AHCA
MINIMUM WAGE
NOMINATE
DSRIP
Congressional Republicans, divided between conservative and moderate camps, decline vote on bill to repeal-replace Obamacare.
HCA meets with state officials and stakeholders on minimum wage implementation issues.
There’s still time to nominate a colleague for the Ruth F. Wilson award (and other categories) to be presented at May 3-5 HCA Annual Conference.
PPS Action Plans head into comment period this week. Members encouraged to weigh in.
PAGE 3
PAGE 5
PAGE 9
PAGE 11
COMING UP “Unpack the Home Health CoPs” April 5, 2017 Albany Marriott 189 Wolf Road, Albany, NY Senior Financial Managers Forum (NEW DATE) April 7, 2017 Renaissance Albany Hotel 144 State Street, Albany, NY Blueprint for OASIS Accuracy OASIS C-2 April 19-20 Workshop April 21 COS-C Exam Doubletree by Hilton 100 Nott Terrace Schenectady, NY Registration for these programs and other events are at http:// hca-nys.org/eventseducation/upcomingevents.
Your Source for HOME CARE News, Policy and Advocacy
Vol. 2, Issue 13 | March 27, 2017
HCA Engages Members on Grassroots Advocacy as April 1 State Budget Deadline Nears Federal health care actions add unusual new political dynamic to this year’s state-level negotiations A new state budget is due by week’s end. HCA and our government affairs representatives, at Hinman Straub, have been in continual contact with key legislative offices as negotiations continue to take shape. Last week, HCA sent an action alert to members urging your advocacy in support of the home care provisions in the one-house budget bills. These bills, crafted by the Senate and See BUDGET p. 2
Rep. Faso Urges CoP Delay in Letter to CMS Chief Verma Responding to HCA’s direct advocacy, Congressman John Faso (R-Kinderhook) has written to the newly confirmed Administrator of the U.S. Centers for Medicare and Medicaid Services (CMS) calling for a six-month delay in CMS’s See DELAY p. 7
INSIDE HCA Engages Members on Advocacy as April 1 State Budget Deadline Nears.........1 Rep. Faso Urges CoP Delay in Letter to CMS Chief Verma........................................1 Rediscover, Reimagine, Reinvent at HCA’s Annual Conference in Saratoga...........1 House Suspends Vote on Health Care Law Proposing Major Cuts to Medicaid.......3 MLTC Update: Service Area Changes....................................................................4 HCA Attends Stakeholder Meeting on Minimum Wage Implementation...............5 Member Hiring Announcement......................................................................6 Nominate a Home Care Leader for the Ruth F. Wilson Award.................................9
Rediscover, Reimagine, Reinvent at HCA’s May 3 to 5 Annual Conference in Saratoga Please join HCA on May 3 to 5 to “Rediscover, Reimagine, Reinvent Home Care” during our Annual Conference in Saratoga Springs. A brochure is now available, including a registration form, See CONFERENCE p. 8
Answer Important HCA Technology Survey for Advocacy on Your Behalf.......10 HCA Data Webpage Now Includes 2015 Medicare Hospice Data................10 DSRIP Update...........................................................................................11 Star Rating Preview Reports Available......................................................12 HCA’s Roger Noyes Writes Book About Early Red Cross Nursing Leader.........13 Delays Announced in Medicare Payment Models......................................14 NGS Creates Home Health Certification Job Aid.........................................15 HHQI Resources Reflect QAPI Requirements of New CoPs .........................16 Resources.........................................................................................................16
The Situation Report: the Home Care Association of New York State BUDGET from p. 1 Assembly, are now undergoing reconciliation with the Governor’s budget plan. We urge you to visit our Legislative Action Center to continue sending these pre-written, but customizable, messages. Simply click http://p2a.co/4lApjWv, enter your contact information, and click “send” to reach your elected representatives in Albany about home care’s priorities in the budget. As previously reported, both the Senate and Assembly budget bills offer critical payment rate adequacy language, including language presented by HCA. This language would ensure that vital home care and MLTC personnel costs (including wage funding for the home care workforce) and service costs are truly covered in the premiums and rates for Medicaid coverage. The bills also move to augment the Governor’s proposed investment program for all health sectors. “We support this investment, along with efforts to dedicate 25 percent earmarked exclusively for community-care providers,” states HCA’s advocacy action message. “This allocation of 25 percent dedicated for community care is consistent with the state’s efforts to reduce hospital use by 25 percent. These efforts rely on community care providers who need adequate investment to achieve state goals.” HCA’s advocacy message also urges the rejection of cuts to MLTC plans and opposes the Governor’s proposed ban on MLTC marketing, “which runs counter to the state’s multiyear policy design of promoting MLTC enrollment,” our advocacy message says. “Rate adequacy and MLTC support are critical for the stability of the entire home and community-based system.” Please continue sending this message and otherwise reaching out to your Senate and Assembly representatives for home care support. Unusual federal dynamic As always during this point in the process, negotiations remain fluid. But what’s unusual is the fact that much of the political uncertainty emanated from Washington – specifically related to decisions about the health care proposal debated in the U.S. House of Representatives. That bill was eventually suspended. Governor Cuomo and Republican Members of the New York House Congressional Delegation traded barbs last week over proposed amendments in the federal health care bill, championed by Upstate 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
