representatives of assisted living provider associations, consumer advocates, a former county service administrator, and two university-based policy analysts, one of whom previously worked for the NC Department on Aging.

The interviews focused on respondents' views about several key areas and issues. This section summarizes their views and provides illustrative examples of their responses. These comments are not verbatim quotes, but have been paraphrased to protect the respondents' anonymity and edited for brevity. A list of information sources for the state description and the individuals interviewed can be found at the end of this summary.

General Comments About the State's Residential Care System

Because many of the same residential care facilities serve both private pay and Medicaid residents, most respondents expressed views about the industry as a whole.

A few stated that the state's residential care system provides options for those with the money to pay privately and for the very poor but not for elderly persons with low to moderate incomes.

Two respondents expressed views about the state's Certificate of Need program for assisted living facilities, one noting that it needed to be better targeted.

One expressed concern about the lack of oversight of Multi-Unit Housing with Services facilities

Others criticized the state's moratorium and Certificate of Need program for nursing homes.

One mentioned that the overbuilding of market rate assisted living facilities could result in a larger number of Medicaid clients being served in these newer and "nicer' settings.

General Comments on Medicaid's Role in Residential Care Settings

Many respondents were very pleased that the state is using Medicaid funds to provide personal care to residents of adult care homes and felt it improved the quality of care. However, while there is a general sense that Medicaid coverage resulted in some quality improvement, some believe that the adult care home population is becoming more and more impaired, and that the homes are not able to provide the level of care residents need.

Others are concerned that the state is using limited resources inefficiently by providing nursing care to this population through the Medicaid Home Health program.

One respondent mentioned that the state had at one time looked into using the private pay model of assisted living for waiver clients.

One stated that she had opposed allowing waiver clients to receive care in assisted living.

One noted that not all facilities accept Medicaid residents and discussed some of the reasons for this.

Licensing and Regulatory Requirements

Many respondents--both providers and consumer advocates--expressed concerns that the licensing category of assisted living was too broad and created problems, both for consumers and for facilities that provide the new model of assisted living.

A few respondents raised serious concerns about quality and safety.

Staffing

Several expressed concerns about inadequate staffing.

One respondent noted that it is difficult to recruit and retain good staff.

Others expressed concern about inadequate enforcement of new training requirements.

Medication Administration

Several raised concerns about quality issues relate to medication administration.

National Standards

A few felt that national standards could be useful as long as they are put forth as a model and not mandated.

Outcome-Based Regulations

A few respondents stated that the regulations are too rigid and need to be more person-centered and outcome based.

One noted that when looking at regulations, consumer advocates need to distinguish between the majority of providers who are doing a good job, and the few providers who are not.

Admission and Retention Requirements, and Aging in Place

One noted that the aging in place philosophy is not so easy to implement.

Some felt that while retention requirements needed fine-tuning, it was not a good idea to have rigid requirements as in nursing homes.

One felt that while flexibility is desirable, parameters are needed.

Many of the respondents expressed a wide range of concerns about the ability of adult care homes to meet the needs of its residents. Most concerns related to homes keeping people beyond the point where they should be discharged.

One made a distinction between the need for protections for residents with and without families.

Some expressed concerns about the level of nursing care needed by residents in adult care homes.

Negotiated Risk Agreements

Most respondents had not heard of these agreements or any issues related to them. One felt that the state needed to provide more guidance to providers regarding their use, predominantly in private pay assisted living.

Service Rates

A few mentioned the need for a different rate system than the current one.

One mentioned that the Medicaid rates in adult care homes are not sufficient to provide care to persons with dementia.

Suggested Changes to Improve the Medicaid-Funded Residential Care System

Respondents had numerous suggestions for improving the state's residential care system generally, and Medicaid specifically.

A few mentioned that adult care homes should serve homogeneous populations, and that the state needed different regulations to assure the quality of care for the different populations.

A number stated that the state needed better assessment procedures and data for a number of purposes.

Two respondents said the that the state needed to better utilize Medicaid funding, noting that North Carolina has a 64 percent match, and the Special Assistance payment is all state and county money.

