October 2, 2015 Edition of ASAP by Home Care Association of New York State

ASAP

A Weekly Publication Of HCA Home Care Association of New York State

Legislative Issues  Public Policy



News

Volume 20, No. 34 October 2, 2015

Emergency Preparedness Alert: Hurricane Joaquin DOH Activates HERDS emergency response survey State emergency preparedness officials are tracking the progress of Hurricane Joaquin and have begun sending important alerts to providers throughout the state. The path of the storm remains uncertain, with the greatest threat to downstate regions. State Department of Health (DOH) officials warn, however, that numerous parts of the state may be impacted (akin to storms Irene and Lee in 2011). See JOAQUIN p. 3

HCA Symposium to Demo Vanguard Quality Risk Tool, Wound Care Apps, with Focus on Your Quality Imperative HCA’s Quality Symposium,“The Quality Imperative: Raising the Bar in Home Health Care,” is ready to receive your registrations, online, or by fax/mail using the brochure at the back of this week’s ASAP. See VANGUARD p. 2

Inside ASAP Emergency Preparedness Alert: Hurricane Joaquin...........................1 HCA Symposium to Focus on Your Quality Imperative.......................1 DOH Activates Full CHHA Rebasing Adjustment..............................1 Member Hiring Announcement..........................................................4 HCA President Cunningham Meets with Schumer on Federal Issues....5 DOH Posts Nursing Home Transition Materials...............................6 eMed NY Posts Updated MEVS/DVS Provider Manual......................6 Supervision Plus Change of Venue, HCA Meet-ups, Provider Forums.....7 HCA to Hold Free Member Call on Companionship Exemption......7 HCA, Associations, DOH Meet on Payment and Other Issues............8 Value Based Payment Committees Further Detail Methodology......10 CMS Contractor Aims F2F-focused Probe & Education Reviews.....11 HCA, Medical Society Partner to Address Health Care Disparities..11 Influenza Not Yet Prevalent in New York.............................................12 DSRIP Updates...................................................................12 FIDA News........................................................................................13 Conference on Health Care Competition & Consolidation..............14 DOH Holds Long Term Care Meeting...............................................14 NGS Education Programs.................................................................15 Publications.............................................................15

HCA President Joanne Cunningham met this week with U.S. Senator Charles Schumer. See the story on page 5.

DOH Activates Full CHHA EPS Rebasing Adjustment The state Department of Health (DOH) this week had eMedNY activate the revised Episodic Payment System (EPS) rates for CHHAs effective Thursday, October 1. In response, HCA Executive Vice President Al Cardillo today wrote again to State Medicaid See REBASING p. 6

Helping New Yorkers Feel Right At Home

ASAP – a publication of the Home Care Association of New York State VANGUARD from p. 1 This two-day program, on November 17 and 18 near Albany, is chock full of information to help you meet the changing quality imperative in home health. As we note in the conference brochure, CAHPS surveys, Home Health Compare, HQRP, OASIS remain important concerns; but today “home care is faced with new and even bigger machinery for inducing quality enhancements” under new models of care. It doesn’t matter whether you are a CHHA, LTHHCP or LHCSA: you need to focus your “energies, resources and intellectual capital” to meet a vigorous new quality imperative under DSRIP, MLTC and value-based payments. One item that will soon offer major help is HCA’s Quality Risk Tool, now in the RFP stage of development for statewide use by 2016. It offers a methodical roadmap for measuring risk areas in clinical, financial and operational quality oversight. The conference will give you the latest demonstration and developments of this

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first-of-its-kind initiative, created by HCA’s Quality Committee and a subgroup of members working with HCA staff. We’ll also provide broad updates from state officials and quality of care experts; a look at federal Star Ratings and ways to improve your scores; an exciting demo on a new technological app that will help you reduce costs and challenges associated with wound care; and a major focus on the quality imperative for LHCSAs, CHHAs and LTHHCPs operating in contract relationships with other providers, managed care plans and in new models. You’ll hear directly from successful Licensed Agency field experts to assist your LHCSA’s own quality enhancement activities. Plus, representatives from managed care plans will show your CHHA, LHCSA or LTHHCP what it needs to do to meet the quality imperative under MLTC and other managed care arrangements. This Quality Symposium is HCA’s most ambitious yet, and we urge you to check out the incredible lineup of presenters in our PDF brochure at the back of ASAP. You can also register online at https:// www.eventville.com/Catalog/ EventRegistration1.asp?EventId=1011709.

ASAP is a weekly publication of the Home Care Association of New York State (HCA). Unless otherwise noted, all articles appearing in ASAP are the property of the Home Care Association of New York State. Reuse of any content within this newsletter requires permission from HCA. President: Editor:

Joanne Cunningham, jcunningham@hcanys.org Roger L. Noyes, Director of Communications, rnoyes@hcanys.org Al Cardillo, Executive Vice President, Policy & Programs, acardillo@hcanys.org Patrick Conole, Vice President, Finance & Management, pconole@hcanys.org Andrew Koski, Vice President, Program Policy and Services, akoski@hcanys.org Alexandra Blais, Director of Public Policy, ablais@hcanys.org Laura Constable, Senior Director, Membership & Operations, lconstable@hcanys.org Celisia Street, Director of Education, cstreet@hcanys.org Mercedes Teague, Finance Manager, mteague@hcanys.org Jenny Kerbein, Director of Governance and Special Projects, jkerbein@hcanys.org Billi Hoen, Manager, Meeting and Events, bhoen@hcanys.org Teresa Brown, Administrative Assistant, tbrown@hcanys.org 388 Broadway, 4th Floor, Albany, NY 12207 Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org