2
Volume 2, No. 13 March 27, 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 V ice President acardillo@hcanys.org Patrick Conole Vice President, Finance & Management pconole@hcanys.org Andrew Koski Vice President, Program, Policy & Services akoski@hcanys.org Alexandra Fitz Blais Director of Public Policy ablais@hcanys.org Laura Constable Senior Director, Membership & Operations lconstable@hcanys.org Celisia Street Director of Education cstreet@hcanys.org Mercedes Teague Finance Manager mteague@hcanys.org Jenny Kerbein Director of Governance & Special Projects jkerbein@hcanys.org Billi Wilson Manager, Meetings & Events bwilson@hcanys.org Teresa Brown Administrative Assistant tbrown@hcanys.org
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
House Representatives in New York, that would end the county cost obligation for its share of Medicaid in New York State only (and just for Upstate Counties and Long Island). Governor Cuomo assailed the unusual New York-state specific amendments in the federal bill, saying the proposal would cost the state’s Medicaid program $2.3 billion annually, at a time when the federal health care bill was already otherwise proposing to cut federal Medicaid support to states by means of a capped block-grant program. The Governor said the amendments would result in an unprecedented tax increase in New York State, along with health care providers shouldering the burden. The proponents argue that no other state imposes local Medicaid liability as does New York and that the state should fund the Medicaid services it requires under its program. The amendment called for the change to go into effect in 2020, so it is too early to tell the specific impact of such a proposal on home care or other sectors, and the provision was suspended along with the rest of the health care bill after the House leadership did not garner enough support for it to go forward. (See related story, this page.) For more information, please contact a member of HCA’s Policy staff.
House Suspends Vote on Health Care Law Proposing Major Cuts to Medicaid Republican leaders of the U.S. House of Representatives pulled and set-aside the American Health Care Act (AHCA) – the House’s plan to repeal and replace the Affordable Care Act (ACA), also known as Obamacare – after a major political push late last week did not yield enough support for the bill to go forward to a vote. The vote was originally scheduled for Thursday (the seventh anniversary of Obamacare). Then it was delayed until Friday … and then suspended altogether, largely because the delicate balance of negotiations confronted divisions among more conservative Republicans, who sought a faster track on the proposed ACA changes, and moderate Republicans concerned that the bill would deny coverage to constituents. In a late bargaining move on Friday, the Trump Administration tried to persuade members of the House Freedom Caucus by offering to strip away some of ACA’s essential health benefit clauses that require insurers to cover certain types of services. This change further stiffened opposition from the moderate wing of Republicans. House Democrats, meanwhile, were near universally against the bill. Throughout last week, HCA enlisted the support of HCA members on a grassroots push to communicate opposition to the bill, following outreach by HCA President Joanne Cunningham the week prior, who alerted Members of New York’s Congressional Delegation about the bill’s risks for home care. Among our main concerns was the fact that the House bill included per-capita caps on Medicaid funding to states, like New York. Also known as “block grants,” this change was expected to substantially reduce the federal-share of state Medicaid funding, creating state budget gaps that the Governor and Legislature would need to manage by limiting benefits (a possible major impact on home care volume and/or changes in coverage for some employees), imposing provider funding reductions, or pursuing alternative revenue sources for the Medicaid program. Continued on next page
3
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
