DOH Monthly Briefing – Finance – August 2019

Carl J. Pucci in Finance & Reimbursement

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

July 1, 2019 Rates 

The 7/1/19 rates are under Executive review. No further updates were given. 

Case Mix Workgroup 

The Case Mix Workgroup recommendations were submitted to DOH on 6/28/19 (see member mailing). As the 7/1/19 rates are still under review, it is still uncertain as to DOH's response to the Workgroup recommendations. 

Bedhold Revised Regulations 

The revised bedhold regulations were adopted, effective 5/29/19 (see member mailing). NYSHFA has been compiling members' bedhold questions and has forwarded them to DOH. DOH is formulating a Frequently Asked Questions (FAQ) based on questions submitted by the Associations and Providers. The FAQs are close to finalization and should be released in the near future. Members should continue to email their bedhold questions to both as well as to NYSHFA. 

2017 CRA Reconciliation

The 2017 Cash Receipts Assessment Reconciliation is under review with DOB and should be finalized during early fourth quarter 2019. The CRA per diems will now reflect actual 2018 provider payments versus the previously announced plan to update the paid per diem from 2016 to 2017. The CRA per diem will again be updated to the 2019 rates, upon final approval. This process should minimize the reconciliation effect, as well as lead to more timely reconciliations going forward. 

2018 NHQI/1% Restoration/2% QP Penalty 

The 2018 NHQI data results have been posted to the DOH website. DOH has indicated it would prepare the 2018 NHQI, 1% Restoration, and 2% QP Penalty rate packages for submission to DOB in early September (following finalization of the 2018 RHCF data.) DOH also plans on again offsetting the NHQI adjustment with the 1% Restoration payments, similar to last year. Facilities who are either coming off the 2018 2% QP Penalty or being added to the 2019 2% QP Penalty will have their 1/1/19 rates retroactively adjusted. DOH will share drafts of the respective rate calculations with the Associations in advance of issuing. 

Advanced Training Initiative (ATI) 

DOH is finalizing the ATI surveys for both 2018 and 2019. Additional training options have been added. DOH will prepare two separate calculations and fund two years to bring ATI to current status. Eligibility will be determined utilizing the respective 2017 and 2018 RHCF Sch P retention calculation. Since the MLTC to FFS transition has not yet been approved, ATI funding may once again flow through the MLTC plans during 2019. 

EO-38 Website

DOH is in discussions with their counsel regarding the EO-38 website updates. The form on the current website still requires a waiver for Executive salaries exceeding $199,000, despite the court ruling excluding non-Medicaid funds from the calculation (and this potentially negating the waiver requirement). NYSHFA continues to follow-up with DOH Legal seeking guidance related to the EO-38 filing. A separate member mailing will be issued once EO-38 guidance has been received. 

FFS Transition 

DOH is responding to CMS request for additional information (RAI) related to the transition back to FFS. DOH is still in discussions with CMS. No further updates were provided. 

IGT Payments 

IGT payment calculations are being finalized, and still await CMS SPA approval. As in prior years, the IGT funding will be split into two payments (tentatively September 2019/March 2020). 

Universal Settlement (US) 

DOH indicated that the fifth and final payment of US could again take place as early as Fall 2019. 

OMIG MDS Audits 

The 2016 audit field work is complete. DOH/OMIG are resolving a data issue prior to issuing final audit reports. The 2017 OMIG MDS audit plan is currently being developed.

Capital Attestations 

A DAL outlining this years’ capital attestation process should be issued within the next week or so. Once issued, providers will have a 30-day response time to ensure timely issuance of the capital rates.