HHS and CMS
LTHHCP
RENEWALS
LEGISLATION
President-elect Trump has made his appointments to head HHS and CMS. Learn more about the prospects.
Progress is moving on the state’s work to allow Episodic Payment System billing for LTHHCPs.
Be on the lookout for HCA membership renewal packets to maintain your membership in 2017!
As announced in an e-mail alert last week, Gov. Cuomo has acted on a series of bills, including home care measures.
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Your Source for HOME CARE News, Policy and Advocacy
Vol. 1, Issue 13 | December 5, 2016
COMING UP Tools, Resources and Knowledge for VBP Readiness and Success Dec. 15, 2016 DoubleTree by Hilton Hotel Tarrytown 455 S. Broadway, Tarrytown, NY 10591 Northeast Home Health Leadership Summit: “Extreme Makeover, Home Care Edition” Jan. 17-19, 2017 The Colonnade Hotel Boston To register for HCA conferences and events, please visit our education page at http:/ /hca-nys.org/eventseducation/upcomingevents
Now is Time to Act on Home Care Contract Amendments for Minimum Wage Funding New York City home care providers should be communicating now with their MLTC plan contractors about minimum wage contract amendments. These amendments to existing contracts would address funding that the state is making available to plans to address the December 31 minimum wage increase. See AMENDMENTS p. 4
HCA Needs Your Responses on Signature Annual Home Care Industry Survey HCA needs your answers to our newly prepared 2016-17 State of the Home Care Industry survey, which is vital for our advocacy efforts in 2017. See SURVEY p. 3
INSIDE Act Now on Minimum Wage Contract Amendments.............................................1 HCA Needs Your Responses on Home Care Industry Survey..................................1 HCA Redoubles Efforts on F2F Repeal..................................................................1 DOH Issues Home Care, Hospice Emergency Preparedness Reg. Reminder..........4 Press Reports: Large MLTC Announces Plan to Discontinue Services on LI..............5 Important Upcoming Deadlines.........................................................................7 Trump Names HHS and CMS Appointments...........................................................8 DOH Actively Working to Make LTHHCP EPS Billing a Go.......................................9 It’s HCA Membership Renewal Time...................................................................9 Workforce Investment Opportunities, Data Insights at VBP Conference.........10 Cuomo Vetoes Essential Personnel Bill, Signs Advanced Aides .........................11
With New Congress, and Political Changes in Washington, HCA Redoubles Efforts on F2F Repeal As political changes sweep through Washington, HCA this week redoubled our ongoing efforts to urge Congressional action on the disastrous Medicare Face-to-Face (F2F) rule which has long been a target of HCA advocacy. See F2F p. 2
Make 2017 Your ‘Makeover’ Year at Home Health Leadership Summit.............12 DSRIP Mid-Point Assessments Reports Released for all PPSs............................13 Value Based Payment Update...................................................................13 DOH Publishes Updated Hospice Medicaid Rates.........................................14 Encouraging Home Care Participation in National Influenza Vaccinate Week...15 FIDA Webinar Scheduled..............................................................................16 OMIG Posts Compliance Cert. Forms & Compliance Review Guidance..............17 OIG Releases Semi-Annual Report.................................................................18 Upgrades Made to UAS...................................................................................18 Emergency Rule Issued for OTs and Occupational Therapist Assistants............19 NGS Updates................................................................................................20 Resources.........................................................................................20
The Situation Report: the Home Care Association of New York State F2F from p. 1 In a letter sent late last week to New York’s Congressional Delegation (see http://hca-nys.org/wp-content/uploads/2016/12/ F2FlettertoCongress120216.pdf), HCA President Joanne Cunningham expressed appreciation for the bipartisanship that has characterized much of the New York Delegation’s work on home care policy, including, and especially, its past work to press for changes on F2F. At HCA’s urging, Republican and Democratic representatives from New York wrote to the U.S. Centers for Medicare and Medicaid Services (CMS) in 2013, calling for simplification of F2F. The letter was signed by 75 Members of Congress. Given this bipartisan record of action, even in an otherwise politically charged environment on the federal front, Ms. Cunningham’s letter this past week urged the Delegation’s “continued voice of consistent and vigorous opposition” to the F2F rule, “independent of the current environment,” while urging a similar spirit of bipartisanship to “safeguard the programs which work to assure access” to home care. This latter point is critical given overtures already being made to significantly limit the Medicare benefit and cap payments to states for their Medicaid programs.
Volume 1, No. 13 December 5, 2016
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, Policy & Programs acardillo@hcanys.org Patrick Conole Vice President, Finance & Management pconole@hcanys.org
“The Medicare F2F rule has taken on a shape all its own, through a faulty implementation process at CMS,” Ms. Cunningham wrote on December 2. “Its current design flaws – namely, the duplicative, confusing, inconsistent and arbitrary administration of F2F – have little to do with its statutory basis in the Affordable Care Act (ACA), and much to do with how it has been implemented and enforced.”
Andrew Koski Vice President, Program, Policy & Services akoski@hcanys.org
HCA has repeatedly engaged Congress on this issue, offering draft legislation to mitigate the F2F requirement and rallying Congressional support for a F2F repeal or fix. Ms. Cunningham’s letter reminds Congress about the core problems with F2F and seeks a renewed effort to make its repeal a priority as Congress regroups for a new session.
Laura Constable Senior Director, Membership & Operations lconstable@hcanys.org
With an incoming Trump administration, and his vows to repeal and replace the Affordable Care Act (ACA), several questions remain as to whether an ACA repeal measure would affect some of the non-insurance provisions of ACA, like F2F, which have been separately implemented by federal authorities in extension of the underlying ACA authorization for CMS to do so.
