July Managed Care Policy & Planning Meeting Highlights
Although the state is moving forward aggressively to make Community First Choice Option (CFCO) services available to both managed care and fee-for-service Medicaid recipients, the implementation date has been delayed from Oct. 1 to Dec. 1, 2016. CFCO issues sparked much discussion during the July Medicaid Managed Care Policy and Planning meeting, which also included an update on Managed Long Term Care (MLTC) rates and a presentation on the Medicaid Incontinence Supply Management Program, an MRT initiative.
The monthly meeting has been restructured to focus on mainstream Medicaid managed care issues in the morning with MLTC-specific issues and issues common to all plans covered in the afternoon. Highlights of the afternoon discussion are provided below with section titles serving as links to the associated handouts.
As of June 2016, 66 MLTC plans serve 171,500 enrollees. The bulk of these, 90 percent, are in partial-capitated plans with Medicaid-Medicare integrated plans (Programs of All Inclusive Care for the Elderly (PACE), Medicaid Advantage Plus (MAP), and Fully Integrated Duals Advantage (FIDA)) each accounting for slightly more than three percent of statewide enrollment. The Conflict-Free Evaluation and Enrollment Center (CFEEC) that screens individuals for enrollment into MLTC reports a 97 percent approval rate, which has remained consistent throughout the year.
Along with CFCO implementation preparations (addressed below), DOH is focusing on the transition into managed care of individuals currently in the Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Waivers. This transition is not scheduled to begin until Jan. 1, 2018, but because some of the services overlap with CFCO services, the state will need to address some of the same questions with both initiatives.
The latest draft Waiver Transition Plan and related webinar are available here, and DOH has scheduled NHTD/TBI Waiver transition stakeholder meetings for Sep. 14th from 1-3 pm and Oct. 4th from 10-12 noon.
With FIDA demonstration approaching its Dec. 2017 sunset, DOH is seeking stakeholder input regarding continuation and expansion of the program. A FIDA Webinar held on July 22nd is posted under the "Webinars" section of the MRT 101 web page. It reviews FIDA facts and figures, outlines the reforms and changes that the program has undergone since its launch, and discusses its future. The presentation provides a statistical overview, but detailed county and plan data – which include the number of individuals eligible, enrolled, and opting out – are posted here.
DOH announced that the roll-out of CFCO for Medicaid beneficiaries, in both fee-for-service and managed care arrangements, will be Dec. 1, 2016, a slight delay from the originally announced Oct. 1 date. Pointing out that CFCO is more encompassing than a program and acknowledging that implementation is a major undertaking, DOH suggested that those seeking a comprehensive understanding review the Medicaid state plan amendment authorizing CFCO and indicated that the state’s approach would mirror the approach used to incorporate NHTD and TBI waiver services into managed care. A good overview of CFCO is available in an archived webinar presented to the School of Public Health, and DOH is working on a set of FAQs.
State implementation preparation activities include drafting a 60-day notice letter to plans, developing policy papers (including billing guidance), issuing guidance materials for Maximus, efforts on plan readiness (handbook, educational materials, policies and procedures), establishing an enhanced provider network directory inclusive of CFCO services providers, and working on contract amendments. DOH has formed a number of internal workgroups to address various components of implementation.
In response to meeting participant questions, DOH explained that it will not certify providers of CFCO services that do not provide licensed services, but that DOH would compile and distribute lists of providers. The implementation process will require new network providers and contract changes for all plans, and consumer education will be an important component. Although DOH did not share a formal projection of expected clients for CFCO services, DOH expects the new services – in particular, cueing and social transportation – to be popular. The enrollment in NHTD/TBI waivers (roughly 6,000) may be an indicator, but demand will likely be higher. The CFCO State Plan Amendment includes estimates of eligible individuals.
Some concern was expressed about adding a large new set of providers not accustomed to billing managed care. The state pointed out that a number of these providers offer NHTD/TBI waiver services and that some of the services are included in the FIDA benefit package. DOH will distribute billing codes to be used for CFCO services by October, and Mercer is working on rate adjustments that should be ready by the end of summer.
MLTC plans should have recently received their draft Phase 5 rates covering the last quarter of the 2015-16 State Fiscal Year (SFY). These rates will include both a reconciliation of the number of nursing home enrollees used to calculate the nursing home add-ons for Phases 2, 3, and 4 as well as the distribution of the high cost nursing home pool. DOH provided a sample calculation of the nursing enrollee count reconciliation (i.e., lookback calculation) and is preparing and will distribute additional details regarding how the price mitigation distributions were calculated.
Phase 4 rates that cover October through December of 2015 have been loaded into the payment system and will be paid in August. DOH is finalizing the 2016-17 SFY rates and intends to complete the work in early August. These rates will include an annual nursing home add-on calculated using projected counts of enrollees residing in nursing homes and utilize base costs and risk scores calculated on regional data for all regions, rather than relying on a geographic adjustment factor for regions 2, 3, and 4. The actuarial memo associated with the rates will be available in August as well.
In response to questions regarding how funding related to the Fair Labor Standards Act (FLSA) should be disbursed to network providers, DOH clarified that starting in April 2016, the FLSA funding will be reflected in the premium base and that they intend to allow plans and providers to work out how the money will flow to providers. The FLSA adjustment amount will be itemized on Schedule C of plan rate sheets.
DOH will announce the second plan meeting on minimum wage shortly and is collecting plan questions on both minimum wage and FLSA funding issues to address at the meeting. DOH is preparing policies and reporting requirements for both minimum wage and FLSA funding issues.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841