Another expressed concern about cuts in the state's Medicaid budget.

A number said that the state needed to better support home care.

Several noted that the state should permit family supplementation in assisted living settings to pay for private rooms.

One noted that even continuing care retirement communities (CCRC) have requested information on how to keep private pay residents who have spent down.

Future Plans

Recommendations for Other States


SOURCES

Publications

Bolda, E., Initial report on North Carolina domiciliary care policy. The Long Term Care Resources Program, Duke University Center for the Study of Aging and Human Development (1991).

Gregory, S.R. and Gibson, M.J., Across the States: Profiles of Long Term Care. Public Policy Institute, AARP, November 2002.

Hawes, C., Lux, L., Wildfire, J., Green, R., Packer, L. E., Lannacchione, V., and Phillips, C., Study of North Carolina domiciliary care home residents. (February 15, 1995). Report submitted to the North Carolina Department of Human Resources.

Kassner, E. and Williams, L., Taking Care of their Own: State-funded Home and Community-based Care Programs for Older Persons, AARP, September 1997.

Kassner, E. and Shirley, L., Medicaid Financial Eligibility for Older People: State Variations in Access to Home and Community-Based Waiver and Nursing Home Services, AARP, April 2000.

Manard, B. et. al., Policy Synthesis on Assisted Living for the Frail Elderly: Final Report, submitted to Office of the Assistant Secretary for Planning and Evaluation, December 16, 1992. [Executive Summary]

Mollica, R.L., State Assisted Living Policy: 1998, Report (ASPE and RTI) June 1998. [Full Report]

Mollica, R.L., State Assisted Living Policy: 2000, National Academy for State Health Policy; funded by The Retirement Research Foundation (LTC13). August 2000.

Mollica, R.L., State Assisted Living Policy: 2002, National Academy for State Health Policy, November 2002

Mollica, R.L., and Jenkens, R., State Assisted Living Practices and Options: A Guide for State Policy Makers, A publication of the Coming Home Program, funded under a grant from The Robert Wood Johnson Foundation, September 2001.

O'Keeffe, J., People with Dementia: Can They Meet Medicaid Level-of-Care Criteria for Admission to Nursing Homes and Home and Community-Based Waiver Programs?, AARP, August 1999.

Smith, G. et. al., Understanding Medicaid Home and Community Services: A Primer, U.S. Department of Health and Human Services, Office of the Assistant secretary for Planning and Evaluation, October 2000. [Full Report]

State Assistance Programs for SSI Recipients, January 2001, Social Security Administration, Office Of Policy, Office Of Research, Evaluation, and Statistics, Division Of SSI Statistics and Analysis.

Stone, J.L., Medicaid: Eligibility for the Aged and Disabled, Congressional Research Service Report for Congress, updated July 5, 2002.

Websites

Aged, Blind and Disabled Medicaid Eligibility Survey http://www.masterpiecepublishers.com/eligibility/

Department of Health and Human Services http://www.dhhs.state.nc.us/

DHHS Division of Aging http://www.dhhs.state.nc.us/aging/

DHHS Division of Facility Services http://facility-services.state.nc.us/gcpage.htm

DHHS Division of Medical Assistance http://www.dhhs.state.nc.us/dma/

DHSS Division of Social Services http://www.dhhs.state.nc.us/dss/cty_cnr/depts.htm#top

North Carolina Administrative Rules, Aging: Program Operations http://ncrules.state.nc.us/ncadministrativ_/title10ahealtha_/chapter06agingp_/default.htm

North Carolina Administrative Rules, Licensing of homes for the aged and infirm http://ncrules.state.nc.us/ncadministrativ_/title10healthan_/chapter42indivi_/subchapterdrule/subchapterdrule.doc

North Carolina Assisted Living Association http://www.ncassistedliving.org/

Formal and Informal Interviews

Elise Bolda, PhD, Research Assistant Professor
Institute for Health Policy, Muskie School of Public Service
University of Southern Maine

Jerry Cooper, Executive Director
NC Assisted Living Association

Jackie Franklin, Special Assistance Program Manager
Adult Social Services Section, Division of Aging

