AUDIT
BILLS
SEPSIS
DEIP $
The Comptroller’s office has forwarded its audit of CHHA EPS to OMIG for $16.6 million in state payment errors.
The Legislature has introduced two HCA bills on technology and care for veterans.
HCA completes fourth in a series of webinars on the home care sepsis tool, with program rollout coming soon.
HCA seeks clarification on eligibility for DEIP program offering funds for HIT integration.
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COMING UP Home Care Council of HCA Member Forum March 6, 2017 10 a.m. to 12:30 p.m. Hunter College Brookdale Campus 425 East 25th Street, NYC The Osborn Room (Mezzanine Level) Registration for this program and other events is at http://hcanys.org/eventseducation/upcomingevents.
HCA’s offices will be closed next Monday (February 20) for President’s Day but we will publish The Situation Report as regularly scheduled for Monday circulation.
Your Source for HOME CARE News, Policy and Advocacy
Vol. 2, Issue 7 | February 13, 2017
From Advocacy Day Last Week to Budget Hearings This Week, HCA Presses Forward on Critical Priorities HCA’s Board of Directors and Member Leaders gathered in Albany early last week for our 2017 State Advocacy Day, featuring a series of meetings where HCA and members communicated our state budget priorities to lawmakers. See BUDGET p. 3
Senate Majority Leader John Flanagan (second from left) addresses the HCA Board and Member Leaders during HCA’s State Advocacy Day on February 7.
Register Now For March 15 Senior Financial Managers Forum With state budget negotiations in full swing, and intense federal activity on health policy, HCA invites member CEOs, CFOs, finance managers and other senior staff to our popular Senior Financial Managers Forum in Albany on March 15.
INSIDE From Advocacy Day to Budget Hearings..........................................................1 Register Now For 3/15 Senior Financial Managers Forum..................................1 Is Your Clinical Team Proficient in the Newly Implemented OASIS-C2?.................3 Important Links..............................................................................................4 Tom Price Confirmed as HHS Secretary.............................................................6 Comptroller’s CHHA EPS Audit Referred to OMIG...............................................7 Wage Parity Certification Forms Due March 1...................................................8 New Court Action on Jimmo Case.....................................................................9 DOH Posts 2017 CHHA Pediatric Medicaid Rates............................................10 Assembly Introduces HCA Home Care Technology Act.....................................11
See FORUM p. 2
HCA Veterans Home & Community Based Pilot Bill Introduced...........................12 HCA Sepsis Initiative Prepares for Rollout........................................................13 New Developments in State Value Based Payment...........................................14 Webinar Highlights Opportunity for Home Care in New Models.......................15 NYS Health Foundation Funding Available........................................................16 Clarification Regarding Criteria for Data Exchange Incentive Program...............17 Updates from CMS’s Home Health and Hospice Open Door Forum.....................18 DOH Posts LHCSA Guidance Documents...........................................................19 Guidance Issued on Late Appeals Process........................................................20 NGS Updates..................................................................................................20 Important Deadlines....................................................................................21 Resources...........................................................................................................22
The Situation Report: the Home Care Association of New York State FORUM from p. 1 This rigorous, informationloaded Forum, for HCA members only, brings together HCA Policy staff, Department of Health officials, finance consultants, and federal analysts to inform your budgeting, projections and understanding of all significant Medicaid and Medicare payment, reimbursement and finance factors affecting your bottom line as a home care provider or MLTC plan. See our brochure at the link below for the lineup of must-hear speakers and sessions, including a new segment on the implications of OASIS C2, which will give home care finance officers some important considerations in their oversight of cost factors related to clinician activities. Please return your registration soon, to assure a seat at this important annual event offering focused information for you and your finance teams. Download the brochure at http://hca-nys.org/wp-content/uploads/ 2017/02/Senior-Financial-Managers-Forum-Registration-FormMarch.pdf.
Home Care Association of New York State (HCA) 388 Broadway, 4th Floor, Albany, NY 12207 Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org
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The Situation Report is a weekly publication of the Home Care Association of New York State (HCA). Unless otherwise noted, all articles appearing in The Situation Report are the property of the Home Care Association of New York State. Reuse of any content within this newsletter requires permission from HCA. Joanne Cunningham HCA President jcunningham@hcanys.org Roger L. Noyes Director of Communications, Editor of The Situation Report rnoyes@hcanys.org Al Cardillo Executive V ice President acardillo@hcanys.org Patrick Conole Vice President, Finance & Management pconole@hcanys.org Andrew Koski Vice President, Program, Policy & Services akoski@hcanys.org Alexandra Fitz 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 & Special Projects jkerbein@hcanys.org Billi Wilson Manager, Meetings & Events bwilson@hcanys.org Teresa Brown Administrative Assistant tbrown@hcanys.org
The Situation Report: the Home Care Association of New York State BUDGET from p. 1 We thank those members who participated and shared your experiences with legislators on payment, regulatory, workforce and infrastructure pressures. Advocacy Day provided the HCA community with an early foothold in the legislative process as negotiations now escalate toward the April 1 deadline for a final state budget. Your meetings with lawmakers – coupled with the legislative language proposals that HCA has already circulated to state officials – provide an important platform from which to build further advocacy engagement and continued activities to reinforce our priorities. Coming up next on the calendar for HCA are a series of hearings to further convey our budget positions, including HCA’s upcoming testimony before a joint legislative hearing on the health and Medicaid budget this Thursday. At this hearing, we will again share data and evidence underpinning our calls for home care and MLTC payment adequacy (including minimum wage funding and restoration of MLTC cuts), regulatory relief, infrastructure investment and support for workforce needs. HCA is also gearing up for a separate set of hearings planned by Assembly Health Committee Chairman Richard Gottfried later this month on issues related to the home care workforce. This area of concentration aligns with HCA’s call for language in the budget that would compel the state to further examine critical home care workforce shortages and recruitment and retention issues, especially in light of the recently implemented minimum wage hike and other system changes. As noted in our recent report on NYS Home Care Program and Financial Trends 2017, home care agencies contend with a 24 percent turnover rate for aides and a 21 percent turnover rate for nurses and other professional staff. Approximately 14 percent of home health aide positions, 17 percent of personal care aide positions, 13.51 percent of registered nurse positions, and 10.6 percent of therapist positions are unfilled due to shortages. On average, agencies are unable to accept 37.3 cases due to staff shortages. These and other findings were shared with the Legislature as part of our State Advocacy Day briefing documents, which are posted to HCA’s website at http://hca-nys.org/advocacy-pac/state. Please be on the lookout for additional state advocacy opportunities and action items using our Legislative Action Center and other tools as budget-related negotiations and activities progress.
