ASAP
A Weekly Publication Of HCA Home Care Association of New York State
Legislative Issues Public Policy
News
Volume 20, No. 44 December 18, 2015
HCA Appeals to Governor to Restore EPS Funding HCA Needs Your Response to Fiscal Survey So We are Armed with Impact Data HCA met with officials of the Governor’s office and state Department of Health (DOH) on Wednesday urging the restoration of Episodic Payment System (EPS) funding for home care to the agreed-upon, state budgeted levels. DOH this October reduced EPS funding by two-to-three times the cut level built into the 2015-16 budget. The budget had established a projected impact of EPS rebasing this year that agencies have been relying upon in their forecasting, at odds with the levels later implemented by DOH. See EPS p. 5
Have You Had a Chance to Complete HCA’s Financial Survey Yet?
FLSA Funding Update
HCA’s State Advocacy Day is February 2: details coming soon!
Late last Friday, after ASAP went to press, HCA met with state Department of Health (DOH) finance staff to obtain more information about the state’s plan to provide funding to managed care plans and home care providers to help them with new costs under the recently adopted changes to the federal Fair Labor Standards Act (FLSA). See FLSA p. 2
HCA wanted to check in again and make sure you saw the message and ASAP article last week about completing our 2015 Home Care Financial Condition online survey. See SURVEY p. 3
Inside ASAP HCA Appeals to Governor to Restore EPS Funding..........................1 Have You Completed HCA’s Financial Survey Yet?...............................1 FLSA Funding Update..........................................................................1 Important Dates to Take Note Of…....................................................2 Don’t Forget to Renew Your HCA Membership...................................4 Member Hiring Announcements…......................................................4 FLSA Changes Highlighted at January 6 Program...............................6 CMS Releases New Home Health Utilization, Payment Dataset.…..6 Forums for Upstate LHCSAs, Downstate HCC Members…...............7 Early Bird, Hotel Deadline Extended for HH Leadership Summit.......8 Deadline Extended to Jan. 4 for HCA’s Board Nominations................9 Value Based Payment Subcommittees Submit Recommendations....9 Governor Vetoes Fiscal Intermediary Licensure Bill..........................10 DOH Eyes Revisions, Testing of Emergency Preparedness Survey....10 HHCAHPS Preview Reports with Star Ratings Available..................11 Upcoming Recertification for DDE Users….......................................12 Q&As Posted on Nonprofit Capital Investment Program.................12 FIDA Update…...................................................................................13 DSRIP Update.....................................................................................13 OMIG Posts Compliance Webinars’ Q&As........................................13 NGS Closed on Christmas and New Year’s..................................…..14 Publications.................................................................................................14
This is the last issue of ASAP for 2015 as we head into the holiday and New Year season. We will send you e-mail alerts as needed over the next two weeks and will publish ASAP again on January 8. Our offices will be closed from December 25 through January 3, reopening on January 4. HCA wishes you a joyous end to the year.
Helping New Yorkers Feel Right At Home
Volume 20, No. 44 December 18, 2015
ASAP – a publication of the Home Care Association of New York State FLSA from p. 1 As covered in last week’s (and prior) newsletters, the state intends to increase the managed care plan rates by the state share of $.34 per hour to account for new overtime, travel and live-in requirements and also provide an increase to Medicaid fee-forservice rates. The state has not decided how the money will flow from the managed care plans to their contracted home care providers; for instance, if the funds will be passed through on all home care hours or if the plans will have leeway in distributing an aggregate amount. DOH intends to issue instructions on such a “pass-through” once it finalizes the method. At last Friday’s meeting, DOH confirmed that in January it hopes to adjust plans’ rates for the period October 1, 2015 through March 31, 2016 to account for the FLSA changes. For April onward, Mercer (the state’s contracted actuary for managed care rates) will use a data-collection survey to solicit home care providers’ actual costs and then make a prospective adjustment to the plans’ rates. DOH is also still considering HCA’s proposed set-aside/stop-loss pool mechanism to better finance overtime and other new labor costs. HCA continues to emphasize the impact of these new costs and advocate that the state provide money to plans and their home care providers as soon as possible. We will keep members informed of the state’s actions. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
Take Note: Important Dates Minimum Wage Increase from $8.75 to $9.00 per hour: December 31, 2015 (see: http://www.labor.ny.gov/ workerprotection/laborstandards/ workprot/minwage.shtm) Deficit Reduction Act (DRA) Certification form: Due December 31, 2015 (see: https://www.omig.ny.gov/ certification-header?type=dra) NYS Mandatory Provider Compliance Program Certification form: Due December 31, 2015 (see: https:// www.omig.ny.gov/certificationheader?type=ssl) 2014 CHHA/LTHHCP Statistical Report: Due January 11, 2016 2014 LHCSA Statistical Report: Due February 8, 2016 2014 Hospice Cost and Utilization Report: Due February 8, 2016
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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ASAP – a publication of the Home Care Association of New York State
SURVEY from p. 1 We realize that these surveys can take time to complete, but they are the best way for us to obtain and trend current data on your experience with the fiscal and regulatory environment of home care in New York State. If you completed the survey, thank you. If not, please do so as soon as you can. The survey has 30 questions. All answers will be used in the aggregate and no agency-specific identifying information will be shared. The survey due date is January 15, but we ask for your responses as soon as possible so that we can start reviewing the data and preparing our resource documents for our February 2 State Advocacy Day. A PDF of the survey is published at the back of this week’s ASAP, and you are welcome to e-mail or fax it back to HCA’s Communications Director Roger Noyes at rnoyes@hcanys.org or (518) 426-8788. You can also complete the survey online at https://www.surveymonkey.com/r/2015HomeCareFinCondSurvey. If you have any questions, do not hesitate to contact Roger Noyes at rnoyes@hcanys.org. We will be sending further information about our State Advocacy Day next week, once the program agenda is finalized, and once we’ve gotten firm commitments from state elected officials and other speakers who have been invited to address advocates. The program will begin the night before, on February 1, where we’ll hold a Political Action Committee (PAC) reception in Albany, followed by a meeting of our Board of Directors and legislative visits on February 2. Like last year, HCA is asking our Board of Directors to come to Albany for this program, as the association’s leadership core, to engage in legislative visits with key staff, but we welcome other non-Board HCA member leaders to join us for this important opportunity to meet face-to-face with key legislators and staff of the Governor’s office at the Capitol. Please stay tuned for an e-mail alert next week with registration and agenda details. Below is a brief timeline-at-a-glance.