Bill Hottell, Manager
Adult Care Homes

Bill Lamb
UNC Institute on Aging

Sandra Crawford Leak, Associate Program Director
Long Term Care Resources Program
Center for the Study of Aging and Human Development
Duke University

Mary Jo Littlewood, Manager
Community Alternative Program

Lou Morton, Program Consultant
Adult Care Homes

Beverly Patnaik
Long Term Care Resources Program
Center for Study on Aging and Human Development
Duke Medical Center

Lynn Perrin, Section Chief
Medicaid Policy and Institutional Services

Helen Savage
AARP--NC Chapter

Dennis Streets,
Division of Aging

Carol Teal, Executive Director
Friends of Residents in Long Term Care

Mary Reca Todd, Supportive Housing Team Leader
North Carolina Housing Finance Agency

Judy Walton, Administrator of Managed Care for Seniors
Division of Medical Assistance
Office of the Director
NC Department of Health and Human Services

Susan Williamson, President and CEO
North Carolina Association of Nonprofit Homes for the Aging

Andy Wilson, Project Coordinator
Medicaid Eligibility Unit
N.C. Division of Medical Assistance.

Lou Wilson, Executive Director / Facility Operator
North Carolina Association Long Term Care Facilities


ENDNOTES

  1. Gregory, S.R. and Gibson, M.J., Across the States: Profiles of Long Term Care. Public Policy Institute, AARP, November 2002.

  2. Prior to 1995, North Carolina (North Carolina) was a 209(b) state and had the option of using more restrictive financial eligibility criteria than that of the Supplemental Security Income (SSI) program to determine financial eligibility for Medicaid. During this time, persons who were eligible for SSI, either because they were disabled or 65 years or older, were not automatically eligible for Medicaid, as they were in most states.

    Individuals could become eligible for Medicaid by spending down to $242, or $317 for a couple. Resource limits were also more restrictive than SSI. The one exception to this income standard was linked to receipt of the SSI state supplement, called Special Assistance (SA), which was provided only to individuals residing in adult care homes.

    In January 1995, the state began covering all SSI recipients under Medicaid, and in 1999 increased the income standard to 100 percent of the federal poverty standard. This standard is used to determine eligibility for all long term care services in the state, including nursing homes. The state also has a medically needy program.

  3. As permitted under the §1902(r)(2) less restrictive income methodologies, the state excludes wages paid by the Census Bureau for temporary employment; it also does not count the following: personal effects & household goods; life estate interest and tenancy in common interest (except for optional state supplements); burial plots; cash value of life insurance if the total face value does not exceed a specified amount.

  4. At a county's option, blind and disabled adults who are not eligible for SSI may also receive a supplement in a private living arrangement. They are covered under "certain disabled" provisions but receipt of the SA does not confer Medicaid eligibility as it does to individuals residing in Adult Care Homes.

  5. In August 1995, the combined SSI/SA payment was lowered from $982 to $800. The savings were used to provide the state match for the new Medicaid personal care benefit. The reduction resulted in some people in adult care homes not meeting the Special Assistance income eligibility criteria, and thus losing Medicaid eligibility. However, the state grand-fathered them for continued coverage.

  6. There are some exceptions, a discussion of which is beyond the scope of this report.

  7. The information in this section draws heavily from Elise Bolda's report: Initial report on North Carolina domiciliary care policy. The Long Term Care Resources Program, Duke University Center for the Study of Aging and Human Development (1991).

  8. Hawes, C., Lux, L., Wildfire, J., Green, R., Packer, L. E., Iannacchione, V., and Phillips, C. Study of North Carolina domiciliary care home residents. (February 15, 1995). Report submitted to the North Carolina Department of Human Resources.

  9. One respondent noted that some owners believe a minimum of 60 beds are needed to make a profit.

  10. One respondent stated that people on Medicaid could not afford private rooms because Medicaid only pays for services, not for lodging.

  11. Elise Bolda's report: Initial report on North Carolina domiciliary care policy. The Long Term Care Resources Program, Duke University Center for the Study of Aging and Human Development (1991).

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