Overview
Our preliminary analysis of MassHealth’s payments to Old Colony Elder Services (OCES) for adult foster care (AFC) during our audit period found that MassHealth paid $326,355 of AFC claims to OCES for members for dates of service on which OCES also received payment from the Executive Office of Elder Affairs (EOEA) for the members to receive home care. All of the members were participating in EOEA’s Frail Elder Waiver program (FEW), and although the payments were allowable, the Office of the State Auditor (OSA) believes that some of the services may be duplicative.
Home care services provided under FEW include companion care and home-delivered meals. Companion care consists of nonmedical services provided by a caregiver, such as socialization, meal preparation, laundry, shopping, escorting to appointments, and light housekeeping tasks, that are incidental to a member’s care and supervision. These services are similar to AFC that some MassHealth members have already received. For example, MassHealth members’ AFC caregivers are already required to provide meals. Moreover, certain services that are part of companion care—specifically, meal preparation, laundry, shopping, and light housekeeping—are considered instrumental activities of daily living (IADLs), which are already provided under AFC regulations. Therefore, claims paid for a member to receive both AFC and home care on the same day may include payments for duplicative services.
OSA did not perform audit procedures that would allow us to determine to what extent, if any, the $326,355 that MassHealth paid OCES for AFC may have been for services that were included in the payments EOEA made to OCES for home care. However, OSA believes that MassHealth should further examine this issue and determine whether there are opportunities for cost savings.
The Executive Office of Health and Human Services and MassHealth commented on this issue:
Home delivered meals and companion services provided under EOEA’s Home Care program are not duplicative of MassHealth AFC services. The EOEA Home Care program’s Home Delivered Meals service provides meals delivered to the home and the EOEA Home Care Program’s Companion Service provides non-medical socialization. Conversely, MassHealth AFC services provide medically necessary assistance with personal care delivered by a live-in caregiver, and it does not include coverage of—nor do the rates for AFC include any costs associated with—home delivered meals or socialization (i.e. companion services). . . . Neither of these Home Care program services provide assistance with personal care and the rates for MassHealth AFC services do not include any costs associated with meals or socialization.
As noted above, OSA’s review of MassHealth regulations seemed to indicate that some of the services provided under the Home Care and AFC programs could be duplicative. For example, Section 408.435(D) of Title 130 of the Code of Massachusetts Regulations (CMR) states that in order for a member to be in a qualified setting, an AFC caregiver must provide him/her with three daily meals served at regular intervals, as well as snacks. To OSA, the requirement of providing regular daily meals to members under AFC appears, to some extent, to be duplicative of the home-delivered meals provided under EOEA’s Home Care program. Further, although OSA acknowledges that under the Home Care program, companion services include nonmedical socialization, they also include IADL-type services such as meal preparation, laundry, shopping, escorting to appointments, and light housekeeping tasks as defined in 651 CMR 3.02. In comparison, IADLs provided under the AFC program in accordance with 130 CMR 408.402 include basic tasks such as meal preparation, laundry, shopping, transportation, and housework, which appear to be duplicative of those provided under the Home Care program. Therefore, OSA believes that it would be prudent for MassHealth to further examine this issue and determine whether there are opportunities for cost savings.
| Date published: | June 29, 2020 |
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