August Managed Care Policy and Planning Meeting Highlights
Updates from the Department of Health (DOH) staff at the August Medicaid Managed Care Policy and Planning Meeting provided more detail about the calculation of Managed Long Term Care (MLTC) rates for the 2016-17 state fiscal year and reviewed the Department's work plan on implementing the Community First Choice Options. As is now the standard, the morning was dedicated to mainstream Medicaid managed care issues with MLTC matters, as well as issues relevant to both mainstream and MLTC, addressed in the afternoon. Highlights of the afternoon discussion are outlined below. The meeting agenda is available here, and section headings link to relevant handouts.
There are several changes in the 2016 rate setting methodology, the most notable one being the elimination of the managed care efficiency adjustment on the community portion of the rate (the adjustment had never been applied to the nursing home part of the rate). LeadingAge NY had argued that such an adjustment was not appropriate for long term care services, and we are pleased to see it absent from the 2016 rate methodology. The state has also made a change in how rates are calculated for plans outside of New York City (regions two, three, and four). Rates in these regions are now based on regionally-specific base costs along with separate risk scores developed for each region. Previously, the base costs for all three regions were calculated as one, and a geographic factor was used to adjust rates by region. The care management component is now calculated on a regionally-specific basis as well.
During the assessment instrument transition (from the Semi-annual Assessment of Members (SAM) to the Uniform Assessment System (UAS)), data from both assessments were blended to calculate risk scores. The scores are now based entirely on UAS data with 2016 rates relying on the most recent assessment performed in Calendar Year 2015. The administrative cap remains at $215. Various other adjustments used in the rate calculation (e.g., IBNR, HR&R, wage parity) will be itemized on Schedule C of the rate packet. While DOH will continue to collect nursing home resident counts during the year, a 12-month nursing home add-on will be calculated based on plan reported counts from March 2016 and six month enrollment trends for the NYC area (three month trend for upstate).
The average premium change when 2016 rates are compared to the prior year is 4 percent, although the largest year-to-year increases are in wage parity and FLSA adjustments. Because DOH changed the rate component display to more closely resemble what Mercer does, the change percentages shown in the handout are not comparable to the display from previous years. The actuarial memo will provide a greater level of detail and will be reviewed at a future plan meeting or a dedicated webinar.
Responding to questions regarding the potential state takeover of Net Available Monthly Income (NAMI) collections, Medicaid Director Jason Helgerson reported that the state continues to discuss the concept with the Centers for Medicare and Medicaid Services (CMS). While CMS is not resisting the proposal, they are trying to understand it because it is the first time they have received such a request from a state.
Planned mid-year adjustments to MLTC rates include an October 2016 adjustment for minimum wage, a December adjustment for CFCO, and updates to nursing home add-on if nursing home resident counts vary significantly from projections. April 2016 draft Program of All Inclusive Care for the Elderly (PACE) rates are expected to be complete in September; October 2016 PACE, FIDA, and Partial Capitation draft rates are expected to be completed in September and October; and Medicaid Advantage and Medicaid Advantage Plus January 2016 draft rates are projected to be completed in December 2016.
July statewide MLTC enrollment reached 174,135 with partial capitated plans representing 90.2 percent of statewide enrollment. The state shared a map showing the number of plans serving each county. Other than six North Country counties that are each served by two plans, three or more plans (Partial-capitation and/or PACE) are approved in all other counties.
DOH reported that the revised PACE model contract has been posted here and that slides from the webinar held on July 22nd on the future of the FIDA program are available here. DOH intends to hold another webinar on Sept. 16th at 2 pm that will focus on FIDA advertising materials and participant success stories. DOH also announced that in response to Zika virus concerns FIDA plans may offer insect repellant as part of their 2017 benefit package. Plans opting to offer coverage are required to notify DOH and CMS by email (alana.stelline@health.ny.gov and mmcocapsmodel@cms.hhs.gov). NHTD/TBI Waiver Transition Stakeholder meetings are scheduled for Sept. 14th, from 1 to 3 pm, and Oct. 4th, from 10 to 12 noon.
A provider survey aimed at better gauging the costs of meeting Fair Labor Standards Act (FLSA) provisions was circulated earlier this month and can be viewed here.
DOH shared their CFCO-related task list for August, which focuses on internal activities including: illustrating how CFCO services will be accessed by fee-for-service populations; developing policies and protocols for CFCO services such as social transportation and assistive technology; finalizing implementation guidance to local districts; and providing guidance and training for Maximus. Responding to questions about plan and provider involvement in the process, DOH clarified that they intend to engage with plans and providers as soon as the preliminary internal work is done, and that their plan includes an October webinar.
Some plans expressed concern that there may not be sufficient time to complete the amount of work required to put necessary systems in place to meet a December 2016 start date. DOH responded to participant questions regarding how individuals would qualify for CFCO services by clarifying that recipients would need to meet the nursing home level of care (or enrollment standard for MLTC) and that the Conflict Free Evaluation and Enrollment Center (CFEEC) would play a key role in qualifying individuals for these services. Participants also requested that DOH provide training to Administrative Law Judges involved in the fair hearing process to ensure their familiarity with CFCO dynamics.
The state released the final first year payment to PPS on Aug. 3rd, and year two first quarter reports are being reviewed by the independent assessor. PPS are able to add new providers to their networks from Aug. 8th through Sept. 8th. DSRIP includes the opportunity for providers to request regulatory waivers, and round three requests were due Aug. 1st. Jason Helgerson said the state had granted hundreds of these waivers and urged meeting participants to raise awareness of their availability with providers. PPS narratives describing project progress and challenges were due Aug. 5th, and on-site audits are slated to begin shortly. PPS will receive written results of the audits in October or November 2016. An updated run of attributed members is expected in mid-September.
The state continues to present Value Based Payment (VBP) bootcamp sessions, with the final two three-session series slated to start in the Central/Western part of the state on Aug. 31st and on Long Island in late September. The second session in NYC is scheduled for Aug. 17th at Bronx Community College. Registration information is available here. Archived videos of the three bootcamp sessions held in Albany are available here.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841