HCA’s State Advocacy Day Timeline: What you Need to Know Now •
Before January 15: Complete HCA’s Financial Condition Survey
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Next Week: Look for an agenda and registration for our Advocacy Day program
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Late January: HCA will circulate Advocacy Day resource documents
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February 1: Join us for our PAC reception in Albany
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February 2: HCA members and HCA staff will participate in prescheduled visits with the Legislature and Governor’s office.
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ASAP – a publication of the Home Care Association of New York State
Title: Chief Financial Officer Organization: Westchester Visiting Nurse Services Group/VNSW/WCAH
It’s easy, just complete a simple form and you are ready to continue your membership in 2016
Westchester Visiting Nurse Services Group (VNSW/ WCAH) seeks a Chief Financial Officer for its group.
HCA reminds members to renew your membership in HCA before the year closes out. We’ve made the process simple for you, by asking you to complete an online form with simple contact information and any changes in your dues level.
The CFO will oversee all financial operations of the agency, including billing and payroll. The CFO would also coordinate the preparation of the budget and financial projections. Minimum qualifications include: At least 10 years of experience in health care finance, with at least 5 years in a financial leadership position. Knowledge of McKesson is a plus. Must have strong organizational and leadership skills. Send résumés to Kristine Giglio via email to kgiglio@vns.org.
By now, your agency’s key member contact should have received a link to our online forms for renewal. We’ve republished those links below. Simply find your organization type/category and complete the online form at one of the links below. Please pick only one link that relates to your organization type: Non-government-sponsored CHHA, LTHHCP, LHCSA members: https:// www.surveymonkey.com/r/ 2016HCAMembership
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County or government-sponsored home care agency members: https:// www.surveymonkey.com/r/ HCACounty
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Title: Director of Patient Services Organization: Winthrop University Hospital Home Health Agency Winthrop seeks a Director of Patient Services for the CHHA, which services Nassau, Suffolk and Queens. The DPS is responsible for the administrative, professional and clinical operations of the agency. Minimum qualifications include: BSN, NYS RN license, two years of professional nursing experience, two years of supervisory experience in a CHHA or related program, Master’s degree preferred. Send résumés to Anne Calvo via e-mail to acalvo@winthrop.org. Patient Relations Manager
HCC of HCA members: https:// www.surveymonkey.com/r/HCC-HCA
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Associate members: https:// www.surveymonkey.com/r/FQJY6H3
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Vendor members: https:// www.surveymonkey.com/r/F2BLJN7
HIRING
Don’t Forget to Renew Your HCA Membership in 2016
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Volume 20, No. 44 December 18, 2015
Americare, New York’s leader in home health care, seeks a high energy, dynamic, self-starter for an exciting career opportunity in its patient relations department. The Patient Relations Manager’s primary responsibility will be to develop relationships and educate MDs about home care and the benefits to their patients. The ideal candidate will have 2-3 years home care or pharmaceutical experience. An excellent compensation and benefits package is offered, including: 401K with company match, medical, dental and direct deposit.
Note: These links are for member renewals only. If you are not yet an HCA member or need more information, contact our Director of Membership Laura Constable at lconstable@hcanys.org or (518) 810-0660.
E-mail résumé to hrrecruiter@americareny.com. www.americareny.com. EOE
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Volume 20, No. 44 December 18, 2015
EPS from p. 1 HCA requested this week’s meeting to ask the state to restore the remaining funds (the difference between the DOH level and the levels assumed in the state budget) on the heels of Governor Cuomo’s recent veto of legislation that would have ensured funding at the budget level by limiting any cut from rebasing to exceed the adopted budget amount. In a letter to the Governor, legislative sponsors Senator Kemp Hannon and Assemblyman Richard Gottfried requested the Governor to restore the home care EPS funding level to the budget agreement regardless of whether he signed or vetoed their codifying bill – aligning EPS rebasing with the budget process and the agreement with the Legislature.