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JOAQUIN from p. 1 Depending on the storm’s track, high force winds could hit on Monday, October 5, with potential heavy rainfall, flooding and loss of power in the Metro New York City region, Long Island and Hudson Valley, especially. DOH’s most recent storm guidance urges all provider administrators and managers to review their emergency response and evacuation plans; and make sure that all staff contact information is up to date, especially through the Health Commerce System (HCS), which is a key directory for DOH to reach your preparedness teams. Instructions for ensuring accurate communications, through HCS, eFinds, and the Health Electronic Response Data System (HERDS), are in the DOH guidance at http://hca-nys.org/wp-content/uploads/ 2015/10/ctrlaccamstmpNotification_19234.pdf. HERDS survey Earlier today, DOH sent an alert informing providers that it has activated its HERDS survey at https:// commerce.health.state.ny.us/hpn/ctrldocs/alrtview/postings/Notification_19244.txt. The alert says the survey is due by 4 p.m., after ASAP press time, but HCA is reminding providers to complete it as soon as possible if you have not yet done so. All CHHAs, hospices and LHCSAs in New York City, Long Island and the lower Hudson Valley are required to fill it out through the HCS. At this time only the first two forms of this survey – HCEMRAGENCY Home Care Emergency Agency Form and HCEMRCAPACITY Home Care Emergency Capacity Form – need be filled out. Providers may disregard the questions concerning Transportation Assistance Levels (TALs). General preparations To prepare for the storm, your activities should also include the following: notifying and alerting staff; adjustment of shifts and management of staffing shortages due to potential transportation impacts; securing needed supplies and preparations for staff that remain on site if roadways are not passable; and determining what to do if your agency’s communications are impacted. These protocols should already be spelled out in your agency-specific emergency preparedness plan. Facilities, in particular, should ensure they have enough general supplies to last a period of at least 72 hours after the storm begins without expectation of delivery from suppliers. New York City providers in need of supplies should contact New York City Emergency Management. Long Island and Westchester facilities (or other parts of the state) should contact their County Emergency Operations Centers (EOCs), or County Offices of Emergency Management if your district’s EOC is not activated, DOH says. In a separate notice, Nassau County has reported that its EOC is currently activated. It can be reached at (516) 573-9649 or (516) 573-9635, or the main Office of Emergency Management number at (516) 573-0636. Home care and hospice instructions Home care and hospice providers should especially heed the following specific guidance that DOH included in its most recent communication to the provider community: •

Home care agencies and hospices are encouraged to review patient care needs and consider adjustment of visits to ensure that Level 1 patients are visited prior to the start of the storm. These, and all 3

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patients, should be reminded of how to call for assistance if they lose their power or have a medical emergency. •

Make plans for adjusting staff schedules/prioritizing patient visits in the days immediately following the storm, particularly if travel is still impeded, with a focus on reassigning staff based on proximity to patients so as to limit travel and reduce staff exposure to hazardous conditions.

•

Agencies should also ensure that staff and their patients have enough supplies to cover a period of at least 72 hours following the start of the storm.

•

Agencies should be ready to contact staffing services if a large proportion of their regular staff are unable to travel and perform any of their normal visits for a period of time following the storm.

•

Agencies should also be ready to communicate with their patients during and immediately following the storm to perform checks on their safety and condition of their health.

•

During emergencies, if agencies are in need of services or supplies, they should contact their local Emergency Manager through the county EOC.

HCA will continue to alert you of further guidance. Please be sure to record any specific structural hindrances to your care of patients amid the storm, so that HCA can act on your behalf to mitigate these impacts during or after the emergency.

VP Chief Financial Officer at Strong Home Care Group

HIRING

Leads and manages operations that drive the financial performance for Strong Home Care Group (SHCG), including Visiting Nurse Service of Rochester and Monroe County (VNS), Community Care of Rochester (CCR) – dba Signature Care, Finger Lakes Visiting Nurse Service (FLVNS) and Finger Lakes Home Care (FLHC). Proactively provides oversight and leadership to all financial activities of the combined agency that maximizes reimbursement, controls costs, and fully utilizes agency resources. Additionally provides executive management oversight for Information Technology Services and selected support operations as assigned by the CEO. “PLEASE VISIT www.vnsnet.com FOR A FULL DESCRIPTION” Qualified candidates please send résumé to: Human Resources, 2180 Empire Blvd., Webster, NY 14580 Fax: 585-787-8369; Email: employment@vnsnet.com. VNS values diversity and encourages minorities to apply. E.O.E.

Chief Financial Officer The Visiting Nurse Service of Northeastern New York is a dynamic, progressive home health organization dedicated to delivering the highest quality level of care through industry best practice. The 195 employees of VNS deliver skilled healthcare in the Capital District. The CFO reports to the CEO and serves as an integral member of the senior management team. The right candidate will provide the leadership, management and vision necessary to ensure that the agency has the proper operational controls, administrative and reporting procedures, and people systems in place to effectively grow the organization and to ensure financial strength and operating efficiency. This position will provide useful financial insights to help make better decisions about formulating and executing strategy. Requirements: Bachelor’s degree from an accredited university or college; Finance background, Federal Government reimbursement experience and an MBA in Accounting, Finance or Business are preferred; Minimum of 10+ years of experience in senior level finance management; Progressive knowledge of current financial and accounting computer applications; Excellent verbal, analytical, organizational and written skills. Send résumé and cover letter to: Fax: 518-382-5699; E-mail: porcellik@vnshomecare.org. Human Resource VNS, 108 Erie Blvd. Schenectady, NY 12305.

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HCA President Cunningham Meets with Schumer on Federal Issues House considers F2F bill HCA President Joanne Cunningham met with U.S. Senator Charles Schumer this week as part of HCA’s continued efforts to press the case for a fix to the U.S. Centers for Medicare and Medicaid Services (CMS) rebasing cuts to home care. As reported last week, Senator Schumer has led a Senate letter to seek CMS’s reconsideration of the current regime of rebasing cuts, following a similar letter being sent in the U.S. House. (See p. 1 story, last week’s ASAP). Ms. Cunningham also discussed other burning federal home care issues, like the need for major changes to the Medicare home health face-to-face (F2F) requirement that has been crippling providers with complicated documentation standards and the risk of recoupments for technical reasons outside their control. On this matter, the House Energy & Commerce Subcommittee on Health held a hearing yesterday to consider legislation that would modify the F2F documentation requirement. This particular bill is being drafted by Congressman Greg Walden of Oregon. The bill, called the “Home Health Documentation and Program Improvement Act of 2015,” would streamline the process of home health admission. It seeks to eliminate superfluous paperwork and remove a “one-sizefits-all” approach, recognizing that the need for face-to-face documentation is most critical in cases where patients are not well connected with physicians, as is often the case for patients admitted to home health services following a hospital stay. This bill would also demand that CMS repay home health providers for valid claims that have previously been denied based on their assessment of an insufficient physician narrative. The National Association for Home Care and Hospice (NAHC) submitted testimony for this hearing where it detailed the obstacles that this requirement presents to home health providers, as echoed by witnesses who also spoke to the confusion and complication of the current process. Several subcommittee members supported the proposed F2F modifications. While a complete repeal of the face-to-face requirement may be ideal, NAHC, and HCA, recognize that this bill would provide relief and compromise that may be more manageable for agencies than the current requirement. The bill language has not been finalized and HCA will examine it at that time. NAHC has urged further action around the F2F requirement outside of this piece of legislation, including a suggestion that exceptions should exist, perhaps by way of a waiver process. They have also pressed for the inclusion of a telehealth provision to complete the F2F encounter requirement. Meanwhile, as extensively reported in past editions of ASAP, NAHC has filed a lawsuit against CMS’s F2F rule that is pending in the courts. HCA continues to advocate for similar action and, as always, will consistently put forth these concerns to New York’s Congressional Delegation, as we did in meetings with Senator Schumer this week.

