August 21, 2017 Edition of the Situation Report

COMPLIANCE

TPL

HOSPICE COMPARE

COURT RULING: ARBITRATION AGREEMENTS

Register today for Compliance Symposium on October 19 for the latest on compliance hot topics, OIG and OMIG audit concentrations and more.

The next round of TPL case reports, with instructions to demand-bill Medicare, are being sent to select providers, covering cases from Oct. 1, 2016 to March 31.

Launch of Hospice Compare includes public posting of scores for 7 Hospice Item Set (HIS) quality measures.

Court rules that certain arbitration agreements are unenforceable if they waive class-action rights.

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COMING UP Senior & Financial Manager’s Retreat September 7-8 Mohonk Mountain House New Paltz Optimizing Your Agency’s Revenue Cycle for Improved Financial Performance September 13, 2017 New York City All HCA programs and registrations are posted at http://hcanys.org/eventseducation/upcomingevents

Your Source for HOME CARE News, Policy and Advocacy

Vol. 2, Issue 30 | August 21, 2017

HCA on Post-Acute Care Management Models Workgroup, Provides Input This week, the state Department of Health (DOH) convened its first meeting of the ”Post-Acute Care Management Models Workgroup,” which is part of the “Regulatory Modernization Initiative (RMI),” jointly chaired by Mark Kissinger, Special Advisor to the Commissioner of Health, and Sara Butterfield, Senior Director of Health Care Quality Improvement at IPRO. The workgroup was convened by DOH to prompt discussion, solutions and possible changes in regulations or statutes impacting home care and other sectors of the health See WORKGROUP p. 3

Summer Schedule HCA is publishing The Situation Report on a biweekly schedule for the summer. Our next edition will be on September 5 when we resume our weekly schedule following the Labor Day holiday. We will notify you by e-mail of all important breaking updates.

Join HCA President, Executives from 20 States for D.C. Public Policy Summit and Advocacy Meetings on Sept. 11, 12 Join HCA President Joanne Cunningham and the Council of State Home Care Associations for its second annual Public Policy Summit and Capitol Hill Advocacy Day on September 11 and 12 in Washington.

See SUMMIT p. 2

INSIDE HCA on Regulatory Workgroup, Provides Input.................................................1 Join HCA President, Executives for D.C. Public Policy Summit on Sept. 11 & 12...1 Compliance Symposium on Oct. 19 Highlights Compliance Hot Topics...............4 Important Deadlines and Due Dates...............................................................4 Half-Price Discount on 9/13 Bootcamp for Finance Retreat Attendees..............5 HCA Previews DOH Webinar on 2016 LHCSA Statistical Report..........................6 Managed Care Update...................................................................................6 CMS Proposes CJR Model Changes, Cardiac Rehab and Other Episodic Model.....8 OMIG Resumes Semiannual TPL Case Requests............................................10 CMS Unveils Hospice Compare: Quality Data Now Available to Public.............10

CMS Releases Updated Data on Medicare Hospice Utilization and Payment............11 OIG Updates Work Plan..........................................................................................12 Court Rejects Appeal of Tokhtaman Decision..........................................................12 New Ruling on Class Action Waivers in Arbitration Agreements............................13 Bill Dombi Named Interim Head of NAHC...............................................................14 HCA’s Mercedes Teague Joins Whitney Young Health Center Board..........................15 OASIS-C2 2018 Guidance Manual Available...........................................................15 DOH Issues May & June Global Cap Reports...........................................................15 VBP University Launched......................................................................................17 Nassau County Living Wage Increased...................................................................18 Changes in Ownership Must be Reported................................................................18 Resources.........................................................................................................................19

The Situation Report: the Home Care Association of New York State

SUMMIT from p. 1 HCA, through Ms. Cunningham, is a member of the Council, which is a body of state home care association executives engaged in collective advocacy and collaboration efforts.

This year’s Summit, which draws providers from 20 states, will feature: officials from the U.S. Centers for Medicare and Medicaid Services (CMS) discussing the new home health Conditions of Participation (COPs); hospice data reporting; Medicaid reform; and a panel discussion featuring the Medicare Administrative Contractors (MACs) from across the country.

On the second day of the Summit, September 12, each respective state home care association will visit with members of its Congressional Delegation for federal advocacy.

HCA is preparing a series of updated briefing papers that we will be sharing with the membership soon to support this effort.

Advocacy visits will be coordinated by HCA and our federal legislative affairs representatives, with further details provided soon to those who register for this event.

A flyer with further information is here: http:// www.thehomecarecouncil.org/_files/live/PPSummitFlyer.pdf.

An online registration process is here: http:// www.thehomecarecouncil.org/index.php?pID=28.

Volume 2, No. 30 August 21, 2017 

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 Vice 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 & Graphic Design jkerbein@hcanys.org Billi Wilson Manager, Meetings & Events bwilson@hcanys.org

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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Teresa Brown Administrative Assistant tbrown@hcanys.org

The Situation Report: the Home Care Association of New York State WORKGROUP from p. 1 care system, particularly hospitals. Due to federal and state policy changes incentivizing patient-centered and integrated care, providers have looked to streamline regulations to become more flexible partners and, in some cases, to gain authority to deliver care in other settings, including the home.

HCA and its member organizations have been increasingly concerned about providers that have sought to reconfigure their service delivery system and cross over into home care jurisdictional authority, which is governed by Article 36 of the state’s Public Health Law. HCA has communicated this concern regularly to DOH, including directly to the Commissioner of Health.

In addition, HCA has long advocated successfully for the adoption of state policy changes that would enable a team approach, recognizing that provider systems seek more flexibility to provide necessary care to patients and that cross-sector teams of clinicians and providers (each bringing the expertise of their particular care competency) need state policy directives that enable them to be more nimble and collaborative while respecting jurisdictional boundaries.

The workgroup discussed this avenue for increased collaboration, based on section 2805x of the Public Health Law. That section, also known as the “hospital-home care-physician collaboration program,” was a statutory construct that HCA and the hospital community got enacted into law in 2015.

