DSRIP Weekly Update-Oct. 7, 2014

It was another busy week for those interested in and working on the Delivery System Reform Incentive Payment (DSRIP) program. As you'll see below, there are several new pieces of information that are out for public comment, all with different time frames. Please let us know if you have any comments that you would like us to include in our advocacy efforts.

Ongoing Advocacy on Safety Net Status and Attribution

We have been persistent in our advocacy efforts to ensure that members have the proper role and weight in any DSRIP Performing Provider System (PPS). As we outlined in a letter to the Department of Health (DOH) sent this week, we remain concerned about a variety of issues and have requested further discussion regarding:

• New certified home health agencies that will in time meet the Safety Net designation, but do not yet due to the timing of the DSRIP Safety Net data analysis;
• Non-Medicaid providers that should be designated as Safety Net providers, and the general need for clarity on non-Medicaid providers’ ability to be designated as such; and,
• Utilizing the assisted living program, home care and adult day health care services in the attribution hierarchy. Given the loyalty patterns in accessing these services and their direct impact on hospitalizations and emergency room visits, they should be factors. 

Related to attribution, it should be noted that the State is exploring whether or not they can and should provide PPSs with lists of individuals attributed to a particular PPS. There are a variety of concerns including HIPAA and preserving choice for the consumer.

We will keep members apprised on developments with these critical issues.

Last Chance to Become a Safety Net Provider through Vital Access Exception

As the Safety Net lists are still being updated, DOH has issued the Vital Access Provider (VAP) Exception application. The VAP exception is an appeal process for Medicaid providers that did not qualify for the Safety Net designation under the prior appeal processes. This is essentially the last opportunity to be deemed a Safety Net provider and fully participate in the DSRIP program. Again, non-safety net providers can participate in DSRIP, but may only receive up to five percent of their PPS's award.

There are three categories that a Medicaid provider may appeal for a VAP exception under:

1. A community will not be served without granting the exception because no other eligible provider is willing or capable of serving the community.
2. 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.
3. Any state-designated health home or group of health homes.

The VAP Exception form is posted on the DSRIP website and is due by 5 p.m., Tues., Oct. 14, 2014. No extensions will be granted. Questions regarding the VAP Exception or Safety Net process should be sent to DOH at BVAPR@health.state.ny.us.

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. Click here for more information about this opportunity. 

Draft Project Plan Application Resources

DOH posted information regarding the draft DSRIP Draft Project Plan Application, including a webinar. 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. Click here to access these resources. DOH is also working with Public Consulting Group, the Independent Assessor selected entity to provide the PPSs with additional support regarding the application and scoring guide. 

PPSs will need to submit applications by Tues., Dec. 16, 2014. Applications will reportedly have an initial review and those that fail to meet the standards will be given a short period of time to resolve deficiencies. 

Financial Stability Test

DOH posted the Draft DSRIP PPS Lead & Financial Stability Test on the DOH DSRIP sites for public review and comment. All PPS Lead Providers will be required to pass the Financial Stability Test in advance of the submission of the DSRIP Project Plan Application discussed above. If the lead fails to pass the test, that entity will not be able to serve as the PPS lead. The PPS would then need to identify another lead or become members of another PPS, in order to continue participation in DSRIP. Comments will be accepted electronically until Wed., Oct. 15, 2014 at dsripapp@health.ny.gov. More information can be accessed here.

Regulatory Reform

As you will recall, 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.

KPMG Assembles a Team to Provide Support and Resources

KPMG, the DSRIP Support Team selected entity, has reportedly staffed up to provide support to PPSs. LeadingAge NY will be talking with KPMG representatives later this week and invite members to provide us with questions or feedback on their involvement.

As we reported last week, KPMG released a guide on governance for DSRIP PPSs. It is our understanding that they are currently developing additional guides, as well. The governance guide, as well as future guides, can be accessed here.

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