DOH Monthly Briefing – Finance – October 2018

Carl J. Pucci in Finance & Reimbursement

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

MDS Case Mix Picture Dates

As previously reported, DOH will be analyzing data from both the April 25, 2018 and July 25, 2018 collection periods. DOH has not yet disclosed how the data from both picture dates will be blended but has confirmed that the statewide effect will not exceed the $15M savings per the Executive Budget. The MDS data upload period (10/3 – 10/26/2018) is underway, however DOH is currently experiencing technical issues which are expected to be resolved in the next few days. DOH will evaluate whether more time will be allotted to providers for MDS submissions. DOH remains committed to the CMI Workgroup going forward to analyze MDS historical trends and provide input with respect to future Case Mix periods. 

1% Restoration/NHQI

The combined 1% Restoration/NHQI package has been approved by DOB. The "Good Cause" waiver is now in place, which technically allows for retroactive funding beyond the two-year stipulation, as well as lump-sum funding vs. a per diem adjustment methodology. (Note: The NHQI retroactive period will now encompass 2013 through 2017 (5 years to include the latest RHCF data). DOH will fund the earliest two fiscal years of the 1% Restoration ($140M) concurrently with the NHQI retroactive adjustment through 2021/22, then $70M going forward. The 1% Restoration is allocated based on an individual nursing home's Medicaid revenue divided by total Medicaid revenue. DOH is finalizing the payment template and will provide the Associations with a draft DAL outlining both the 1% and NHQI calculations, as well as a summary of the combined 1%/NHQI effect upon each facility. For those facilities still owing moneys net of the 1%, a recoupment calculation (15% of weekly Medicaid check) and timeline will be provided. 

2% Quality Pool (QP) Penalty

The 2% QP Penalty, which is based on the 2016 and 2017 NHQI data, will be effective retroactive to the 7/1/18 rates (including the benchmark rates). The revised rates will be issued with Medicaid cycle #2145 (check release date 10/17/18). 92 providers are affected by the penalty and will absorb a 2% rate reduction. Those facilities that DOH deems financially disadvantaged (now updated to 2017 negative operating margin and negative fund balance) will be exempt from the initial penalty period. For recent ownership changes occurring during 2017 (as evidenced by a Part 1 RHCF filing), DOH may consider the previous owners 2016 RHCF data to determine the FD exemption. DOH may allow additional discretionary exemptions. 

Capital 

The 2019 Capital Attestation forms are required to be submitted by this Friday, October 12, 2018. The attestation filing is mandatory regardless if a facility is contesting its initial 2019 capital rate.

Universal Settlement (US)

The fourth-year payment of the US has been approved by DOB for payment. DOH expects to release the payment to the trustees within the next week. The $10M special appeals fund (i.e., Bucket 9) is included.

Gateway System

DOH will be issuing a DAL in the near future providing details regarding their migration from the HCS System to the Gateway System, specifically for future rate processing packages. Specific questions related to historical information access, and timing of future rate postings on the Gateway System have yet to be addressed.

FFS Transition

  • DOH is working to obtain CMS approval of the 1115 Amendment.
  • The Department has requested CMS expedite the process and plans to have regular contact with CMS to advance the initiative.
  • Once DOH confirms next steps and implementation dates with CMS, further guidance and additional stakeholder meetings will be scheduled.
  • The Department is considering options related to whether SNF's should continue involvement in various VBP levels in a FFS environment. NYSHFA will be providing further input to DOH. 

CRA Reconciliation

The 2017 Cash Receipts Assessment Reconciliation has been sent to DOB for approval and is expected to be released within the next 30 days. The CRA per diems will be updated to a 2017 base (from 2016) for inclusion in the 1/1/19 rates.

Transportation Adjustment

The duplicate transportation adjustment has been approved by CMS. The statewide prices will be adjusted accordingly, and the estimated impact is approximately $0.08/day for the under 300 bed peer group, and $0.18/day for over 300 beds. This adjustment has also been processed via Medicaid cycle #2145 (check release date of 10/17/18).

OMIG Audits 

The 2015 OMIG Audits are now complete. DOH expects to release the 5% cap for affected providers within the next 30 days. The 2016 audits have commenced in the Buffalo region. 

Shared Savings 

DOH will be issuing further communications related to the program, as well as more detailed filing instructions.

Minimum Wage 

DOH is reviewing the 2019 survey data for inclusion in the January 2019 rates. They continue to work on reconciliation methodology related to the 2018 payments.

Upper Payment Limit / IGT

The 2018 UPL ($225M) is at DOB for approval and will again consist of two payments (Fall 2018 and Spring 2019).

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

NYSHFA/NYSCAL CONTACT:

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