Mercedes Teague Finance Manager mteague@hcanys.org
Alexandra Fitz Blais Director of Public Policy ablais@hcanys.org
Celisia Street Director of Education cstreet@hcanys.org
Jenny Kerbein Director of Governance & Special Projects jkerbein@hcanys.org
The Republican-led House of Representatives has made ACA’s repeal – as well as fundamental changes to Medicare and Medicaid
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
Teresa Brown Administrative Assistant tbrown@hcanys.org
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The Situation Report: the Home Care Association of New York State – among the signature actions of its proposed agenda. Mr. Trump has selected Rep. Tom Price, a staunch opponent of ACA, to head the U.S. Department of Health and Human Services, adding more thrust to the prospect of an ACA repeal. (See related p. 8 story.) All of these trends – coupled with a new Congress, a new appointee to head CMS, and a comparatively antiregulatory Trump administration – create an evolving political landscape for future action on F2F. Nevertheless, HCA, in its letter to Congress, communicates strongly the fact that repeal of F2F is irrespective of ACA, given past bipartisan support to change the rule based on the fact that CMS’s implementation, independent of ACA, has been viewed as an overreach beyond Congressional intent. Meanwhile, HCA is preparing some reports to further brief a new Congress and Administration on many of our federal priorities for reimbursement support and regulatory changes. We will keep the membership apprised of these efforts over the coming weeks.
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SURVEY from p. 1 As in past years, the results of this survey will be paired with a data analysis, culminating in a written report showing home care’s major financial and regulatory stresses. It will also reinforce your needs for program and investment support. The report will be used to help advance our advocacy agenda as part of the upcoming State Budget negotiations and state legislative session. The survey seeks your answers in four main areas: 1) Basic Financial Information; 2) Payment, Accounts Receivable and Other Finance Issues; 3) Labor Issues; and 4) Participation in New Models of Care. Please answer the questions to the best of your ability and relevance to your organization. The due date for completion of surveys is January 6. The survey can be completed online at the following link: https://www.surveymonkey.com/r/HCAfinancesurvey We expect that this survey process may require input from multiple staff at your agency, namely your executive and finance teams, so we already sent a survey alert to those specific staff levels identified in our HCA member database for your organization. We recommend that you print out a PDF version of the survey first, complete it on paper, and then enter your information in the online link, just in case you experience website connectivity issues in the process of completing your answers. Alternatively, you can simply fax or send a PDF scan/electronic attachment of the completed survey and HCA will enter the data for you. We welcome your responses in whatever format is easiest for you. The PDF version of the survey is available here: http://hca-nys.org/wp-content/ uploads/2016/11/FinancialConditionSurvey2017.pdf. The online survey settings allow you to change your responses at any time, even in the event your website browser closes. Nevertheless, we still recommend that you prepare the survey offline first, using the PDF, and then enter data online if you choose to submit your responses this way. We can’t stress enough how important your input is for our advocacy in 2017. Please be assured that all agency-identifying information will be kept strictly confidential and reported only in the aggregate. If you have any questions or difficulties completing the survey, please contact HCA’s Communications Director Roger Noyes at rnoyes@hcanys.org or (518) 810-0665. We will be sending further reminders over the coming weeks to assure as complete a sample of survey responses from the membership as is possible. Thank you in advance for participating.
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AMENDMENTS from p. 1 Such discussions must be held without delay, given that the additional state Department of Health (DOH) guidance, issued on November 22, requires plans to notify DOH by December 7 about those providers who have not agreed to contract amendments covering the minimum wage funding. That November 22 guidance is at the links below:
Supplemental MLTC Minimum Wage Guidance: http://hca-nys.org/wp-content/ uploads/2016/11/Supplemental-MLTC-MWGuidance-for-Exhibit-11.22.16.pdf Minimum Wage Funding for MLTC Partial Capitation Program FY16-17 NYC Region: http://hca-nys.org/wp-content/uploads/2016/ 11/Minimum-Wage-Funding-Availabe-inAggregate-by-MLTC-Plan_11.22.16.pdf
These should be read in tandem with previous DOHissued guidance on October 28. See http://hca-nys.org/wp-content/uploads/2016/10/ MWGuidelines102816.pdf. HCA has reached out to providers and MLTC plan members about what they are hearing and asks that you continue to relate your experiences to Andrew Koski at akoski@hcanys.org. As reported in last week’s edition of The Situation Report, the November 22 guidance leaves unaddressed significant issues of clarity and protection requested by both providers and plans, including the amount of the $1.33 per hour increase that plans are required to pay their home care contractors. The guidance also fails to state that managed care plan rate reductions offsetting the increase are prohibited. HCA has reached out to Administration officials about the financial discrepancies that providers and plans have been reporting to HCA regarding these rates and we will continue to press for resolution of these issues.
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Last week, HCA met with officials from the state Division of Budget and the Governor’s Office to continue advocacy on these concerns. These officials affirmed in very strong terms the Administration’s intention that these funds fully reach the providers and workers, and asked to be apprised of reported problems or contradiction. Tell us more about your experience through HCA’s financial condition survey On Thursday, HCA circulated our 2016-17 State of the Home Care Industry survey, which we release every year as part of our advocacy planning for 2017. The survey culminates in a report detailing the financial pressures on the home care industry in New York State, and several of the survey questions deal with wage, overtime and hours issues in home care that we need your input on. Please see the related p. 1 story.
State Issues Home Care, Hospice Emergency Preparedness Regulatory Reminder Please read and revisit/update your procedures accordingly Late last week, the state Department of Health issued an emergency preparedness Dear Administrator Letter (DAL) for home care and hospice which appears to be a reaffirmation of existing requirements for emergency preparedness. All CHHAs, LHCSAs, LTHHCPs and hospices should review the DAL (available at http://hcanys.org/wp-content/uploads/2016/12/ DAL_Emergency-Preparedness_120116.pdf) and be sure to address any areas of procedure that require updating or response in your emergency preparedness planning. With the onset of the winter weather season, and other potentials for natural or
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man-made hazards, it is important for home care and hospice programs to revisit the rules and regulations related to: your comprehensive emergency preparedness plans; communications requirements; patient rosters for rapid identification and location of patients at risk during emergencies; evacuation procedures; drills; home care emergency response surveys; and more. It is also especially important that providers maintain an accurate and up-to-date profile of your staff and operations on the Health Commerce System (HCS), as the HCS is a primary communications vehicle during emergencies for the Department to reach providers and obtain critical information for the safety of patients and the security of operations. The DAL also contains an attachment reminding providers of the patient classification levels for purposes of prioritizing access during emergencies, as well as the Transportation Assistance Levels (TALs) which provide a universally recognized scale for the rapid assessment of patients’ transportation assistance needs during a planned evacuation.