ASAP – a publication of the Home Care Association of New York State REBASING from p. 1 Director Jason Helgerson seeking his action to suspend the new rebased rates, especially as the action is totally contradictory to DOH reforms dependent upon home care, completely adverse to home care delivery, and is contrary to a remedial bill that had unanimously passed the Legislature earlier this year, awaiting delivery to the Governor, to hold the rebasing adjustments to the level included in the state fiscal plan. This follows an intensive meeting last week with the governor’s secretary for health Paul Francis presenting a comprehensive case for suspending any further rate cuts to home care and for signing the HCA-developed EPS legislation. Given this development, it is vital for agencies to continue writing the Governor’s office seeking his signature of S.5878/A.8171, a safety-net measure that aligns the rebasing process with forecasts assumed in the state budget, preventing a harmful drain on agency resources at a time when home care stability is needed to meet the state’s own policy goals. An advocacy campaign on this bill is at http://p2a.co/6snbQwL.

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The CHHA rebasing includes changes in the EPS grouper logic and other updated values which will require adjustments to provider billing software. The revised grouper and related rates will be effective for claims with an episode begin date of October 1, 2015 or later. HCA members can access the revised rates and related information regarding the EPS at the following DOH website: http:// www.health.ny.gov/facilities/long_term_care/ reimbursement/chha/. The schedule of rates effective October 1, 2015 reflects full implementation of the 2013 base year for the 108 case-mix-adjusted payment rates for your agency for providing services to patients 18 years of age and older under the episodic payment system. Two additional rates are provided for assessments and non-OASIS maternity patients. These rates have replaced the current interim rebasing adjustment rates which were effective April 1, through September 30, 2015.

The new rates are calculated in accordance with Article 3614.13 of the Public Health Law and Part 86-1.44 of the Commissioner’s Administrative Rules and Regulations to reflect a full rebasing of the EPS.

It is important to note that these CHHA EPS rate revisions do not include any adjustment to the rates for pediatric patients, who continue to be reimbursed on a historical fee-for-service per unit basis in accordance with Part 86-1.13.

Based on this statutory requirement, the Department has determined that the latest complete base year data available for rebasing is calendar year 2013 and has now finalized the data for implementation of the required rebasing utilizing 2013 claims data and corresponding 2013 OASIS assessment data.

HCA will keep the membership apprised of any response regarding the status of these rates as we continue to press the Governor’s office for its commitment to act in support of the rebasing limits embodied in S.5878/A.8171.

DOH Posts Nursing Home Transition Materials

eMedNY Posts Updated MEVS/DVS Provider Manual eMedNY has posted an updated Medicaid Eligibility Verification System (MEVS) and Dispensing Validation System (DVS) Provider manual. Please see https://www.emedny.org/ProviderManuals/5010/ MEVS/MEVS_DVS_Provider_Manual_(5010).pdf.

The state Department of Health (DOH) has posted materials from a webinar entitled: “Transition of Nursing Home Populations and Benefits to Medicaid Managed Care,” which was held on September 22, 2015. Materials are at http://www.health.ny.gov/health_care/ medicaid/redesign/docs/2015-0922_nh_transition.pdf.

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Supervision Plus Change of Venue, HCA Meet-ups, Provider Forums and More All Coming Up! HCA’s fall education and member engagement agenda is crowded with new ways to reach and educate you. Make sure you aren’t missing all of these important opportunities. On a housekeeping note, we’ve changed the venue for the October 20 Supervision Plus program, Dr. Robert Fazzi’s acclaimed training in home care management methods, which is now being held in New York City. Providers from any region are invited to attend. To learn more, see the registration form on our “Education and Events” page at http://hca-nys.org/events-education/upcoming-events. There, you will also find registration for several upcoming HCA Regional Meet-Ups in every part of the state to discuss local experiences and concerns with big policies like the Delivery System Reform Incentive Payment (DSRIP) program, as well as technical issues specific to your locale. A list of Meet-Up locations is in the flyer at the back of this week’s ASAP. You’ll also see information about our upcoming Member Forums for LTHHCPs, LHCSAs and MLTCs which will provide entity-specific updates and discussion for further advocacy and assistance related to your provider or plan type. We have a number of other exceptional programs ready for you, including our Corporate Compliance Symposium and newly announced Quality Symposium (see related p. 1 story), our next signature HCA conferences, and a Bootcamp on labor law issues.

HCA to Hold Free Member Call on Companionship Exemption HCA will hold a free members-only call on October 9 from 1 to 2 p.m. to provide an update on implementation of the U.S. Department of Labor’s (U.S. DOL) final rule that eliminates the “companionship exemption” for aides employed by home care agencies. To register, please complete the online form at https://www.surveymonkey.com/r/KRH2J2B. You will receive a confirmation and call-in number prior to the call. The National Association for Home Care and Hospice (NAHC) and other parties have requested that the U.S. Supreme Court issue a “stay” of the U.S. Court of Appeals’ August 21 decision that upheld U.S. DOL’s final rule. NAHC expects the Supreme Court to make a decision on the stay request prior to October 13 – the anticipated date of implementation. On this members-only call, Frank Fanshawe, HCA’s counsel and Partner at Wilson Elser Moskowitz Edelman and Dicker, LLP, will provide a legal update and discuss ways for agencies to prepare for the upcoming changes. As mentioned in many communications and programs, the major changes for New York are that aides, under this rule, will have to be paid at time-and-a-half of their regular rate of pay instead of time-and-a-half of minimum wage, and agencies will have to keep much more detailed records for their 24-hour live-in cases. Continued on next page