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Is Your Clinical Team Proficient in the New OASIS-C2? Make sure your team registers for comprehensive OASIS C-2 training in April To support the educational needs of home health clinicians on OASIS data collection, HCA is hosting a two-day, comprehensive workshop with the expert trainers from OASIS Answers. The session offers participants a “Blueprint” to keep clinicians up to date, along with key resources and source documents to consult on an ongoing basis after the workshop. The workshop also serves as a comprehensive review for candidates who are seeking or renewing their COSC designation (Certificate for OASIS Specialist-Clinical). Details are below. Workshop: April 19-20, 2017 8 a.m. to 4 p.m. OPTIONAL COS-C Exam: April 21, 2017* 9 a.m. to 11:30 a.m. *Separate registration with OASIS Answers is required. Training participants receive a discounted exam fee. See event flyer below for details. Workshop/Exam Location Doubletree by Hilton 100 Nott Terrace Schenectady, NY 12308 Download the flyer and registration form: http://hca-nys.org/wp-content/uploads/ 2017/01/Blueprint-for-OASIS-SchenectadyFlyer-2017.pdf Register online: https://www.eventville.com/ Catalog/ EventRegistration1.asp?EventId=1012100
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Important Links Below are some website links that HCA routinely checks for updates and information relevant to providers and MLTC plans. We encourage you to bookmark the links that interest you or that provide information important to your agency.
State Department of Health (DOH) Health Commerce System: https://commerce.health.state.ny.us/public/hcs_login.html DOH Library of Official Documents (General Information System Messages, Administrative Directives and Informational Letters): https://www.health.ny.gov/health_care/medicaid/publications/index.htm eMedNY: https://www.emedny.org/index.aspx DOH Emergency regulations: https://regs.health.ny.gov/regulations/emergency DOH proposed rules: https://regs.health.ny.gov/regulations/proposed-rule-making DOH recently adopted regulations: https://regs.health.ny.gov/regulations/recently-adopted Supplemental Information on Specific MRT Proposals: https://www.health.ny.gov/health_care/ medicaid/redesign/supplemental_info_mrt_proposals.htm Medicaid Update newsletter: https://www.health.ny.gov/health_care/medicaid/program/update/ main.htm DSRIP: https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/ NYS health regulations: https://www.health.ny.gov/regulations/ Home Care — Information for Health Care Professionals: https://www.health.ny.gov/facilities/ home_care/professional.htm DOH funding: https://www.health.ny.gov/funding/ Home Care Registry: https://apps.health.ny.gov/professionals/home_care/registry/home.action Home Care Rates: https://www.health.ny.gov/facilities/long_term_care/reimbursement/ Managed long term care (including Model Contracts): https://www.health.ny.gov/health_care/ managed_care/mltc/ Medicaid managed care (including Model Contract): https://www.health.ny.gov/health_care/ managed_care/index.htm Managed care reports: https://www.health.ny.gov/health_care/managed_care/reports/index.htm
U.S. Centers for Medicare and Medicaid Services (CMS) CAHPS: https://www.homehealthcahps.org/ CMS press releases: https://www.cms.gov/Newsroom/Newsroom-Center.html CMS fact sheets: https://www.cms.gov/Newsroom/Search-Results/index.html?filter=Fact%20Sheets HHS press releases: https://www.hhs.gov/about/news/2017-news-releases/index.html
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Continued from previous page Paperwork Reduction Act notices: https://www.cms.gov/Regulations-and-Guidance/Legislation/ PaperworkReductionActof1995/PRA-Listing.html Policy & Memos to States and Regions: https://www.cms.gov/Medicare/Provider-Enrollment-andCertification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html Recovery Audit Program updates: https://www.cms.gov/Research-Statistics-Data-and-Systems/ Monitoring-Programs/Medicare-FFS-Compliance-Programs/Recovery-Audit-Program/ Recent_Updates.html 2017 CMS Transmittals: https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Transmittals.html Federal Policy Guidance on Medicaid: https://www.medicaid.gov/federal-policy-guidance/federalpolicy-guidance.html?filterBy=bulletin%23dynamic-list Medicare revalidations: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/ MedicareProviderSupEnroll/Revalidations.html Provider manuals: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/ index.html?redirect=/Manuals/IOM/list.asp Home Health Quality Initiative (includes OASIS information): https://www.cms.gov/Medicare/QualityInitiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/index.html?redirect=/ HomeHealthQualityInits/14_HHQIOASISUserManual.asp
Others Federal Register: https://www.federalregister.gov/public-inspection/current Recovery Audit Program Contractor: https://dcsrac.com/IssuesUnderReview.aspx OMIG audit protocols: https://www.omig.ny.gov/audit/audit-protocols 2017 New York State Register: https://www.dos.ny.gov/info/register/2017.html NYS health data: https://www.health.data.ny.gov/ State Department of Labor minimum wage information: https://www.labor.ny.gov/workerprotection/ laborstandards/workprot/minwage.shtm U.S. Department of Labor home care resources: https://www.dol.gov/whd/homecare/agencies.htm U.S. Department of Labor Bureau of Labor Statistics: https://www.bls.gov/home.htm Grants Gateway (state funding sources): https://grantsgateway.ny.gov/IntelliGrants_NYSGG/module/ nysgg/goportal.aspx?NavItem1=2 State Education Department recently adopted rules and regulations: http://www.counsel.nysed.gov/ rules/indices.html State Education Department Office of the Professions: http://www.op.nysed.gov/
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Tom Price Confirmed as HHS Secretary By a 52-to-47 vote, the U.S. Senate has confirmed U.S. House Rep. Tom Price’s nomination as the next Secretary of the U.S. Department of Health and Human Services (HHS). The vote came after 2 a.m. on Friday, and was cast strictly along party lines. Democrats have opposed the nomination in large part due to Mr. Price’s lead in sponsoring House legislation aimed at repealing the Affordable Care Act (ACA). Mr. Price, a physician, has served on the influential House Ways and Means Committee. HHS is a cabinet-level department of the federal government. It has 11 divisions, including the U.S. Centers for Medicare and Medicaid Services (CMS), the Food and Drug Administration, the U.S. Centers for Disease Control and Prevention, the Office of the Inspector General, and others. For home care and other sectors, CMS, in particular, holds extensive influence, including through CMS’s vast jurisdictional authority over the administration of the Medicare and Medicaid programs. In addition to a repeal of ACA, Mr. Price has embraced other fundamental changes to the government health programs now under his direction. This includes several proposals widely supported by his Republican colleagues, such as turning Medicare into a premium-support system and refashioning Medicaid into a block-grant system. Both proposals would essentially eliminate the programs’ longstanding status as open-entitlements. He has also raised issues with certain bundled payment demonstrations and the