The discussion was framed around five general questions that workgroup members were asked to respond to in their comments: 1. What are the current barriers to the provision of home care and other supports immediately following discharge from a hospital, nursing home, or other institution?

2. Does the current New York State statutory and regulatory framework support the current policy direction to drive more care outside of institutional settings?

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3. What specific laws and regulations hinder flexibility in the provision of post-acute care in community-based settings?

4. How can the state support sustainability for successful models, such as Delivery System Reform Incentive Payment (DSRIP) and Value based Payment (VBP) demonstrations, which prevent inappropriate hospitalizations and re-admissions to inpatient settings?

5. What is the impact of federal policy guidance such as the conditions of participation (COPs) and other federal policies?

The workgroup received comments from HCA President Joanne Cunningham, the Visiting Nurse Service of New York, and other provider sectors including those representing hospitals, nursing homes, consumer directed programs, behavioral health, managed care plans and others. Discussion focused on the burden of regulations impacting the home care sector, including the federal CoPs, workforce challenges, the need for investment in information technology to connect all sectors, and other issues.

The discussion was an initial framing of challenges facing the health care system with respect to management of post-acute patients. The workgroup will be convened again on September 13 for a follow-up discussion.

HCA will continue to actively pursue the streamlining of regulations that would enable home care providers and their contracted managed care plans to participate as flexible partners in VBP and new models of care delivery. HCA will also continue its work with DOH to advance policy directives and changes from the Department that would promote and advance collaborative models of care delivery.

Information on the RMI, including the agenda from the Workgroup’s first meeting and a list of its members and other workgroup material, is at https:/ /www.health.ny.gov/regulations/ regulatory_modernization_initiative/.

For more information, contact HCA Policy staff.

The Situation Report: the Home Care Association of New York State

Volume 2, No. 30 August 21, 2017 

Compliance Symposium on Oct. 19 Highlights Compliance Hot Topics, OIG and OMIG Audit Concentrations and More HCA announces our Corporate Compliance Symposium on October 19 in Albany.

One of our signature conferences, the Symposium draws CEOs, COOs, corporate compliance officers and other managers who have responsibility for planning, operationalizing, and establishing a complianceconscious culture at your organization.

Each year, HCA flags the compliance hot-topics and focus areas, matched with the expertise of top officials and consultants to help you get a handle on issues with direct implications for your financial stability, your reputation, your value to system partners, and the overall integrity of your patient-care mission.

From big-picture considerations to the concrete mechanics of maintaining a compliance program, this conference will: emphasize the focus areas targeted by government auditors (i.e., OMIG and OIG); provide takeaways and best-practice guidance based on real-world cases of HIT- and HIPAA-related breaches and enforcement actions; help you overcome exposure and identify new risks introduced by your participation in new integrated models of care; and examine growing segments of the home care continuum that are drawing scrutiny and new regulatory activity from state compliance agencies.

To learn more and register, please download the brochure at the back of this week’s newsletter. Online registration is available at https://www.eventville.com/Catalog/EventRegistration1.asp?EventId=1012248.

Important Upcoming Deadlines

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Requirement

Effective/Due Date

More Information

Hospice survey on minimum wage

Aug. 23, 2017

http://www.surveygizmo.com/s3/3665058/MinimumͲWageͲSurveyͲHospice

Long Term Care Workforce Investment Organization application

Aug. 28, 2017

https://www.health.ny.gov/health_care/medicaid/redesign/2017/mltc_invest.htm

State Home Care Worker Wage Parity certification forms due to CHHAs, LTHHCPs and Managed Care Organizations

Sept. 1, 2017

https://www.health.ny.gov/health_care/medicaid/redesign/mrt_61.htm

CDPAS Wage Parity Rate Update form

Sept. 8 for managed care plans

http://hcaͲnys.org/wpͲcontent/uploads/2017/07/CDPASWageParityUpdateForm.pdf

Comments on 2018 Proposed Rule for Medicare Home Health Prospective Payment System

Comments due https://www.gpo.gov/fdsys/pkg/FRͲ2017Ͳ07Ͳ28/pdf/2017Ͳ15825.pdf September 25, 2017

LTHHCP 2016 Medicaid Cost Report (LTHHCPs that only bill under CHHA EPS must file a CHHA Medicaid Cost Report, which was due August 15)

Sept. 30, 2017

https://commerce.health.state.ny.us/public/hcs_logout.html

State Home Care Worker Wage Parity Law applies to CDPAS

Oct. 13, 2017

https://www.health.ny.gov/health_care/medicaid/redesign/mrt_61.htm

Federal Emergency Preparedness Rule in Effect

Nov. 16, 2017

https://www.cms.gov/Medicare/ProviderͲEnrollmentͲandͲ Certification/SurveyCertEmergPrep/EmergencyͲPrepͲRule.html; https://www.gpo.gov/fdsys/pkg/FRͲ2016Ͳ09Ͳ16/pdf/2016Ͳ21404.pdf

Revised Medicare Home Health Conditions of Participation

Jan. 13, 2018

https://www.gpo.gov/fdsys/pkg/FRͲ2017Ͳ01Ͳ13/pdf/2017Ͳ00283.pdf

The Situation Report: the Home Care Association of New York State

Volume 2, No. 30 August 21, 2017 

Half-Price Discount on Sept. 13 Revenue-Cycle Bootcamp for Attendees of Finance Retreat In September, HCA is holding two important programs for finance staff: our Senior and Financial Manager’s Retreat on September 7-8 (New Paltz) followed by a September 13 bootcamp on Optimizing Your Agency’s Revenue Cycle for Improved Financial Performance (New York City).

As an added incentive for your finance staff to participate in these offerings, we are extending a half-price discount (from $99 to $49) on the bootcamp registration for individuals or organizations that are HCA members and attend both programs. Simply check the box labeled “Financial Managers Education Package Discount Rate” on the bootcamp registration form (http:// hca-nys.org/wp-content/uploads/2017/08/HCA-Bootcamp-Optimizing-Your-Revenue-Cycle..SenFinancial-Mgrs-Discount.pdf) to indicate that you or a colleague from your organization is also attending the Senior and Financial Manager’s Retreat.