“In doing so, this bill would shift $4.5 billion in Medicaid costs to state and county governments in New York, creating a fiscal crisis that will result in: higher taxes, draconian health care service cuts, reimbursement cuts to providers, or some combination of outcomes,” our Legislative Action Center item stated. “All of these outcomes would fall on the backs of New York’s citizens. At a time when two-thirds of Medicare-certified home health providers in New York State are already operating in the red, our patients and our staff cannot accept any further cuts.” “It is true that some parts of the Affordable Care Act created significant challenges for home care, including Medicare cuts and new regulatory requirements,” the Action Item acknowledged. “But the current repeal-and-replace plan would further, and drastically, harm fundamental home care programs and services in ways that far outweigh and, indeed, augment any of the problems introduced by ACA. These problems should instead be addressed in a more targeted way, and not with the blunt approach of the AHCA.” In a last-minute amendment late last week, the bill also included a New York-specific change that would have removed the county share of Medicaid costs in upstate counties and Long Island, meaning that the state would have to pick up the costs, adding to the budget shortfall already otherwise proposed by the Medicaid block grants. The amendments, negotiated by House Republicans representing upstate New York districts, drew criticism from Governor Cuomo who said the amendment would add another $2.3 billion in state obligations, necessitating unprecedented state tax increases and/or cuts to providers – though it is unclear how this $2.3 billion shift would have aligned with the other Medicaid cost changes otherwise encompassed by the “block grant” provisions in the bill. Next steps remain to be seen. President Trump has warned that ACA, now left in place, “unfortunately will explode” under its own weight, according to press reports. Some reports also suggested that the Trump Administration has leverage on the enforcement of ACA provisions, which could provide another avenue to chip away at the program, President Obama’s signature domestic initiative. HCA and our legislative Affairs Representative, Brett Heimov of Envision Strategy, will continue to engage the House and Senate as any next overtures are pursued, and we will keep you apprised of all developments.
MLTC Update Service Area Reductions Announced The state Department of Health (DOH) has announced that GuildNet and Elderplan Partial Cap managed long term care (MLTC) plans will not be accepting new enrollees in one or more counties and existing plan members in those counties will have to select another plan. Effective immediately, both GuildNet Partial Cap and Elderplan Partial Cap plans will no longer be accepting new enrollments in Suffolk; existing members have been sent notices that they will have to choose another plan. DOH notes that for GuildNet members, GuildNet Gold MAP will remain an option in Suffolk County. In addition, GuildNet Partial Cap won’t be accepting new enrollments in Nassau and Westchester counties and members in those plans have been sent notices that they will have to select
4
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
another plan. GuildNet Gold MAP and GuildNet Gold FIDA, however, will remain an option in Nassau County. The DOH-approved correspondence to existing enrollees lists all MLTC options in the affected counties and directs the member to New York Medicaid Choice, the state’s Enrollment Broker, for education. Each plan will be undertaking targeted care management outreach to educate members and assist with facilitating transition to a new MLTC plan of choice. DOH is also working closely with New York Medicaid Choice to ensure that members receive education on plan choice and network affiliations. GuildNet and/or Elderplan will remain responsible for their membership in the affected counties until such time as the member’s MLTC plan of choice completes assessment and a smooth transition has been completed. While existing enrollees are encouraged to select another plan by the end of May, the plans will continue to service the enrollees until they do so. For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
HCA Attends DOH, DOL, OMIG Stakeholder Meeting on Minimum Wage Implementation On Thursday, HCA participated in the Minimum Wage Stakeholder Meeting held by the state Department of Health (DOH) with representation from the state Department of Labor (DOL) and the state Office of the Medicaid Inspector General (OMIG). This stakeholder meeting was the third in a series that DOH has led intending to engage and inform association and industry representatives. It included provider and plan association representatives, government affairs staff on behalf of providers and plans, and other state employees. DOL began the meeting by providing a history overview of the increased minimum wage mandate, the basics of the implementation, and general logistics, all of which have been reported extensively in past newsletters and alerts. Additionally, DOL stressed that providers should be sure they are taking care to pay the correct overtime rates, especially if they typically pay weekly rates. If there are any questions, DOL has many resources on its website and will be prioritizing related questions received by phone and e-mail. Also, related to wage parity, DOL emphasized that the law’s mandated levels are expected to be paid in applicable regions (New York City, Long Island and Westchester), and DOL will recover underpayments of wage parity through increased enforcement efforts. Therefore, providers are urged to be sure that they are paying the increased minimum wage plus supplementals on top of that. Particular care is encouraged if paying into third party benefit plans. DOL also made a point to emphasize that retaliation against any employees who make a labor-law-related inquiry or complaint is strictly prohibited and could, and often does, result in fines which could be as high as $20,000. DOL has processed over 300 of these cases in the past twelve months and, in most cases, it
