DOH Monthly Briefing – Finance – January 2018

Carl J. Pucci in Finance & Reimbursement

DOH held its monthly briefing earlier today. The following summarizes the topics discussed. 

2018-19 Executive Budget Proposals 

  • Care Management - DOH confirmed the Executive Budget that proposes to allow a long term care enrollee in the nursing home be disenrolled from the managed long term care plan and placed in fee-for-service after a consecutive period of six months or more. Among other things, NYSHFA will be following up with membership regarding the next steps once enrollees revert back to fee-for-service. Additionally, inquiries will be sent to DOH on the administrative, payment and contracting process for the nursing facility. This will be discussed further with DOH next week at a subsequent meeting.
  • Capital Streamlining Rate Reduction – This proposal establishes a Capital Workgroup which will review capital regulations and rate methodology to achieve a proposed 1% reduction in capital expenditures to hospitals and residential nursing facilities (est. at $7.6M for SNF’s) in capital payments for state fiscal year 2018/19. Absent a coordinated plan by the workgroup to reduce capital expenditures, the Commissioner of Health is authorized to reduce capital rates by 1%, during the state fiscal year.
  • Quality Penalties – This proposal imposes an additional 2% penalty on facilities which fall into the fourth and fifth NHQI quintiles over a two-year period. Therefore, if a SNF falls into quintile 5 two years in a row, or drops from quintile 4 to quintile 5 over a two year period, they will be affected by the penalty. The estimated $20M budget savings would affect approximately 92 SNF’s. DOH will share the impacted provider list with the Associations. A subsequent meeting with DOH is being scheduled for next week to further discuss. 

Case Mix – This proposal would result in an estimated $15M in budget savings related to increases in case mix. DOH compared annual increases under the PRI system (2004-06) with the MDS system (2012-17) and noted significant annual increases (2%/year PRI vs 5%/year MDS). In addition, they noted OMIG MDS audit recoupments more than doubled ($30M in 2014 vs $12M in 2012) which raised concerns with respect to the case mix validity. DOH’s goal is to achieve half of the 2014 OMIG recoupment ($15M) over the state fiscal year 2018/19. According to DOH legal, legislation is not necessary to implement this reduction (nor was it part of the 2018/19 Executive Budget.)

1% Restoration 

Although no timeline for payment was given, DOH outlined a proposed payment plan for the four-year cumulative $280M owed for the 1% Restoration. DOH would remit $140M in the first fiscal year approved, followed by $70M in payments each of the next two fiscal years.

Quality Pool

DOH is beginning implementation of the Nursing Home Quality Pool (NHQP), enacted in the 2010/11 State Budget as a consequence of the recent State Supreme Court decision favoring the State. DOH recognizes the challenges associated with four years’ worth of NHQP retroactivity, and is offering possible implementation options. The Department stressed that since the NHQP is budget neutral, and cannot impact the Global Cap, any monies paid out to providers must be equal to monies recouped. NYSHFA has just received the facility-specific impacts of the four-year period and will provide input to DOH at the separately scheduled Quality Pool meeting referenced above. Attached is the DOH Quality Pool outline with more details. 

January 1, 2018 Rates

The 1/1/18 rates are still with DOB, and should be released in the near future. They include the July 2017 MDS update, the attested 2018 capital rates and the minimum wage adjustment for both employees and contracted staff. DOH committed to updating the benchmark rate in a timely manner.

Advanced Training Initiative (ATI)

The ATI Application Surveys have been completed and approved by DOH in advance of the anticipated $46M funding. The payment calculations for 223 facilities (all approved), are under DOH review, then must go for DOB approval. DOH is expected to adjust rate premiums for MLTC plans, who, in turn, would issue lump-sum payments to eligible providers within 30 days. The goal is to fund the ATI by 3/31/18. DOH indicated that a VBP-one contract addendum must be in place to receive ATI funding. Since the target date for lump sum payment is March 31, 2018, applicants will be given a full 12 months to complete training (i.e., 3/31/19).

2016 CRA Reconciliation

DOH has posted CRA facility-specific data on its website (under “Nursing Home Rates”). The respective payment adjustment is in cycle #2106 (check date 1/1/18 and release date 1/17/18).

Nursing Home Remittance Reports

With the discontinuance of the FMG FoxPro Reports, DOH is seeking an alternative software solution and has put such a request into EMEDNY. No further timetable has yet been provided by DOH. Although the weekly remittance report includes recoupment detail, the Associations again stressed the unavailability of retroactive adjustment details during this time. 

NYSHFA/NYSCAL CONTACT:

Carl J. Pucci
Chief Financial Officer
518-462-4800 x36