Though each program has a different scope, both are geared for similar staff: CFOs, finance managers and executives with responsibility for budgeting and other finance decisions.

Our September 13 bootcamp, in particular, will teach you how to analyze and target underperforming areas of the revenue cycle through the use of metrics for improving cash flow. Presenter Phil Feldman is a CPA with over 15 years of finance experience, including his current position at Sandata Technologies, where he has executive responsibility for Sandata’s business unit that provides end-to-end revenue cycle services to home care agencies for improving revenue and cash flow.

This is a can’t-miss opportunity to get concrete, actionable, and practical tools and insights to better control the financial process for tracking patient care from intake to the final payment of a balance.

Registration information for both programs is below.

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Brochure: Senior and Financial Manager’s Retreat: http://hca-nys.org/wp-content/ uploads/2017/08/HCA-Senior-Financial-Managers-Retreat-Brochure-2017.pdf

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Online Registration: Senior and Financial Manager’s Retreat: https:// www.eventville.com/Catalog/EventRegistration1.asp?EventId=1012224

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Flyer and Registration: Bootcamp on Revenue Cycle Management: http://hca-nys.org/ wp-content/uploads/2017/08/HCA-Bootcamp-Optimizing-Your-Revenue-Cycle..Sen-FinancialMgrs-Discount.pdf

The Situation Report: the Home Care Association of New York State

Volume 2, No. 30 August 21, 2017 

HCA Previews DOH Webinar on 2016 LHCSA Statistical Report The state Department of Health (DOH) has shared with HCA materials for an upcoming webinar on completion of the 2016 Licensed Home Care Services Agency (LHCSA) Statistical Report.

This webinar was a recommendation by HCA, HCA members and other provider associations that are participating in DOH’s LHCSA Statistical Report Workgroup.

As communicated to members in many articles for The Situation Report, HCA and some members have been active participants in this Workgroup whose goals are to: 

Increase the compliance rates for the LHCSA Statistical Report;

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Capture data relevant to service delivery;

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Ensure quality data is collected in a timely manner;

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Ensure terminology in the report is used universally across the industry; and

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Streamline data reporting.

HCA has already submitted extensive comments, based on member feedback, to simplify the LHCSA Statistical Report and has been part of discussions at two Workgroup meetings.

HCA appreciates DOH’s work on the webinar, as the information will be very helpful to LHCSAs. Though the changes made in the 2016 LHCSA Statistical Report encompassed only a small part of our recommendations, we appreciate the changes and understand that our other suggestions will be given serious consideration by DOH in revising the 2017 Report (released in the summer of 2018).

For more information, contact Andrew Koski at akoski@hcanys.org or (518) 810-0662, or Patrick Conole at pconole@hcanys.org or (518) 810-0661.

Managed Care Update HCA participated in the August 10 Managed Care Policy and Planning meeting held by the state Department of Health (DOH). The following information was provided.

FIDA 

Voluntary enrollment in Healthfirst and RiverSpring Fully Integrated Duals Advantage (FIDA) plans are now available in Westchester County, effective July 1.



One additional FIDA plan is moving through the approval process with expected voluntary enrollments to begin in both Westchester and Suffolk County for the third quarter of 2017.

Continued on next page

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Volume 2, No. 30 August 21, 2017 

Continued from previous page 

A digital media advertising campaign targeting providers in Westchester and Suffolk Counties will be running throughout August.

Marketing Guidance has been issued to all MLTC Partial Capitation plans ceasing future marketing activities: 

All marketing materials must continue to be submitted by the plan to DOH for review and approval.

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Significant change, expansion in use or new marketing materials will not be considered appropriate.

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Plans may continue to use marketing materials that have previously received DOH approval, to the extent that approval was given.

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Discovery of unapproved marketing material will result in regulatory action.

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A Frequently Asked Questions (FAQ) document with more guidance will be issued shortly to address comments and concerns.

The ban on marketing, which HCA strenuously opposed, was advanced in the Governor’s executive state budget proposal earlier this year.

MLTC Value-Based Payment (VBP) 

DOH indicated that all MLTC plans must achieve 100 percent VBP Level 1 contracting by January 1, 2018, despite the fact that this is not required by the VBP Roadmap.



An MLTC Level 1 VBP Arrangement readiness survey went out to MLTC plans on July 27, 2017 to gather more specific information on their current providers, operations and infrastructure in relation to quality measurement and the handling of quality data. This will allow DOH to better gauge the MLTC plans’ readiness to engage in MLTC VBP arrangements for measurement in year 2017.

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The survey response date was extended from August 11 to August 16, 2017 and surveys should have been sent to MLTCVBP@health.ny.gov. The inclusion of Consumer Directed Personal Assistance Services/Fiscal Intermediary (CDPAS/FI) provider data is optional for this survey. Any plan that has already submitted the survey instrument may resubmit it with the CDPAS information removed, if the plan so chooses.

Other 

DOH is working on the Consumer Directed Fiscal Intermediary authorization process enacted as part of this year’s state budget and expects to complete it by October 1, 2017.

Continued on next page

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Continued from previous page 

DOH has awarded the Medicaid Managed Care actuary contract to Deloitte Consulting. The contract period runs through 2022, and Deloitte will be responsible for assisting the state with VBP initiative and setting premium rates for managed care plans.

For more information, contact HCA Policy staff.

CMS Proposes CJR Model Changes, Cancelation of Episodic Payment and Cardiac Rehabilitation Models This week, the U.S. Centers for Medicare and Medicaid Services (CMS) announced a proposed rule to reduce the number of mandatory geographic areas participating in the CMS Innovation Center’s Comprehensive Care for Joint Replacement (CJR) model, from 67 to 34.

In addition, CMS proposes: to allow CJR participants in the 33 remaining non-mandatory areas (and for low-volume and rural hospitals in all selected geographic areas) to participate on a voluntary basis; technical refinements and clarifications for certain payment, reconciliation and quality provisions; and a change to increase the pool of eligible clinicians that qualify as affiliated practitioners under the Advanced Alternative Payment Model (APM) track.

