The traditional continuing care retirement / life plan community (CCRC) model offers independent seniors the security of access to a higher level of care such as assisted living and skilled nursing should their care needs change, along with the resources of a CCRC, on a single campus. The emerging “continuing care at home” model offered by community operators, however, gives older adults many of the same benefits of campus-based CCRCs, including care management, transportation and the like, with the added benefit of “aging in place” in one’s own home, in the community at large. This model is particularly appealing to younger, healthier seniors who are not yet ready to move onto a campus. Or they may have negative perceptions of living on a separate campus setting exclusively with other older adults.

The CCaH model has moved from the conceptual phase in several states into actual proposals and communities. There are a few potential concerns or risks — beyond actuarial or financial — that a sponsor may encounter with this model. 

Technology risks.  For older adults living “off campus” in their own homes, the CCRC may rely on technologies such as remote monitoring and communications to be the community’s “eyes and ears” for tracking members’ health and well-being. If those technologies are deployed, then the operator will have to ensure that the technologies, and the data being transmitted to and from a senior’s home, are protected against any cybersecurity or other breaches, and that they otherwise are compliant with HIPAA and data privacy laws. Any unauthorized disclosure or breach may have significant, collateral reputational harm to the sponsor of the CCRC, whose offering, after all, is intended to be a form of insurance against life’s risks. 

Care management risks. Although technologies no doubt will enable the CCRC’s oversight of seniors remotely, arguably, no substitute exists for actually observing residents on a daily basis.  Sponsors will have to consider how to provide effective care management services to residents living off campus. 

Census stability risks. CCRC members who remain in their own homes may not cultivate the kind of interpersonal ties that help cement their bond to the CCRC. As such, those older adults may be more prone to leave the community and terminate the agreement. That potential instability should be factored into the financial modeling, among other aspects of the community‘s operations.

Health and safety risks. Living in one’s own home may limit the extent to which an older adult interacts with fellow CCRC members and staff members, or takes advantage of the amenities and activities more readily available and convenient on the campus. If it is true that independent living residents remain healthier, and for longer periods of time, because of the socialization and engagement with activities they experience while on campus, that benefit may not be fully realized by those choosing the CCaH model.  The sponsor should try to engage those residents with the CCRC despite their living off campus. 

What is more, CCRC residences typically are designed with rooms and spaces to minimize the risk of falls, to accommodate wheelchairs and other devices often used by older adults to aid mobility, and to otherwise enhance the physical safety of senior residents. By contrast, the senior who chooses the CCaH model may not have “senior-friendly” safety features built into the home. Consequently, although many older adults choosing this option may be relatively healthy on admission, they may be at greater risk of the incidental hazards found in the typical home environment.

Level-of-care transitions risks. In my earlier article, I had discussed some of the challenges that a CCRC faces when the time comes for transitioning residents to a higher level of care. A resident’s resistance to moving may be even more pronounced when he or she has to leave the home where he or she may have lived for much or all of his or her adult life.

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We now are on the cusp of this new CCaH model, which offers a promising alternative to the traditional CCRC campus and other competing models for senior living. Because this model is largely untested, however, operators need to be mindful of the possible risks that may emerge and plan accordingly.

Brian McGovern is a partner at Crowell & Moring’s New York office. He provides legal counsel and representation to healthcare and nonprofit clients, including continuing care retirement communities, nursing homes, home care agencies, hospices, hospitals, pediatric facilities and managed care plans.

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