DOH Monthly Briefing – Finance – December 2016

Carl J. Pucci in Finance & Reimbursement

DOH held its monthly briefing earlier today. The following is a brief summary of the topics of discussion:

1% Restoration
DOH has shared its proposed methodology to process the 1% restoration, which encompasses rate years 2014/2015 ($140M), as well as rate year 2016 ($70M). The methodology would proportionally increase the direct and indirect prices to achieve the required funding based on a facility’s total revenue percentage to statewide revenue percentage. The restoration dollars, once in the base prices, would thus be affected by both Case Mix Index (CMI) and Wage Equalization Factor (WEF) going forward.

NYSHFA shared the proposed calculations with its Payment for Services Committee earlier today, and is in general support of the methodology, as are the other statewide and regional associations. The 1% Restoration is still pending CMS approval, thus DOH has not given specific payment timelines. A DAL with further information is expected.

Minimum Wage
The rate increase attributable to the minimum wage methodology, still pending CMS approval, is slated to be incorporated into the January 1, 2017 rate package for both SNFs and ALPs. The minimum wage workgroup will reconvene in early 2017 to discuss preparations for the April 2017 rate impacts. Rate adjustments will be incorporated into the miscellaneous adjustment line on the rate sheets.

Rate Packages
Updates to the following rate packages were noted by DOH:

•    July 2016 rates: updated for January 2016 case mix paid via cycle 2047, check release November 30, 2016.

•    January 2017 rates: At DOB for approval. Rates will be updated for July 2016 case mix, minimum wage (once CMS approves) and 2017 capital attestations. Expect rates mid-January 2017. Note: DOH noted that it has achieved its goal of issuing scheduled rates updated with the most current MDS submissions.

•    2015 Cash Receipts Assessment: Presently at DOB, expect January/February processing. Note: paid per diem will remain at 2014 base thru 2017 rate year (NYSHFA continues to advocate for a 2015 updated base).

Advanced Training Initiative (ATI)
Rate package is in final review, DOH expects to pay by year-end. Performance measures/ benchmarks are in discussion between DOH and the associations.

Quality Pool
2013 – 2015 Quality Pool continues to be delayed pending litigation. Regulations have been approved.

Transportation Carve-Out
2007 Base year medical transportation costs are to be removed from the pricing rates. CMS has approved the state plan amendment, and regulations are in process. Expect during first quarter 2017.

OMIG Audits
The 2012 adjusted audit rates are complete and should be posted in the next few days. The 2013 audited rates are currently at DOB and should be processed sometime in January. The 2014 audits are still in process, as DOH and OMIG continue to work towards streamlining future audits so as to authorize release of the 5% CMI cap where applicable, as well as minimize retroactivity issues with the MLTC’s going forward. DOH will be issuing further OMIG audit guidelines to better assist facilities with the MDS submission process.

Capital Attestation
DOH received 350 capital attestations, and have approved approximately 160 to date, with 40 rejections. The remaining 150 attestations remain under review, as DOH attempts to finalize by late next week. Those attestations still not approved may be delayed until April 1, 2017. DOH may then carry-forward a facility’s 2016 capital rate into 2017 pending final attestation determination.

DOH will continue to keep members updated on these issues going forward.

Carl J. Pucci
Director, Finance & Reimbursement
518-462-4800 x36