CMS also is proposing through this rule to cancel the Episode Payment Models (EPMs) and the Cardiac Rehabilitation (CR) incentive payment model, which were scheduled to begin on January 1, 2018, and to rescind the regulations governing these models.

Comments on this proposed rule must be received by October 15.

The proposed rule is at https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-17446.pdf.

CMS justifies its proposed changes by stating: First, we believe that requiring hospitals to participate in additional episode payment models [EPM and CR] at this time is not in the best interest of the agency or the affected providers. Many providers are currently engaged in voluntary initiatives with CMS, and we expect to continue to offer opportunities for providers to participate in voluntary initiatives, including episode-based payment models. We are concerned that engaging in large mandatory episode payment model efforts at this time may impede our ability to engage providers, such as hospitals, in future voluntary efforts.

Similarly, we also believe that reducing the number of providers required to participate in the CJR model will allow us to continue to evaluate the effects of such a model while limiting the geographic reach of our current mandatory models.

Finally, we believe that canceling the EPMs and CR incentive payment model, as well as altering the scope of the CJR model, offers CMS greater flexibility to design and test other episode-based

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payment models, while still allowing us to test and evaluate the impact of the ongoing CJR model on enhancing the quality of care while reducing costs.

CJR model changes The CJR model holds participant hospitals financially accountable for the quality and cost of a CJR episode of care and incentivizes increased coordination of care among hospitals, physicians, and postacute care providers.

The episode of care begins with an admission to a participant hospital, wherein the beneficiary is ultimately discharged under MS-DRG 469 (Major joint replacement or reattachment of lower extremity with major complications or comorbidities) or 470 (Major joint replacement or reattachment of lower extremity without major complications or comorbidities). The episode ends 90 days post-discharge in order to cover the complete period of recovery for beneficiaries. The episode includes all related items and services paid under Medicare Part A and Part B for all Medicare fee-for-service (FFS) beneficiaries, with the exception of certain exclusions.

For New York State, the CJR model is currently operating in Erie and Niagara counties, New York City, Long Island and the northern metropolitan area. CMS proposes that the CJR model would be voluntary in Erie and Niagara Counties and remain mandatory in New York City, Long Island and the northern metropolitan area.

CMS is also proposing that certain low volume and rural hospitals no longer have to participate, but will be allowed to make a one-time, voluntary election to continue to participate in the CJR model. These include 12 hospitals in New York and they are listed in Table 3 of the proposed rule.

EPM and CR model cancellations Under the three new EPMs, acute-care hospitals in certain selected geographic areas would have targeted care for Medicare FFS beneficiaries receiving services during acute myocardial infarction (AMI), coronary artery bypass graft (CABG), and surgical hip/femur fracture treatment (SHFFT) episodes.

All related care within 90 days of hospital discharge would have been included in the episode of care.

Under the CR incentive payment model, acute-care hospitals in certain selected geographic areas would have received retrospective incentive payments for beneficiary utilization of cardiac rehabilitation/ intensive cardiac rehabilitation services during the 90 days following the hospital discharge that initiated an AMI or a CABG episode.

For more information on the CJR model, visit: https://innovation.cms.gov/initiatives/cjr.

For more information on the EPM and CR models proposed for cancellation, please visit: https://innovation.cms.gov/initiatives/epm.

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The Situation Report: the Home Care Association of New York State

Volume 2, No. 30 August 21, 2017 

OMIG Resumes Semiannual TPL Case Requests Using Traditional Appeals The state Office of the Medicaid Inspector General (OMIG) has resumed its semi-annual demand billing process for the first half of federal fiscal year (FFY) 2017.

Details are outlined in a letter that some Medicare-certified home care providers should have received from OMIG and its Third Party Liability (TPL) contractor, the University of Massachusetts Medical School (UMMS).

The letter identifies which cases have been selected to undergo appeals (through demand billing), with dates of services that occurred in the first and second quarters of FFY 2017 only (October 1, 2016 through March 31, 2017).

UMMS’s letter also instructs providers to continue to monitor the status of their demand bill claim(s) once submitted. Providers are required to correct any claims that are rejected or suspended by the Medicare Administrative Contractor (MAC), National Government Services (NGS). In addition, providers are required to timely submit a complete medical record to NGS once the Additional Development Request (ADR) is issued.

If your agency is selected for future quarterly initiatives, a separate notification letter and “Case Selection Report” will be sent at that time.

HCA members interested in knowing whether they should have received a letter from OMIG can e-mail HCA at info@hcanys.org.

For specific questions about the letters, contact UMMS’s Laurie Burns at (866) 626-7594.

CMS Unveils Hospice Compare: Hospice Quality Data Now Available to Public HCA learns that some demographic info may be incorrect; Hospices are urged to review site for accuracy Last week, the U.S. Centers for Medicare and Medicaid Services (CMS) unveiled the new Hospice Compare website at: https://www.medicare.gov/hospicecompare/.

Hospice Compare is a result of a provision in the Affordable Care Act that required established procedures for making hospice quality data available to the public. The site provides a snapshot of the CMS-defined quality of care measures for each hospice facility. Consumers are able to search for all Medicare-approved hospice providers that serve their city or ZIP Code and then find agencies, along with provider quality information.

Important: It has come to HCA’s attention that the organizational demographic information (e.g. address, phone number, tax status) displayed on the Hospice Compare website is incorrect for some hospices. HCA encourages all hospices in New York to review closely all of the information on CMS’s Hospice Compare website and to contact your CASPER /ASPEN and Regional Office coordinator if there are any errors that

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need to be corrected. You can find more information about CASPER /ASPEN and Regional Office coordinators at https://data.medicare.gov/Hospice-Compare/Hospice-CASPER-ASPEN-Contacts/qx7xwipa/data.

Data That is Displayed on Hospice Compare This initial launch of Hospice Compare includes individual scores for each of the following seven quality measure (QM) scores in the Hospice Item Set (HIS).       

