DOH Monthly Briefing – Finance – November 2018

Carl J. Pucci in Finance & Reimbursement

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

1/1/19 Notice Rates

DOH released the 1/1/19 notice rates on 11/1/18, as scheduled. (Please reference NYSHFA EXTRA, dated 11/2/18 for details.) In addition to the initial 2019 capital rate, the notice rates contain a 1.5% increase to the operating rate for all providers. (contained in Line 13 of the summary rate sheet.) The 1/1/19 published rate (expected mid-January 2019) will be updated for the July 2018 CMI.

1% Restoration/NHQI

The combined 1% Restoration/NHQI package has been approved by DOB and is currently slated for Medicaid cycle #2152 (expected release date 12/5/18). 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. A DAL as well as a specific DOH website link will be posted with further details.

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. The MDS data upload period (10/3 – 10/26/2018) has been completed, and the resulting data is now being analyzed. If members still have unmatched records, they should contact DOH via the address as soon as possible to resolve. DOH remains committed to the CMI Workgroup going forward to analyze MDS historical trends and provide input with respect to future Case Mix periods.

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 have been issued via 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. The 2% QP reduction is also contained in line 13 of the summary rate sheet.

Gateway System

DOH has issued a DAL with details regarding their migration from the HCS System to the Gateway System, specifically for upcoming 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.

2018 NHQI

NHQI data should be released by the end of 2018. Further details will be forthcoming.

FFS Transition

Limit the Nursing Home Benefit in Partially Capitated MLTC Plans to Three Months

  • DOH submitted request to amend the 1115 Waiver and limit the nursing home benefit in Managed Long Term Care Plans to three months.
  • After three months, the beneficiary will be involuntarily disenrolled and coverage for nursing home services will be covered by Medicaid fee –for- service IF individual qualifies for institutional Medicaid coverage.
  • Draft letter sent to CMS requesting amendment in September 2018
  • Public comment period extended to November 23, 2018
  • When CMS approves amendment DOH will set up stakeholder meetings to discuss how to operationalize
  • Once amendment is approved, members will receive a Medicaid Choice (MAXIMUS) notice as well as a notice that their benefit is being changed back to fee – for –service.

 CRA Reconciliation

The 2017 Cash Receipts Assessment Reconciliation has been sent to DOB for approval and is expected to be finalized during fourth quarter 2018. The CRA per diems will be updated to a 2017 base (from 2016) for inclusion in the 1/1/19 Rates.

OMIG Audits

The 2015 OMIG Audits are now complete and DOH is presently analyzing audit results. The 2016 audits have commenced in the Buffalo region.

Minimum Wage

DOH is reviewing the 2019 survey data for inclusion in the January 2019 rates. The 2017 minimum wage reconciliation should be released to facilities by the end of November.

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


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