ALFA unhappy with VA’s proposed definition of ADLs

The revised definition of activities of daily living (ADLs) proposed in the Jan. 23 Federal Register by the U.S. Department of Veterans Affairs (VA) to qualify for its Aid and Attendance benefit is “excessively limiting,” according to the Assisted Living Federation of America (ALFA). Comments on the proposed rule are being accepted until March 24.

ALFA, in a letter signed by the organization's senior vice president of public policy, Maribeth Bersani, said it agrees with most of the VA’s proposed changes for eligibility, including a 36-month look-back period and a revision that defines net worth as income and assets. The organization commented on three parts of the proposed rule, however.

ALFA said that the ADL definition would no longer recognize two motivators for older adults who move into assisted living or memory care communities: the inability to ambulate on their own and the inability to administer their own medications. Seventy-five percent of assisted living residents have at least two chronic conditions that could affect their ability to ambulate without assistance, Bersani wrote. The average assisted living resident, she added. takes as many as nine drugs every day, and 77 percent of them—especially those who have cognitive impairments—need help doing so.

ALFA recommended that the VA use the definition of basic ADLs from the Medicare Benefits Policy Manual, Chapter 16, Section 110 [PDF]: “Custodial care serves to assist an individual in the [ADLs], such as assistance in walking, getting in and out of bed, bathing, dressing, feeding, and using the toilet, preparation of special diets, and supervision of medication that usually can be self-administered.”

Two other comments

ALFA also asked the VA to address the needs of residents who choose to live in independent living communities and have their care and services provided by the community or a third-party provider separately contracted for by the veteran. “Just because someone lives in independent living does not mean they are living ‘independently,’ ” Bersani wrote. Because the Fair Housing Act and the Americans With Disabilities Act consider an independent living apartment to be someone’s home, she added, residents are entitled to bring in the services and supports they need to age in place.

ALFA also recommended that the VA consider using data from Genworth’s annual Cost of Care Survey as an alternative to data from the MetLife Mature Market Institute (MMMI) Survey of Long-Term Care Costs to determine maximum reimbursement of hourly wages for home health aides, as proposed, and to consider variations in pay rates across the country. ALFA says it is unclear that MetLife will continue to conduct its survey; indeed, a note on the MMMI website says that the institute stopped publishing new research and materials on June 1, 2013.

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