5
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
says the employer has been found at fault. Any time there is a question, employers are encouraged to call DOL before responding to the employee. DOH’s Office of Health Insurance Programs (OHIP) reviewed previously-provided information related to the mandate and implementation, but also did provide written confirmation, via its presentation slides, that plans “may negotiate their own rates as long as they are in compliance with the minimum wage” and that “plans have flexibility and may re-negotiate rates (including reductions); however, minimum wage funding cannot be used to subsequently increase rates after a reduction to address minimum wage.” The state also confirmed that it is in the process of developing a supplemental cost report for home care providers to verify that resources included in the rates were utilized for minimum wage. For Certified Home Health Agencies (CHHAs), DOH stated that this new information could possibly be added to the existing Medicaid Cost Report. HCA also asked that industry stakeholders be included in this process, and DOH confirmed that HCA will have an opportunity to review and comment on the new supplemental cost report in the near future. OMIG, in partnership with DOL, will be conducting audits of Managed Care Organizations and providers to ensure that payments were made in accordance with statutory requirements. These audits will be similar to audits already taking place by OMIG. When asked if there will be a process for redistributing money to providers who did not receive adequate funds, DOH confirmed that this would happen but the process will take time. DOH also said that it encourages (though does not require) plans to collect attestations from their provider contractors, despite plan and provider representatives agreeing that this was unreasonable, burdensome and would not be likely to happen across the board. When asked about FIDA, DOH confirmed that the rate package was currently with the state Division of Budget (DOB) for approval. Mainstream rate packages would be soon to come. DOH was also asked if there was a plan to reimburse providers for the 24-hours/oneday of increased minimum wage paid to employees on December 31, 2016 that was not in the rates, but they did not have an answer at this time. With any questions, please contact the HCA Policy staff.
6
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
DELAY from p. 1 implementation of the new federal home health Conditions of Participation (CoPs). As earlier reported, CMS released the CoP changes in mid-January. Rep. Faso’s interest in the issue stemmed from a January meeting with HCA President Joanne Cunningham who communicated that the new CoPs introduced the most significant changes in operating requirements for home health agencies in more than two decades. Ms. Cunningham asked Rep. Faso and other Members of the New York Congressional Delegation to press CMS for a delay of the CoPs, as most provisions are currently slated to go into effect on July 13, 2017. Rep. Faso responded quickly on a plan of action, writing directly to CMS Administrator Seema Verma last week, calling for a delay to no earlier than January 13, 2018. “I believe providers and state regulators need greater time to fully understand and implement what are a wide range of changes to the CoPs,” Rep. Faso writes. “Home care providers understand the rationale and goals of the CoP changes, and they report vigorous and hurried efforts to get their staff trained and ready. Moving back implementation by six months will allow for all parties involved to be better prepared to operate and ultimately provide quality care to home care beneficiaries.” HCA was the first association representing home care to ask for a CoP delay and we were quickly joined by several state home care associations representing other parts of the country. HCA has urged other Members of the New York Congressional Delegation to join in Rep. Faso’s initiative, and we thank him for taking the lead on this important call for delay. Rep. Faso’s letter can be read on our website at http://hca-nys.org/wp-content/uploads/2017/03/FasoLetterCoPs.pdf. HCA’s briefing paper, calling for the CoP delay, is available at http://hca-nys.org/wp-content/uploads/2017/01/OneYearDelayCoPs2017.pdf. CoP Program: April 5 HCA reminds providers to join us for an in-person, comprehensive session that will be “Unpacking the New Home Health CoPs” in Albany on April 5. This program is the second installment of HCA education to assist providers on the most significant federal regulatory changes in 30 years. Our April 5 session will take you deeper into the CoPs, offering implementation action items, operational and clinical practice refinements, and insights from peer agencies that have already begun moving quickly with their compliance and readiness activities. Don’t miss this opportunity for further insights and tools to set your agency on a path to success in CoP readiness, especially if you are a CEO, COO, Administrator, Clinical Supervisor, Director, Educator, Performance Improvement Manager or are responsible for the oversight and delivery of care and services. More information and registration are at http://hca-nys.org/wp-content/uploads/2017/02/Unpacking-the-New-Home-Health-CoPs-Registration-Form.pdf.