mission of the Center for Medicare and Medicaid Innovation. While HHS and CMS are responsible for executing any such changes in Medicaid and Medicare policy, these proposals would first require legislation from Congress; although, the leaders of both houses, which are substantially in Republican control, have likewise embraced these major health care changes. It is expected that Mr. Price will be the Trump Administration’s point person on the ACA repeal effort and negotiations over Medicare and Medicaid policy changes vigorously supported by the GOP leadership and opposed with similar fervor by Democrats. Meanwhile, the Senate has yet to act on the Trump Administration’s pick to lead CMS: Seema Verma. Media reports indicate that her confirmation vote is coming soon, possibly on February 16. Ms. Verma has served as President, CEO and founder of SVC, Inc., a national health policy consulting company. Over the past 20 years, she has worked on a variety of policy and strategic projects involving Medicaid, insurance, and public health, working with Governors’ offices, State Medicaid agencies, State Health Departments, State Departments of Insurance, as well as the federal government, private companies and foundations. HCA will continue to keep the membership updated on all key developments in relevant federal agencies for home health.
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Comptroller’s CHHA EPS Audit Referred to OMIG Following a recent audit of the CHHA Episodic Payment System (EPS), the office of the state Comptroller has referred its findings to the state Office of the Medicaid Inspector General (OMIG) regarding $16.6 million in payment errors to providers, stemming from discharge codes and others. As previously reported, the comptroller’s audit determined that the Medicaid claims processing system under EPS made overpayments to a number of CHHA providers due to claim submissions which resulted in inaccurate payments when billing for partial episodes that were paid as full episodes. CHHAs should consult the EPS Billing Guidelines to ensure the integrity of billing and avoid recoupment actions. See: http://www.health.ny.gov/facilities/long_term_care/reimbursement/episodic/ billing_guidelines_04-09-13.htm. The state Department of Health (DOH) is responsible for ensuring that there are no duplicate or overlapping payments for Medicaid services, and its systems, including EPS, should be designed to identify these risk areas, especially in cases when duplicate billing occurs outside the provider’s knowledge, due to the discharge or admission activities of another entity. HCA will be contacting OMIG to ensure a reasonable timeframe for pay back. We will also seek assurances from DOH that its billing systems are able to flag occurrences of duplicate billing prior to payment, so that agencies aren’t subjected to future retroactive recoupment actions. According to the Comptroller, the majority of overpayments were based on erroneous discharge codes used by a CHHA providing multiple episodes to the same patient, or an erroneous discharge code used by a CHHA for a patient who was discharged directly to an MLTC plan. The overpayments fall into the following three major categories: 1. CHHAs receiving a full payment for a partial episode, when that provider subsequently initiated a new episode for the patient within 60 days of the beginning of the first episode, resulting in a duplicate payment to the CHHA. 2. CHHAs receiving a full payment for a partial episode when the patient was subsequently enrolled in an MLTC plan within 60 days of the beginning of the episode, resulting in overlapping payments. These situations could be the result of an erroneous discharge code submitted by the CHHA when the patient is discharged directly to MLTC or an inadvertent situation when the patient is discharged to a nonlong-term-care setting, but subsequently enrolls in an MLTC within 60 days of the beginning of the episode. 3. CHHAs receiving a full payment for a partial episode when the patient subsequently is admitted to another CHHA within 60 days of the beginning of the episode. These situations could be an erroneous discharge code by the CHHA when the patient is discharged directly to the other CHHA or an inadvertent overbilling when the patient is discharged home or to a hospital, but is subsequently admitted to the second CHHA within 60 days of the beginning of the episode. The Comptroller’s audit also noted a few instances where CHHAs created a new episode apparently based on a change in rate code (due to a new OASIS, or a change in age group). Such a situation should not trigger a new episode. The CHHA should still bill a full 60-day episode, where applicable. In accordance with previously
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published billing guidance, the rate code should be based on the most recent OASIS assessment available as of the start date of the episode (or within 5 days after the start date), and the age group must match the patient’s age on the “through” date of the claim. In an effort to minimize future billing errors that could result in payback requirements, all CHHA providers should check their billing systems to insure that they are in full compliance with the above-noted billing rule requirements for partial episodes. Information regarding CHHA rates, CHHA billing questions, and other CHHA related issues may be found at http://www.health.ny.gov/facilities/long_term_care/reimbursement/chha/. HCA has requested a list of those CHHAs affected by this audit and is awaiting a determination from DOH about obtaining it. Specific questions regarding this audit can be sent to DOH at: BLTCR-CH@health.ny.gov. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Wage Parity Certification Forms Due March 1 The next round of state-required Home Care Worker Wage Parity Law certification forms is due March 1 for CHHAs, LTHHCPs, and Managed Care Organizations (MCOs) who provide or arrange for aide services in New York City, Long Island and Westchester. CHHAs, LTHHCPs and MCOs must certify prospectively to the state Department of Health (DOH), on an annual basis, their compliance with the Wage Parity Law. These certification forms are due to DOH by March 1, 2017 for the March 1, 2017 to February 28, 2018 period. The forms are available at https://www.health.ny.gov/health_care/medicaid/redesign/2016/2016-0217_wage_parity_alert.htm. Agencies should change the date to 2017 before sending to DOH at HCWorkerParity@health.ny.gov. Meanwhile, CHHAs, LTHHCPs and MCOs that contract with LHCSAs or other entities are required to obtain a written certification on a quarterly basis from the LHCSA or other entity which attests to the LHCSA’s compliance with the state’s Home Care Worker Wage Parity Law for defined certification periods and on a prospective basis. The form, also due March 1, 2017, covers the period March 1, 2017 to May 31, 2017, and is sent to the CHHA, LTHHCP or MCO, not to DOH. The wage parity levels for New York City, Long Island and Westchester are at https://www.health.ny.gov/ health_care/medicaid/redesign/mrt_61.htm. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
