DOH Issues MLTC Value-Based Payment FAQs

The Department of Health (DOH) has released answers to "frequently asked questions" (FAQs) about its new value-based payment (VBP) contracting requirement for the partially-capitated Managed Long Term Care (MLTC) program. All partially-capitated MLTC plans were directed to enter into VBP arrangements with their nursing home and home care network providers by Dec. 31, 2017. These VBP contracts were, at a minimum, required to incorporate the applicable potentially avoidable hospitalization (PAH) measure and an incentive payment based on performance on that measure.

The FAQs cover a broad array of issues, including basic information about VBP under the MLTC program, attribution of MLTC enrollees to home care agencies, aggregation of providers with less than 30 members of a given plan (or less than 30 long-stay residents facility-wide, in the case of a nursing home), timeframes for data reporting, and the differences in the VBP data provided for home care agencies and nursing homes. Highlights of the FAQs include the following:

• The measurement year for purposes of calculating provider performance and associated incentive payments can be 2018.
• “All fully-integrated MLTC plans are required to be in VBP arrangements by April 1, 2018.” We believe, but have not been able to confirm, that this statement applies only to Medicaid Advantage Plus (MAP) and Fully Integrated Duals Advantage (FIDA) plans and not to Programs of All-Inclusive Care for the Elderly (PACE).
• Licensed home care services agencies (LHCSAs) that share fewer than 30 enrollees with a given MLTC can be aggregated with other agencies that have low attributed enrollment, or the MLTC and LHCSA may propose to the Department an alternative method of measuring performance.
• Since nursing home performance on PAH is calculated at the facility level, rather than the attributed member level, only nursing homes with less than 30 long-stay residents facility-wide must be aggregated with other nursing homes for purposes of calculating performance (not nursing homes with less than 30 residents attributed to a given plan).
• Beginning in 2019-20, MLTC plans will be required to begin shifting contracts into higher-level VBP arrangements, such as shared savings and two-sided risk. Higher-level VBP arrangements will be required to adhere to social determinants of health requirements, which are described in a DOH webinar here.

The FAQs are available here, and additional MLTC VBP resources can be accessed here. LeadingAge NY has made available free of charge to members a series of five webinars on Medicare and Medicaid VBP. The webinars are available here.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124