Press Reports: Large MLTC Plans to Discontinue Services on Long Island, Westchester HCA reports on other MLTC updates provided by state officials at recent meetings In a letter to the Cuomo Administration, GuildNet, one of the state’s largest MLTC plans, announced that it will no longer enroll new recipients on Long Island and Westchester for MLTC services, citing reimbursement issues, according to news reports. GuildNet’s total enrollment in these counties is 4,602, writes Politico New York (See http:// www.politico.com/states/new-york/albany/ story/2016/11/guildnet-cant-pulling-out-ofsome-counties-because-of-calamitousreimbursement-107541). HCA wanted to inform the membership in the event that your services may be affected by this development. According to the Politico article, EmblemHealth had also previously decided to discontinue MLTC services, and these cases were later assumed by GuildNet. The matter was discussed during a recent Medicaid Managed Care Advisory and Review Panel (MMCARP) call where state Department of Health officials assured callers of a smooth transition for any affected cases.
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Speaking generally about the MLTC program, and not this case specifically, HCA has long been concerned about the inadequacy of premiums paid to MLTCs for necessary patient services and provider operations, and, in turn, the downstream effect on home care providers. As noted in our most recent report on the financial condition of the industry, “63 percent of MLTC plans had negative premium incomes in 2014, up from 57 percent in 2013 and 42 percent in 2012 (a 49 percent increase since 2012). This has a downstream effect on timely payments to providers as the plans cope with underfunded premiums, a condition which HCA has sought to mitigate in proposals seeking a sound actuarial analysis of payment adequacy to plans and contract providers.” HCA recently issued our new financial survey of the industry which is being paired with a data analysis to update our findings on the financial condition of MLTCs and providers alike. Please see our related p. 1 story. Other managed care updates HCA participated at the state Department of Health’s (DOH) December 1 MMCARP meeting
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where the following managed-care-related information was disseminated:
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MLTC enrollment (November) includes: 185,042 for all MLTC plans; 167,590 for partial capitated plans; 6,392 in Medicaid Advantage plans; 5,669 in Programs of All-Inclusive Care for the Elderly (PACE); 4,991 in Fully Integrated Duals Advantage (FIDA) plans; and 400 in FIDA for individuals with intellectual and developmental disabilities (FIDAIDD). The last public meeting of the Nursing Home Transition Diversion/Traumatic Brain Injury (NHTD/TBI) waivers workgroup on the transition to managed care was held on November 16. DOH’s Division of Finance and Rate Setting gave a presentation on rate setting for the transition to managed care. The presentation, full draft of the NHTD/TBI Transition Plan, June 22 webinar, 1915c Waiver Transition Timeline, Common Elements of Public Comments, and NHTD/TBI Waiver Transition Q&As are at: https://www.health.ny.gov/ health_care/medicaid/redesign/mrt90/ tbi-nhtd_waiver_trans_ingo.htm. The next Waiver Transition Stakeholder Phase II meeting will be in late January. For more information, please contact: waivertransition@health.ny.gov. In early 2017, DOH will launch a stakeholder process for planning the future of integrated care in New York after the FIDA demonstration ends in 2019; the process will include evaluating how and whether to consolidate or maintain existing integrated products. Pending final review of the Medicare provider networks, DOH anticipates
rolling out FIDA to Region 2 (Suffolk and Westchester) in 2017. Community First Choice Option and managed care carve-in
New York State is adding Community First Choice Option (CFCO) services to the mainstream Medicaid managed care and MLTC benefit packages effective April 1, 2017.
CFCO services will include those that, until now, have been only available through waivers including: assistive technology; community transitional services; home-delivered/congregate meals; environmental modifications; vehicle modifications; and activities of daily living and instrumental activities of daily living skill acquisition, maintenance, and enhancement.
A CFCO Frequently Asked Questions document was recently posted: https://www.health.ny.gov/ health_care/medicaid/redesign/2016/2016-1019_cfco_faqs.htm.
A 60-day announcement with the April 2017 effective date was issued to plans.
An Administrative Directive Memorandum (ADM) is being reviewed by the Department’s legal counsel before being finalized and shared with local departments of social services.
A supplement to the member handbook and template member letter have been finalized, with discussions still pending for when and how to issue it.
A guidance document for plans is in the final clearance process to provide details on the carvein of CFCO services, including: social transportation; vehicle and environmental modification; and moving assistance.
An implementation webinar is scheduled for January 5, 2017.
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Important Upcoming Deadlines
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Requirement
Effective/ Due Date
Home Care Worker Wage Parity certification forms, covering December 1, 2016 to February 28, 2017, for LHCSAs and other entities that contract with Managed Care Organizations (MCOs), CHHAs and/or LTHHCPs serving New York City, Long Island and Westchester
Dec. 1, 2016
http://www.health.ny.gov/health_care/medicaid/redesign/mrt_61.htm
MLTC plans must submit to state Department of Health a list of providers with whom the plans and providers have not agreed to contract amendments related to the minimum wage funding
Dec. 7, 2016
http://hcaͲnys.org/wpͲcontent/uploads/2016/11/SupplementalͲMLTCͲMWͲ GuidanceͲforͲExhibitͲ11.22.16.pdf
Independent Assessor’s initial recommendations related to its MidͲPoint Assessment of all 25 Performing Provider Systems under DSRIP
Comments due by December 21, 2016
http://www.health.ny.gov/health_care/medicaid/redesign/dsrip/pps_map/ midpoint/index.htm
2015 CHHA/LTHHCP Statistical Report
Dec. 30, 2016
https://commerce.health.state.ny.us/public/hcs_login.html
2015 Hospice Cost and Utilization Report
Dec. 30, 2016
https://commerce.health.state.ny.us/public/hcs_login.html
State and federal compliance program certification forms
Dec. 31, 2016
https://www.omig.ny.gov/compliance/certification
Minimum Wage Increases to: $11 for New York City; $10 for Long Island and Westchester; and $9.70 for rest of the state
Dec. 31, 2016
http://www.labor.ny.gov/legal/laws/pdf/minimumͲwage/19aͲamendedͲ rule.pdf
Healthcare Personnel Influenza Vaccination Report for personnel employed from October 1, 2016 to March 31, 2017
May 1, 2017
http://hcaͲnys.org/wpͲ content/uploads/2016/10/ctrlaccamstmpNotification_21226.pdf
More Information