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New Court Action on Jimmo Case In early February, a federal judge issued an order adopting a corrective action plan and mandating two additional requirements by the U.S. Department of Health and Human Services (HHS) in the Jimmo case. HCA has written extensively about the case, which called into question the application of a so-called “Improvement Standard” for Medicare home health beneficiaries. At issue in the case is the view that some contractors erroneously allowed for nursing and rehabilitation coverage only when a beneficiary is expected to “improve,” as opposed to cases where the treatment plan aims for health maintenance. The case has little applicability to other types of home care cases where improvement is not an issue. Under the original settlement, the U.S. Centers for Medicare and Medicaid Services (CMS) agreed to revise its Medicare manuals to clarify that home health and skilled nursing facility “coverage of nursing care does not turn on the presence or absence of an individual’s potential for improvement from the nursing care, but rather on the beneficiary’s need for skilled care.” Also, skilled care may be necessary to improve a patient’s current condition, to maintain the patient’s current condition, or to prevent or slow further deterioration of the patient’s condition. After CMS was given time to implement the settlement, the plaintiffs asserted that CMS had not adequately revised the Medicare manuals to reflect the maintenance coverage standard and that CMS’s educational campaign was “deficient,” prompting a return to court to seek further action. The more recent February order is at http://www.medicareadvocacy.org/wp-content/uploads/2017/02/Jimmo-v.Sebelius-Corrective-Action-Order.pdf. In this most recent decision, the judge has approved a plan under which CMS must develop a new website dedicated to the settlement, with frequently asked questions, and information that disavows the application of an “Improvement Standard.” CMS must also post a “Corrective Statement” on the website and include the statement on a national call. Lastly, it must direct the Medicare Administrative Contractors and Medicare Advantage Organizations to conduct education on the Jimmo manual clarifications. The U.S. Department of Health and Human Services (HHS) Secretary is required to certify compliance with the order by September 4, 2017. In response to the court order, CMS has posted a Jimmo v. Sebelius Settlement Agreement Program Manual Certifications Fact Sheet at http://www.cms.gov/Medicare/Medicare-Feefor-Service-Payment/SNFPPS/Downloads/ jimmo_fact_sheet2_022014_final.pdf. For more information, contact the HCA Policy staff.
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DOH Posts 2017 CHHA Pediatric Medicaid Rates Includes FLSA, NYC Wage Parity, and minimum wage adjustments The state Department of Health (DOH) has posted to the Health Commerce System (HCS) the initial 2017 Medicaid fee-for-service (FFS) rates for CHHAs who are serving pediatric patients (under 18 years of age). These updated rates have been transmitted to the Office of Health Insurance Programs and eMedNY payment system for payment. On December 7, 2016, DOH published similar initial 2017 CHHA Pediatric Medicaid rates; however, that Dear Administrator Letter (DAL) stated that those rates were notice rates only and posted to the HCS so CHHAs in the New York City (NYC) area could see their minimum wage rate adjustment. HCA is expecting in the very near future for DOH to post the initial 2017 Medicaid rates for the Personal Care program as well as an update to the CHHA Episodic Payment System (EPS) rates to account for a minimum wage adjustment for NYC providers. The initial non-Episodic Payment System (EPS) CHHA rates reflect a zero roll factor adjustment as well as an overall zero trend factor for the rate period January 1, 2017 through December 31, 2017. The initial 2017 CHHA rates also include the 3-percent adjustment for purposes of improving recruitment and retention of non-supervisory home care services workers with direct patient care responsibilities, along with a 4.7 percent rate add-on adjustment for the newer Recruitment, Training and Retention (RT&R) initiative ($100 million statewide). The DAL for the initial CHHA rates includes additional information on: the statewide aggregate Administrative and General (A&G) cap, which is 27.44 percent in 2017; regional guidelines or ceilings; worker recruitment and retention adjustments; the rate hotline process; revisions to the 2016 annual cost report; and the rate appeals process. FLSA Adjustment Beginning on October 13, 2015, $0.34 was added to the CHHA pediatric hourly rates for home health aide services to reflect changes which were effective on that date in the federal Fair Labor Standards Act (FLSA). Because the 2017 rates are based on CHHAs’ 2015 Cost Reports, approximately 2.5 months of increased FLSA costs are already included in the base year cost data. Consequently, DOH has increased the home health aide rates for 2017 by $0.27. DOH notes that this additional FLSA funding is provided under the RT&R methodology authorized by Public Health Law Section 3614 paragraph 9 and 10. As such, if CHHAs do not utilize these funds to meet new overtime and travel requirements, the funds must otherwise be directed to RT&R of non-supervisory direct care workers only and CHHAs are prohibited from using such funds for any other purpose. NYC Wage Parity and Minimum Wage Adjustments Home health aide payment rates for New York City (NYC) providers were adjusted to a minimum of $20.95 per hour beginning March 1, 2014, to enable CHHAs to meet the “Wage Parity” requirements of Section 3614.14
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of the state Public Health Law. Effective January 1, 2017, the minimum payment rate for NYC CHHAs has been increased to $22.28 to additionally reflect the scheduled increase in the minimum wage in New York City. The additional amount consists of $1.00 per hour in wages and $0.33 per hour in payroll taxes and fringe benefits. The $0.27 FLSA adjustment detailed earlier in this article is in addition to the $22.28 minimum. DOH notes that both the FLSA adjustment and the NYC wage adjustments (if applicable) have been applied to the bottom-line “Revised 2017 Rates,” usually on Page 3 of the CHHA rate sheet, through an override to the “2017 Medicaid Rate,” which follows the A&G adjustment and prior to the addition of the two workforce percent adjustments. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Assembly Introduces HCA Home Care Technology Act Assembly Health Committee Chairman Richard Gottfried has introduced HCA’s “Home Health Information and Clinical Technology Act,” or A.5046. The HCA bill would establish support for home care health information and clinical technology infrastructure across state reimbursement and program policies. Currently, there are essentially no state or federally-backed provisions supporting these services for home care, managed long term care or mainstream managed care. The HCA/Gottfried bill would direct the Commissioner of Health to engage home care providers, managed care plans, statewide home care/managed care associations and other stakeholders in the development of a health information and clinical technology infrastructure support program for the home care system to:
Promote quality, accessibility, care management, innovation and cost-effectiveness in care.