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Continued from p. 7 HCA also surveying impact on providers As a reminder, following an alert sent to you earlier this week, HCA is also asking all of our members to complete a very short survey to ascertain the impact of the DOL rule if it goes into effect. The survey is here: https://www.surveymonkey.com/r/FVG89PH. HCA, along with LeadingAge New York and the New York State Association of Health Care Providers, has developed this seven-question survey so that we have data for our advocacy on your behalf. We are specifically advocating that the state provide additional Medicaid funding via Medicaid fee-for-service rates and managed care capitated premium rates to help home care providers meet new overtime costs. Your completion of the survey is vitally important in our efforts to get the state to address the effects of these changes. If you receive the survey from multiple associations, please complete it only once. Please complete the survey by Friday, October 16. If you have any questions, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

HCA, Associations, DOH Meet on Payment and Other Issues This week, HCA and other provider associations met with the state Department of Health (DOH) as part of new regularly scheduled meetings to discuss vital payment, reimbursement and other issues that affect home care providers and their patients. Some of the topics covered included: pending reimbursement cuts to CHHAs as a result of rebasing (those cuts, as reported on p. 1, have since been implemented); the Qualified Incentive Vital Access Provider Pool (QIVAPP); retroactive payment adjustments due to providers for the period of April 1, 2014 through March 31, 2015, based on the elimination of the 2 percent Medicaid fee-for-service across-the-board reduction in the 2014-15 state budget; new costs for overtime and other changes related to the elimination of the companionship exemption; the live-in policy for MLTC enrollees; recent wage and overtime decisions in the courts; managed care plan financial instability; and others. In all the above issues, HCA and the other provider associations emphasized the fragile economic condition of home care agencies as they face increased wage and related employee costs; payment reductions; new regulatory requirements; and the need to change their operations – and invest – to participate in new models of care. CHHA Episodic Payment System (EPS) Rebasing HCA told DOH that we met last week with the Governor’s Health Cabinet to discuss the October 1 CHHA EPS rebasing that will result in significant payment reductions to CHHAs. We had requested that the Governor’s office put a hold on the full rebasing that will take upwards of $100 million out of the system, instead of the $30 million that was in the state budget fiscal plan. (See p. 1 story for the latest information on this issue.) DOH staff at the meeting indicated that the issue remains under the aegis of other department staff, but the associations used the meeting as a means to emphasize the crippling effect that pending EPS reductions would 8

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have amid other DOH payment policies in collectively harming patient care and agency stability. HCA reminds members to continue pressing for the Governor to sign HCA legislation that would scale back these cuts. Further information and an online advocacy campaign are posted to our Legislative Action Center, at http://p2a.co/ 6snbQwL, where you can send a message to Governor Cuomo directly with a push of the button. Companionship Exemption Changes DOH said it plans to survey managed care plans this week to ascertain the estimated new costs stemming from expected changes in overtime rules. These changes are a result of the soon anticipated implementation of a federal rule that eliminates the companionship exemption for agencies. Managed care plans will be reaching out to their home care network providers for such data. (see related p. 7 story.) Once DOH obtains survey results, it will decide how to address the new costs in possible adjustments to both Medicaid fee-for-service rates and managed care capitated premium rates. HCA, LeadingAge NY and the New York State Association of Health Care Providers (HCP) are also surveying our own members to assess the financial and other impacts of the expected change in calculating overtime. HCA sent members an Alert this week with a link to our survey. (See separate p. 7 story.) We are also holding a free member conference call to update you on the issue. The call will be held on October 9, from 1 to 2 p.m., in advance of the anticipated October 13 implementation of the rule, pending actions in the courts where home care plaintiffs have challenged the federal regulation. QIVAPP DOH reported that IPRO will be sending a letter to about 100 providers who have been identified as being eligible for the second round of QIVAPP monies ($35 million in federal funding). The home care providers will be asked to verify that they meet the QIVAPP requirements. IPRO will also conduct desk audits and/or site visits related to this initiative aimed at reconciling awarded funds based on a determination of eligibility. The entire process, from audit to reconciliation, will take about three months. Meanwhile, the state is expected soon to request approval from the U.S. Centers for Medicare and Medicaid Services (CMS) for the QIVAPP federal funding. Live-in Cases DOH has sent a survey to MLTC plans that asks them if they are in compliance with MLTC Policy 14.08: “Paying for Live-In 24 Hour Care for Personal Care Services and Consumer Directed Personal Assistance Services” (http:/ /www.health.ny.gov/health_care/medicaid/redesign/docs/mltc_policy_14-08_paying_for_live_in_cases.pdf ). Under this policy, plans are required to provide a rate of payment for live-in cases that is based on at least 13 hours of care, and this policy is retroactive to April 1, 2014. Based on the plans’ responses to the survey, DOH will decide any further action. Fiscal Intermediary Services After the meeting, HCA sought further information on the state’s policy for entities that want to provide fiscal intermediary (FI) services to managed care plans. DOH had earlier released guidance (http://www.health.ny.gov/ health_care/medicaid/redesign/docs/mltc_policy_15-05.pdf ) which seemed to indicate that such entities had to obtain a separate Medicaid provider identification number even if they already had one. Continued on next page

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Continued from p. 9 DOH had told HCA that this interpretation was not correct and a separate Medicaid provider number is not needed if the organization already has one. DOH hopes to soon release further guidance. Meanwhile, entities without a provider number who want to provide FI services should submit a Medicaid provider application as soon as possible since the Department’s approval process can be lengthy. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org or Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Value Based Payment Committees Further Detailing Methodology The subcommittees of the state’s Value Based Payment (VBP) initiative continued their meetings this week, further focusing on intensive design details and issues for VBP implementation. State Department of Health/KPMG slides for the VBP Technical Design I and II subcommittee meetings can be viewed at http://hca-nys.org/wp-content/uploads/2015/10/TD-II-Meeting-3_PresentationSlides_Draft_FINAL.pdf and http://hca-nys.org/wp-content/uploads/2015/10/NYS-VBP_Technical-DesignI-SC_Meeting-3_Presentation_FINAL.pdf. The subcommittees have moved toward discussion and early drafts of options for recommendations on shared savings/risk levels, attribution, advanced VBP innovator programs, and related issues. A major overall focus continues to be on whether and what criteria should be established as “guidance,” and whether and what should be considered as “requirements/standards.” As one of many components discussed in subcommittee, the Technical Design II group examined concepts for attribution of patients to VBP contractors. Two of the possible draft recommendations include: •

Attribution to the primary care physician/practitioner for “ Total Care for Total Population” VBP arrangements, as well as for “Integrated Primary Care” and “Chronic Care” bundles.