Patient Treated with an Opioid who is Given a Bowel Regimen (NQF #1617) Pain Screening (NQF #1634) Pain Assessment (NQF #1637) Dyspnea Treatment (NQF #1638) Dyspnea Screening (NQF #1639) Treatment Preferences (NQF #1641) Beliefs/Values Addressed (If Desired by the Patient) (NQF #1647)

Hospices with a QM denominator size of fewer than 20 patient stays (based on 12 rolling months of data) will not have the QM score publicly displayed since a score on the basis of small denominator size may not be reliable.

The next refresh for Hospice Compare will take place in the first quarter of 2018. At that time, the Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) measure scores are expected to be added to the available information for consumers.

A star rating system will also eventually be added, but there is no implementation timeframe specified

by CMS at this time.

Additional information on Hospice Compare can be found at https://www.cms.gov/Newsroom/ MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-08-16.html or at https:// www.medicare.gov/hospicecompare/.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

CMS Releases Updated Data on Medicare Hospice Utilization and Payment The U.S. Centers for Medicare and Medicaid Services (CMS) announced last week that it has posted the second annual release of the Medicare Hospice Utilization and Payment Public Use File at the following CMS page: https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trendsand-Reports/Medicare-Provider-Charge-Data/Hospice.html.

The file is a comprehensive resource for information on hospice utilization, payments, submitted charges, diagnoses, and beneficiary demographics organized by hospice provider and state. The public data set includes information on 4,232 hospice providers, over 1.38 million hospice beneficiaries, and over $15.9 billion in Medicare payments for 2015.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

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Volume 2, No. 30 August 21, 2017 

OIG Updates Work Plan The federal Office of Inspector General (OIG) has posted an updated work plan as part of its recent practice to release monthly updates.

The work plan is at https://go.usa.gov/xRdge.

One of the recently added items of interest to HCA members is Duplicate Drug Claims for Hospice Beneficiaries. Previous OIG work (A-06-10-00059) found that Medicare may have paid twice for prescription drugs for hospice beneficiaries, once under the Medicare Part A per diem rate and again under Medicare Part D. OIG will follow up on this work and review the appropriateness of Part D drug claims for individuals who are receiving hospice benefits under Part A. It will also determine whether Part D continues to pay for prescription drugs that should have been covered under the per diem payments made to hospice organizations.

Previously, OIG updated its work plan once or twice each year; however, “in order to enhance transparency around OIG’s continuous work planning efforts,” effective June 15, 2017, OIG is updating its Work Plan website monthly.

Last month, OIG updated its work plan to: include whether selected states made Medicaid payments for consumer-directed personal assistance program claims in accordance with applicable federal and state regulations; and to use data from the Comprehensive Error Rate Testing (CERT) program to identify the common characteristics of “at risk” home health providers that could be used to target pre-and post-payment review of claims.

Additional information on the OIG work plans is at https://oig.hhs.gov/reports-and-publications/workplan/index.asp.

OIG Updates at Oct. 19 Compliance Symposium HCA’s October 19 Corporate Compliance Symposium (see p. 4 story) will include a review of focus areas for OIG audit activities, among other “hot topics” in compliance. Please be sure to attend.

Court Rejects Appeal of Tokhtaman Decision On August 15, 2017, the First Department, Appellate Division (an intermediate state appellate court covering Manhattan and the Bronx) denied Human Care’s motion to appeal to the Court of Appeals (the state’s highest court) in response to the First Department’s April 2017 decision in Tokhtaman v. Human Care.

As a result, the First Department’s April 2017 decision will not be considered on appeal by the Court of Appeals, and the case will, absent a settlement by the parties, return to the trial court (Supreme Court, New York County) for further proceedings, including discovery and resolution of the case’s pivotal question – whether the plaintiff lived on her employers’ premises – as a matter of law.

In April 2017, the First Department issued a decision in Tokhtaman, rejecting the New York State Department of Labor’s so-called “13-hour” rule for the compensation of “live-in” home care aides (i.e., the standard by

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which an aide is paid for 13 hours of a 24-hour shift, provided the aide is afforded 8 hours of sleep time, 5 of which are uninterrupted, and 3 uninterrupted hours for meals). In rejecting the 13-hour rule, the First Department held that, even though the plaintiff was a “live-in” home health aide, she could recover unpaid wages for hours worked in excess of 13 hours for each 24-hour shift if she could demonstrate that she was not a “residential employee” – one who lives on the premises of the employer.

Another case centering on this issue is working its way through the appellate courts: Andryeyva v. New York Health Care, Inc. HCA submitted an amicus brief in this case. Oral arguments were held in mid-January before the Second Department, Appellate Division (an intermediate appellate court covering the counties of Richmond, Kings, Queens, Nassau, Suffolk, Westchester, Dutchess, Orange, Rockland and Putnam). The Second Department has not yet issued a decision on that appeal.

HCA members should be sure to pass this update along to your legal counsel and stay tuned for further updates from HCA on all relevant cases.

New Ruling: Class Action Waivers in Arbitration Agreements Violate Labor Act On July 18, the Appellate Division, First Department issued a decision (with two of the five justices dissenting) in Gold v. New York Life Insurance Co., ruling that employee arbitration agreements are unenforceable if they waive an employee’s right to assert claims against the employer on a collective or class action basis. It is not clear whether this decision will be appealed to the Court of Appeals, the state’s highest court.

Notably, the Appellate Division, First Department is an intermediate-level state appeals court with jurisdiction over Manhattan and the Bronx. State courts within the First Department are obligated to follow this decision unless it is overturned, while state courts in other parts of the state are not required (but are permitted) to follow it.

In Gold, the First Department followed a ruling of the U.S. Court of Appeals for the Seventh Circuit (a federal appellate court covering parts of the Midwest that struck down an employee class action waiver). In the Seventh Circuit ruling, the court declined to enforce the employee arbitration agreement which waived the right to assert collective or class action claims against the employer because it “precluded employees from seeking any class, collective or representative remedies to wage and hour disputes,” a “concerted activity” under Section 7 of the National Labor Relations Act (NLRA) that an employee cannot bargain away in an agreement.