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Trump Names HHS and CMS Appointments President-elect Donald J. Trump made two key health care announcements for his administration last week, including Republican Georgia Congressman Tom Price as head of the U.S. Department of Health and Human Services (HHS) and health policy consultant Seema Verma as Administrator for the U.S. Centers for Medicare and Medicaid Services (CMS). Rep. Price, a physician and staunch opponent of the Affordable Care Act (ACA), sponsored one of the most detailed ACA repeal-and-replacement measures in Congress. President-elect Trump vowed throughout his campaign to overturn President Obama’s signature health care law, and his appointment of Rep. Price to his top health care cabinet post appears to further reinforce this position. News analysts have suggested that Rep. Price’s experience in Congress, including his key finance and procedural committee posts, would assist in the Trump Administration’s health policy negotiations with the legislative branch. Notably, all cabinet-level officials, except for the White House chief of staff, require Senate confirmation, which means that Price’s nomination will have to go before the Senate for approval. The appointment drew strong criticism from Democrats. One vocal critic was New York Senator Charles Schumer, the incoming Senate Minority Leader, who assailed the HHS pick in remarks widely reported in the media. The House Republican conference – from which Rep. Price hails – has recently floated proposals for a Medicare premium support program, as well as a measure to block-grant the Medicaid program. Both programs fall under the auspices of HHS. These proposals would fundamentally reshape the government programs, moving them away from open-ended entitlements toward effectively capped systems. HHS is a cabinet-level department of the federal government. It has 11 divisions, including the Food and Drug Administration, the U.S. Centers for Disease Control and Prevention, the Office of the Inspector General, CMS, 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. CMS specifically oversees Medicaid funding to states, like New York, as well as state waiver approvals and state plan amendments. Its transmittals and rulemaking capacities, meanwhile, dictate many regulations and reimbursement systems affecting the home care sector, from the Medicare face-to-face rule to the Home Health Prospective Payment System (HHPPS), which establishes home health payment levels under Medicare. It also oversees the Medicare administrative contractors responsible for reviewing and processing claims. Mr. Trump’s pick to head CMS, Seema Verma, is currently the President, CEO and founder of SVC, Inc., a national health policy consulting company, according to a press release on the Trump transition team website. 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 be working through our Government Affairs team at Envision Strategy, and its Managing Director Brett Heimov, to advance home care’s priorities with federal regulators at CMS and HHS as the new appointments take hold.
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DOH Actively Working to Make LTHHCP EPS Billing a Go State Department of Health (DOH) officials have informed HCA that program and technical staff are working to institute the Episodic Payment System (EPS) and rates for LTHHCP providers. DOH indicated that it needs to address technical aspects of the billing system to properly accommodate LTHHCPs. DOH further indicates that staff are meeting next week on a resolution and will update HCA accordingly. HCA has been urging DOH to finalize the billing system for LTHHCPs following the Department’s new procedural and policy clarification in August recognizing the LTHHCP’s capability for direct patient admission, services and management under LTHHCP state and federal home health agency standing. HCA has provided extensive communication to LTHHCP providers and other stakeholders on this important policy affirmation, as well as on additional roles and opportunities for LTHHCP as outlined in the DOH policy document. HCA’s original alert and DOH document about this development are posted as a PDF to our website here: http://hca-nys.org/wp-content/uploads/2016/12/DOH-Offers-Vital-Clarity-on-LTHHCPProviders.pdf. Subsequent communications by HCA have covered the developments for establishing EPS reimbursement under the LTHHCP. (Managed care reimbursement for the LTHHCP would continue to be based on LTHHCP-plan negotiations). HCA has been communicating the urgency for resolution of this billing issue for LTHHCPs and their partners. We will continue to press for finalization of the rate and billing mechanisms. For further information, contact Al Cardillo at acardillo@hcanys.org.
It’s HCA Membership Renewal Time Be on the lookout for renewal invoices mailed to you last week HCA has begun our process of sending membership renewal packets so you can continue your HCA membership in 2017. By now your organization should have received the mailing. If not, please contact HCA’s Director of Membership Laura Constable at lconstable@hcanys.org. Our renewal process is a bit different this year. The packet includes a dues invoice with a highlighted amount reflective of your past patient revenue and dues which we invite you to select for your 2017 commitment. If your patient revenue has changed, however, simply choose the other options available on the printed invoice. Also, to help you manage, plan and budget for HCA education, our invoice invites you to pre-pay a designated amount for your staff to participate in signature events like HCA’s Senior and Financial Manager’s Retreat, Annual Conference, Compliance Symposium, webinars, bootcamps, workshops and more. Your staff benefits from these programs; and your commitment now will give them the flexibility
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to register whenever events or conferences are announced. You can change the amount designated for HCA education, and your staff are certainly encouraged to attend as many educational programs as necessary, beyond this initial commitment. We hope you find this option useful in your education budgeting. The packet also includes a piece called “HCA in 2017” describing some of the many ways in which HCA provides value to you and your organization. We welcome you to read this brief publication and share it with any decision-makers at your organization who may be involved in budgeting or processing your organization’s membership. You can read the piece here: http://hca-nys.org/wp-content/uploads/2016/12/HCA-ValueStatement-2017.pdf. Have you contributed to HCA’s PAC? Now is also a good time to make a contribution to HCA’s Political Action Committee (PAC), which we invite you to do in conjunction with your member dues invoice. Your PAC contributions help HCA engage in the political process to support candidates who oppose home care cuts and advance policies to assist home care’s function in a changing health care environment. Instructions are listed on the dues invoice. For-profit entities may contribute directly to the PAC. Please note, however, that not-for-profit organizations may not directly contribute, but employees of these organizations certainly can. We look forward to being your advocate, your source of information and technical assistance, and your go-to place for education and resources on all home and community-based matters affecting providers throughout New York State in 2017.