•

Attribution to home care provider or nursing home (depending on the residential status of the beneficiary) for the MLTC subpopulation.

The draft concept would also permit a managed care organization and VBP contractor to agree on a different approach to attribution, upon notification to the state. These and other critical points of discussion are captured in the meeting slides and will be further detailed to the membership by HCA as the drafts continue to evolve. HCA is developing multi-tier plans to assist providers with informational and technical aspects of VBP; further information will be forthcoming. We brought the issue to members during HCA’s Senior and Financial Manager’s Conference in mid-September, and we have steadily covered VBP developments and mechanics in HCA communications. We strongly urge providers to continue reviewing all of the available materials on VBP and to proactively consider and strategically plan your approaches for potential involvement. For further information, contact Al Cardillo at acardillo@hcanys.org. 10

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CMS Contractor Aims F2F-focused Home Health Probe and Education Reviews Beginning This Week In May 2015, the U.S. Centers for Medicare and Medicaid Services (CMS) announced its plans to conduct a ‘Probe and Educate’ review on home health claims to ensure agencies understand the new certification requirements, specifically the revised face-to-face (F2F) encounter requirements, effective January 1, 2015. CMS’s May announcement can be found at: https://www.cms.gov/Research-Statistics-Data-and-Systems/ Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/ Home_Health_Medical_Review_Update.html. According to the announcement, reviews started on October 1 for claims with episodes that begin on or after August 1, 2015. The specifics of the review (number of claims, length of review, education methods, etc.) have yet to be published. CMS has indicated to our colleagues at the National Association for Home Care and Hospice (NAHC) that claims reviewed during the ‘Probe and Educate’ period will be denied by the Medicare Administrative Contractors (MACs) if the certification requirements are not met. CMS maintains they have no authority to pay claims where the criteria for Medicare coverage are not evident. CMS stated in its original announcement that it plans to post additional details and information online regarding the ‘Probe and Educate’ review process, yet it has not done so to date. Whether this will delay the ‘Probe and Educate’ review process is unclear, but agencies should expect to see increased medical review activity on home health claims over the next several months. Please see related p. 5 story on F2F legislation and advocacy efforts. For further information, contact HCA’s Patrick Conole at (518) 810-0661 or at pconole@hcanys.org.

HCA, Medical Society Partner to Address Health Care Disparities Building off of continuing discussions and partnership possibilities on this issue, HCA and representatives of the Medical Society of the State of New York (MSSNY) met this week with state legislative representatives on joint concepts for addressing disparities in health care. Last year, HCA was invited to present to MSSNY’s Committee on Health Disparities regarding home care’s unique potential as a partner in addressing population health. HCA and several providers teamed up to demonstrate unique aspects of the home care model which lend themselves to addressing disparities. We also showcased specific approaches/initiatives successfully implemented by providers. HCA and MSSNY have since discussed opportunities for securing state support on care collaboration. This week HCA and MSSNY jointly met with the director of the legislative commission that focuses on issues of particular impact/concern to the state’s minority populations. HCA and MSSNY discussed the concept of garnering legislative and/or budgetary support for initiatives that would partner our associations as well as providers in multiple possibilities for addressing disparities, whether broad-based focusing on underserved communities, or condition-specific endeavors such as cardiac, diabetes, high-risk pregnancy, sickle cell, and other conditions known to be more prevalent in particular subpopulations. Next steps will involve HCA and MSSNY moving to specific proposal development. HCA will be reaching out further within the membership to invite input into this process. This initiative is well aligned not only to state 11

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and national public health priorities, but also to the emerging state models of care and coverage, including DSRIP, VBP (see related p. 10 story), and others. For further information, please contact Al Cardillo at acardillo@hcanys.org.

Influenza Not Yet Prevalent in New York Flu mask requirement not in effect now The state Department of Health (DOH) has posted a notice that influenza is not prevalent in New York at this time and, thus, home care and other health care providers are not yet required to meet the state’s flu-mask and reporting mandate. This mandate requires certain personnel to wear a surgical or procedure mask while in areas where patients or residents are typically present if the personnel have not been vaccinated against influenza for the current influenza season. HCA gave a similar status update in last week’s ASAP based on communications with DOH, but now DOH has publicly reported that the mandate is not yet in effect. Please see: http://www.health.ny.gov/diseases/ communicable/influenza/seasonal/providers/prevention_of_influenza_transmission/. Last year, DOH declared influenza prevalent from December 11, 2014 to May 14, 2015. HCA members should prepare now to meet the influenza mask requirement once DOH declares that influenza is prevalent. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

DSRIP Updates The state Department of Health (DOH) has posted the presentations from the first Annual PPS (Performing Provider System) Learning Symposium held on September 17 and 18. Please see http://www.health.ny.gov/ health_care/medicaid/redesign/dsrip/providers_professionals.htm. According to DOH, the Symposium was designed to: •

Develop partnerships across PPSs who have received Delivery System Reform Incentive Payments (DSRIP), as well as mechanisms to share emerging best practices and evidence-based approaches to successfully complete project deliverables.

•

Highlight promising efforts across the state (and nationally) to transform current care delivery practices and improve care transitions.

•

Promote further dialogue between PPSs and DOH about current key issues impacting PPS capacity to achieve DSRIP goals.