Support state goals for home care participation in integrated care, including, but not limited to, Medicaid managed care, managed long term care, DSRIP, VBP models, FIDA, health homes, patient-centered medical homes, accountable care organizations, and hospital-home carephysician collaboration programs.
Facilitate home care participation in regional health information organizations (RHIOs). (Please see related p. 17 story about funding opportunities for connection to RHIOs, also known as Qualified Entities.)
The bill would include the following program components:
Capital grants to CHHAs, LHCSAs and LTHHCPs for clinical and health information technology. Continued on next page
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Continued from previous page
Technology adjustment to the episodic payment system, for assistance to CHHAs, LHCSAs and LTHHCPs.
Technology adjustment for managed long term care and mainstream managed care.
Technology support under the department’s health workforce initiatives.
Technology incentive payments under the managed care quality incentive payments.
Technology support under DSRIP.
Health care reform act technology funding.
Support for home care information and clinical technology is fundamental to the success of the state’s new models of integrated care, and vital to home care’s participation in them. This has been a high priority initiative of HCA, including major emphasis at last week’s State Advocacy Day meetings in Albany. HCA has also called for inclusion of such technology support in the State Budget. HCA has convened a technology committee that is examining this and a wide series of proposed actions to support home care technology and technology integration with system partners, and with regional and state health information systems. HCA thanks Assemblyman Gottfried for his sponsorship and strong support. In the Senate, this legislation has also been supported by Senate Health Committee Chairman Kemp Hannon, whom we anticipate will also introduce a companion bill. HCA urges members to write in strong support of this bill to Assemblyman Richard Gottfried, NYS Assembly, LOB 822, Albany, NY 12248, (518) 455-4941, or GottfriedR@nyassembly.gov; HCA will provide guidance on Senate outreach upon introduction in that chamber. For further information, please contact Al Cardillo at acardillo@hcanys.org.
HCA Veterans Home and Community Based Pilot Program Legislation Introduced Assembly Veterans Committee Chairman Michael DenDekker has reintroduced HCA legislation (A.3415) to establish the Veterans Home and Community Based Pilot program to provide integrated, interdisciplinary and person-centered services to veterans. Pilots would be established as collaborative models that would include home care agencies (CHHAs, LHCSAs, and/or LTHHCPs), physicians and other partners to coordinate and provide services. The Director of the State Division of Veterans Affairs would be authorized to apply for federal waivers that would integrate the various sources of veterans’ health care financing through the pilot program, promoting a comprehensive, coordinated plan of care and service for veterans. A same-as bill was introduced last session by Senator Thomas Croci, Chair of the Senate Veterans Committee, and HCA will be reaching out to Senator Croci to seek his sponsorship again this
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session. As a parallel track, HCA will explore with the sponsors the potential of including this bill in the Legislature’s budget legislation. HCA developed this legislation after working with a group of individual HCA home care providers from around the state, and co-sponsoring a veterans home care roundtable with the New York State Health Foundation, which featured participation of HCA, the HCA providers, veterans advocacy organizations, the Foundation staff and Board, and other key local and national parties. The effort was also supported from data provided by U.S. Rep. Thomas Zeldin. In the wake of this effort, HCA’s Executive Vice President Al Cardillo was asked to serve on the Congressman’s Veterans Advisory Committee, where HCA input is offered on issues of significance to veterans. HCA is proud to have authored and to be working to advance this legislation and related supports on behalf of our veterans and their families. Members who wish to weigh in on this bill should call or write with your strong support to Assemblyman Michael DenDekker, NYS Assembly, LOB 841, Albany, NY 12248, (518) 4554545, or DenDekkerM@nyassembly.gov; once we learn the status of introduction in the Senate, HCA will advise members on outreach to the Senate sponsors. For further information, please contact Al Cardillo at acardillo@hcanys.org.
HCA Sepsis Initiative Prepares for Rollout National sepsis experts call initiative “pioneering” Now that the fourth-in-a-series of webinars has finished on February 9, HCA’s unique home care sepsis initiative is moving toward imminent rollout to home care agencies. The webinars, co-conducted by HCA, IPRO and partners, follow more than two years of intensive work with experts at all levels to develop this initiative. The initiative – a first-of-its kind in the nation – includes a sepsis screening tool innovated by the HCA Quality Committee and sepsis workgroup for use by home care clinicians in identifying potential sepsis risk or possible presentations of sepsis/severe sepsis. The tool also prompts follow-up and intervention steps as warranted, including preventive education, coordination with the physician, and potential referral for EMS and hospital care. An algorithm and protocol have also been created to accompany the tool to further guide home care clinicians. Friday’s webinar was targeted as a “Train-the-Trainer,” and was preceded by webinars providing background on sepsis, its relationship to home care, integration of the HCA tool with an agency’s electronic health records, guidance for agency adoption and implementation of the tool, and other key aspects. All of the webinars have been recorded and are available at: http://atlanticquality.org/initiatives/sepsis-initiative/ educational-eventswebinars/. HCA, its Quality Committee, Sepsis Workgroup and partners have been working diligently to establish a path for home care contribution to the prevention, early recognition and prompt treatment/mitigation of sepsis. In a parallel initiative, the HCA tool has been incorporated in pilot projects sponsored by the U.S. Centers for Medicare and Medicaid Services (CMS) in New York State. These projects have been implemented by IPRO and focused on community based efforts in early sepsis recognition and entry into care. Frequently misunderstood by individuals and missed in initial diagnosis throughout the health system, sepsis is often a quick and deadly killer, costing the health care system $24.7 billion nationally; for
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survivors, sepsis often leaves severe, life-altering effects. The HCA initiative will provide a major, potential game-changing capability for home care in sepsis intervention. It is specifically designed for compatibility with hospitals (for which sepsis protocols have been established) and EMS (thus further syncing with integrated/ coordinated care). HCA will be providing further details on rollout of the tool, which will be made available to home care agencies via user-agreement with HCA. The intent of the user-agreement is to ensure standardized use of the tool and protocols, and other criteria critical for quality. All of the webinars (linked at the beginning of this article) are a prerequisite for user-authorization. Interest in this initiative continues to be communicated to HCA from other sectors, other states and providers around the country. HCA acknowledges the work of the HCA Quality Committee, Board, Sepsis Workgroup and partners, including IPRO, the National Sepsis Alliance and expert state and national physicians. In particular, HCA thanks sepsis workgroup leader and innovator, Amy Bowerman, RN, Director of Quality Improvement for the VNA of Utica & Oneida County and Director of Patient Services for Senior Network Health. For additional information, please contact Al Cardillo at acardillo@hcanys.org.