The Seventh Circuit also ruled that its decision to strike down the arbitration agreement under the NLRA was not inconsistent with the Federal Arbitration Act (FAA), which relates to the enforcement of arbitration agreements, because the FAA provides that agreements to arbitrate are enforceable unless there are grounds at law or in equity for the revocation of the agreement. The Seventh Circuit held that, since the arbitration provisions violated the NLRA, there were grounds at law for non-enforcement of the agreement under the FAA. The First Department in Gold agreed with the Seventh Circuit, striking down the collective and class action waiver on the grounds that it violated the NLRA and was “void and invalid” under the FAA. In so proceeding, the First Department noted that there is a “split” among the federal Circuit Courts on the lawfulness and enforceability of employee collective and class action waivers, and then went on to specifically reject the rulings of the federal Circuit Courts that have found such waivers lawful and enforceable, including a

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longstanding decision of the Second Circuit (the federal appellate court with jurisdiction over, among others, federal courts in all of New York State).

As a result of the First Department decision, there is now also a “split” between the state and federal courts that cover Manhattan and the Bronx. This means that, under the Second Circuit precedent, a federal court with jurisdiction over actions in Manhattan and the Bronx would enforce an employee arbitration agreement with a class action waiver, while a state court with jurisdiction over actions in those areas would reject such waivers as unlawful under the new First Department precedent. But the U.S. Supreme Court is expected to fix this relatively soon.

In view of the current federal Circuit Court “split,” the U.S. Supreme Court is scheduled to consider in the coming months whether collective and class action waivers in employee arbitration agreements are enforceable. The U.S. Supreme Court decision will bring uniformity and finality to this issue which has divided the courts. Until the U.S. Supreme Court issues a decision, however, agencies in Manhattan and the Bronx must endure a judicial environment where there is a “split” between the state and federal courts.

Home care agencies that utilize employee arbitration agreements, particularly those that operate within Manhattan and the Bronx, should consult with their legal counsel on the use and potential enforceability of such agreements. Additionally, home care agencies should work with their legal counsel to address any issues that might arise from new court decisions, particularly the much anticipated U.S. Supreme Court decision that will decide the fate of employee arbitration agreements containing collective and class action waivers.

This article was prepared by HCA’s legal counsel, Frank J. Fanshawe, and Rachel D. Bernzweig, Law Clerk, both of Jackson Lewis.

Bill Dombi Named Interim Head of NAHC Following Death of Longtime President Val Halamandaris Following the recent passing of its longtime president, Val Halamandaris, the National Association for Home Care and Hospice (NAHC) has named Bill Dombi as NAHC’s interim president.

HCA was greatly saddened to learn of Mr. Halamandaris’s passing, which we reported to the membership in the August 7 edition of our newsletter. NAHC has created a memorial website for Mr. Halamandaris (at valjhalamandaris.nahc.org) where we encourage visitors to share and read remembrances.

Mr. Dombi has been NAHC’s Vice President for Law since 1987. He is also director of the Center for Health Care Law, a public interest law firm established by NAHC, and executive director of the Home Care and Hospice Financial Managers Association, a professional organization for individuals who work for consulting, planning, management, financial or CPA firms who are employed by home care agencies.

HCA has relied on Mr. Dombi’s unparalleled expertise on many levels in our engagement with policymakers and our education programs for HCA members on home health issues throughout the years.

According to a press release and media accounts, NAHC’s executive committee of the board of directors is seeking a search firm with experience in executive recruitment to aid in finding a permanent president for the organization.

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HCA’s Mercedes Teague Joins Whitney Young Health Center Board HCA congratulates our Finance Manager, Mercedes Teague, on her recent appointment to serve on the board of directors of the Whitney M. Young, Jr. Health Center.

The Whitney M. Young, Jr. Health Center, Inc. opened on July 19, 1971 with clinical facilities in the city of Albany under the direction of Albany Medical College and the newly formed Northside Health Center Advisory Council. Over the past four decades, the center has expanded its sites and services to offer residents in the Capital Region comprehensive, quality health care without regard to income. Its patient population has grown from 2,700 in 1973 to nearly 20,000 in recent years. It continues to operate under the governance of a consumer-dominated board of directors and the leadership of a professional senior management team. Whitney Moore Young, Jr. was executive director of the National Urban League from 1961 until his untimely death in 1971.

Home Health Quality Reporting Program: OASIS-C2 2018 Guidance Manual Available The 2018 guidance manual for the OASIS-C2 version of the Outcome and Assessment Information Set (OASIS) data set is available. This version corrects errors from the previous version and contains clarifications about the “One Clinician Rule.” The effective date is January 1, 2018.

The guidance manual is at https://www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/ Downloads/2017-08-10-eNews.pdf.

Visit the OASIS Data Sets and OASIS User Manuals pages at the links below for more information. 

Data sets: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ HomeHealthQualityInits/OASIS-Data-Sets.html.



User manuals: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ HomeHealthQualityInits/HHQIOASISUserManual.html.

DOH Issues May & June Global Cap Reports: Medicaid Spending $18M Above Projections The state Department of Health (DOH) has recently issued its May and June 2017 monthly Medicaid Global Cap report.

The full reports can be downloaded at: 

May 2017 Report: https://www.health.ny.gov/health_care/medicaid/regulations/global_cap/monthly/ sfy_2017-2018/docs/may_2017_report.pdf



June 2017 Report: https://www.health.ny.gov/health_care/medicaid/regulations/global_cap/monthly/ sfy_2017-2018/docs/june_2017_report.pdf Continued on next page

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Continued from previous page Pursuant to legislation, the Medicaid Global Spending Cap has increased from $18.6 billion in fiscal year (FY) 2017 to $19.5 billion in FY 2018, an increase of 5.2 percent. These May and June 2017 reports mark the second and third reports for the new fiscal year.

The reports find that overall spending through this June 2017 period was $18 million above Medicaid Global Cap projections, across all sectors, a difference of $5.538 billion in actual spending versus $5.520 billion in estimated spending for the period.

