Nursing Home Reimbursement Update
The Department of Health (DOH) has posted updated rates reflecting the carve-out of transportation costs and has obtained the necessary federal “Good Cause” waiver to allow the processing of assessment reinvestment payments to proceed. These were among the updates that DOH provided during last week’s discussion on nursing home Medicaid funding issues with LeadingAge NY and other associations. DOH also announced that Lana Earle has been named the Director of the Division of Long Term Care, succeeding Andrew Segal, who left earlier this summer. Ms. Earle is well known to providers as a former director of the Bureau of Long Term Care Reimbursement and was most recently heading up the State’s efforts on Health Homes. Highlights from the meeting are outlined below.
Capital Attestations: The majority of homes submitted capital rate attestations confirming the State’s calculation or requesting a correction by last Friday’s due date. If you have not done so, please do so as soon as possible to help prevent delays in updates to the capital component of your home’s Medicaid rate. The attestation form is part of a Dear Administrator Letter (DAL) that is available here.
MDS Roster Submission: The MDS roster submission system is now operational. Homes should upload their April 25th and July 25th census rosters to the Health Commerce System (HCS) using the DOH MDS software. DOH has not changed the upload due date of Oct. 26th. Certifications are due by Oct. 31st. At the outset, DOH did experience some additional systemic issues that resulted in some roster-to-MDS matching difficulties. DOH believes that these have now been resolved and is responding to provider concerns and requesting that those impacted resubmit their rosters.
Please be sure, if you are requesting corrections or assistance from DOH, to send any messages containing resident information via secure transfer. (Log on to the HCS, select “my content," select “all applications,” select “S,” select "Secure file transfer 2.0," click “launch the secure file transfer 2.0,” and under "package actions" click “send package.” Address the file to BLTCRMDS.)
The DAL listing submission dates is available here. In meeting discussions, DOH confirmed that they are seeking to ensure that case mix calculations use the most proximate MDS filed prior to each picture date. Information on obtaining and installing the MDS upload software is available here.
Case Mix Adjustment: DOH reconfirmed that they will not make a decision on how to blend data from the two picture dates (April 25th and July 25th) to determine the case mix index (CMI) used in January 2019 rates until after they have received and analyzed the results of the roster upload currently underway. The upload process is currently scheduled to end Oct. 26th, with certifications due by Oct. 31st. They also reiterated that their intention is to meet the budget requirement to save $15 million in the current fiscal year, and once the CMI for January is determined, they do expect to convene a workgroup to address CMI going forward. We continue to stress to DOH that providers need to know their Medicaid rates as soon as possible for budgeting purposes.
Revised July 2018 Rates: DOH has posted revised July 2018 rate sheets reflecting the carve-out of transportation from the direct component. The direct component is reduced by $0.08 for free standing homes with fewer than 300 beds and by $0.18 for hospital-based homes and homes with 300+ beds. (The exact change in rate will fluctuate since the direct component is subject to wage and case mix adjustments). The reduction is retroactive to July 1, 2018 and will be reflected in Medicaid payment cycle 2145, which has a check release date of Oct. 17th. The associated DAL is available here.
Please note that rate sheets are now posted in a different section of the HCS, the “Healthcare Financial Data Gateway,” that will be used to post rate information going forward. Information on accessing this section is available here. DOH copied access information from the prior rate sheet section, meaning that nursing home staff with access to the rate sheets previously should be able to access the new section with no further action. For those who may need it, DOH did include the HCS Access Request Form along with the instructions on accessing the new section.
The 2 percent reduction to July 1st rates for those homes subject to the newly enacted quality penalty (i.e., those who were in the lowest Nursing Home Quality Initiative (NHQI) quintile in 2017 AND ALSO were in one of the two lowest quintiles in 2016) is incorporated in the revised rates and will be reflected in payment cycle 2145. The DAL addressing the penalty calculation is posted here.
Nursing Home Quality Initiative and Reinvestment of Assessment: The Department has obtained the required federal “Good Cause” waiver, clearing the last approval hurdle for making the $140 million reinvestment payments and making $250 million in NHQI adjustments (2013 through 2017). We remind members that DOH is netting the 2013 through 2017 NHQI adjustments into a single lump sum adjustment that may be positive or negative. The NHQI adjustment will be made in the same Medicaid payment cycle as the assessment reinvestment payment. Exact timing is unclear, but the facility-specific amounts and Medicaid rate cycle will be announced as soon as finalized.
DOH is working on processing the payments and adjustments, but homes are not likely to see these reflected in a Medicaid payment for a number of weeks. We will let members know as soon as DOH schedules the payment cycle.
Assessment Reconciliation: DOH staff has completed the 2017 assessment reconciliation calculations, and the information has been forwarded for review. Adjustments (up and down) are likely to be reflected in a payment cycle closer to the end of the year. DOH intends to use the 2017 reconciliation as the basis for the per-day assessment reimbursement amount in 2019.
OMIG MDS Audits: The Office of the Medicaid Inspector General (OMIG) is forwarding the final few 2015 MDS audit reports to DOH. This will allow DOH to recalculate rates based on these audit findings and remove any case mix constraints imposed on rates from this time period. This is also expected to occur late in the year. OMIG is currently in the process of auditing 2016 MDS assessments, indicating that they have started in the western part of the state.
Transition to Fee-for-Service: DOH and the Centers for Medicare and Medicaid Services (CMS) continue implementation discussions without any transition dates established as of yet.
Minimum Wage: The 2019 minimum wage adjustment, which will be additive to the amount currently shown on the “Misc.” line of the Medicaid rate sheet, will be included in the notice rates. Homes should be prepared to complete a minimum wage reconciliation survey that DOH intends to issue shortly. Providers unable to document the need for the minimum wage funding that they received will be required to return it. The only appropriate use of minimum wage funding is to increase wages to workers whose hourly rate is below the minimum wage and to fund wage-sensitive benefit costs that are driven by the wage increase.
Universal Settlement: Hinman Straub, the designated Trustee Law Firm that processes Universal Settlement payments for most non-profit and public homes, has received the funding for the fourth payment and issued checks that LeadingAge NY sent out by United Parcel Service (UPS) early this week. Please contact us if you do not receive your check by Friday. To obtain the tracking number, please contact Ken Allison at kallison@leadingageny.org.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841