Overview of Virginia’s CCC+ Waiver
The Commonwealth Coordinated Care Plus Medicaid Program (CCC Plus or CCC+) is Virginia’s mandatory managed care program through which state residents of all ages, including those in nursing homes, receive their Medicaid benefits. In addition to medical, behavioral health, and nursing home care, a variety of home and community-based services (HCBS) are available for elderly and disabled persons who at risk of institutionalization (nursing home care). It is through the Commonwealth Coordinated Care Plus Waiver that these long-term care services and supports are made available.
HCBS may include in-home personal care assistance, adult day care, personal emergency response systems, and home modifications for safety and accessibility. Transitional services are also available to assist persons who are currently residing in a nursing home, but can live in the community with Medicaid waiver benefits.
Beneficiaries of the CCC Plus Waiver Program receive all of their benefits via a single Medicaid health plan provided by a managed care organization (MCO). A MCO is essentially a private healthcare company. The MCO has a network of care providers and program participants receive services via these providers. There are several managed care plans from which to choose.
There is some flexibility of providers for persons receiving home and community based services, as some benefits, such as respite care and personal care assistance, may be consumer directed. This means that rather than receive services by the MCO’s network of licensed care providers, a program participant can hire their own caregiver. While this includes adult children, nieces / nephews, grandchildren, and siblings, spouses and parents of minors cannot be hired. A financial management services agency handles the financial aspects of employment responsibilities, such as withholding tax and issuing payments.
The CCC Plus Medicaid Waiver is not an entitlement program, which means meeting eligibility requirements does not equate to immediate receipt of program benefits. Instead, the waiver has a limited number of participant enrollment slots, and when these slots are full, a waitlist for program participation forms.
The Commonwealth Coordinated Care Plus Waiver Program is a 1915(b) Managed Care Delivery System Waiver that operates along with a 1915(c) Home and Community Based Services (HCBS) Waiver. The CCC Plus Waiver includes the former Technology-Assisted Individuals Waiver and the Elderly or Disabled with Consumer-Direction Waiver. The CCC Plus Waiver Program is contained within the state’s CCC Plus Program.
Medicaid pays doctors, hospitals, and other providers in one of two ways, either “Fee-For Service” or “Managed Care”. Under Fee-For Service, Medicaid pays providers directly for each service they provide. Beneficiaries can receive services from any Medicaid-certified provider. Under Managed Care, Medicaid contracts with a Managed Care Organization (MCO). Medicaid pays the MCO a set amount for each beneficiary, rather than for each service provided. The MCO has a network of doctors, hospitals, and other providers and the MCO pays them. Beneficiaries must use providers within the network.
Benefits of Virginia’s CCC+ Waiver
In addition to care coordination, medical benefits, such as preventative care, physician appointments, laboratory work, x-rays, and hospitalization, mental health benefits, and durable medical equipment, a variety of long-term services and supports (LTSS) to prevent nursing home placement are available via the CCC Plus Waiver. An individual care plan will determine which of the following LTSS a program participant will receive.
– Adult Day Health Care – daytime supervision, personal care assistance, and health services in a community-based group setting
– Assistive Technology
– Community Transition Services – to assist with relocating to a private residence from a nursing home (i.e., covering a security deposit and utility set-up fees, moving expenses, purchasing essential household items)
– Home Modifications – also called environmental modifications (i.e., widening of doorways for wheelchair access, addition of grab bars, installing a ramp)
– Personal Care Assistance – assistance with daily living activities, such as bathing, dressing, eating, transferring, and toileting
– Personal Emergency Response System
– Private Duty Nursing
– Respite Care – short-term care to relieve a primary caregiver
Program participants can live in their own home or the home of a loved one. They cannot live in an assisted living residence or an adult foster care home.
Eligibility Requirements for Virginia’s CCC+ Waiver
The CCC Plus Waiver Program is for VA residents who are aged (65+ years old) or under the age of 65 and disabled who meet the following eligibility criteria.
Financial Criteria: Income, Assets & Home Ownership
The applicant income limit is equivalent to 300% of the Federal Benefit Rate (FBR), which increases on an annual basis in January. In 2021, an applicant, regardless of marital status, can have a monthly income up to $2,382. When both spouses are applicants, each spouse is considered individually, with each spouse allowed income up to $2,382 / month. When only one spouse is an applicant, the income of the non-applicant spouse is not counted towards the income eligibility of his/her spouse. Furthermore, monthly income from the applicant spouse can be transferred to the non-applicant spouse as a spousal income allowance, also called a monthly maintenance needs allowance. The maximum amount that can be transferred in 2021 is $3,259.50 and is intended to ensure the non-applicant spouse has a minimum monthly income of this amount. Non-applicant spouses who have their own income equal to or greater than this amount are not entitled to a spousal income allowance.
