DSRIP Weekly Update-Aug. 5, 2014
LeadingAge NY and other stakeholders met with Jason Helgerson, New York State Medicaid Director, and key Department of Health (DOH) staff last week to discuss issues related to the Delivery System Reform Incentive Payment (DSRIP) program. DOH was receptive to our concerns and ideas, which are discussed below. In addition, news came out this week regarding the Independent Assessor, and key information was shared in the Attribution and Valuation seminar.
Safety Net Appeals Issues and Future Opportunities
On Aug. 31, LeadingAge NY and our colleagues from other associations met with Jason Helgerson and DOH staff to discuss concerns regarding the DSRIP Safety Net designation process, as outlined in a memo to DOH. We were concerned that several categories of providers were neglected in the Safety Net process, including Assisted Living Programs (ALPs), Adult Day Health Care (ADHC) programs and home care agencies. DOH made it clear that they ran an analysis for any provider type for which they had adequate data. Thus, they must rely on other data to demonstrate that it meets the Safety Net provider criteria, hence the appeals process.
DOH shared that the next Safety Net Appeal process will likely become available on Aug. 12, 2014, with 15 days to respond. We provided DOH with some feedback on the Safety Net Appeal process; they are open to ways in which to amend the process to facilitate accurate completion of the form. We urge any member interested in participating in a DSRIP Performing Provider System (PPS) to complete the Safety Net Appeal form in mid-August. Those who appealed and were not successful may also re-appeal. We are providing DOH with recommendations on how to change the form to make it easier to submit for each provider type, so let us know if you have suggestions. Also, if you applied for an appeal and were not designated as a Safety Net provider, but believe you fit the criteria, let us know.
We raised concern about new providers, such as Certified Home Health Agencies (CHHAs) that have not been operating long enough to provide the data the Safety Net Appeals process required. DOH said they are willing to review data from the provider, and felt that at least six months of data would be important to establish Safety Net provider status. We will continue to explore how CHHAs without that much data can still somehow pursue the Safety Net designation. The vital access provider designation, which will follow this safety net appeals process, might present some opportunity for those who are a unique provider in the community.
Both DOH and the Centers for Medicare and Medicaid Services (CMS) are reluctant to keep PPS’ open to new providers, however, given the potential volatility that could present to the health care system and the PPS itself. They are considering a mid-point evaluation of PPS’ to determine if any changes should be made; however once solidified, PPS’ will remain generally the same. We did raise questions about mergers, acquisitions and the potential evolution of providers, which DOH said they are considering.
Of concern is that DOH voiced the sentiment that DSRIP Safety Net Providers should be Medicaid providers, as opposed to providers of service to Medicaid-eligible people. We stressed that this distinction is not made clear in the Safety Net definition or appeals process, nor did we see this distinction in the waiver Special Terms and Conditions. This is an issue we will be exploring further.
DOH also clarified that, for the purposes of DSRIP, an individual eligible for both Medicare and Medicaid has the same “value” as a Medicaid-only or uninsured person in the attribution and valuation process. We were concerned, as hospitalizations are covered under Medicare, however both the State and CMS would like to see reductions in hospitalizations for that population as well as the others.
Attribution and Valuation Webinar
On Fri., Aug. 1, DOH held a DSRIP Attribution and Valuation webinar, presented by Jason Helgerson and Greg Allen, director of the division of program development and management within the NYS Office of Health Insurance Programs (OHIP). Both the webinar and slides can be accessed here. The webinar provides an update to the DSRIP attribution and valuation methodologies, and announces Project 2.d.i (“the 11th Project”).
Independent Assessor
DOH announced that Public Consulting Group (PCG) Inc. has been selected as the DSRIP Independent Assessor. This arrangement is contingent upon the negotiation of a contract. The role of the Independent Assessor is to perform the independent review of the Performing Provider Systems’ DSRIP Project Plan applications, and conduct key reporting, monitoring and technical assistance functions over the duration of the DSRIP program. Click here for more information about the Independent Assessor role.
Last week, DOH announced that KPMG had been awarded the DSRIP Support Team designation.
In conclusion, it has been another busy week in the DSRIP world. Don't hesitate to let us know how we can support your participation in DSRIP.
Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828