DSRIP Weekly Update Oct. 14, 2014

As usual, there were a variety of updates, changes and new information this week regarding the Delivery System Reform Incentive Payment (DSRIP) program.

Vital Access Provider Exception Deadline Extended

The deadline for the Vital Access Process (VAP) Exception has been extended from Oct. 14 to 5 p.m., Oct. 17, 2014. DOH is also explicitly asking certain providers to file a VAP Exception form if included on any of the following lists:

Pending Safety Net OMH/OASAS 1915i Providers
Pending Safety Net Harm Reduction 1915i Providers
State Designated Health Homes and Downstream Care Management Agencies

The VAP Exception instructions state that if your list is pending approval, you will be granted a VAP Exception pending approval and you do not need to submit this form; but this is no longer correct. DOH explains that these lists are pending approval, and the completion of this form is a cautionary measure. The Centers for Medicare and Medicaid Services (CMS) approval process for these special safety net lists has been delayed, and the VAP Exception process will help ensure that these providers have every opportunity to become designated as Safety Net provider.

The VAP Exception appeal process is also open to other Medicaid providers, physicians and pharmacies that did not qualify by the Safety Net Definition by calculation or by appeal. If the exception is granted, then the applicant will be qualified and can fully participate in the DSRIP program. The three categories that a Medicaid provider or organization may appeal for a VAP exception under are:

A community will not be served without granting the exception because no other eligible provider is willing or capable of serving the community.
Any hospital is uniquely qualified to serve based on services provided, financial viability, relationships within the community, and/or clear track record of success in reducing avoidable hospital use.
Any state-designated health home or group of health homes.

Remember that providers that are not deemed as Safety Net providers can still participate in DSRIP Performing Provider Systems (PPSs), but may only receive up to five percent (as a group) of their PPS’s award.

Click here for more information. Questions related to the Vital Access Provider Exception or DSRIP Safety Net process can be sent to DOH at BVAPR@health.state.ny.us.

DSRIP Toolkit Update

DOH updated the Toolkit to provide corrections to ensure alignment of metrics with Attachment J. Click here to view the changes.

LeadingAge NY Talks with KPMG

LeadingAge NY, along with other association colleagues, talked with KPMG, the DSRIP support team entity last week. KPMG is actively involved in all DSRIP PPSs, and is available for support. One key issue raised was the need for PPS leads to be engaging long term care and post-acute providers, behavioral health and substance abuse providers in discussions. We see our members as critical to the success of many DSRIP objectives. We will continue to work with our colleagues and with DOH and KPMG on these issues. We will also continue to talk with KPMG and have collectively offered our resources to provide education and help communicate between DSRIP PPSs and the State.

DSRIP Measure Specification and Reporting Manual

The DSRIP Measure Specification and Reporting Manual has been posted on the DOH DSRIP website here. The manual contains information about the measures required for the DSRIP projects, the reporting mechanisms, timeframes, and other details. The manual also contains information about the performance goals and the methods used to establish annual improvement targets and determining high performance. DOH will accept comments by email until Nov. 10, 2014.

Reminder of Public Comment Opportunities

In addition to the above opportunity, there are a variety of ways in which you can help shape aspects of DSRIP through public comment. Below is a summary of current opportunities to provide DOH with your thoughts, concerns and questions. We encourage members to copy us on any comments so that we may include them in our advocacy as well.

Draft Project Plan Application Resources : A webinar and information regarding the draft DSRIP Draft Project Plan Application, which PPSs will submit in Dec. 2014, is available here. We recommend that members review the resources because DOH will be accepting public comment electronically until Wed., Oct. 29, 2014 at dsripapp@health.ny.gov.

Financial Stability Test: DOH posted the Draft DSRIP PPS Lead & Financial Stability Test on the DOH DSRIP sites for public review and comment. PPS leads must be able to pass this test to maintain the lead status. Comments will be accepted electronically until Wed., Oct. 15, 2014.

Regulatory Reform

We want to remind members that DSRIP provides the opportunity to request waivers of State and federal regulation and statute. LeadingAge NY provided DOH with initial suggestions and encourages members to be engaged with their PPSs about other ways in which such waivers would help promote DSRIP objectives. Please let us know what sorts of waivers you are considering and how we can assist you in the request. Click here for more information about this opportunity.

Capital Restructuring Program Funding

DOH and the Dormitory Authority of the State of New York announced the availability of $1.2 billion to support capital projects that help strengthen and promote access to essential health services, including projects that will improve infrastructure, promote integrated health systems and support the development of additional primary care capacity. Any members hoping to access funds through this opportunity should be talking with the PPS leads and partners to help ensure it is included in the final application in December. We are also working to ensure that some of these funds are available outside of the DSRIP process, as the statutory language specifies. Click here for more information about this opportunity.

LeadingAge NY is committed to helping our members succeed in DSRIP projects in the context of a rapidly changing health care landscape. Don't hesitate to reach out to us if we can be of help or support. Questions for DOH can be directed to DSRIP@health.ny.gov.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828