DOH Posts 2021 Nursing Home Medicaid Rates
Late last week, the Department of Health (DOH) posted January 2021 Nursing Home Medicaid Notice Rates on the Health Commerce System (HCS), along with an accompanying Dear Administrator Letter (DAL) (available here). Please note that the posting is in compliance with regulatory notice requirements and that nursing homes are still waiting for final January and April 2020, as well as July 2020, Medicaid rates.
The January 2021 notice rates as posted incorporate a July 2019-based case mix index (CMI) as well as the 2020 minimum wage adjustment. We anticipate that the final January 2021 rates will contain a CMI based on July 2020 Minimum Data Set (MDS) assessments as well as a 2021 minimum wage adjustment. Members may find the case mix and minimum wage information in the newly posted rates instructive since they represent the adjustments (CMI and minimum wage) that should be reflected in their final January 2020 rates once they are issued. The January 2020 rates are currently undergoing final State review.
Here is our understanding of the status of outstanding nursing home Medicaid rates for the various six-month rate periods:
January 2020: DOH posted initial January 2020 rates which update the capital component but still reflect a CMI based on January 2019 MDS assessment as well as the 2019 minimum wage adjustment. DOH reconciled payment for services provided in January through March to these rates in Medicaid payment cycle 2243 (Sept. 2nd check release date). When approved by the Division of the Budget (DOB), DOH will update the January 2020 rate to reflect a CMI based on July 2019 MDS assessments and a 2020 minimum wage. DOH will reconcile Medicaid payments made for Jan. 1st through April 1st to the new January 2020 rate.
April 2020: Other than a 5 percent cut to the capital component, these rates are the same as the January 2020 rates and are expected to be updated for CMI and minimum wage in the same way and at the same time as January 2020 rates. Providers are currently being paid these rates (starting with Medicaid payment cycle 2243 (Sept. 2nd check release date)). DOH will reconcile Medicaid payments made for April 2nd through June 30th to the new April 2020 rate once it is updated.
July 2020: The CMI in these rates is expected to be based on a January 2020 picture date. The roster process used to calculate the CMI for these rates has not yet begun. Once the MDS roster verification process is completed, the new CMI is calculated, and DOB approves the new rates, DOH will issue July 2020 rates. The July rate should be the same as the final April 2020 rate, except with an updated CMI. DOH will reconcile Medicaid payments made for July 1st through Dec. 31st to the new July 2020 rate.
January 2021: On Oct. 30th, DOH posted draft initial January 2021 rate sheets that reflect 2021 capital, a CMI based on the July 2019 picture date (including 5 percent constraint, if applicable), and a 2020 minimum wage adjustment. The capital component may already reflect an attested-to, corrected amount for some or still list the original DOH calculation for others (note that the attestation process continues until Nov. 13th). These rates are for information and will not be the basis of payment anytime soon. The final January 2021 rates are expected to be updated to reflect a final 2021 capital calculation (corrected based on attestation, if needed), a CMI that we expect will be based on a July 2020 picture date, and a 2021 minimum wage adjustment.
Please note that while we expect (and DOH indications suggest) that CMI will be set based on a picture date methodology at least in the short term, a change in methodology is always possible, and it is best practice for providers to treat every Medicaid MDS assessment as if it were being used for calculating the CMI.
Please contact us with questions.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841