In 2021, the asset limit is $2,000 for a single applicant. For married couples, with both spouses as applicants, the asset limit is $4,000. When only one spouse is an applicant, the assets of both the applicant and non-applicant spouse are limited, though the non-applicant spouse is allocated a larger portion of the assets to prevent spousal impoverishment. (Unlike with income, Medicaid considers the assets of a married couple to be jointly owned). In this case, the applicant spouse can retain up to $2,000 in assets and the non-applicant spouse can keep up to $130,380. This larger allocation of assets to the non-applicant spouse is called a community spouse resource allowance.
Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.
Assets should not be given away or sold under fair market value within 60-months of long-term care Medicaid application. This is because Medicaid has a look back rule and violating it results in a penalty period of Medicaid ineligibility.
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take their home. Fortunately, for eligibility purposes, Virginia Medicaid considers the home exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has “intent” to return to the home and his / her home equity interest is no greater than $603,000. Home equity interest is the current value of the home minus any outstanding mortgage.
– The applicant’s spouse lives in the home.
– The applicant has a child of any age who is disabled or blind living in the home.
– The applicant has a dependent child under 21 years old living in the home.
To learn more about the potential of Medicaid taking the home, click here.
Medical Criteria: Functional Need
An applicant must require either a nursing facility level of care (NFLOC) or hospital level of care. The tool used to determine if this level of care need is met is the Virginia Uniform Assessment Instrument (UAI). One’s ability / inability to complete their activities of daily living (i.e., transferring from the bed to a chair, mobility, bathing, toileting, eating) is considered. One’s living situation, physical health, and relevant to some persons with Alzheimer’s disease or a related dementia, behavioral issues, such as regular attempts to leave one’s home or removal of one’s clothes in inappropriate places, are also considered. A diagnosis of dementia in and of itself does not mean one will meet the NFLOC. For an applicant to meet the hospital level of care need, a medical device, such as a mechanical ventilator, to make up for the loss of a critical body function is required. Furthermore continuing and significant nursing care to prevent death or increased disability is needed.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for Virginia Medicaid. There are a variety of planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.
Virginia has a Medically Needy Medicaid Program for applicants who have high medical expenses relative to their income. Also known as a “spend down” program, applicants are permitted to spend “excess” income on medical expenses and health care premiums, such as Medicare Part B, in order to meet Medicaid’s income limit.
When persons have assets over the limits, there are many options. Irrevocable Funeral Trusts are pre-paid funeral and burial expense trusts that Medicaid does not count as assets. Medicaid asset protection trusts are another option that protects assets from Medicaid’s asset limit, as well as protects them from Medicaid’s estate recovery program. Still another option is to “spend down” countable assets, such as paying off debt, updating home plumbing and heating, and buying household furnishings.
Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of Medicaid benefits. Professional Medicaid planners are educated in the planning strategies available in the state of Virginia to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid eligibility. Unfortunately, some planning strategies violate Medicaid’s 60-month look back rule and should be implemented well in advance of the need for long-term care. However, there are some workarounds, such as the Modern Half a Loaf, and Medicaid planners are aware of them. For these reasons, it is highly suggested one consult a Medicaid planner for assistance in qualifying for Medicaid when over the income and / or asset limit(s). Find a Medicaid planner.
How to Apply for the Commonwealth Coordinated Care Plus Waiver
Before You Apply
Prior to applying for the CCC Plus Waiver, applicants need to ensure they meet the eligibility criteria. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a free Medicaid eligibility test to determine if one might meet Medicaid’s eligibility criteria. Take the Medicaid eligibility test.
As part of the application process, applicants will need to gather documentation for submission. Examples include copies of Social Security and Medicare cards, bank statements up to 60-months prior to application, proof of income, and copies of life insurance policies, property deeds, and pre-need burial contracts. Unfortunately, a common reason applications are delayed is required documentation is missing or not submitted in a timely manner.
To apply for the CCC Plus Waiver, one should contact the Virginia Department of Social Services in their area. Contact information for DSS can be found here. A functional screening will be completed to determine if one meets the need for long-term services and supports.
For additional information about Virginia’s CCC Plus Program and the CCC Plus Medicaid Waiver, click here. Persons can also call the CCC Plus Helpline at 1-844-374-9159.
Since the CCC Plus Medicaid Waiver is not an entitlement program, there may be a waitlist for program participation. This program is approved for approximately 44,680 beneficiaries per year. In the case of a waitlist, an applicant’s access to a participant slot is determined by date of application.
The Department of Medicaid Assistance Services (DMAS) administers the Commonwealth Coordinated Care Plus Waiver Program.
Approval Process & Timing
The Medicaid application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed even further. In most cases, it takes between 45 and 90 days for the Medicaid agency to review and approve or deny one’s application. Based on law, Medicaid offices have up to 45 days to complete this process (up to 90 days for disability applications). Despite the law, applications are sometimes delayed even further. Additionally, as wait-lists may exist, approved applicants may spend many months waiting to receive benefits.