Nursing Home Reimbursement Update
In meetings with LeadingAge NY and other associations this week, the Department of Health (DOH) provided updates on several nursing home payment issues and shared timelines for implementing the provision that will return most long-stay nursing home residents to fee-for service (FFS). Highlights of the discussion are provided below.
Medicaid Rate and Payment Updates
July 2019 Rates. The Department reports that they have addressed all but a few roster submission correction requests. Signed submission certifications are due Jan. 14th and should be emailed as soon as possible to primail@health.ny.gov. Any member that has correction requests that have not been addressed should email DOH immediately. Please let us know as well.
DOH will move quickly to issue updated July 1, 2019 rates incorporating the case-mix calculations based on the submissions.
Return to the Two-Week Payment Lag. We remind members that to expedite the reversal of the retracted July 2019 rates, non-specialty nursing homes were removed from the two-week Medicaid payment lag. Homes received two weekly Medicaid payments in each of two weeks. DOH intends to return homes to the two-week payment lag when the updated July rates are issued and by no later than the end of March 2020. This means that homes will experience two weeks without a Medicaid payment. While we are working with DOH to try to ensure that the two weeks without payment are non-consecutive, members should ensure sufficient reserves to withstand the return to the lag in the first quarter of 2020.
January 2020 Rates. Once the July 2019 rates are complete, DOH intends to implement the roster collection cycle using a July 31, 2019 picture date that will be the basis for the case-mix adjustment in the January 2020 rates. Providers should ensure that all Minimum Data Set (MDS) assessments associated with that time frame are complete and accurate to help minimize issues when DOH matches assessments to residents listed on the roster.
2019 Quality Pool. The Department is finalizing the 2018 Nursing Home Quality Initiative (NHQI) score sheets and expects to post them shortly for provider review.
One Percent Across-the-Board Budget Cut. DOH verified that on the FFS side, the cut is being applied to Medicaid payments for dates of service after Jan. 1, 2020. It is not intended to impact lump sum payments associated with prior periods such as the NHQI or the reinvestment of the 0.8 percent assessment. The multi-group letter protesting the cut is available here.
Assessment Reinvestment and 2018 NHQI Payment Adjustments. The Department reports that the payment of the 1 percent supplement (i.e., the reinvestment of the 0.8 percent assessment), which will be paid at the same time as the 2018 NHQI payment adjustments are made (up or down based on the facility’s quintile assignment), is expected to be made within a month.
2018 Assessment Reconciliation. The assessment reconciliation payment adjustment amounts have been approved by the Division of the Budget (DOB) and have been sent to eMedNY. Providers should be seeing the adjustment (up or down based on an individual organization’s circumstances) in January. We will share the Medicaid payment cycle number as soon as it is confirmed.
Nursing Home Benefit Change
On Dec. 19, 2019, the Centers for Medicare and Medicaid Services (CMS) approved the State’s waiver amendment that limits the partially capitated MLTC plan nursing home benefit to three months for individuals who are designated as long-stay residents. The terminology used by DOH in describing the population impacted by the change is now “Long Term Nursing Home Stay” (LTNHS) and no longer “permanent placement.” Unless seeking to return to the community, LTNHS members will be disenrolled from partially capitated MLTC plans and revert to FFS Medicaid after a three-month period. The three-month clock begins on the first day of the month following the date on which the individual was designated to be in a LTNHS. These changes do not apply to participants of Programs of All-Inclusive Care for the Elderly (PACE) or Medicaid Advantage Plus (MAP) plan members.
DOH outlined the timing of member notifications for the different categories of individuals affected by the change:
- New Nursing Home Residents Not in MLTC. The so-called “front door” to MLTC enrollment has been closed, meaning that new nursing home long-stay residents who have not already enrolled in MLTC are no longer required to do so.
- Current MLTC Members in a LTNHS. The shift from MLTC to FFS Medicaid for individuals who have met the three-month threshold will be the largest single change. The disenrollment of MLTC members who have been in a LTNHS for longer than three months will be effective March 1, 2020 for non-New York City (NYC) members and April 1, 2020 for NYC members. DOH estimates that notifications of impending disenrollment will be mailed to non-NYC members on Feb. 13th and to NYC members on March 16th. A draft of that letter is available here. Plans will be able to submit involuntary disenrollment packages for NHLTS 3+ members starting on March 23rd. Disenrollments initiated between March 23rd and April 11, 2020 will be effective May 1, 2020, with subsequent disenrollments following the regular involuntary disenrollment processing schedule.
- New Nursing Home Residents Instructed to Select a Plan. Maximus, the State’s Medicaid enrollment contractor, has made phone calls to these individuals informing them that they no longer need to join a plan and will continue to receive their nursing home services through FFS Medicaid. The same information is being provided to these residents in a letter that was mailed on Jan. 8th and is available here.
- Nursing Home Residents Scheduled for Feb. 1st Enrollment. Maximus has made phone calls to these individuals informing them that they will NOT be enrolled in the plan and will continue to receive their nursing home services through FFS Medicaid. The same information is being provided to these residents in a letter that was mailed on Jan. 13th and is available here.
- Community Members. All partially capitated MLTC plan members will receive a letter informing them of the nursing home benefit limitation. A copy of the letter is available here. These will be mailed over several days beginning on Jan. 17th.
- The notice being sent to all plan members is on DOH letterhead. All of the other notification letters (those sent only to nursing home residents) have New York Medicaid Choice letterhead and refer to FFS Medicaid as “regular Medicaid.” DOH hopes to issue an initial set of Frequently Asked Questions shortly and is in the process of briefing stakeholders, including managed care plans, provider associations, Local Department of Social Services (LDSS) staff, and consumer representatives, on the implementation.
- DOH is requesting the assistance of providers to identify residents who are actively seeking to return to the community to ensure that they are not disenrolled from MLTC to make sure that they have the necessary structures in place to receive services in the community.
We will share additional information as it becomes available, but please contact us with questions and concerns.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841