New Developments in State Value Based Payment The newest developments in value based payment (VBP) were discussed at Friday’s VBP Steering Committee. HCA Executive Vice President Al Cardillo is HCA’s representative on the steering committee. HCA members can view the state’s VBP project slide-deck for the meeting at http://hca-nys.org/wp-content/ uploads/2017/02/VBP-Workgroup-Feb-10-2017-meeting_final.pdf. Discussions focused on:
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Recommendations of a sub-workgroup on program Integrity issues, including areas and concerns about the need for regulatory flexibility and changes in state Office of the Medicaid Inspector General (OMIG) audit protocols to align with these new models, as well as concerns about the integrity of practices given the anticipated implications associated with VBP’s powerful incentives for shared savings and shared risk. The state Department of Health (DOH) has asked the steering committee to provide further comment and then will make the Program Integrity Report draft available for public comment over a thirty-day period. HCA will strongly encourage member review and comment on this report.
VBP Innovator Requirements. DOH provided the steering committee with requirements it expects will apply to VBP innovators, which will be providers/systems in a position to move forward with advanced VBP arrangements, such as full capitation for total costs for total populations served. The requirements included such criteria as: prior successful experience in a VBP program and/or contracts of a similar nature to that proposed for innovator status; financial reserve/stability benchmarks; minimum number of covered lives; network adequacy; and others.
Anticipated Quality Measures for Certain VBP Categories. Sub-workgroup recommendations were discussed with the committee for VBP quality metrics for maternity care, HIV/AIDS and Health and
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Recovery Plans (HARP). These discussions reviewed one-by-one a wide series of metrics for these categories, and whether the metrics were being recommended as mandatory/pay for performance, pay for reporting, or optional/in need of further study/not appropriate for metric use at this time. HCA encourages members to review the slide-deck and offer any comments to HCA. Comments should be provided to acardillo@hcanys.org. Most importantly, HCA continues to encourage and urge providers to explore VBP opportunities. More information is expected with regard to integrated care, long term care and other VBP target populations and services at the next, March 7, meeting of the steering committee. However, providers, MLTCs, and physician/hospital/other partners should be pursuing discussions and possibilities ongoing. (Note related page 13 and 15 articles on Sepsis and Gold STAMP.) For further information, contact Al Cardillo at acardillo@hcanys.org.
Webinar Highlights Opportunity for Home Care in New Models Home care opportunities in quality and performance – a priority for patients and tailor made for new models like DSRIP and VBP – were discussed in a February 8 webinar for health care providers in the state. The webinar specifically focused on prevention, reduction and management of pressure ulcers in the health care system through the Gold STAMP model, with special emphasis on home care and nursing home care. The webinar was recorded and is viewable at http://cphceworkforce.adobeconnect.com/p9p85dm1uha/. Gold STAMP is a collaboration-based, interdisciplinary, evidence-based program of excellence in preventing/reducing pressure injury, producing measured outcomes of improved quality and cost-saved. Gold STAMP offers home care agencies and partners a tailor-made prototype for the “new” and evolving health care environment, and its new and dominant models of care and coverage (such as DSRIP, value based payments, ACOs, managed care, and others. Pressure injuries are a condition of extremely high fiscal and patient/family consequence. As such, they are an important target of new care and coverage models. According to the National Pressure Ulcer Advisory Panel, over 2.5 million U.S. residents develop pressure ulcers every year, costing $9.1 billion to $11.6 billion per year, and $20,900 to $151,700 per person per pressure ulcer. About 60,000 people each year die with pressure ulcers. HCA Executive Vice President Al Cardillo, who was among the webinar faculty, emphasized that Gold STAMP’s specific design elements offer inherent capabilities in addressing pressure injuries and in offering home care and partners a model syncing with new model designs and reform policies. The model is based on a multi-sector collaborative – creating a partnership among hospitals, nursing homes and home care, with organizational and clinical integration. It provides for cross-partner:
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Care transition system and tools; Clinical tools (Braden Scale); Communication tools (including care transitions)
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Action planning; Team meetings and assessment; Management; and Staff training in skill-sets, and points-of-contact and leadership designation (“coach”, “champion”), further facilitating collaboration and management.
Establishment of a Gold STAMP model in your agency also provides a program template for building and applying principles to other health conditions. The main Gold STAMP resource page (www.goldstamp.org) links to these tools and resources, including a library of webinars and references, which are ready-made to assist home care providers and other partners to implement a program. The state has made Gold STAMP a part of its Medicaid Redesign Team program, and pressure ulcer training has been on the recommend list of training and education under the state’s $245 million health workforce centers of excellence initiative under development. For further information, please contact Al Cardillo at acardillo@hcanys.org, or the Gold STAMP home page linked above.
NYS Health Foundation Funding Available The New York State Health Foundation (NYSHealth) is currently accepting applications for its 2017 Special Projects Fund. Applicants must submit an online inquiry form to determine whether a proposed project fits the funding criteria. The deadline for the online inquiry form is March 15, 2017. Selected organizations will be invited to submit full proposals, with a deadline of May 17, 2017. NYSHealth Special Projects Fund awards are one-time, nonrenewable funding opportunities consistent with the Foundation’s mission to improve the health of all New Yorkers but through projects that are outside of the Foundation’s main priority areas. Projects eligible for funding should include:
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A clear articulation of need and a focus on vulnerable populations.
A clear articulation of opportunity, goals, timelines, objectives, and measurable outcomes.
