DSRIP Weekly Update-Sept.9, 2014

There is a lot of new information available this week for those of you involved in the Delivery System Reform Incentive Payment (DSRIP) program.

DSRIP and Health Home Webinar

The Department of Health (DOH) will present a webinar on Wed., Sept. 10 from 1:30 p.m. to 3 p.m. to provide information on the role of Health Homes in DSRIP Performing Provider Systems (PPS), including the role of and payment flow to the downstream care managers. Click here to register.

Safety Net Appeals and the Vital Access Provider Exception

DOH is now processing applications for the second and reportedly last Safety Net appeals process; applications were due on Aug. 27. DOH will update the lists on the website as they are finalized; physician and pharmacy lists have already been revised.

LeadingAge NY advocated for Safety Net status for certain non-Medicaid providers such as adult care facilies and licensed home care services agencies that serve a large number of Medicaid-eligible individuals. The Association also advocated for newly established Certified Home Health Agencies (CHHAs) that had a history of being a safety net provider as a Long Term Home Health Care Program (LTHHCP), or intend to be a safety net provider when fully operational, to be given special consideration. LeadingAge NY will keep members apprised of any developments on this issue. Questions regarding the Safety Net designation should be directed to DOH at BVAPR@health.state.ny.us.

Once DOH finalizes the safety net appeals lists, the Vital Access Provider Exception appeal process will begin. This appeal process will be for Medicaid providers, physicians and pharmacies for facilities that did not qualify by the Safety Net Definition. There are three conditions under which a provider may be eligible for this designation, which essentially deems Safety Net status to the provider:

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; or,
any state-designated health home or group of health homes.

According to the Special Terms and Conditions, these potential Vital Access Provider exceptions must be posted for public comment 30 days prior to application approval, and must be approved by CMS.

It is important to remember that providers that do not qualify for the Safety net designation can participate in PPSs, but cannot receive payments exceeding five percent of a project’s total valuation. That being said, CMS can approve payments above this amount if it is deemed in the best interest of Medicaid members attributed to the PPS.

Project 2.d.i Details and Other Project Toolkit Updates

DOH posted the finalized version of the DSRIP Project Toolkit, which now includes project 2.d.i. (the 11^th project). These documents can be viewed here. The DSRIP Project Toolkit includes new details and clarifications to several projects, including the 11th project. LeadingAge NY is pleased to report that some of the changes reflect or address the Association's comments and questions on the toolkit. Hinman Straub, LeadingAge NY's counsel, is preparing a comprehensive summary of the changes. Below, however, a few highlights that are likely to be of interest to members.

Project 2.a.v. Create a Medical village/alternative housing using existing nursing home infrastructure has been modified to:

state that assisted living residences, enhanced assisted living residences and special needs assisted living residences are applicable settings to replace skilled nursing facility beds. LeadingAge NY advocated for this inclusion.
specifically recognizes te Naturally Occurring Retirement Communities and requires inclusion in planning, which LeadingAge NY promoted.
note new payment strategies such as Institutional Special Needs Plans (ISNPs); LeadingAge NY highlighted the potential opportunities for ISNPs to DOH.
explain that respite services (scheduled short term admissions) and adult care facility and assisted living services are other aspects of the continuum to replace skilled nursing facility beds. Again, LeadingAge NY recommended this and appreciates the clarification.
award additional points to any project involving the closure or downsizing of capacity in poorly performing nursing homes (assuming the community needs assessment supports the downsizing).

Project 2.b.iv. Care transitions intervention model to reduce 30 day readmissions for chronic health conditions and 2.b.v. Care transitions intervention for Skilled Nursing Facility (SNF) residents has been modified to:

provide additional resources for these projects: www.caretransitions.org and http://innovation.cms.gov/initiatives/CCTP; LeadingAge NY raised these models as potential reources with DOH.
discuss that hospitals and skilled nursing facilities may partner to develop a standardized protocol to assist with resolution of identified care transition issues; including the development of a standard medical record transfer form to follow the patient during any care site transfer.

Project 3.a.v. Behavioral Interventions Paradigm in Nursing Homes (BIPNH) was modified to:

add language to describe these interventions: "Interventions that rely on increased training of the usual care staff to identify and address behavioral health concerns have been found to be effective management tools. Resources from other evidence based SNF initiatives to reduce avoidable hospital admissions, e.g., INTERACT may be integrated into this program." LeadingAge NY requested clarification on this issue.

Project 3.g.ii. Palliative Care - Integration of palliative care into nursing homes specifically mentions implementation of the MOLST.

Again, LeadingAge NY is pleased to see many of our suggestions and questions regarding the toolkit addressed. A more in-depth analysis of the changes will be available soon.

New Data and Resources Available

DOH added new DSRIP Chartbooks to the performance data section of the DSRIP website. These Chartbooks include maps and charts of Medicaid Avoidable Hospitalizations and Clinical Process of Quality Measures, based on Medicaid claims data. Click here for an overview of how to read the charts, and here to view the Chartbooks. Questions about the Chartbooks should be directed to DOH at doh.sm.OPCHSMWEB.

DOH unveiled additional interactive data regarding Medicaid utilization a few weeks ago. These “dashboards” afford users interactive views of Medicaid enrollment and utilization data from 2011 to current and allow users to filter data by region, county or zip code. The dashboards are useful for anyone seeking to better understand service use in the Medicaid program and provide more information than the Medicaid utilization reports previously posted. Click here for more information.

DOH updated the DSRIP webpage to provide the most recent versions of the documents that govern the DSRIP initiative, per the Centers for Medicare and Medicaid. Included in these updates are: Attachment I: Program Funding and Mechanics Protocol; Attachment J: Strategies and Metrics Menu; as well as the updated Project Toolkit noted above.

Members are encouraged to let us know what their needs and questions are regarding DSRIP. You may also contact DOH regarding DSRIP questions at dsrip@health.ny.gov.

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