As you renew your HCA membership for 2016, check out a recent video message from HCA President Joanne Cunningham about all that HCA has in store for the coming year. Just click the box above or view the video directly on Youtube at https://youtu.be/eZT4Apr9kTw
However, in Wednesday’s meeting, DOH officials argued in favor of their full cut level on the basis that, since EPS’s inception in 2012, the migration of home care patients into managed care has decreased the actual expenditure levels under EPS to the amounts reflected in the new base, thus “justifying” their action. HCA, joined by the leaders of several HCA providers, contested the Department’s action, explaining the wide gaps between the costs and methods reflected in the DOH-derived base year for EPS and actual costs borne by home care providers. HCA specifically listed for the Executive many of the currently unrecognized, unreimbursed cost-inputs that are critical to home care’s functioning, access, stability and, ultimately, its ability to fulfill its sought-after role in the changing health care system. HCA and providers further profiled the already-serious financial condition of home care agencies across the state, and gave specific examples of the DOH EPS cut’s impact on agency operations and services. We also underscored the conflict between these cuts and the state’s reliance on home care for the success of its new policies, reforms and models of care. At the meeting’s conclusion, the Executive continued to stand firm on its EPS cut level, irrespective of the budget agreement or the argued impact on home care. However, State Medicaid Director Jason Helgerson expressed willingness to consider, and to work with HCA toward, potential future revisions in the methodology that would better reflect home care agency costs and needs in the evolving system. We appreciate that overture and opportunity for progress resulting from this meeting. In next steps, HCA will follow-up to present the Executive with proposals for improving the state’s reimbursement levels and methods for home care, as well as continue to reach out to the state Legislature for further support and proposals for remedy. Continued on next page
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ASAP – a publication of the Home Care Association of New York State Continued from previous page Important: your HCA Financial Condition Survey responses will help this effort In last week’s ASAP and in two alerts to the membership, HCA circulated our 2015 Home Care Financial Condition survey which asks several questions about CHHA EPS rebasing and other fiscal impacts for CHHAs and other home care agencies over the past year. Your answers to this survey are vital to our advocacy on your behalf. The survey is available for completion online, but we have published an entire PDF version of the survey at the back of this week’s ASAP, and you are welcome to complete it by hand on a printed PDF – and fax it back to HCA – or complete the online version of the survey at https://www.surveymonkey.com/ r/2015HomeCareFinCondSurvey. We greatly appreciate your attention to this effort during a time when your organization is focused on so many other major priorities. Please contact any of the HCA Policy staff or HCA Communications Director Roger Noyes (rnoyes@hcanys.org) if you have any questions or concerns related to your completion of the survey. For further information, please contact Al Cardillo acardillo@hcanys.org or Patrick Conole pconole@hcanys.org.
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FLSA Changes Highlighted at January 6 Program: Register Today HCA will hold another program on the recent Fair Labor Standards Act (FLSA) companionship exemption changes that is similar to a well-attended program we had on December 15. The January 6 program will review the FLSA changes concerning overtime, travel and live-in cases; other home care labor issues; and ways for agencies to protect themselves from lawsuits over these and other practices. The program will be led by the Littler Mendelson law firm, attorneys that have years of experience in representing home care agencies in lawsuits, including one of the plaintiffs in the legal challenge to the FLSA rule. Members who attended the December 15 program found the information on compliance very valuable and left with a lot of good tools to help them in this very complicated area. We urge you to register for the January 6 event before it gets filled. Registration is at http://hca-nys.org/wp-content/ uploads/2015/11/January-6-Survival-BootcampCompanionship-Registration-Form-2.pdf.
CMS Releases New Home Health Utilization and Payment Dataset The U.S. Centers for Medicare and Medicaid Services (CMS) this week released a new dataset: the Home Health Agency Utilization and Payment Public Use File (Home Health Agency PUF). This data set, which is part of CMS’s Medicare Provider Utilization and Payment dataset, details information on services provided to Medicare beneficiaries by home health agencies (HHAs). These new data include information on 11,062 HHAs, over 6 million claims, and over $18 billion in Medicare payments for 2013. The data is posted on the CMS website at: https://www.cms.gov/Research-Statistics-Data-and-Systems/ Statistics-Trends-and-Reports/Medicare-Provider-Charge-Data/HHA.html. The data set identifies individual HHAs using their 6-digit identification number. Services furnished by these HHAs are grouped according to case-mix groupings, or home health resource groups (HHRGs). For each 6
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HHA and HHRG, the data set has the total number of episodes that were provided, distinct number of beneficiaries served, the HHA’s total and average charges, the total and average Medicare payments, and the total and average Medicare standardized payments. The HHA provider dataset also has additional information on low-utilization payment amount (LUPA) episodes and outlier payments. The data set does not contain any individually identifiable information about Medicare beneficiaries. To further protect the privacy of Medicare beneficiaries, any aggregated records which are derived from 10 or fewer claims are excluded from the Home Health Agency PUF. The data also allows for many types of analyses to be performed, including, for example, summary analyses by HHRG and state. For further information, contact HCA’s Patrick Conole at (518) 810-0661 or at pconole@hcanys.org.