An effective plan for evaluating the measurable impact of the project based on the potential funding to be received.
The experience, potential, and readiness of the applicant organization to complete the project successfully.
A demonstration of how the project will be financially and programmatically sustainable after one-time grant support from NYSHealth (particularly relevant for projects that start new services). It is important to explain the business plan for sustaining the project. Continued on next page
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Strong potential for replication elsewhere in New York State or nationally.
Information on how and why the initiative represents a special opportunity for NYSHealth funding.
A degree of creativity or innovation.
More information is at http://tinyurl.com/jr6y3la.
Clarification Regarding Criteria for Data Exchange Incentive Program As previously reported, the New York E-Collaborative (NYeC) held two recent webinars related to the new Data Exchange Incentive Program (DEIP), which includes funding to increase Health Information Exchange (HIE) adoption by Medicaid providers in New York State. DEIP was stablished by the state Department of Health (DOH) in partnership with the U.S. Centers for Medicare and Medicaid Services. It helps cover the costs of connection to a provider’s local Qualified Entity (QE), which was formerly known as a Regional Health Information Organization (RHIO). The incentive funds available are $10,000 per organization on a first-come, first-served basis, and the program is open to a variety of Medicaid participating organizations and providers including long-term care providers such as Article 36 home care agencies and hospices. HCA has sought clarification on the eligibility criteria to ensure that CHHAs and LHCSAs are both eligible based on their definitions of “accepting Medicaid.” While HCA has advocated that both types of home care providers should qualify for funds, NYeC needs to check with DOH. Once we get a definitive answer, we will notify members. HCA has also clarified that eligible organizations can only receive funding to connect to one QE. In order to participate and receive these funds, organizations must:
Have an Electronic Health Record (EHR) that is certified by the federal Office of the National Coordinator for, at a minimum, Privacy and Security criteria. If you are unsure whether your EHR system is certified, consult this site: https://chpl.healthit.gov/#/search
Accept Medicaid (Fee-for-Service or Medicaid Managed Care)
Not already be connected and contributing data to a QE/ RHIO
The organizations that receive DEIP funds will be required to subsequently contribute a pre-defined set of data elements to their local QE once connected. Those data elements are defined in the set of slides from the webinar that are linked below. Slides from the webinars can be found here: http://www.nyehealth.org/nyec16/wp-content/uploads/2016/04/ DEIP-Webinar_February2017.pdf. Please direct any related questions to Alex Fitz Blais (ablais@hcanys.org) or Andrew Koski (akoski@hcanys.org).
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Updates from CMS’s Home Health and Hospice Open Door Forum The U.S. Centers for Medicare and Medicaid Services (CMS) held its Home Health and Hospice Open Door Forum last week which included updates on the new home health Conditions of Participation (CoPs), Medicare claims processing issues, home health star ratings, and quality measure reporting. The following is a summary of each issue. Home Health Conditions of Participation (CoPs) On January 13, CMS issued a final rule which revises the home health CoPs. A CMS representative summarized key provisions of the final rule which focus on patient centered and outcome oriented care planning. Patient rights are expanded to list the rights of patients, and improve investigations for patient complaints. The comprehensive assessment includes assessing for patients’ goals and preferences, and the caregivers’ willingness and availability to assist in the care. In addition, home health agencies (HHAs) will be required to provide, in writing, specific information related to the care, such as a visit schedule and medication list. Communication between the HHA and the physician is also emphasized. Patients, caregivers, and physicians must be informed of updates to the plan of care and discharge plans. The CoPs also include requirements for HHAs to have a quality assessment and performance improvement program and infection control program. CMS has a new e-mail address for questions related the final CoPs. Questions may be submitted to NewhhaCoPs@cms.hhs.gov. HCA’s comprehensive memo on the CoPs is at http://hca-nys.org/wp-content/uploads/2017/01/MedicareHomeHealthCoP011817.pdf. CMS responded to HCA’s inquiry during the call stating that it did not have any information regarding when the Interpretive Guidelines for home health CoPs will be available. These Interpretive Guidelines assist state surveyors in their enforcement of the CoPs. CMS’s delay in releasing Interpretive Guidance has a downstream effect on providers subject to these state-level surveillance activities, as all stakeholders need time to interpret, gain clarification, implement and plan for enforcement of the new rules. CMS’s delay in issuing these Interpretive Guidelines is one reason why HCA is seeking a one-year suspension in the effective date of these sweeping new CoP requirements. Our briefing paper to Congress calling for the CoP delay in implementation is at http://hca-nys.org/policy-positions/hca-takes-aim-at-federal-regs-seeks-copimplementation-delay. Medicare Claims Processing CMS reminded participants that Medicare systems will deny the home health claim in cases where an OASIS is not found upon receipt of a final claim for a home health episode and the receipt date of the claim is more than 30 days after the assessment completion date. CMS stated that the edit does not apply to Requests for Anticipated Payment (RAPs) nor will it be used to enforce the requirement that the OASIS be submitted within 30 days. CMS also clarified that the Annual Update to the Therapy Code List (in Change Request 9782) applies to Medicare Part B therapy (outpatient) services and not to therapy billed on a home health claim Type of Bill (TOB) 32x or a hospice claim TOB 81x or 82x. Continued on next page
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Continued from previous page Quality of Patient Care Star Rating A CMS official announced potential changes under consideration to the home health Star Ratings. CMS is soliciting comments on its plans to remove the measure Influenza Immunization Received for Current Flu Season (based on assessment data from the OASIS) and add the claims-based measure Emergency Department (ED) Use without Hospitalization. The potential change is based on recommendations from a Technical Expert Panel (TEP). TEP members emphasized that factors beyond an agency’s control can influence performance on the Flu Vaccination measure and recommended that adding the ED Use without Hospitalization measure would appropriately reward agencies that are successful in lowering ED use among their patients. On January 20, 2017, CMS held a Special Open Door Forum call to announce the Star Rating changes. Comments will be accepted until February 20, 2017 and may be submitted to HH_QM_Comment@abtassoc.com. Home Health Compare (HHC) CMS stated that on January 26 the Home Health Compare website was refreshed to reflect the removal of several measures that were finalized in the 2017 home health prospective payment system rate update rule. These measures will remain on agencies’ preview reports for several months due to system changes that must occur in order to remove them from the reports. The next Home Health and Hospice Open Door Forum is on March 22, 2017. For further information, contact HCA’s Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
