Nursing Home Reimbursement Update
Although staff is still working to collect the data that will be used for adjusting the case mix, the Department of Health (DOH) anticipates releasing 2019 Medicaid rates with updated case mix indexes (CMIs) close to the Jan. 1st effective date. DOH provided this and other updates on funding issues during a recent monthly meeting with LeadingAge NY and other associations. Highlights of the discussion are outlined below.
NHQI and Supplemental Payments: Payment adjustments reflecting 2013 through 2017 Nursing Home Quality Initiative (NHQI) results were included in Medicaid payment cycles 2152 and 2153. The adjustments were timed to coincide with the 1 percent supplemental payment that represents the reinvestment of a portion of the cash receipts assessments homes pay. Negative NHQI adjustments were netted against the supplemental payment. Homes whose negative NHQI adjustment exceeded the supplemental payment will have up to 100 percent of their Medicaid check for cycle 2154 (release date of Dec. 19th) recouped, with any remaining NHQI liability recouped at a 15 percent rate starting with Medicaid rate cycle 2161.
The Department has not provided final guidance on whether this funding is subject to the cash receipts assessment, but we recommend that members presume that it is until the determination is announced. The Dear Administrator Letter (DAL) explaining the payment calculations and timing of future supplemental payments is available here. This year’s distribution is a good guide for next year’s amount as well, unless a home experiences a significant change in its Medicaid revenue.
2019 Rate and Case Mix Adjustment: DOH staff are completing troubleshooting roster submission issues and expect to have sufficient data to calculate and analyze case mix based on both picture dates shortly. Final decisions on determining the case mix for the January 2019 rates will be made based on the outcome of data analysis, but it is likely that the two CMIs (based on April and July picture dates) will be blended to reduce rates by the annual $15 million savings required by the 2018-19 State Budget. In the absence of a better methodology to budget for the change, members may want to use a proportional amount as a placeholder (i.e., an approximate decrease of $2.20-$2.40 for the first three months of 2019 and a $0.55-$0.60 decrease for the remaining nine months, multiplied by the direct component wage equalization factor shown on line 3 of the home’s Medicaid rate sheet).
Other than nine correction requests that were rejected and a handful of corrections still underway, capital corrections that homes requested but that were not reflected in the draft preliminary capital rate sheets will be reflected in the January rate sheets. The Department expects to issue the final rate sheets close to the Jan. 1st effective date. Other than case mix, the January rates should match the amounts providers saw in the draft preliminary rates, including provider-specific minimum wage funding and a 1.5 percent increase to the operating component due to the Health Care Transformation Fund enacted in the 2018-19 State Budget. The 1.5 percent increase is calculated based on the July 2018 operating component and applies to both geriatric and specialty rates as well as Adult Day Health Care rates. The amount will remain fixed and is effective Nov. 1, 2018. DOH will issue November 2018 rates and make a retroactive payment to reflect the increase.
OMIG Audits and Rate Revisions: The Office of the Medicaid Inspector General (OMIG) has forwarded all 2015 MDS audit results to DOH. DOH hopes to issue recalculated rates based on audit findings that also remove any CMI constraints on July 2015 and January 2016 rates early next year. OMIG reports that 2016 MDS audits are mostly complete in Western and Central New York and that it is concentrating on New York City and Hudson Valley areas at this time, followed by Capital District homes.
Other Issues: Members should anticipate receiving a minimum wage survey in the coming weeks that will collect actual 2017 wage data and be used to reconcile minimum wage funding that was provided for 2017 based on projections. The November issue of the Medicaid Update reminds providers to file the required compliance certifications before the end of the year. Information is available here; to access the Medicaid Update, click here.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841