Forums Scheduled for Upstate LHCSAs & Downstate HCC Members In January, HCA is holding two members-only Forums: the first for our upstate LHCSA members on January 14, and the second for our Home Care Council (HCC) of HCA Members on January 28. Both sessions will address discrete issue areas of concern to both segments of our membership, including some overlapping issue areas such as the companionship exemption changes for overtime and the state's proposed funding mechanism; the proposed $15/hour minimum wage and HCA advocacy in this area; regulatory issues; and more. The Upstate LHCSA forum will include a discussion of regional LHCSA-specific concerns and opportunities/challenges under the Delivery System Reform Incentive Payment (DSRIP) program and value-based payment. The HCC Forum will also delve into regional issues related to the companionship exemption changes and the Human Resources Administration. Details for both meetings are below; registration/agenda information is at http://hca-nys.org/events-education/upcoming-events. Upstate LHCSA Forum January 14, 2016 10 a.m. to 12:30 p.m. Location: VNA Homecare, 1050 West Genesee Street, Syracuse, NY 13204 All HCA-member upstate LHCSAs are invited. Home Care Council of HCA Member Forum January 28, 2016 10 a.m. to 12:30 p.m. Hunter College Brookdale Campus 425 East 25th Street (Between 1st Ave. and FDR Drive) The Osborn Room (Mezzanine Level) New York, New York 10010 All HCC of HCA Members are invited. 7
Home care vendors, consultants, providers and business associates: Have you seen HCA’s new 2016 Marketing Prospectus? It offers a range of sponsorship and exhibiting opportunities for 2016. Check out a short, 2-minute video about the prospectus at https:// youtu.be/thQbgk9VU-M, or download the prospectus directly from our website at http://hca-nys.org/events-education/ sponsors-exhibitors.
ASAP – a publication of the Home Care Association of New York State
Volume 20, No. 44 December 18, 2015
Due to Overwhelming Response Rate, Early Bird and Hotel Deadline Extended for Northeast Home Health Leadership Summit Early-bird rate extended to December 23, and hotel rate extended through January 4! With so many people joining the home health leadership “go team” at the Northeast Home Health Leadership Summit, participating associations have extended the early-bird deadline to December 23 (close of business) and the hotel deadline has extended to January 4 or until the room block sells out. Now you have more time to register for the discounted rate at this premier conference of home health executives in the northeast. If you haven’t checked out our fun, 2-minute video about the conference, we encourage you to do so as you get primed for this first major conference of 2016. Click the image above or go directly to youtube at: https://youtu.be/SmMe4o3UF8Y. To register, please visit the summit website at http://nehomehealthsummit.com/ where you can find online registration, a brochure and a list of our sponsors. 8
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Deadline Extended to Jan. 4 for HCA’s Board of Directors Nominations The HCA Nominating and Governance Committee is seeking applications for members on HCA’s main governing unit, our Board of Directors, which is an exceptional opportunity for a visionary home care leader to influence the strategic direction of our organization and serve with distinction on behalf of New York’s entire home care industry. Applicants should have demonstrated leadership potential, a strong interest in public policy and advocacy, and commitment to promoting and implementing a vision and strategic policy direction for the home care industry and the Association. The deadline has been extended until January 4, so get your nominations in as soon as possible by downloading the form at http://hca-nys.org/wp-content/uploads/2015/12/2016-HCA-Board-Nomination-Application-3.pdf.
Value Based Payment Subcommittees Submit Recommendations Core Committee Begins Review Over the past several weeks, various subcommittees meeting under the value-based payment (VBP) initiative have concluded their round of work and submitted recommendations to the state Department of Health on their topical areas. Yesterday, DOH convened its overall core VBP steering committee, of which HCA is a member, to review the subcommittees’ recommendations and provide initial comment. The Department has invited core committee members to provide written comments by December 24, and DOH intends to then further review with the subcommittees and core committee before proceeding with a final proposal package. HCA invites our home health, hospice, and managed care plan members to review the latest material and provide your comments, perspectives and recommendations to us to consider for our written comments next week. The DOH slides and a consolidated summary embodying the recommendations can be viewed here: http://hca-nys.org/wp-content/uploads/2015/12/ConsolidatedVBPSubcommitteesrecommendations121620151.pdf http://hca-nys.org/wp-content/uploads/2015/12/VBPWorkgroupPresentationSCsrecommendation_1217151.pdf The core committee will meet again in early January to consider the balance of recommendations not discussed at yesterday’s meeting. DOH also plans to convene the committee at various intervals throughout the spring to consider further issues, design elements and implementation matters, as well as to establish a further set of subcommittees to delve more deeply into areas that the current subcommittees examined but felt needed additional analysis and discussion. Meanwhile, at HCA’s suggestion, DOH will prepare a matrix showing all of the various recommendations and changes proposed for VBP and the particular route by which each change or planned step would be implemented (i.e., legislatively, by regulation, contract change, administrative procedure, or budget). HCA will also continue our efforts in providing state-level advocacy for home care in value based payment, technical assistance to providers, and additional information and education to assist providers as this process moves forward. HCA continues to strongly encourage providers to be as familiar as possible with the VBP construct, especially the areas targeted by the state and the subcommittees, so that you can identify and advance your capabilities and value-proposition to potential partners (including managed care plans, hospitals, physicians, behavioral health providers and others). For further information, please contact Al Cardillo at acardillo@hcanys.org. 9
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Governor Vetoes Fiscal Intermediary Licensure Bill Governor Cuomo has vetoed legislation that would have required a new licensure process for entities providing fiscal intermediary (FIs) services to patients receiving consumer directed personal assistance services (CDPAS). HCA had raised a number of issues with the legislation (S.5565B/Hannon; A.7535B/Gottfried), including, among other concerns: •
The fact that there is no need for licensure, as home care agencies and other FI entities are already licensed by the state and face strict oversight and do not need to undergo a duplicative process;
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FIs already have to follow state regulations and state Department of Health (DOH) guidance documents that were recently updated;
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The lack of DOH resources to administer a new licensing process and anticipated delays in approval for new FIs and the adverse impact on consumers.