DOH has also posted the latest DSRIP White Board Video. The video features state Medicaid Director Jason Helgerson discussing key DSRIP updates, the PPS shift from planning to implementation, value based payment pilot opportunities, PPS network additions, and the DSRIP midpoint assessment. The video can be viewed at https://youtu.be/Ngt30esw_z8. Continued on next page 12

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Volume 20, No. 34 October 2, 2015 

Continued from p. 12 Other resources DOH hosted a webinar on September 22 covering data security and it released additional supporting guidance to assist PPSs in understanding and completing their Systems Security Plans. Resources are at the links below: •

https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/data_security/docs/2015-0922_faqs_systems_security_plans.xlsx

•

https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/data_security/docs/2015-0922_ohip_system_security_plan_wrkb_instr.docx

Data sharing and opt-out On October 6 from 10 to 11:30 a.m., DOH will host a webinar to discuss its mailings to Medicaid recipients offering explanations of DSRIP and data-sharing. The presentation will cover DSRIP, the consumer letter, data-sharing, the timetable and call center support. Registration is at https://attendee.gotowebinar.com/ register/4634813515553763074. Project Approval and Oversight Panel Meeting On November 9 and 10, the DSRIP Project Approval and Oversight Panel (PAOP) will meet with the upstatebased DSRIP PPSs in Albany. The meeting is open to the public, but there will be no public comment period. No pre-registration is required. November 9 will be a full-day meeting, structured as an update session for the panel members, and an opportunity for the panel members to check in with each of the PPSs. November 10 is half-day. The meetings will be webcast at http://www.health.ny.gov/events/webcasts/. A full agenda and more details will be sent out next month. Any questions may be directed to dsrip@health.ny.gov.

FIDA News DOH has posted materials from its September 9 webinar on the Fully Integrated Duals Advantage Program (FIDA) at https://www.health.ny.gov/health_care/medicaid/redesign/fida/docs/2015-0909_fida_stakeholders.pdf. Some important information includes: •

Westchester and Suffolk Counties will begin in 2016.

•

DOH has submitted a request for extension and, if approved by CMS, the program would run through December 2019. Continued on next page 13

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Volume 20, No. 34 October 2, 2015 

Continued from p. 13 •

DOH and CMS are in the process of updating the Interdisciplinary Team (IDT) Policy to provide flexibility to both plans and providers.

•

Some of the proposed IDT changes relate to greater flexibility for IDT participation; timeframes for meetings and communications; and acceptance of electronic signatures and verbal approvals of care plan.

•

Some challenges include: lower than expected enrollment numbers; IDT logistics; provider participation in the IDT; and training requirements.

See separate story below on possible changes to FIDA and other MLTC products.

Conference to be Held on Health Care Competition and Consolidation The New York State Health Foundation (NYSHealth) will hold a conference entitled Competition and Consolidation in Health Care: Can We Get the Balance Right? in New York City on November 4, from 8:30 a.m. to 12:30 p.m. The agenda and registration information are at http://tinyurl.com/qgdskao. The program announcement states: Spurred by federal and state policies, a wave of consolidation is sweeping across health care. Providers are merging, affiliating, and entering into new partnership arrangements that create large organizations with enhanced market power. Similarly, health insurers are merging at a rapid pace and gaining market share. As New York State embarks on ambitious efforts to transform its health care system, it will be crucial to strike a careful balance between competition and consolidation. NYSHealth is sponsoring a public forum to explore these issues featuring keynote speaker Martha Coakley, former Attorney General of Massachusetts; a panel featuring senior New York State officials; and a panel focused on the perspectives of consumers, providers, insurers, and employers.

DOH Holds Long Term Care Meeting On Tuesday, HCA participated in a Long Term Care Forum held by the state Department of Health (DOH) in New York City. The purpose of the forum was for DOH to provide updates about the future of various MLTC products (partial caps, Medicaid Advantage/MA, PACE) and the Fully Integrated Duals Advantage (FIDA) program, as well as to open the floor for discussion and feedback. The meeting centered on recommendations made in a DOH-developed draft White Paper which is posted, along with forum slides, at https://www.health.ny.gov/health_care/medicaid/redesign/. The draft proposes options for possible MLTC model enhancements under a so-called “MLTC Plus” designation. DOH proposes that such enhancements could better align MLTC with DSRIP (Delivery System Reform Incentive Payment) program goals, including value-based payment; integrate behavioral and physical health; enhance care transitions, and incentivize primary care physicians to meet certain patient-centered care and oversight metrics. DOH also proposes modifications to FIDA, including an effort to make changes to the Interdisciplinary Team (IDT) policy, such as providing bonus payments for primary care participation in the IDT. Other modifications 14

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Volume 20, No. 34 October 2, 2015 

 Continued from p. 14 include changes to the network and/or enrollment requirements, enhancing and/or eliminating services from the benefit package, or allowing plans to market FIDA, and more. There was also a proposal to freeze new MLTC partial plan enrollment by December 2016 for companies that have a FIDA plan but do not have at least 25 percent of total members in some type of integrated plan (FIDA, MAP or PACE). Forum participants included HCA and other provider associations, managed care plan representatives, and consumer advocates who all provided feedback on the proposals. State Medicaid Director Jason Helgerson; the Director of the Division of Long Term Care, Mark Kissinger; and other representatives from DOH and the U.S. Centers for Medicare and Medicaid Services (CMS) were present. HCA’s comments included urging DOH to consider home and community based providers’ existing strengths, involvement and achievements as they relate to the White Paper’s proposals for expanded MLTC duties. HCA urged that DOH reformat the proposals to build upon the existing base via MLTC-provider collaboration, rather than “reinventing the wheel.” HCA asserted that this approach would optimize what is already working, promote efficiency and smart use of existing investments, promote existing provider partnerships (e.g., home care and hospital), and avoid imposition of new/duplicative costs and administrative burden on MLTCs. Additionally, HCA urged that any expansion of duties and service jurisdiction for MLTC-home care include streamlining and alignment of potential additional layers of regulation, and avoid compounding an already overburdened regulatory structure for providers and plans. HCA also stressed that expansion of services and duties must be accompanied by adequate premiums for MLTCs and rate payments for providers. Finally, HCA suggested that DOH explore Medicare shared savings potential for MLTCs and providers via a collaborative model between MLTC and Medicare-certified providers and their subcontracting agencies. Points raised by others included the need for health information technology investment for long term care providers and sustainable managed care rates if responsibilities and services are increased. Plans also called for immediate changes to FIDA, noting that otherwise some of them will be forced to stop offering a FIDA plan. Many also commented that the IDT requirements were too stringent and must be modified significantly if they were to remain, citing concern over lack of provider buy-in. Also, a DOH proposal to freeze new MLTC partial capitation enrollment was opposed by plan representatives. HCA will be providing further feedback on DOH’s White Paper. We encourage members to review it and send us any comments they may have. Members who want to submit comments should send them to mltcworkgroup@health.ny.gov with the subject header “LTC forum” by close of business on October 9. For more information, contact HCA Policy staff.