Workforce Investment Opportunities, Data Insights at December 15 Value Based Payment Conference HCA is excited to present two top-rate sessions offering an advance preview of workforce investment opportunities and an interactive data-analysis workshop to get you ready for Value Based Payments (VBP). These and other sessions await you next week at HCA’s can’t-miss program on Tools, Resources and Knowledge for VBP Readiness and Success (December 15 in Tarrytown). This one-day, highly focused conference examines issues specific to VBP, but it also provides tangible insights and information that are useful for any of the current payment models. Sessions include: observations from a panel of managed care payors; an exclusive look at workforce investment opportunity areas; and major data-development guidance demanding your attention for all areas of negotiated or riskbased payment in home care. The state Department of Health (DOH) is poised to grant $250 million in new funding for home care workforce training to meet the needs of a frail, elderly and disabled population. Home care agencies can benefit from an early tip on what’s to come. On December 15, you’ll get this chance, by hearing from the state’s point person on the outline of this workforce training program, including how home care agencies can access the funding, as this initiative could be key to preparing your workforce for the VBP transition ... and more. Internal data assessment, meanwhile, is one of the most powerful and proactive steps a home care agency can take on the eve of VBP implementation in the Medicaid and Medicare marketplaces. Our December 15 program will give you a deep dive into your clinical data through an established and proven process using
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powerful tools, including: benchmarking, percentages and rates, graphs and charts, check-sheets, stratification and trending. These are just a few of the segments during our December 15 program to prepare you for VBP. Don’t miss this final signature HCA program of 2016, as the state Medicaid and federal Medicare marketplaces move swiftly toward these new models of risk and value based payment. Online registration is at https:// www.eventville.com/Catalog/EventRegistration1.asp?EventId=1012048 and a brochure is at http://hcanys.org/wp-content/uploads/2016/11/VBP-Readiness-and-Success-Brochure-Dec-15-2016.pdf. Be sure to reserve your seat today!
Cuomo Vetoes Essential Personnel Bill, Signs Advanced Aides and Other Measures As announced in an alert last week, Governor Cuomo issued over 70 vetoes in a recent spree of legislative actions – among them his veto of home care and hospice “essential-personnel” legislation, repeating an action the Governor has taken the past two years despite the bill’s unanimous support each year in the Legislature, as well as the vigorous efforts by bill sponsors, HCA, and partners to clarify misconceptions about the bill’s intent. The Governor also signed a series of other bills which were closely watched and shaped by HCA. This includes legislation authorizing an “advanced home health aide” designation allowing for flexibility in the assignment of aide tasks (Chapter 471; A.10707/S.8110), and an offsite services bill (Chapter 450; A.7714C/S.8081), which permits “house-calls” to patients in their homes by hospital and clinic physicians and other primary care practitioners in these settings. This latter bill, in particular, included HCA amendments to avoid jurisdictional entanglements in Article 36, the domain of home care. Further details The HCA-developed “essential-personnel” bill (S.6692B/A.9381B), which Governor Cuomo vetoed on November 28, was unanimously passed by the Legislature in recent sessions. HCA worked closely with legislative sponsors, partners and providers to engage the Governor’s office on the merits of this measure, which would extend essential-personnel status to home care and hospice staff so they can reach patients during declared emergencies when curfews or travel restrictions are in effect. Most recently, we alerted members to write the Governor on the bill, using our Legislative Action Center, to make clear that this legislation, contrary to past misreading by advisers to the Governor, provides for access “solely according to procedures, plans and designs adopted by each locality’s emergency management plan and officials.” As such, “the bill abides and does not override these local roles, nor does it impose any mandate or new role for local governments,” we explained. Governor Cuomo has made emergency preparedness and response a tenet of his administration’s public policy goals. Given this imperative, HCA will work with the Governor’s office and legislative sponsors to pursue a course that appropriately supports the work of home care and hospice in emergency response and planning. This includes efforts from the local district level on upward, as we continue engaging regional health department emergency managers, health emergency preparedness coalitions, and a range of stakeholders in meetings being conducted by HCA throughout the state on emergency preparedness needs and coordination efforts. HCA and partners have been holding these focus sessions progressively across regions of the state, covering 34 counties since April, as part of a broad strategy for home care and hospice emergency preparedness. The AHHA bill, meanwhile, will also be an ongoing focus of development and shaping as the measure heads into the implementation phases, following the Governor’s approval. This bill has long been supported by the
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Governor but was laid aside in previous sessions of the Legislature, until this year, given concerns about a range of issues, several of which will continue to be advocated by HCA during a workgroup process incorporated as part of the final bill. HCA has, in the past, led proposals to permit flexibility in the allowed tasks for home health aides, ensuring that this flexibility is consistent with existing nurse discretion to educate, train and assign family members in a patient’s care. However, this current bill for AHHA requires additional work, and HCA will pursue an implementation pathway that seeks funding for training, compensation and oversight of AHHAs, as well as the reconciliation of excessive layers in the bill for new requirements and regulations. We will also address the bill’s lack of: fair liability protections for nurses and agencies utilizing AHHAs in good faith; alignment between managed care plan procedures and the bill’s AHHA procedures for nurses, agencies and aides; clear provisions for approved home health aide training programs to seamlessly qualify for AHHA training, upon provider application and state approval; and other concerns. Importantly, the hospital/clinic offsite services bill was amended as result of HCA’s close work with the Healthcare Association of New York State (HANYS) to: specifically target its focus to primary care; exclude from offsite service authority any direct hospital or clinic crossover into home care and home care agency services defined in Article 36 (necessitating use of a home care agency for such services); and provide that implementing guidance and/or regulations be developed in concert with home care agencies and the association.
Make 2017 Your ‘Extreme Makeover’ Year with Design Tips at the 15th Annual Northeast Home Health Leadership Summit The Northeast Home Health Leadership Summit is the premier gathering and once-a-year opportunity for home care agency executives from New England, New York and New Jersey to come together. Register today for this unique venue to network with peers from around the Northeast and hear about the landscape of issues affecting services in the region. You’ll learn the trends affecting providers in nearby states (including broader ideas that will help you in your organizational planning), while you participate in exceptional workshops, panel sessions and expert presenter focus topics, including the following preconference sessions:
Foundational Work: The Federal Focus to Reform Post-Acute Care Delivery (Erin Smith, JD, Executive Director, Post-Acute Care Center for Research)
Using Your Assets in Care Redesign: Key Elements in Building Successful Bundling Relationships (Cindy Krafft, PT, MS, HCS-O, Kornetti & Krafft Health Care Solutions)
Transitioning from Volume to Value to Meet Population Health Goals (Bethany Gilboard, CEO, Innovative Health Alliance of New York and Alliance for Better Healthcare)
View the complete Summit agenda at http://www.nehomehealthsummit.com/wp-content/uploads/2016/11/ NELS-2017-Conference-Brochure.pdf. Please also be sure to take advantage of the early-bird registration discount through December 16. Visit the Summit Website: http://nehomehealthsummit.com.