The Governor’s veto message supported some of our concerns by recognizing that FIs already need to obtain a Medicaid number which subjects them to additional oversight by the federal government, DOH and the state Office of the Medicaid Inspector General, and that DOH has clarified the conditions under which MLTC plans may sign an administrative agreement with an FI to administer CDPAS services. In his veto message Governor Cuomo also indicated that: The next step toward ensuring that all fiscal intermediaries are held to the same compliance standard is to develop a statewide regulatory and licensure program. However, the statewide licensure program proposed by this bill poses significant fiscal challenges which must be carefully evaluated and negotiated as part of the budgeting process. For these reasons, I am constrained to veto this bill. In the interim, however, I am directing the Department to work collaboratively with the Department of Financial Services, the bill’s sponsors, and interested stakeholders to develop a fiscally-sound framework for regulating fiscal intermediaries that best serves the needs of persons utilizing [CDPAS].
HCA will reach out to DOH so that we are included in future discussions about further regulating the FIs. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
DOH Planning Revisions, Testing of Emergency Preparedness Surveys HCA participated in a meeting yesterday with state Department of Health (DOH) officials to review DOHrevised survey instruments for home care agencies and hospices for completion and tracking during public emergencies. Specific parts of a multipart survey process are designed by DOH to be put into motion in emergencies depending on the nature, extent and details of the emergency. The sections of the survey include basic agency and patient information, agency surge capacity resources and/or assistance needs, evacuation and repatriation information, and others. Continued on next page 10
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Continued from previous page The Department also reviewed a survey intended for completion by hospice providers to determine the status and extent of hospice emergency preparedness planning. The Department plans to issue in the next several months a Dear Administrator letter reminding, clarifying and stipulating for providers the required contact persons and roles for indication on the Health Commerce System (HCS). HCA reminds providers to check their agency’s contacts currently listed/required for the HCS to be sure that all such individuals and related information are accurate and up to date. HCA has posted a version of this story on our website with six links to the draft surveys. Please see this story on our “General News” feed at http://hca-nys.org/category/general-news and provide HCA with any further comments on the surveys, which we, in turn, will add to our feedback to the Department. DOH plans an HCS emergency preparedness drill this spring using the revised survey tools. HCA requested and DOH agreed to conduct a webinar, likely to be held in February, providing a walk-through of the surveys and an opportunity for exchange with the home care sector. For further information, please contact Al Cardillo at acardillo@hcanys.org.
HHCAHPS Preview Reports with Star Ratings Available Preview Reports reflecting results from the Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey from July 2014 through June 2015 (third-quarter 2014 to second-quarter 2015) are now available on https://homehealthcahps.org under the “For HHAs” tab. Home health agencies (HHAs) must be logged into the website to view their reports. These same data will be updated on Home Health Compare (at www.medicare.gov) in late January 2016. The Preview Reports present the publicly reported results with Star Ratings for those agencies with a sufficient number of completed interviews to receive Star Ratings. Agencies must have data for 40 or more patient surveys in the reporting period in order to have Star Ratings. To access an agency’s HHCAHPS Preview Report, log into the HHCAHPS website using your username and password. Select the “Preview Reports” link under the “For HHAs” tab. If you have forgotten your password, click the login link, type in your username, click “Forgot Password,” and follow the directions to have your password sent to you via e-mail. If you have comments about your HHCAHPS Star Ratings on the Preview Report, please e-mail the following information to hhcahps@rti.org by December 31, 2015: •
Your name, your facility name, your CCN, and your contact information.
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Your comments about your preview report.
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If you believe your Star Ratings are not correct, submit evidence showing why. If you have historically had higher ratings than are shown, this is not considered evidence for incorrect ratings; you must 11
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provide information showing that the data submitted by your vendor for the most recent quarter are incorrect and therefore may have impacted ratings. For information about the HHCAHPS Preview Reports, refer to the March 23, 2012 announcement at https:/ /homehealthcahps.org/GeneralInformation/Announcements/tabid/269/EntryId/142/HHCAHPSPreview-Reports.aspx. If you have any questions about HHCAHPS Star Ratings on your HHCAHPS Preview Report, contact hhcahps@rti.org or (866) 354-0985. More information on Star Ratings is at https://www.cms.gov/Medicare/Quality-Initiatives-PatientAssessment-Instruments/HomeHealthQualityInits/HHQIHomeHealthStarRatings.html.