NGS Education Programs National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), has recently posted the following educational webinars. Certifying Home Health Care (Monday, October 5, from 12:30 to 2 p.m.) This webinar will provide a greater understanding of patient/beneficiary eligibility, face-to-face encounters and certification requirements as per the 2015 Medicare home health benefit regulations. Attendees will be 15

ASAP – a publication of the Home Care Association of New York State

Volume 20, No. 34 October 2, 2015 

provided with resources and references and a question and answer period will follow this session. Registration is at https://attendee.gotowebinar.com/register/1165221008344812034. How to Correct and Avoid the Top Home Health Claim Errors (October 13, from 2 to 3:30 p.m.) This webinar is designed to educate home health providers on the top rejection and returned-to-provider (RTP) reason codes and how to review, resolve and prevent them in the future. Registration is at: https:/ /attendee.gotowebinar.com/register/8409136766767972353. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Publications •

“2016 Part D and Medicare Advantage plan landscape information,” by the New York Legal Assistance Group http://www.wnylc.com/health/entry/192/

•

“ICD-10 Conversion/Coding Infrastructure Revisions to National Coverage Determinations (NCDs) – 3rd Maintenance CR,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/ MLNMattersArticles/Downloads/MM9252.pdf

•

“New York Consumer Guide to Health Insurance Companies,” by the state Department of Financial Services http://www.dfs.ny.gov/consumer/health/cg_health_2015.pdf

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

The Quality Imperative: Raising the Bar in Home Health Care

November 17 & 18, 2015 Hilton Garden Inn 235 Hoosick Street Troy, NY 12180

www.eventville.com/hcanys

November 17 & 18, 2015 Hilton Garden Inn 235 Hoosick Street Troy, NY 12180

The Quality Imperative: Raising the Bar in Home Health Care Quality outcomes have always driven your work in home care. But today’s environment is making quality deliverables a more commanding imperative, and a linchpin for the success of your agency. CAHPS surveys, Home Health Compare, HQRP, OASIS … in many respects, these are the first legacy of quality improvement leverage points. They remain important concerns. But today, home care is faced with new and even bigger machinery for inducing quality enhancement that demand an equally vigorous response from CHHAs, LTHHCPs, and LHCSAs alike. All home care providers must focus their energies, resources and intellectual capital to understand and retool their organizations for the new quality imperative. HCA’s Quality Symposium presents an opportunity to learn the broad strokes and inner workings of New York State’s quality home care imperative. You’ll hear about concrete tools, resources and information that will arm agencies to effectively compete in this environment. You’ll also learn about interventions for specific clinical areas that align with the demands of MLTC, DSRIP, Value Based Payments and other new care models.

AGENDA

Tuesday, November 17 – Day 1 8:30am

Registration Opens with Light Breakfast

9:00am

HCA Welcome

9:00 – 10:00am

State Update on Quality & Payment Innovation Patrick Roohan, Director, Office of Quality and Patient Safety, NYS Department of Health Hear from one of New York State’s most influential and thoughtful policymakers about the plans and vision of the State in designing state policy to encourage and promote quality health care. Mr. Roohan will discuss the State’s vision for quality innovation and improvement through policy changes that will affect how all health care providers (including home care) participate in the Medicaid marketplace.

10:00 – 10:45am

HCA Quality Risk Tool Laurie Neander, Chief Executive Officer, Bassett Healthcare Network: At Home Care Al Cardillo, Executive Vice President, HCA HCA, working with key home care leaders across New York State, has formulated and developed a quality of care risk tool that is currently in the RFP stages of development. This session will offer a look at this unique HCA quality risk tool that will be available to members in 2016. It will arm agencies with a thorough, methodical tool to measure risk areas in clinical, financial and operational quality oversight.

November 17 & 18, 2015 Hilton Garden Inn 235 Hoosick Street Troy, NY 12180

The Quality Imperative: Raising the Bar in Home Health Care Tuesday, November 17 – Day 1 - continued 10:45 – 11:00am

Break

11:00am – Noon

Wound Care: There’s an App for that Nathan Ie, CEO, Co-Founder, Healogram Lorraine Poliey RN, WCC, DAPWCA, Wound Care Program Manager, Montefiore Home Care This session will offer insights on a new App designed to help providers reduce the cost of and challenges associated with wound care. Healogram enables providers to more effectively and efficiently measure, monitor, and manage wound patients. Healogram CoFounder Nathan Ie and wound care program manager Lorraine Poliey, RN of Montefiore Home Care will outline details on Healogram’s functionality and share practical insights on ease of implementation, impact on care delivery and potential for enhanced patient outcomes.

Noon – 12:45pm 12:45 – 1:45pm

Lunch

Hotel Information

Promotion of Quality in Managed Long-Term Care

Hilton Garden Inn 235 Hoosick Street Troy, NY 12180

Tracy Langlais, Vice President, Medical Affairs Operations, CDPHP As New York’s health care system evolves, health plans, including MLTCs and MCOs, feel enormous pressure to meet the highest quality outcomes and benchmarks. Aligning home care’s emphasis and priorities on quality innovations and outcomes with the benchmarks that are of utmost importance to managed care plans can lower cost and improve care for patients. Learn from one of the state’s most innovative managed care plans about its priorities for quality innovation and alignment with home care partners. 1:45 – 2:45pm

VBP Clinical Spotlight: TBA

2:45 – 3:00pm

Break

3:00 – 4:30pm

CMS Star Rating System and NYS Home Care Quality Indicators

HCA has reserved a limited block of rooms at the rate of $129 per night. To make a reservation for the evening of Monday, November 16 or Tuesday, November 17, please call (877) 782-9444 before November 2, and ask for the HCA Quality Symposium group rate.

Sara Butterfield, RN, BSN, CPHQ, CCM, Director, Upstate Health Care Quality Improvement, IPRO Learn from one of New York State’s most knowledgeable quality innovation experts about the impact the Star Rating System has had on New York’s home care provider community, and steps that can be taken by agencies to improve their scores. 4:30 pm

Wrap Up and Adjourn Day 1

Day 2 Agenda continued on next page…

November 17 & 18, 2015 Hilton Garden Inn 235 Hoosick Street Troy, NY 12180

The Quality Imperative: Raising the Bar in Home Health Care

REGISTRATION FORM Registration Deadline is November 2.