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The Situation Report: the Home Care Association of New York State
Volume 1, No. 13 December 5, 2016
DSRIP Mid-Point Assessments Reports Released for all PPSs The state Department of Health (DOH) announced this week that the Independent Assessor (IA) for New York’s Delivery System Reform Incentive Payment (DSRIP) program has completed its Mid-Point Assessment of each Performing Provider System (PPS) in the state. Each assessment has an accompanying report that can be viewed, in conjunction with a “companion document” the IA developed, on the DSRIP website linked below. DOH announced it is pleased with the findings, and that based on this information, each PPS is on track for successful project implementation. Many sectors in the health care community have been, and remain, highly concerned and critical of DSRIP’s implementation and status. Each Mid-Point Assessment Report (one per PPS) also includes results from the 360 survey responses of network partners, information on partner engagement for Domain 2 and 3 projects, and narratives from the PPSs regarding their projects and organization. The IA companion document explains the methodology used for the assessment, and a summary of results across PPSs. There is a comment period now open to PPSs and the public through December 21, 2016 seeking feedback on the initial recommendations from the IA based on the Mid-Point Assessments. HCA encourages members to submit comments. Alternatively, or in addition, members are welcome to send comments to HCA’s Policy Team, as we plan to submit a document in response to the IA’s initial recommendations and highlighting the industry’s experiences with DSRIP to date. Comments can be to dsrip_midpoint@pcgus.com. Please copy HCA’s Alex Blais at ablais@hcanys.org. Once comments have been received, the IA will review and make any necessary adjustments to its initial recommendations. Final recommendations will be released by January 3, 2017 and will include all comments that were received. This will mark the beginning of a second comment period which is open to the public until January 23, 2017, at which point the recommendations will be presented to the DSRIP Project Approval and Oversight Panel (PAOP). For more information about the Mid-Point Assessment timeline, visit http://www.health.ny.gov/health_care/medicaid/redesign/dsrip/mid-pt_assessment/201606-21_timeline-and-updates.htm. All Mid-Point Assessment reports and recommendations can be found here: http://www.health.ny.gov/ health_care/medicaid/redesign/dsrip/pps_map/midpoint/index.htm.
Value Based Payment Update The Value Based Payment (VBP) steering committee met on November 29 to review clinical subcommittee recommendations on quality measures and pay for reporting. HCA is a steering committee member. The committee specifically focused on recommended measures for multiple areas of behavioral health, including substance abuse, mental illness and trauma. Considerable time was spent discussing and providing feedback on measures recommended as “mandatory,” versus measures recommended for “reporting only.” The key issues involve the selection and use of measures of most evidentiary significance in quality and performance, and the balancing of provider capability in meeting various measures, versus overload. In addition, discussions are currently revolving around the selection and use of already validated measures, versus measures in new areas of possible significance but of as-yet-
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undetermined validity. This latter “class” of measures is being recommended as, at least initially, more appropriate for “information reporting only,” instead of mandatory performance benchmarks upon VBP onset. The state is seeking feedback on the measures and arrangements it presented (see http://hca-nys.org/wpcontent/uploads/2016/12/11292016VBPWGPresentationFinal.pdf), and has invited any further comment by December 13 at amandaghezzi@kpmg.com. The state VBP project team also provided updates on various VBP clinical categories (summarized in the slide deck), including: maternity, HIV/AIDS, chronic heart disease, pulmonary conditions, diabetes, behavioral health, managed long term care (MLTC), and intellectual/developmental disabilities. Further information on all of these is posted to the Department of Health (DOH) VBP website at: http:// www.health.ny.gov/health_care/medicaid/redesign/dsrip/vbp_library/vbp_final_cag_reports.htm. Further discussion of the committee is planned for January 17 and is anticipated to include more definitive detail on the status of VBP within MLTC. DOH-State Association VBP Implementation Discussion – December 16 DOH announced at the meeting its intent to convene a meeting on December 16 with provider associations representing all sectors to discuss ways in which DOH might further assist providers with VBP implementation. Examples offered included: development of a model VBP contact for providers and plans, citation of literature describing successful interventions, experts and speakers to serve as resources, connections to resources and providers in other states, access to the state’s project team, and others. HCA will be participating in this session and will be offering recommendations on behalf of the home care community. HCA provider and MLTC members are encouraged to offer your advanced input for this meeting directly to HCA at either acardillo@hcanys.org or ablais@hcanys.org. Attend HCA’s Symposium on VBP – December 15 HCA’s December 15 symposium on VBP in Tarrytown NY will provide critical information and guidance to assist with VBP understanding, strategic planning and implementation. Don’t miss this significant opportunity to further gear up for this major change in health care services delivery and payment. For registration and further conference background, see related p. 10 story. For further information on VBP, please contact acardillo@hcanys.org.
