Minimum Needs Requirement Update to the Eligibility Requirements for Managed Long Term Care Enrollment

The Situation Report | July 7, 2025

Effective September 1, 2025, the New York State Department of Health (Department) will implement a change in the MLTC Program eligibility criteria for MLTC Partial Capitation (MLTCP) and Medicaid Advantage Plus (MAP) plans. The new program eligibility criteria are referred to as Minimum Needs Requirements and do not apply to enrollment in Programs of All-Inclusive Care for the Elderly (PACE) plans.

The Minimum Needs Requirement applies to MLTCP and MAP plan enrollment criteria beginning on and after September 1, 2025. Individuals enrolling into a MLTCP or MAP plan on or after September 1, 2025 must meet the Minimum Needs Requirements at initial and subsequent assessments in addition to the need for Community Based Long Term Services and Supports (CBLTSS) for more than 120 days. Individuals enrolled in any MLTC plan prior to September 1, 2025, will be granted Legacy Status and will not be subject to the new Minimum Needs Requirements at reassessment if they remain continuously enrolled in any MLTC plan. This policy does not change PACE enrollment eligibility criteria; however minimum needs criteria for Personal Care Services (PCS)/Consumer Directed Personal Assistance Services (CDPAS) applies to members initially seeking services after September 1, 2025.

Note: While PACE is not subject to the Minimum Needs Requirement for enrollment, individuals with PACE will be granted Plan Legacy and Service Legacy following the same process as other MLTC plans. This status will allow individuals, enrolled in PACE prior to the implementation, to transfer within MLTC lines of business.

Read the full guidance here. 

HCANYS will provide uodates on any additonal changes to the Minimum Needs Requirement as they become available.