Important to Complete DOH NAMI Survey

As part of the state’s initiative to centralize the Medicaid enrollment process, DOH is exploring the possibility of assuming Net Available Monthly Income (NAMI) collection responsibilities from nursing homes.  If it were implemented, such an initiative would benefit homes by relieving them of the administrative duty of collecting NAMI as well as reduce their financial loss in cases where collection proves impossible.

Such a change requires the state to submit a proposal to CMS for approval.  To further this effort, the state is seeking to gather valid data on uncollectable NAMI.  LeadingAge NY and other associations representing nursing homes worked with DOH to develop a brief, five question, online survey.  Earlier this week DOH sent an email (copied below) to nursing home administrators requesting that they complete the survey.    

We urge you to respond to the survey as soon as you can, but no later than Jan. 21.  The survey asks the estimated total annual amount of NAMI your home could have collected, the estimated amount that was uncollected and primary reasons for outstanding NAMI.  To ensure uniform data collection, DOH defined categories of non-payment in an attachment to their email.  The definitions from that attachment are also copied below.  You can access the survey here.

If you have questions, please let us know or contact the DOH Bureau of Long Term Care Reimbursement at NFRates@health.state.ny.us and indicate ‘NAMI Survey’ on the subject line.

Contact:  Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841

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Please refer to the definitions below when completing question #5 of the Uncollectable NAMI Survey

 

SURVEY ON UNCOLLECTIBLE NAMI

QUESTION #5: OUTSTANDING NAMI REASONS- DEFINITIONS

Eligibility Lag:

This refers to NAMI that was not collected because there was a lag in the eligibility acceptance period. At the time the facility was made aware of the NAMI amount, the money was no longer available to be collected.

Examples of this can include (but are not limited to):

• The facility waiting one or more months until the Medicaid Budget Letter was received. By this time the NAMI funds were already spent.

Noncompliance Legal:

This refers to any instance where various legal factors did not allow the Nursing Home to collect the full budgeted NAMI.

Examples of this can include (but are not limited to):

• Any garnishment of income (IRS, child support, etc.) that is not an allowable deduction from monthly income when establishing the NAMI amount.
• Guardianship fees that have not been reduced from the budgeted NAMI amount.
• Lien on estate situations in which the facility placed a lien on a deceased resident’s estate to recover the amount of uncollected NAMI, however Medicaid’s lien took precedence, leaving the facility with nothing to collect.

Noncompliance Pension:

This refers to the pension portion of the NAMI that was not collected for various reasons.

Examples of this can include (but are not limited to):

• Incapacitated residents without a guardian, who cannot redirect their pension check to come to the facility.
• Pension plans that refuse to change the direct deposit or mailing address of the pension check.

Noncompliance- Refusal to Pay/ Funds Otherwise Spent

This refers to NAMI that was not collected because there was some type of refusal to pay or the funds were otherwise spent.

Examples of this can include (but are not limited to):

• Resident cannot pay because he/she is using the funds to upkeep his/her home in the community.
• Resident refuses to pay the facility the full NAMI amount.
• Resident’s family cannot pay, because they are using the money in the community.
• Resident’s family (or any responsible party) deliberately misappropriating funds for their own personal use.