Specifically, DOH mentions the following two significant pressures on the Global Cap: 

Medicaid spending in major Medicaid Managed Care categories was $25 million over projections.

This resulted from slightly higher than expected enrollment.



Medicaid spending in major fee-for-service categories was over projections with nursing home spending $42 million above estimates. This is a result of slightly higher than expected utilization.

As with all other provider or managed care categories, the category “other long term care” (which includes home care, but also other long term care sectors) exceeded its monthly cap, by $6 million, but DOH did not provide any additional explanation for this variance.

In other report highlights: 

The Accounts Receivable (A/R) ending balance for FY 2017 was $204 million. The state is expected to recoup $135 million by the end of FY 2018, resulting in a projected A/R balance of $69 million by March 2018. Through the end of June, retroactive rates owed to the state were $182 million. This reflects net recoveries of $22 million since March 2017.



Total Medicaid enrollment reached 6,096,406 enrollees at the end of June 2017. This reflects a net decrease of 17,161 enrollees since March 2017.

These reports, particularly the semi-annual and annual reports, are important given the superpowers, recently augmented in the 2017-18 state budget, allowing executive actions to cut rates in the event that spending exceeds the cap. As Washington continues to debate a health care overhaul, with billions of dollars in Medicaid funding and expansion dollars at stake, HCA will advocate for a funding mechanism that sustains vital services and accurately accounts for reasonable cost factors, such as enrollment changes and wages and related labor costs, in a flexible interpretation of provider performance relative to the cap.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

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

VBP University Launched The state Department of Health (DOH) has announced the launch of VBP University, an online educational resource created to raise awareness, knowledge and expertise in the move to Value Based Payment (VBP).

It combines informational videos and supplemental materials to help stakeholders understand this major change.

The VBP University curriculum includes four semesters.

Date of Release

Area of Study

July 2017

Background and foundational information on VBP

Semester Two

August 2017

TopicͲspecific information such as governance, business strategy, stakeholder engagement, finance, and data

Semester Three

September 2017

VBP Contracting

Semester Four**

October and VBP Bootcamps** November 2017**

Semester One

**VBP Bootcamps will take place in October and November 2017 in locations throughout the state.

More information including dates and locations will be distributed shortly.

To watch an overview of the VBP University curriculum from state Medicaid Director Jason Helgerson, visit http://www.health.ny.gov/health_care/medicaid/redesign/dsrip/vbp_u/docs/vbpu_welcome_overview.mp4.

Graduation from VBP University Semesters one through three conclude with a quiz on the topics covered. Those who pass all three quizzes will receive a certificate of completion. If you attend a bootcamp, you will receive a printed copy of your certificate. If you are unable to attend a bootcamp, a copy of your certificate will be e-mailed to you.

To begin semester one of VBP University, visit www.health.ny.gov/VBP. Any questions can be sent to MRTUpdates@health.ny.gov.

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Nassau County Living Wage Increased The living wage amounts for providers that contract with Nassau County have increased, effective August 1, 2017. They are $13.98 per hour with health insurance benefits or $16.07 per hour without benefits for the period August 1, 2017 to July 31, 2018.

These amounts, along with other information on Nassau’s living wage law, are at https://www.nassaucountyny.gov/1597/Living-Wage.

The state wage parity law amounts for New York City, Long Island and Westchester are at https://www.health.ny.gov/health_care/medicaid/redesign/mrt_61.htm.

HCA has developed a chart that lists the required levels for: the state minimum wage law; state wage parity requirement; and local living wage laws for New York City, Nassau, Suffolk and Westchester. The chart is at http://hca-nys.org/wp-content/uploads/2017/08/Minimum-Wage-and-Wage-Paritychart_080917.pdf.

Changes in Ownership Must be Reported The U.S. Centers for Medicare and Medicaid Services (CMS) reminds providers that they must update their enrollment information to reflect changes in ownership within 30 days. Owners are individuals or corporations with a 5 percent or more ownership or controlling interest. Failure to comply could result in revocation of your Medicare billing privileges.

Some helpful resources include:

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

“Timely Reporting of Provider Enrollment Information Changes” (https://www.cms.gov/Outreachand-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1617.pdf)



42 CFR 424.516 (https://www.gpo.gov/fdsys/pkg/CFR-2011-title42-vol3/pdf/CFR-2011-title42-vol3sec424-516.pdf)



“Medicare: Vulnerabilities Related to Provider Enrollment and Ownership Disclosure OIG Report” (https://oig.hhs.gov/oei/reports/oei-04-11-00591.asp)



“PECOS Enrollment Tutorial – Change of Information for an Individual Provider” (https:// www.youtube.com/watch?v=eXu_skSiS1Y&list=PLaV7m2zFKpia1McB1WKKkw2esAdiZRem&index=3)



“PECOS Enrollment Tutorial – Change of Information for an Organization/Supplier” (https:// www.youtube.com/watch?v=U0fJnhQ0egk&list=PLaV7m2zFKpia1McB1WKKkw2esAdiZRem&index=4)

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Resources

19



“Medicaid Personal Care or Home Attendant Services,” by the New York Legal Assistance Group http://www.wnylc.com/health/entry/7/



“Update to Hospice Payment Rates, Hospice Cap, Hospice Wage Index and Hospice Pricer for FY 2018 (transmittal),” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R3828CP.pdf



“Home Health Quality Reporting Program Provider Training Participant Questions from In-Person Training on May 3 and May 4, 2017,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ HomeHealthQualityInits/Downloads/May-2017-HH-QRP-Provider-Training-Q-and-A.pdf



“Medicare Parts A & B Appeals Process,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/MLNPublications-Items/ CMS1243294.html?DLPage=1&DLEntries=10&DLFilter=appeals&DLSort=0&DLSortDir=ascending



“Influenza Vaccine Payment Allowances – Annual Update for 2017-2018 Season,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R3837CP.pdf

HCA Corporate Compliance Symposium October 19, 2017 Albany Hilton 40 Lodge Street Albany, NY 12207

October 19, 2017 Albany Hilton 40 Lodge Street Albany, NY 12207 HCA’s Corporate Compliance Symposium is one of our signature conferences, drawing CEOs, COOs, corporate compliance officers and other managers who have responsibility for planning, operationalizing, and establishing a compliance-conscious culture at your organization.