Upcoming Recertification for DDE Users Process impacts All NGS Jurisdiction 6 DDE Users All users who access the Direct Data Entry (DDE) systems are required by the U.S. Centers for Medicare and Medicaid Services (CMS) to recertify their access annually. NGS will begin the annual recertification for logon IDs in the coming weeks, with a few process changes from last year. NGS will divide the logon IDs by Jurisdiction 6 ( J6) contract. Each NGS workload (New York is in the Wisconsin workload) will be required to recertify during a preselected month. The recertification process for New York (under the Wisconsin workload) will begin January 2016. Any user who currently has access to the Part A Wisconsin Fiscal Intermediary Shared System (FISS) DDE will be issued an access code by e-mail. The e-mail containing the access code will be sent to the current authorized e-mail address on file with NGS’s Electronic Data Interchange (EDI). All Logon IDs will be required to have completed the recertification process within two weeks of receiving the access code. Any new or reinstated logon ID on or after December 1, 2015 will not be required to recertify until the following year’s recertification. NGS EDI will provide more information in the coming weeks. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Q&As Posted on Nonprofit Infrastructure Capital Investment Program Submission Deadline Extended As reported in last week’s ASAP, the state has posted Questions and Answers (Q&As) on the Nonprofit Infrastructure Capital Investment Program (NCIP), a potential source of funding for HCA’s nonprofit members. The Q&As are at http://www.dasny.org/Libraries/RFP_-_461/Questions_Answers_12-11-15.pdf. The 61-page document covers many issues including: eligibility of home care agencies, hospices, and MLTC plans; multiple applications by one entity; eligibility of entities that receive Delivery System Reform Incentive Payment (DSRIP) program funds; use of funding for technology upgrades, electronic health records, mobile phones, tablets, and consultants; eligibility of consortiums; use of funds for staff training and development; and others. Continued on next page 12
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Volume 20, No. 44 December 18, 2015
Continued from previous page HCA advises members who plan to seek funding to review the Q&As. The due date for applications has been extended from December 23 to January 29, 2016. More information is at http://www.dasny.org/RFP-BidOpportunities-Solicitations/Details.aspx?id=a24a6852-ee2f45ab-be48-eaa6e10796d7. Please also see last week’s ASAP for additional information.
FIDA Update The state Department of Health will provide an update on the recent changes to the Fully Integrated Duals Advantage (FIDA) program on Tuesday, December 22, 2015, from 1 to 2 p.m. You can register for the webinar at: https://attendee.gotowebinar.com/register/4668963248353531393. The changes were described in last week’s ASAP and are available at https://www.health.ny.gov/health_care/ medicaid/redesign/mrt_101.htm (the same site where the webinar’s materials will be posted).
DSRIP Update On Thursday, January 21 and Friday, January 22, the Delivery System Reform Incentive Payment (DSRIP) Project Approval and Oversight Panel (PAOP) will meet the downstate-based DSRIP Performing Provider Systems (PPSs). The meeting will be held in the Eisner & Lubin Auditorium located within the NYU Kimmel Center for University Life (60 Washington Square South) in New York City. The meeting is open to the public, but there will be no public comment period at these meetings. No pre-registration is required. Please contact Brooke Weinstein at Brooke.Weinstein@health.ny.gov by January 11 for further information. Thursday, January 21 will be a full-day meeting from 10:30 a.m. to 4:30 p.m., structured as an update session for the panel members, and an opportunity for the panel members to check in with each of the PPSs. Friday will start at 9 a.m. and end at 2 p.m. The meetings will be webcast and can be viewed live at: http://www.health.ny.gov/events/webcasts/.
OMIG Posts Compliance Webinars’ Q&As The state Office of the Medicaid Inspector General (OMIG) has posted on its website “Follow-up Questions and Answers” related to the Compliance Elements Webinar Series (Webinars no. 26 through 34). Launched in November 2015, the nine-part webinar series on New York’s mandatory compliance program includes the Introductory Webinar (Webinar no. 26), which outlines the eight elements required of mandatory compliance
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ASAP – a publication of the Home Care Association of New York State
Volume 20, No. 44 December 18, 2015
programs, identifies who is required to have a compliance program, and details the areas of a Medicaid provider’s operations to which compliance programs must apply. The series continues with eight individual webinars (webinars no. 27 through 34), each dedicated to one of the eight elements required of Medicaid providers’ mandatory compliance programs. The webinars: identify a specific compliance element’s statutory and regulatory requirements; outline what OMIG’s Bureau of Compliance looks for when it assesses a Medicaid provider’s compliance program; and detail compliance-related tools and resources available on OMIG’s website to assist provider compliance. The Compliance Elements Webinar Series as well as the “Follow-up Questions and Answers” are at https:// www.omig.ny.gov/resources/webinars. The “Questions and Answers” address: whether companies that submit providers’ Medicaid billing files are required to have a compliance plan; the amount and types of evidence necessary to demonstrate an agency’s compliance activities; whether the OMIG’s compliance program assessment form must be submitted; which staff (and consultants) are covered by an agency’s compliance plan; and which criteria should be used to select a compliance officer.