DOH Publishes Updated Hospice Medicaid Rates The state Department of Health’s (DOH) Bureau of Residential Health Care this week published updated Hospice Medicaid rates for December 1, 2016 through September 30, 2017, and the rates have been forwarded to the Division of Program Operation and Systems (and eMedNY) for payment. The rates, designated by the Standard Metropolitan Statistical Area (SMSA), have been posted to the Department’s public website at: http://www.health.ny.gov/facilities/long_term_care/reimbursement/hospice/. DOH notes that there was a change to the Medicaid Routine Home Care (RHC) rates. This latest update incorporates two rates that result in a higher base payment for the first 60 days of hospice care and a
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reduced base payment for days of hospice service thereafter. It also establishes a service intensity add-on (SIA) payment (Rate code 3991) to the RHC rates for services provided by a registered nurse or social worker during the last seven days of a beneficiary’s life. For hospices that have filed their Certification for Recruitment, Training and Retention (RT&R), the published rates include a 3 percent add-on payment authorized by Section 4013 of the Public Health Law (PHL) and a payment of $9.92 per day as the allocable portion of the payments authorized by Section 3614.9 of the PHL. These funds are solely for the purposes of improving recruitment, training and retention of non-supervisory personnel with direct patient care responsibility, and hospices are prohibited from using such funds for any other purposes. HCA appreciates the Department including the new hospice rate methodology change, as we have made numerous inquiries throughout 2016 as to when DOH would make this change to include the two new RHC rates as well as the new SIA adjustment. For specific questions about the rates, HCA hospice providers can contact DOH’s Russ Smith at (518) 473-4421. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Encouraging Home Care Participation in National Influenza Vaccination Week The Home Health Quality Improvement Campaign (HHQI) has reached out to its state quality coordinators (HCA’s Executive Vice President Al Cardillo serves in this role for New York) to help encourage home health participation in National Influenza Vaccination Week 2016 (#NIVW16), which begins Sunday, December 4. HHQI stresses the potential devastating impact of influenza on the home health population. In support of provider and state association efforts to ensure patients and staff are protected, HHQI offers the following free resources:
The evidence-based Immunization & Infection Prevention BPIP includes an extensive list of immunization resources. All resources are free for registered HHQI participants. Registration is fast and free.
Free access to custom data reports (http://www.homehealthquality.org/Data/Overview.aspx) created especially for home health agencies each month. HHQI uses the OASIS data that home health agencies transmit to the U.S. Centers for Medicare and Medicaid Services (CMS) to generate custom data reports on high-priority topics such as Influenza Immunizations (http:// www.homehealthquality.org/Data-Resources/Influenza-Report-sample.aspx).
A 1-hour webinar on Influenza and the Cardiovascular Population is at http:// www.homehealthquality.org/Cardiovascular-Health/CardioLAN/Webinars/2014-15#012015.
The annual vaccination awareness campaign has been created by the U.S. Centers for Disease Control and Prevention (CDC), which offers additional free resources to promote the importance of influenza immunization:
Buttons, Banners & Badges (http://www.cdc.gov/flu/freeresources/buttons_badges.htm) Continued on next page
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Volume 1, No. 13 December 5, 2016
Continued from previous page
Free Print Resources for older adults (https://www.cdc.gov/flu/freeresources/printseniors.htm#Vaccination)
Weekly U.S. Influenza Surveillance Report (https://www.cdc.gov/flu/weekly/index.htm#ILIMap)
2016-17 Influenza Season Information (https://www.cdc.gov/flu/about/season/current.htm)
HHQI’s homepage can be accessed at http://www.homehealthquality.org/Home.aspx In addition to the public health and quality benefits directly to patients and staff, immunizations are a key performance metric under managed care and other state and federal health reform initiatives aimed at improving population health and reducing costs. Active home care immunization programming may match well and provide engagement interest with potential partners seeking effective performance under these metrics and reform models. HCA would be interested in provider efforts and experiences in this regard, including obstacles you may encounter. HCA is working on legislation for state support facilitating home care’s role in public health interventions and potential partnerships. For further information, please contact HHQI at the above link, or for HCA, contact acardillo@hcanys.org.
FIDA Webinar Scheduled The state Department of Health (DOH) and the U.S. Centers for Medicare and Medicaid Services (CMS) will be hosting a Fully Integrated Duals Advantage (FIDA) program webinar on December 7, 2016 from 3 to 4 p.m. It will include Fidelis Care FIDA Medical Director Dr. Jermel Hawkins and Community Physician Dr. Mohammad Sheikhai. The webinar includes the following agenda:
DOH and CMS Overview of the FIDA Program.
Conversation between Fidelis Care FIDA Medical Director Dr. Jermel Hawkins and Community Physician Dr. Mohammad Sheikhai about their experience participating in FIDA.
Questions and Answers.
Attendees should call into the webinar and click the link to join online: 1. Go to https://meetings.cms.gov/orion/joinmeeting.do?MTID=3ce95cc45edfd20325e6716c014cc5a8 2. Call the following number: 1-877-267-1577 3. Enter the following meeting number on your telephone key pad: 998 543 183. Questions can be sent to fida@health.ny.gov.
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OMIG Posts Compliance Forms & Publishes Compliance Program Review Guidance The state Office of the Medicaid Inspector General (OMIG) has posted the State Social Services Compliance Certification and the Federal Deficit Reduction Act (DRA) of 2005 Certification forms. Both forms are at https://www.omig.ny.gov/compliance. Each form must be completed and submitted online by the end of December. OMIG has recommended in past years that they be filed in mid-December to avoid any delays. OMIG advises providers that the 2016 state form includes some changes to the 2015 form. Home care and other health care providers must complete the State Social Services Compliance Certification to certify that a compliance program is in place and meets the state’s requirements, including eight elements outlined at https://www.omig.ny.gov/images/stories/provider_compliance/ssl_faqs.pdf. In response to providers’ requests, OMIG revised the Mandatory Compliance Program Certification to allow providers to certify multiple Federal Employer Identification numbers (FEINs) or Social Security numbers (SSNs) on one certification form, if five conditions are met. The updated directions on the form outline the five conditions that must be in place in order to certify multiple FEINs/SSNs on a single form. Providers still have the option of completing separate certification forms for each FEIN/SSN, if they prefer. DRA Certification In addition, the DRA applies to health care entities receiving or making $5 million or more in Medicaid payments during a federal fiscal year. The law requires that they establish written policies and procedures informing their employees, contractors and agents about federal and state false claim acts and whistleblower protections. Further, they must certify that they are in compliance with this federal law. More information on the DRA certification can be found at https://www.omig.ny.gov/images/stories/provider_compliance/dra_faqs.pdf. Additionally, OMIG has posted on its website a webinar on completing both state and federal certification forms. The webinar is at: https://www.omig.ny.gov/resources/webinars. OMIG Publishes Compliance Program Review Guidance OMIG also recently published its Compliance Program Review Guidance. The Guidance is available at: https://www.omig.ny.gov/images/stories/compliance/compliance_program_review_guidance.pdf. The Guidance describes what OMIG looks for when it conducts compliance program reviews of providers that are subject to the mandatory compliance program requirements established in New York State Social Services Law and Title 18 of the New York Codes of Rules and Regulations at Section 521.3(c). Providers subject to the mandatory compliance program obligation of those sections can refer to the Guidance to identify the types of questions OMIG will ask when it conducts compliance program reviews. Anyone with questions on the December 2016 certification forms or the Compliance Program Review Guidance can contact OMIG’s Bureau of Compliance at (518) 408-0401. or by using the Bureau of Compliance’s dedicated e-mail address compliance@omig.ny.gov.