Each year, HCA flags the compliance hot-topics and focus areas, matched with the expertise of top officials and consultants to help you get a handle on issues with direct implications for your financial stability, your reputation, your value to system partners, and the overall integrity of your patient-care mission.

From big-picture considerations to the concrete mechanics of maintaining a compliance program, this conference will: emphasize the focus areas targeted by government auditors (i.e., OMIG and OIG); provide takeaways and best-practice guidance based on real-world cases of HIT- and HIPAA-related breaches and enforcement actions; help you overcome exposure and identify new risks introduced by your participation in new integrated models of care; and examine growing segments of the home care continuum that are drawing scrutiny and new regulatory activity from state compliance agencies.

Symposium Agenda Thursday, October 19, 2017

9:30 – 10:00AM

12:45 – 1:15PM

10:00 – 10:45AM

1:15 – 2:30PM

Rosemary McKenna, Principal, Jackson Lewis, P.C., Albany, NY

Jeffrey Gold, Esq., Senior Vice President and Special Counsel, Insurance and Managed Care, HANYS

Registration Opens with Light Breakfast NYS Auditing Priorities: The Home Care Impact

It is incumbent on all organizations to routinely assess whether their compliance plans reflect the priorities of top government auditors at the New York State Office of the Medicaid Inspector General (OMIG) and the federal Office of the Inspector General (OIG). Each year, both of these auditing agencies identify areas of emphasis, concern and priority for each health care sector, including home care. Hear from a top compliance attorney about the priority compliance and integrity areas targeted by both OMIG and OIG that will help sharpen and fine-tune your own organization’s compliance plan.

10:45AM – 11:45AM

The Art of Active Management: Optimizing Value and Compliance in Home Care Tom Meyer, Chief Program Compliance Integrity Officer, HHAeXchange

Nationally, the Medicaid program works with over 57 million beneficiaries yearly to cover medical expenses, but theft, unnecessary billing and other waste issues often go unnoticed when Medicaid service organizations fail to identify gaps in program integrity. Internal controls, monitoring and data efforts are among the tasks facing program integrity and compliance personnel, all of whom want to know how these standards can be obtained efficiently and with minimal intrusion. Based on his work as the Acting Medicaid Inspector General for New York and other top posts at OMIG, Tom Meyer will explain why active management is critical to reducing payment fraud in home care. He will also examine simple steps to best utilize available resources for ensuring plan-of-care compliance.

11:45AM – 12:45PM

Lessons Learned from Recent HIPAA Privacy Rule and Security Rule Enforcement Actions

LUNCH

Program Integrity in a Value Based Environment

The emergence of new integrated care and payment models has fundamentally changed the nature of compliance in the health care arena, particularly with the movement to Value Based Payment (VBP). Hospitals and health systems’ compliance programs and integrity measures are changing to reflect this new environment. Hear from one of the hospital sector’s most expert voices about how the VBP environment has prompted changes in hospital and health system compliance, and learn about new areas of compliance emphasis that have implications on a broad scale for home care providers and other VBP partners. This session will put you ahead of the curve by understanding how VBP program integrity is impacting home and community based service partners in the VBP model.

2:30 – 3:45PM

Avoiding Compliance Pitfalls for Fiscal Intermediaries under CDPAP

Eric Henderson, Deputy Director, Division of Long Term Care, NYS DOH Karis Browder, Long Term Care Service Specialist II, Division of Long Term Care, NYS DOH The Consumer Directed Personal Assistance Program (CDPAP), a large and growing home care program in New York State, has been the focus of recent policy changes, including on the regulatory and compliance fronts. As the program expands, with more fiscal intermediaries (FIs) participating in CDPAP, compliance issues have become a growing focus area for home care providers that function as FIs and for managed long term care plans that contract for CDPAP services. Hear from state officials about the state’s plan to implement a new authorization process for FIs, along with other priority areas of DOH compliance focus that impact the CDPAP.

Reg Harnish, CEO, GreyCastle Security

3:45 PM Faulty compliance and internal controls that govern the protection of patient information are among the most pressing challenges facing health care organizations. The increased use of mobile technologies and applications by all health care providers, including home and community based clinicians, provides new risk areas that leave organizations incredibly vulnerable, absent a strong compliance plan that protects against data breaches and other HIT risks. In fact, in recent months, the federal government has increased its scrutiny and oversight in these areas and has secured millions of dollars in fines and penalties from the health care sector for violations of the HIPAA Privacy and Security Rules. Hear from the chief executive of GreyCastle Security, a leading technology security firm, on lessons learned from these cases. You’ll gain strategies, tools and resources that home care providers and other covered entities can use to reduce compliance risk and increase protections.

Closing Comments

Corporate Compliance Symposium October 19, 2017 Hilton Albany 40 Lodge Street Albany, NY 12207

Thanks to our Symposium Sponsors

Hotel Information Hilton Albany 40 Lodge Street Albany, NY 12207

HCA has reserved a limited block of rooms at the Hilton Albany for the night of Wednesday, October 18 at a discounted rate of $179

per night.

To make your overnight room reservations at the Hilton Albany,

Thanks to our Exhibitors

call: 866-691-1183 and ask for the HCA rate. This rate is valid through September 18. After this date, higher rates will apply based on availability.

Aetna Better Health of New York HHAeXchange Sandata Technologies Simione Healthcare Consultants TSG Financial

REGISTRATION – Please complete this form and fax it to the number below or register online at: http://eventville.com/hcanys

HCA Cancellation Policy HCA registration cancellations received by October 5 are refundable less a 25% administrative fee. No refunds will be issued after this date. Cancellations must be received in writing via e-mail to: info@hcanys.org. Substitutions are permitted.

REGISTRANT INFORMATION Registration Deadline is October 4th

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HCA REGISTRATION FEE ____ Member Fee

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