NGS Closed on Christmas and New Year’s National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC) will be closed December 25 and January 1 for the Christmas and New Year’s Holidays. This includes the Electronic Data Interchange (EDI) Help Desk, Provider Contact Center, Provider Enrollment Line, and Telephone Reopening Unit. Electronic claim files transmitted after 5 p.m. on Thursday, December 24 and Thursday, December 31 will have a claim receipt date of Monday, December 28, 2015 or Monday, January 4, 2016, respectively. EDI front-end acknowledgement transactions will be created as expected as EDI claim files are received. The Direct Data Entry (DDE) Provider Online System will be available on December 25 and January 1 during regular hours. Providers will be able to access NGSConnex and use the Interactive Voice Response (IVR) system at 1-866-2753033 during the closure days. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Publications •
“Access and Oversight Concerns for Home Health Services, Washington DC VA Medical Center,” by the Department of Veterans Affairs Office of Inspector General http://www.va.gov/oig/pubs/VAOIG-14-03823-19.pdf
•
“MLTC Roll-Out – Overtime pay starts for aides, Two plans withdraw from MLTC coverage,” by the New York Legal Assistance Group http://www.wnylc.com/health/news/41/
For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
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2015 State Home Care Financial Condition Survey SECTION 1: Demographic Information 1. List your contact information Your Organization Your Name Your Title Your Email Your Phone Number
2. Please check only one answer for your home care provider type, and please be sure to complete a separate survey for each type if you have multiple types of agencies. CHHA LHCSA LTHHCP
3. My agency is ____ (Please only check one answer) Voluntary Proprietary Public
2015 State Home Care Financial Condition Survey SECTION 2: Financial Data Questions 4 and 5 should be completed by CHHAs and LTHHCPs. Question 6 should be completed by LHCSAs. Your answers can be taken directly from your 2014 Medicaid Cost Reports or your 2013 Statistical Reports. Your Finance Director/Chief Financial Officer can assist you. To help, we have created a reference chart, available HERE. This document references the exact schedules on your cost reports and statistical reports for the information sought in questions 5 and 6. Again, all agencyspecific information provided to us will be kept confidential and will only be used in the aggregate. REMEMBER ... For numerical entries, do not use dollar signs ($), commas (,), decimal points (.), percent signs (%) or other characters, just the raw number. Please round up or down if your answer involves a decimal point. 4. If your agency filed a 2014 cost report, are you completing the cost report section of this survey for your LTHHCP or your CHHA? If you are a LHCSA, please skip to question 6. CHHA (my 2014 cost report) LTHHCP (my 2014 cost report)
5. Provide the following data from your 2014 Cost Report (for CHHAs or LTHHCPs). If you are a LHCSA, please skip to question 6. No. of Full Time Employees (FTEs) Medicare Feeforservice Revenues Medicaid Feeforservice Revenues All Other Payor Revenues, including Managed Care Total Patient Service Revenue All Other NonPayor Revenues Total Revenue Total Operating Expenses
2015 State Home Care Financial Condition Survey 6. For LHCSAs, please complete the following data from your 2013 LHCSA Statistical Report. If you are not a LHCSA, skip to the next question. Total Cases Unduplicated Patient Count Number of Full Time Staffing (as of Oct. 1) Total Contract Revenue Total Direct Revenue Total Costs
2015 State Home Care Financial Condition Survey SECTION 3: Payment and Program Information This section asks for your responses about the impact of billing, regulatory and payment issues. 7. Please estimate what % of your Medicaid managed care claims are paid within the "prompt" pay law timeframe for "clean" claims needing no edits (30 days for electronic claims, 45 for paper). Please just enter a raw number: no percentage sign. ___%
8. What is the average number of days that your revenues (from all payors) remain in Accounts Receivable? Please provide your best estimate. Days
9. What percent of your revenue in Accounts Receivable results in “bad debt” or not getting paid? 0 – 10% 11 – 20% 21 – 30% Over 30%
2015 State Home Care Financial Condition Survey 10. Assuming that your costs have increased in the last year, please rate the impact of each cost factor below on your increased costs. For any that have the "largest impact," please tell us more about about the specific cost impact in the text box below. No Impact Wage and Overtime Costs Benefits Costs Fuel Costs Unfunded Mandates (e.g. Flu vaccination requirements, TPL) Capital Costs Technology investment Other Administrative Costs Billing/Administrative Expenses Associated with Managed Care Basic or advanced staff training Emergency Preparedness and response Staff time and partnership development work on MLTC/DSRIP activities Tell us more about your largest cost impacts
Minimal
Medium
Impact
Impact
Large Impact Largest Impact
2015 State Home Care Financial Condition Survey 11. If your estimated Medicaid revenues have decreased between 2014 and 2015, please rate the impact of the following factors for this change in your Medicaid revenues. No Impact Caseload change due to managed care transition Effect of payment cuts/reimbursement changes (e.g., CHHA EPS rebasing, GRT) Inadequate managed care rates Delay in managed care payments Drop in Medicaid volume due to fewer referrals Staffing cuts
Minimal Impact
Medium Impact
Large Impact
Largest Impact
2015 State Home Care Financial Condition Survey No Impact
Minimal Impact
Medium Impact
Large Impact
Largest Impact
Other (please specify)
12. On October 1, the state implemented CHHA episodic payment system rebasing cuts. Please provide the average % reduction in your Medicaid revenue due to this initiative? (Remember: be sure to only enter the raw number: no percentage sign.) Avg. Percentage reduction (%)
2015 State Home Care Financial Condition Survey 13. If you have Medicaid managed care contracts (MCO and MLTC), please estimate the aggregate % differences between your Medicaid feeforservice (FFS) rates and your negotiated managed care rates for the following service disciplines. (You may leave any of the boxes blank if the statement doesn't apply.) Our aggregate managed care nursing service rate is LESS than FFS by (__%) Our aggregate managed care nursing service rate is MORE than FFS by (+__%) Our aggregate managed care home health aide/personal care service rate is LESS than FFS by (__%) Our aggregate managed care home health aide/personal care service rate is MORE than FFS by (+__%)
14. How have your overall contracted Medicaid managed care (MCO and MLTC) rates changed between 2014 and 2015? Enter zero if your rates have not changed. (Also, be sure to only enter the raw number: no percentage sign.) Increased by ____% Decreased by ____%
15. At any time over the past two years (2014 and 2015), have you had to use a line of credit or borrow money (including gappayment financing from parent organization) to pay for operating expenses? Yes No
16. Please rank from 15 the (actual or potential) impact of the following state regulatory requirements/initiatives (1=highest impact and 5=lowest impact).