DOH Posts LHCSA Guidance Documents The state Department of Health (DOH) has recently posted guidance materials and procedures for filing LHCSA policy and procedure manuals going forward. The materials are at https://health.ny.gov/facilities/home_care/ guidance_docs_for_lhcs_applicants.htm. DOH notes that Policy and Procedure Manuals must be submitted after the LHCSA application has been approved by the Public Health and Health Planning Council (PHHPC) and DOH. See the links below:
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Guidance for Developing Policies and Procedures for a Licensed Home Care Services Agency (LHCSA): https://health.ny.gov/facilities/home_care/docs/guidance_writing_policy_procedure.pdf
Dear Administrator Letters and Directives (Listed on Attachment A): https://health.ny.gov/facilities/ home_care/docs/dal_and_directives.pdf
LHCSA Applicant Worksheet: https://health.ny.gov/facilities/home_care/docs/ lhcsa_applicant_worksheet.pdf
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Tools Used by DOH for Reviewing a Policy and Procedure: o LHCSA P&P Review Tool Part A: https://health.ny.gov/facilities/home_care/docs/
lhcsa_pp_review_tool_part_a.pdf o LHCSA P&P Review Tool Part B: https://health.ny.gov/facilities/home_care/docs/
lhcsa_pp_review_tool_part_b.pdf The first document (linked on the previous page) serves as a resource to assist the LHCSA governing authority, operator and administrator with understanding the basic principles of written policies and procedures, and to assist with applying these principles when developing policies and procedures for each area of operation in the agency. This and other documents include copies of pertinent DOH directives, examples of a policy and procedure index with a crosswalk, materials required prior to a pre-opening survey and a policy template. The DOH directives are also good for existing LHCSAs to review. They include Dear Administrator Letters, Personal Care Aide Scope of Functions and Tasks, a Guide to Home Health Aide Training and Competency Evaluation, Permissible and Non-Permissible Activities (Home Health Aide Services), and more.
Guidance Issued on Late Appeals Process The state Department of Health (DOH) has posted a guidance that outlines the requirements for Fully Integrated Duals Advantage (FIDA) plans to follow when a FIDA participant or Non-Participating Provider requests an appeal after the initial level 1 filing deadline. The guidance is at https://www.health.ny.gov/health_care/medicaid/redesign/fida/mrt101/policy/docs/ 2017-01-25_good_cause_policy.pdf. The document explains that the deadline to request a level 1 appeal is 60 days after a FIDA plan sends the notice of action. Plans have the discretion to waive this deadline, and treat the appeal as if it were filed timely. DOH and the U.S. Centers for Medicare and Medicaid Services (CMS) advise FIDA plans to exercise reasonable judgment in deciding whether or not to waive the deadline. The guidance outlines the procedures for plans when they decline to waive the deadline, including which forms to utilize and how to complete them.
NGS Updates National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), has recently posted the following information to its website.
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NGS to Host a J6 Ask-the-Contractor Teleconference on February 23 – NGS is hosting its Askthe-Contractor Teleconference (ACT) for Jurisdiction 6 (J6) home health providers on Thursday, February 23, from 2-3:30 p.m. This teleconference offers home health providers an opportunity to ask questions and share information. Questions may be sent in advance, but no later than February
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17 to j6.provider.training@wellpoint.com. NGS requests that you do not include protected health information (PHI). The subject line should say: “J6 Home Health ACT Question.” Pre-registration is not required for this teleconference; however, participants will be required to provide the following when joining the call: name, phone number, provider number and name, state abbreviation, and e-mail address. The following is the dial-in number and conference identification number for the call: Dial-in Number: (888) 589-5413; Conference ID Number: 60610143.
NGS Announces April 2017 Dark Days for the Common Working File Hosts – In anticipation of the April 2017 release, the Common Working File (CWF) Hosts will not process claims beginning Friday, March 31, 2017 through Sunday, April 2, 2017. During this period, which is commonly referred to as “dark days,” the CWF Hosts will install the April 2017 Release, complete weekly/ monthly/quarterly processing activities, and perform scheduled data center maintenance. These dark days will limit access to information provided by NGS’s Interactive Voice Response (IVR) system and to NGSConnex. Providers may also experience limited or no access to claims, eligibility, claim overlap, patient status, check inquiry, reopening/redetermination status, offset information, and financial claim information.
For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org. Important Upcoming Deadlines Requirement
Medicare Advantage (MA) Disenrollment Period
Effective/Due Date
More Information
January 1, to February 14, 2017
Disenrollment is effective the first day of the month after the month the MA organization receives the disenrollment request. http://tinyurl.com/zv49s4p
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Home Care Worker Wage Parity certification forms for CHHAs, LTHHCPs and Managed Care Organizations (MCOs) that serve New York City, Long Island and Westchester
March 1, 2017 (for period of March 1, 2017 to February 28, 2018)
https://www.health.ny.gov/health_care/medica id/redesign/mrt_61.htm
Home Care Worker Wage Parity certification forms for LHCSAs that contract with CHHAs, LTHHCPs, or MCOs serving New York City, Long Island and Westchester
March 1, 2017 (for the period of March 1 to May 31, 2017)
https://www.health.ny.gov/health_care/medica id/redesign/mrt_61.htm
Healthcare Personnel Influenza Vaccination Report for personnel employed from October 1, 2016 to March 31, 2017
May 1, 2017
http://hca-nys.org/wpcontent/uploads/2016/10/ctrlaccamstmpNotifi cation_21226.pdf
Medicare Home Health Revised Conditions of Participation
July 13, 2017 (for most provisions)
https://www.gpo.gov/fdsys/pkg/FR-2017-0113/pdf/2017-00283.pdf
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Resources
“Providing Value-Added Services for Medicare-Medicaid Enrollees: Considerations for Integrated Health Plans,” by the Center for Health Care Strategies http://www.chcs.org/media/PRIDE-Value-Added-Services_012617.pdf
“Medicaid Managed Care: Improved Oversight Needed of Payment Rates for Long-Term Services and Supports,” by the Government Accountability Office http://www.gao.gov/assets/690/681946.pdf
“Implementation of New Influenza Virus Vaccine Code,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/ R3711CP.pdf
For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
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