Nursing Home Case-Mix Workgroup News
As members are aware, the final budget for State Fiscal Year (SFY) 2019-20 authorized a workgroup to discuss and make recommendations on the methodology utilized to calculate case-mix adjustments to nursing home rates. The financial plan reflects an administrative savings of $123 million to the State ($246 million total impact, inclusive of federal funds) during SFY 2019-20 from making such a change. Based on the workgroup's first meeting, LeadingAge NY is most concerned about the Department of Health's (DOH) plans to implement this change for the July 1, 2019 rates.
The first meeting of the workgroup took place on May 22nd in Albany. LeadingAge NY staff and members are well represented on the 27-member workgroup, which is chaired by Medicaid Chief Financial Officer Michael Ogborn. DOH revealed the following in the meeting:
- The workgroup will be meeting two more times in June and arriving at final recommendations by June 30th.
- The statewide average Medicaid-only case-mix index (CMI) was 1.309 in January 2018 (a normal collection period), 1.017 in April 2018 (the added collection), and 1.300 in July 2018 (a normal collection period). The total number of Medicaid residents in the rehabilitation categories was 46,067 in January 2018, 12,025 in April 2018, and 44,840 in July 2018.
- The January 2019 rates will reflect the case-mix methodology currently in place.
- The July 2019 rates will reflect an average CMI for each Medicaid resident of the facility based on all Minimum Data Set (MDS) assessments (not just a single assessment as in the current system) submitted during the period Aug. 8, 2018 through March 31, 2019, rolled up into a facility average CMI. The group raised concerns about the average CMI being calculated as a simple average versus an average weighted by resident days.
- DOH is constrained to obtain the $246 million in budgeted total savings and indicated that the $246 million is not a cap on the actual savings that could be realized.
- The Department does not believe that any changes in either law or regulation are needed to implement their proposed change effective July 2019, using MDS assessments from prior periods.
- The 5 percent constraint on changes to CMI in the regulations will not be applied to any resulting adjustments, allowing DOH to implement the changes without the limitation.
- OMIG will continue to audit case-mix determinations for all time periods, including July 2019 rates.
- The focus of the workgroup and its recommendations is on how to improve the accuracy of the case-mix determination process, and to reduce or eliminate abusive practices, for future rate periods (i.e., beginning January 2020).
Workgroup members raised several questions and concerns about the workgroup’s charge, the operational realities of conducting MDS assessments and taking credit for services that could affect RUG-III scoring, how unrepresentative the MDSs for the Aug. 8th – March 31st period are for rate setting, the need for facility validation that all of the MDSs used in rate setting are included and accurate as to payer code, etc., and above all the devastating impact that this cut will create for many facilities.
LeadingAge NY and other associations met on May 23rd by conference call to debrief from the meeting and agree on an aggressive action plan in response to DOH’s plan. We will keep members updated on next steps. In the meantime, please begin to review DOH’s intended methodology for the July 2019 CMI calculation based on your own facility’s data and provide us with any questions or feedback we should offer through the workgroup or to other stakeholders.
Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866