DOH Monthly Briefing – Finance – May 2018

Carl J. Pucci in Finance & Reimbursement

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

Quality Pool Implementation (NHQI) 

The NHQI implementation will consist of a retroactive adjustment for years 2013 – 2016, followed by a prospective adjustment for 2017 and forward.

  • Retroactive Adjustment:

DOH will calculate the four-year retroactive effect of the NHQI for providers receiving monies. A lump-sum adjustment will be processed through eMedNY sometime in late August or early September. For providers owing monies, DOH will first offset the initial 1% Restoration payment (as noted below). DOH will share the NHQI retroactive rate run (which will include the 1% Restoration offset) with NYSHFA for review in the near future.

  • Prospective Adjustment:

Going forward, DOH will match the respective year’s Quality Measure (QM) and Medicaid days (i.e., 2017 QM x 2017 days applied to 2018 rates). This will necessitate a change to the CMS SPA on file, which currently calls for a subsequent reconciliation of the Medicaid days.

Once the 2017 Medicaid days are reported (via the 2017 RHCF filing), DOH will finalize the adjustment to the 1/1/18 rates for the 2017 NHQI.

Both the retroactive and prospective NHQI adjustments will incorporate both FFS and MLTC Medicaid days, so as not to involve the MLTC plans in the NHQI Reconciliation process.

1% Restoration

DOH will fund the earliest two fiscal years of the 1% restoration ($140M) concurrently with the NHQI retroactive adjustment. As reported last month, DOH will “double up” the 1% Restoration payments over the next four state fiscal years (2018-2021) until current. Payments will be made via lump-sum through an eMedNY in a Medicaid cycle, and again will incorporate both FFS and MLTC days.

2% QP Penalty

DOH will base the initial QP Penalty on the 2016 and 2017 quality data. A 2% rate reduction will be applied to the combined total rate (operating and capital) going forward for affected facilities. Per the Executive Budget, Financially Distressed (FD) facilities shall be exempted from the penalty. At the Department’s request, NYSHFA is working with the DOH to establish FD exemption parameters.

Benchmark Rates

DOH expects the 1/1/18 Benchmark Rates to be posted later this week. Note: neither the NHQI or 2% QP Penalty adjustments will be included in this update to the Benchmark Rate. DOH anticipates including both adjustments in the Benchmark Rate once finalized.

Bedhold

DOH will respond to comments raised by the Associations during the recent allotted comment period. The Department will continue to pay the existing bedhold rate until further direction is obtained from the Governor’s office and DOB. 

ATI

Year three payments of the ATI are being funded through the MLTC plans, who, in turn, will have 30 days to distribute a lump-sum payment to eligible providers. A DAL is being drafted with further instructions, and payments to providers are expected by the end of second quarter. 

DOH indicated that next year’s ATI funding (assuming continued CMS SPA approval) will revert back to direct payments from DOH to eligible providers (as in years one and two).

RHCF Deadline

Reminder that the filing deadline is Monday, July 16, 2018.

MDS Look-Back Period

DOH is not committing at this time to a July 25, 2018 census picture date. They are keeping their options open and may not disclose specific biannual dates in advance, as per past practice. We will continue to advocate for transparency on the dates of assessment periods.

NYSHFA will keep members posted on these important rate-setting issues going forward. 

NYSHFA CONTACT: 

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