Nursing Home Reimbursement Update
Nursing homes should be prepared to review draft calculations of their capital rate for 2020, which may be posted to the Health Commerce System (HCS) as early as this week. Department of Health (DOH) staff provided this and other information regarding reimbursement issues during the August monthly meeting with LeadingAge NY and other associations. Highlights of the discussion are provided below.
Review of Draft Capital Rates. As in prior years, homes will have the opportunity to review the DOH capital component calculation for the coming calendar year (2020). DOH intends to have the draft calculations posted before the end of the month and expects to give providers 30 days to respond. Homes that identify an error or omission will be able to submit a corrected calculation along with supporting documentation to DOH. All homes will be required to file a signed attestation, whether requesting corrections or agreeing with the DOH calculation.
CRA Reconciliation and Update. The 2017 Cash Receipts Assessment (CRA) reconciliation is pending final executive review. In addition, the assessment reconciliation amount currently being paid through the fee-for-service (FFS) rate system will be updated retroactive to Jan. 1, 2019 to reflect the amount shown on the managed care benchmark list. Please note that these adjustments may be positive or negative depending on a home's specific circumstance. DOH has not projected a payment date.
Quality Penalty. Homes subject to the 2 percent quality penalty last year continue to have the reduction reflected in their 2019 rate. When this is updated, homes no longer subject to the penalty will see a positive adjustment retroactive to January 2019, while new homes that qualify for the 2019 penalty will receive a negative adjustment. Homes whose 2017 Nursing Home Quality Initiative (NHQI) score was in the fifth quintile and whose 2016 NHQI score placed them in the fourth or fifth quintiles were subject to the 2018 penalty. The 2019 penalty will be assessed on those homes whose 2018 NHQI score places them in the fifth quintile as long as they also were in the fourth or fifth quintile in 2017.
IGT. The Department is finalizing the Intergovernmental Transfer (IGT) payment amounts for public homes. As in the prior two cycles, they will be made in two installments: in fall and spring. The statewide amount is about 13 percent lower than last year, but because the individual distributions are based on Medicaid FFS days, the percent change will vary based on an individual home’s circumstances. We are discussing the draft distribution estimates with DOH. They are currently based on 2018 Medicaid days but may need to be adjusted to 2017 days if required by statute.
Adjustment Calculation Tweak. Members will recall that their home has two Medicaid rates. The majority of Medicaid residents are Medicare Part B eligible, and as such, their rate has a statewide average Medicare Part B offset incorporated. This makes the Medicaid rate for Medicare Part B eligible residents a little lower than the rate for those ineligible. Both the 1.5 percent Health Care Transformation Fund funding and the 2 percent quality penalty are calculated as a percentage of a home’s total Medicaid rate. DOH has adjusted both of these calculations to ensure that the percentages are being applied to the appropriate rate. This slightly increases the transformation funding and slightly decreases quality penalty amounts.
MDS Audits. The Office of the Medicaid Inspector General (OMIG) reported that all the 2016 Minimum Data Set (MDS) audit field work is complete and that approximately 20 percent of the audit reports are done. They are currently developing their audit plan for 2017 assessments. While OMIG expects the process for finalizing remaining 2016 audit reports to go more quickly than in prior years, it appears that the next round of audit-related rate revisions and case mix index (CMI) constraint removals is not likely to occur until 2020.
Advanced Training Initiative. DOH is finalizing the Advanced Training Initiative (ATI) application, which is likely to be issued shortly. ATI is a program that distributes funding to eligible homes to train frontline staff to better identify residents at risk of hospitalization. As in prior years, DOH will determine eligibility based on staff retention rates and will require eligible homes to select the approved training program or programs they intend to implement as part of the application. The Department intends to distribute two years of ATI funding (2018-19 and 2019-20) in this cycle, with eligibility calculated separately for each year.
Other Issues. Other lump sum adjustments on which DOH is working that are expected in the fall include the final payment of the Universal Settlement, 2018 NHQI adjustments, and supplemental payments (i.e., assessment reinvestment). DOH is finalizing a new Frequently Asked Questions document on the new bed hold regulations and is fielding questions on the topic at nfrates@health.ny.gov (please indicate “bed hold” in the subject line).
The meeting did not delve into the changes to the case mix methodology (discussed in a separate Intelligence article), nor did DOH broach the Medicaid spending concerns expressed in recent reports from the State Comptroller and the Division of the Budget (DOB).
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841