Elimination of the "companionship exemption" for home care
Executive compensation/administrative limits
Medicaid ordering, prescribing, referring and attending (OPRA) edit
DSRIP
State Wage Parity requirements in New York City, Long Island, Westchester
2015 State Home Care Financial Condition Survey 17. Which of the following actions does your agency plan to take in response to fiscal pressures, a changing health care environment and new models like DSRIP? (Please check all that apply.) Merge with another agency Collaborate as part of a Health Home, IPA, ACO, DSRIP/PPS or other health system Technology upgrades (EHR, etc.) Workforce retraining Reduce staff and other expenses to become more efficient Use LTHHCP in contracting capacity Phaseout LTHHCP Purchase a CHHA Increase use of CHHA Decrease use of CHHA Apply to open a LHCSA Increase use of LHCSA Decrease use of LHCSA Discontinue telehealth program Close our organization Other (please specify)
2015 State Home Care Financial Condition Survey 18. In your contracts with MLTCs/MCOs, how would you rate the overall impact of the following issues or experiences? (Please check all that apply.) No Impact Inadequate rates Lack of timely authorizations/reauthorizations Lack of timely payment (or increase in accounts receivable) Inconsistent billing codes A lack of state policy clarity about the regulatory requirements (e.g. responsibilities for physician orders, plans of care, supervision) I do not have a CHHA and the MLTC/MCO only wants to contract with a CHHA I do not have a LHCSA and the MLTC/MCO only wants to contract with a LHCSA The MLTCs/MCOs feel they already have a sufficient number of contracts The MLTCs/MCOs plan to cancel our contract
Minimal Impact
Medium Impact
Large Impact
Largest Impact
2015 State Home Care Financial Condition Survey No Impact
Minimal Impact
Medium Impact
Large Impact
Largest Impact
Other (please specify)
19. What % of your Medicaid receipts are FeeForService versus Medicaid Managed Care (MLTC/MCOs)? Feeforservice % is ____ Managed Care % is ____
20. What % of your Medicare receipts are FeeForService versus Medicare Managed Care? Feeforservice % is ____ Managed Care % is ____
21. If you are contracting with an MLTC or MCO, please provide the percentage of your Medicaid revenue derived from each of the following service/contract arrangements. (Simply enter a zero for any services that you do not provide.) Care management services to plan enrollees account for ___% of our Medicaid revenue from plans. Professional services (nursing, therapy) to plan enrollees account for ___% of our Medicaid revenue from plans. Aide services to plan enrollees account for ____% of our Medicaid revenue from plans. Assessment services account for ____% of our Medicaid revenue from plans. Other services account for ____% of our Medicaid revenue from plans.
22. Does your agency contract with MLTCs/MCOs for telehealth services? Yes No
2015 State Home Care Financial Condition Survey 23. If you answered "yes" to the previous question, is your payment for telehealth services adequate under managed care? (Please explain.)
24. If you are involved in a DSRIP Performing Provider System (PPS), what payment arrangement are you involved in or expect directly from the PPS? Feeforservice Capitated payments Bundled payments/ValueBased Payments Specific project area funding Unsure Other (please specify)
25. Has your agency yet received payment directly from a DSRIP PPS? Yes No
2015 State Home Care Financial Condition Survey 26. If you answered "yes" to the previous question, how much payment has your agency received from the PPS and for what purpose(s)? (Please explain in the box below.)
27. If you are involved in a DSRIP PPS, please rate the following experiences. Strongly Disagree
Disagree
Don't Know
Agree
Strongly Agree
N/A
Payment will adequately cover costs and makes participation in DSRIP worthwhile My organization expects increased referral activity from the PPS PPS committees understand the role of home care in meeting DSRIP goals DSRIP participation offers opportunity for growth in home care industry I don't know how my agency will participate in DSRIP
28. By what percentage do you expect your costs will increase due to recent changes (implemented on Oct. 13, 2015) in the federal "companionship exemption" requirements? (Remember, enter only the raw number and no percentage sign.) Percentage Increase (%)
2015 State Home Care Financial Condition Survey 29. Has your agency calculated the potential impact of the proposed minimum wage increase to $15 per hour? If yes, what were your findings and how did you arrive at this calculation?
30. Please rank from 110 which of the following are needed to support you in this current fiscal, regulatory and program environment for home care (1=highest importance and 10=lowest importance).
Policies that ensure adequate reimbursement
Uniform billing codes for managed care payments
Greater state clarity on the role and regulatory responsibilities for agencies
Regulatory relief
Capital and technology funding support
Staff recruitment or retraining funds
Agency/market data and cost analysis
Marketing materials and documentation showing the home care value proposition
Technical assistance through education programming on new models
Assistance in receiving timely authorization/payments
2015 State Home Care Financial Condition Survey THANK YOU Thank you for completing this important survey. If you have any additional comments, please note them in the text box below. 31. Comments