DOH Monthly Briefing - Finance - July 2018

Carl J. Pucci in Finance & Reimbursement

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

7/1/18 Rates

DOH has posted the 7/1/18 rates to the HCS. The rates, updated for the January 2018 MDS collection period, will be processed in Medicaid cycle 2131 with a check release date of 7/11/18. The Cash Receipts Assessment (CRA) billing per diem has also been updated to reflect 2016 (from 2014). Attached is the related DAL with further details.

RHCF Deadline

The RHCF deadline is Monday, July 16, 2018. Members are urged to test their HCS networks prior to the deadline to ensure timely compliance. Due to intermittent software “run-time error” issues, DOH recommends saving data changes to an additional location (i.e., flash drive) to avoid loss of work. In addition, DOH requests that HCS access for operator and CPA certifications be submitted to RHCF-hcs@health.ny.gov by COB Thursday, July 12, 2018 to ensure timely submission of the cost report on July 16th.

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 MLTC distributions and indicated ATI payment letters to eligible providers are imminent. NYSHFA has obtained the master list of ATI funding by MLTC for member reference.

1% Restoration

DOH has received State Plan Amendment (SPA) approval from CMS for the 1% restoration and is verifying CMS SPA approval of the retroactive portion of the Quality Pool. The combined package will then go to the Division of Budget for approval. The target date at this point is early September for processing. 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.

Quality Pool Implementation (NHQI)

As reported in the June 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.

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.

FFS Transition

  • At this time, there is no update from DOH on the movement of enrollees to Fee for Service. The Department is still working through the administrative process and is still awaiting CMS SPA approval. NYSHFA will be attending a health plan meeting on Thursday, July 12 and will seek further updates at that time.

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 to a July 25, 2018 census picture date. DOH is working internally with an outside contractor to analyze MDS data submitted over the past few years. Once this work is finalized, the Workgroup will convene to review and discuss.

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. NYSHFA will be meeting with DOH to review our suggested MDS audit criteria in the next few weeks.

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.

Upper Payment Limit / IGT

DOH is awaiting CMS approval and still expects to remit two payments slated for this Fall and early Spring 2019.

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.

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