DOH Monthly Briefing - Finance – June 2018

Carl J. Pucci in Finance & Reimbursement

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

Quality Pool Implementation (NHQI)

As reported in the May DOH Briefing update, the NHQI implementation will consist of a retroactive adjustment for years 2013 - 2016, followed by a prospective adjustment for 2017 and forward. (Note: should CMS SPA approval occur later in the year, the potential for a five-year retroactive adjustment exists, as the 2017 RHCF data will have been submitted and received.)

  • Retroactive Adjustment:
    DOH will calculate the retroactive effect of the NHQI for providers receiving monies, and lump-sum adjustments will be processed through eMedNY. For providers owing monies, DOH will first offset the initial 1% Restoration payment (as noted below). DOH has shared the NHQI retroactive rate run (which includes the 1% Restoration offset) with NYSHFA for review.
  • 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 previously, 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 eMedNY in a Medicaid cycle, and again will incorporate both FFS and MLTC days. DOH is currently awaiting State Plan Amendment (SPA) approval of the 1% restoration.


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. NYSHFA provided comments related to both the FD criteria, as well as exclusion of Medicaid specialty days (and associated Medicaid revenue) from the calculation. Once the FD criteria has been finalized, DOH will file the CMS SPA.

ATI 

DOH funded year three of the ATI to the MLTC plans in mid-May. Most plans have yet to distribute lump-sum payments to eligible providers. DOH is reviewing the timetable for further MLTC distributions to eligible providers. NYSHFA has obtained the master list of ATI funding by MLTC for member reference.

Case Mix Workgroup

Per the 2018/19 Executive Budget, a Case Mix Workgroup will be established to discuss CMI streamlining in an effort to achieve $15M in savings. DOH is not committing at this time to a July 25, 2018 census picture date pending CMI Workgroup discussions which are slated to take place in the upcoming weeks. DOH is 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. 

OMIG Audits 

DOH will be distributing the 2015 draft audit reports in the next few weeks. Following a 30-day response period, DOH will review provider comments prior to releasing the final reports. The 2016 audits for both census periods will commence once the 2015 audits are finalized. 

Universal Settlement

The Division of Budget will be reviewing DOH’s submission on Universal Settlement this summer. Once DOB approves, the funds could be released as early as September.

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. These discussions will continue after the conclusion of legislative session.

RHCF Deadline

DOH is seeking comments regarding recent changes to the cost report certifications. NYSHFA Payment for Services Committee has been alerted and will provide input. Reminder that the filing deadline is Monday, July 16, 2018.

Minimum Wage

DOH is still working on a survey to providers to match minimum wage requested funding with actual spending. Providers will be asked to attest to funds that were included in the minimum wage adjustment.

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