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OIG Releases Semi-Annual Report The U.S. Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) has released its Semi-Annual Report (April 1 to September 30) to Congress which summarizes its activities for the six-month period that ended September 30, 2016. It is at: https://oig.hhs.gov/reports-and-publications/archives/semiannual/2016/sar-fall-2016.pdf. For fiscal year 2016, OIG reported expected recoveries of approximately $5.66 billion, consisting of nearly $1.2 billion in audit receivables, and over $4.46 billion in investigative receivables. The investigative receivables include about $953 million in non-HHS investigative receivables, resulting from OIG’s work in areas such as the states’ shares of Medicaid restitution. The report discusses the OIG publications, legal and investigative activities related to Medicare and Medicaid, and testimony for this period. One report which home care providers should take note of is a Medicare Compliance Review of a Medicarecertified agency in another state for 2011 and 2012, which can be downloaded at: https://oig.hhs.gov/oas/ reports/region1/11300518.asp. In the report, OIG states that the agency did not comply with Medicare billing requirements for 105 of the 497 home health claims it reviewed. As a result, the agency received net overpayments of $314,000 for calendar years 2011 and 2012. Specifically, the agency incorrectly billed Medicare because beneficiaries were not homebound, beneficiaries did not require skilled services, documentation from the certifying physicians was missing or insufficient to support the services, or, in one instance, a claim contained an incorrect payment code. These errors occurred primarily because the agency did not have adequate controls to prevent the incorrect billing of Medicare claims within selected risk areas, OIG says. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Upgrades Made to UAS The recent UAS-NY Online application upgrade to v.1.2.59 made some enhancements to the software on November 30, 2016. These include:
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An additional six new Environmental Financial “trade-off questions” have been added to the Community Assessment to comply with Community First Choice Option (CFCO) requirements; these are required items.
“Residential Living Status at time of Assessment” has been added to the Check Missing and Sign/ Finalize process for Pediatric assessments to be in compliance with CFCO regulations.
The word “Nurse” was removed from the assessment signature summary display. This change was made because the UAS-NY is now home to a number of assessment and screening instruments associated with other state agencies. The regulations associated with the conducting of their assessments and screens are different than those that apply to assessments associated with long-
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term care. The UAS-NY Community Assessment and Pediatric assessments must be conducted by an RN as regulated by the New York State Nurse Practice Act.
The ICD-10 look-up table has been updated to include the new codes.
Offline Users In addition to the Online Upgrades related to release v.1.2.59, the state Department of Health will also be releasing v.1.2.59 of the Offline Client. This is a required upgrade for all Offline Client users. Complete instructions for upgrading the UAS-NY Offline Application are available in the UAS-NY Training Environment Reference and Resources 8500 Online and Offline Application. Questions can be directed to the UAS-NY Support Desk at uasny@health.ny.gov or (518) 408-1021.
Emergency Rule Issued for Occupational Therapists and Occupational Therapist Assistants The state Education Department (SED) has issued an emergency rule that amends the education requirements for occupational therapists and occupational therapist assistants. The rule is at http://docs.dos.ny.gov/info/register/2016/nov30/pdf/rulemaking.pdf (page two) and http:// www.counsel.nysed.gov/common/counsel/files/rulesandregs/76.1%2076.7%20%20TERMS.pdf. The rule is necessary to implement Chapter 124 of the Laws of 2016, which took effect on November 18, 2016. This law provides SED with the flexibility to issue licenses to applicants who have completed an education that exceeds the current requirements for licensure as either an occupational therapist or occupational therapy assistant, as long as they meet the other licensure requirements for these two professions. Under the emergency rule, to meet the professional education requirement for licensure as an occupational therapist, the applicant must present evidence of: 1) at least a bachelor’s or master’s degree in occupational therapy from a program registered by SED or accredited by a national accreditation agency which is satisfactory to SED, or its equivalent, as determined by SED; or 2) completion of a program satisfactory to SED of not less than four years of postsecondary study which includes the professional study of occupational therapy and which culminates in the degree or diploma accepted by the civil authorities of the country in which the studies were completed as preparation in occupational therapy in that country. To meet the professional education requirement for licensure as an occupational therapy assistant, an applicant must complete at least a two-year associate degree program for occupational therapy assistants registered by SED or accredited by a national accreditation agency which is satisfactory to SED, or its equivalent, as determined by SED.
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NGS Updates National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), has recently posted the following information to its website.
New YouTube ABN Video – NGS has recently released a new YouTube video entitled “What is an Advance Beneficiary Notice (ABN) of Non-Coverage?” The two-minute video is an overview of what an ABN is and where to find the most current form. It can be accessed at: https:// www.youtube.com/watch?v=IvWrB0a7URU.
Determining Provider Enrollment Revalidation Due Date – NGS reminds providers that to avoid a hold on your Medicare payments and a possible deactivation or lapse in your Medicare billing privileges, it’s important to know your revalidate due date. This can be done by either signing into the Internet Based Provider Enrollment, Chain and Ownership System (PECOS) at https://pecos.cms.hhs.gov/pecos/login.do#headingLv1, or by using the Medicare Revalidation List Search Tool at https://data.cms.gov/revalidation and entering your provider name or National Provider Identifier (NPI) number. Generally, the due date will remain with the provider throughout subsequent revalidation cycles, so providers should not have to wonder about the due date for the next revalidation period.
For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
Resources
“Documentation Requirements for the Hospice Physician Certification/Recertification,” by the U.S. Centers for Medicare and Medicaid Services http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/ MLNMattersArticles/Downloads/SE1628.pdf
“Sample Hospice Notice of Election Statement,” by the U.S. Centers for Medicare and Medicaid Services http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/ MLNMattersArticles/Downloads/SE1631.pdf
“Key Medicaid Questions Post-Election,” by the Kaiser Commission on Medicaid and the Uninsured http://files.kff.org/attachment/Fact-Sheet-Key-Medicaid-Questions-Post-Election
For further information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
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