Wednesday, November 18 – Day 2 8:00am

Registration and Light Breakfast

Name: _____________________________________________ Title:_______________________________________________ Agency:____________________________________________ Address:____________________________________________

8:30-10:00am

Quality Care Values in Contracted Home Health Care Services Marki Flannery, Executive Vice President and Chief of Provider Operations, Visiting Nurse Service of New York Maureen Forster, Empire Blue Cross Blue Shield Health Plus This session will offer insights, tools, and innovative program models for enhancing the quality of your home health care services in areas valued by health plans and contracting agencies. Learn from health plan and contracting agency representatives about their current quality initiatives and the quality related indicators/ measures they are seeking in an optimal contracted Licensed Home Care Service Agency to inform your strategic planning toward sustainability and growth in an increasingly competitive service delivery environment. Attendees will have an opportunity for questions and answers with panelists.

10am – 10:15am

Break

City/State/Zip:_______________________________________ Phone:_____________________________ Ext._____________ Email: ______________________________________________ (Required)

www.eventville.com/hcanys

FEE SCHEDULE Full Symposium (Nov 17 & 18) HCA Member Rate Per Person

$259 □

HCA Member Group Rate (3 or more)

$239 □

Non-Member Rate

$339 □

November 17 Only HCA Member Rate

$199 □

Non-Member Rate

$279 □

November 18 Only

10:15am – 11am Quality Care Innovations in LHCSA Delivery James P. Rolla, Vice President, People Care, Inc. Michelle Mazzacco, Vice President/Director, Eddy Visiting Nurse Association/St. Peter’s Health Partners (invited) An executive panel from agencies providing licensed home care services will outline their quality care innovation efforts and provide guidance, tools and tips for planning and implementing quality initiatives. Attendees will have an opportunity for question and answers with panelists.

11:00am – Noon Common Areas of Quality Risk

(and Remedy) Identified in Surveillance Rebecca Fuller Gray, Director, Division of Home and Community Based Services, NYS Department of Health (Invited) This session will provide invaluable insights from the state surveillance of home care agencies and proactive opportunity for quality promotion/risk mitigation from the State’s Director for home care services. In this presentation, Ms. Fuller-Gray will examine areas of quality risk and/or deficiency identified in DOH surveys and present recommendations for remedy, and most importantly, prevention/mitigation of these risk areas and overall quality promotion.

Noon

Wrap Up and Adjourn

HCA Member Rate

$ 89 □

Non-Member Rate

$159 □ TOTAL: $___________

PAYMENT Please check method of payment: (Checks must be received by date of program).

____MC ____VISA ____ AM EXP

____ Check*

*Make checks payable to : HCA Education and Research and mail to: 388 Broadway, 4th Floor, Albany, NY 12207 Credit Card #: _________________________________ Exp. Date:______________ Security Code: _________ ______________________________________________ Name and/or Company Name on Card

______________________________________________ Billing Address of card (including City, State and Zip Code)

______________________________________________ Authorized Signature

Cancellations received in writing via email to info@hcanys.org by November 2, are refundable less a 25% administrative fee. No refunds after this date or for no shows. Substitutions are permitted.

Please fax to: (518) 426-8788

HCA Regional Meet-Ups: Help Us Help You!

+ Add me

•

HCA is continuing our series of Member Forums for specific segments of the HCA membership. These Forums provide a custom-tailored focus on issues affecting LHCSAs, LTHHCPs, MLTCs, and HCA’s Home Care Council (HCC) of New York City members.

Registration

Once complete, please fax to (518) 426-8788. You must provide us with an email address in order to receive your confirmation. ______________________________________________________ Name

We've designed these forums recognizing that each subset of our membership has a unique scope of issue and advocacy needs that demand attention.

______________________________________________________ Title

Please register today to attend one of these important sessions.

______________________________________________________ City/State/Zip

______________________________________________________ Agency ______________________________________________________ Address

______________________________________________________ Phone/Ext.

MLTC forum October 30

11am – 2pm HealthPlus/Amerigroup 9 Pine Street 14th Floor (AKA 14 Wall Street) New York, NY 10005

LTHHCP forum November 13

10:30am – 2:30pm Hilton Albany 40 Lodge Street Albany, New York 12207

Downstate LHCSA forum November 23

10am – 2pm Selfhelp Family Home Care Boardroom 530 Eighth Avenue 5th Floor New York, NY 10018

______________________________________________________ Email (Required) Second Registrant from same organization: ______________________________________________________ Name ______________________________________________________ Title ______________________________________________________ Email (Required)

Payment of $40 per person Total $________ _______ VISA

_________ MC

_______ AM EXP

Credit Card No.________________________________________ Expiration Date:______________ Sec. Code:_______________ Card Billing Address:____________________________________ ________________________________________________________ Name on Card:_________________________________________ Signature:______________________________________________ Or, make checks payable to: HCA E&R and mail to 388 Broadway, 4th Floor, Albany, NY 12207

Lunch will be provided at each of the Forums. Please let us know if you have any dietary restrictions so that we can try to accommodate you. Cancellation Policy: Cancellations received one week prior to the forum will receive a full refund, less 25% of total due as an administrative fee. Cancellations received within one week of the forum will forfeit their registration fee, along with those who register and do not attend. Substitutions are permitted. Please contact Teresa Brown at (518) 426-8764 or tbrown@hcanys.org to cancel.

LEARN

ALBANY

Meet and hear From OMIG’s New Chief, Dennis Rosen! CONNECT

Epic Health Care Changes = Big Regulatory QUESTIONS negotiations

NEW AUDIT Challenges

Gain an understanding of the complicated structures

Right

The

Hilton Albany 40 Lodge Street 8:30am – 4:30pm

Question?

October 8

PROTOCOLS Right

The

TIME

Corporate Compliance Symposium

October 8 Hilton Albany 40 Lodge Street 8:30am â€“ 4:30pm

October EIGHT

Corporate Compliance Symposium

October 8 Hilton Albany 40 Lodge Street 8:30am â€“ 4:30pm

OMIG Priorities

Transition

Leadership CHANGE

Complex Systems

Regulatory Alignment

Corporate Compliance Symposium

October 8 Hilton Albany 40 Lodge Street 8:30am â€“ 4:30pm

Providers negotiations

partnerships

CYBER SECURITY INFORMATION

Legal

Hotel Information

$159 Sept. 7 Corporate Compliance Symposium REGISTRATION

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 

SPECIAL NEEDS In accordance with the Americans with Disabilities Act, or special dietary needs, please let us know how we can accommodate you: _______________________________________________________________

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