7
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
CONFERENCE from p. 1 along with online registration. Simply visit our conference website at www.hcaannualconference.com. HCA’s Annual Conference is our biggest gathering of New York’s home care, hospice and managed long term care community for learning and networking. Our conference theme has a three-part message: Rediscover, Reimagine, Reinvent. It will help you respond to another important trio of ideas that are fundamentally driving health care policy: the CMS-defined “tripleaim” of reducing costs, improving population health, and enhancing the patient care experience. As the health care system pivots toward value-based payments, our lineup of expert presenters will investigate data points, revenue cycle management solutions, clinical strategies, and other avenues to achieve value. Focusing on “cultivating the home care workforce,” you’ll also explore some important cultural principles for employee engagement that will enhance the quality of interpersonal connections among peers and with their patients. As a bonus, our special pre-conference focus on palliative care will help you discover ways of integrating new, patient-centered offerings to meet the prerogatives of valuebased care. All of these sessions – plus our Annual Awards luncheon, networking sessions, exhibit hall of vendors, “town hall” meeting with the HCA Policy team, and others – await you on May 3 to 5 in beautiful Saratoga Springs. Please register today and be on the lookout for more conference updates coming soon.
8
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Nominate a Home Care Leader for the Ruth F. Wilson Award HCA has received an exceptional response to the open call for our 2017 HCA Award Nominations! For those that haven’t yet taken a minute to submit a nomination, please consider those industry leaders you’ve worked with who deserve consideration for HCA’s highest honor – the Ruth F. Wilson Award. The Ruth F. Wilson Award recognizes an individual who has demonstrated exceptional dedication and made a significant contribution to the home care industry, reaching beyond a single agency. Those nominated for the Ruth F. Wilson award will have strengthened the practice of our profession, raised the standards of quality and care for patients, and advanced the level of understanding and mutual cooperation among the home care community, legislators, federal and state agencies, health care providers and the public. Nominees for the Ruth F. Wilson award are similarly recognized for their leadership, like the most recent winners: Laurie Neander, CEO of Basset Healthcare Network: At Home Care, Inc.; Bridget Gallagher, Vice President of Americare Certified Special Services, Inc.; and Michelle Mazzacco, Vice President/ Director of Eddy Community Services/St. Peter’s Health Partners – just to name a few! If you would like to nominate a leader in your home care network or community that meets the criteria for a Ruth F. Wilson Award, or if you would like to nominate others for a Caring or Advocacy Award (the other categories we are still allowing nominations for), you have until March 30. It only takes a minute to complete the online nomination form at https://www.surveymonkey.com/r/2017HCAAwards.
9
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Please Answer Important HCA Technology Survey for Advocacy on Your Behalf To advocate for home care technology investment and policy development on your behalf, HCA has developed a brief survey. It seeks to assess the status of health information technology (HIT) adoption, integration and needs in home care. A link to the survey is at https://www.surveymonkey.com/r/HCAtechsurvey2017. Given that the state budget negotiations include infrastructure monies for health care, which are now in play, your timely response to this survey will provide us with important findings to share with the State Legislature and the Governor’s office to ensure a proportionate allocation for home care. The survey asks some very straightforward questions, many of which simply require a “yes or no” response, and it should only take about 10 minutes to complete. Please complete the survey as soon as possible, and no later than March 31. We stress that a high response rate could support HCA’s advocacy during fast-moving state budget negotiations that will be wrapping up in a matter of days. Our questions, vetted with members of HCA’s Board and Technology Committee, ask about your: use of electronic health records; access to Regional Health Information Organizations and Qualified Entities; costs of HIT adoption and the adequacy of reimbursements for these purposes; integration of your HIT with other entities and payors; your use of “direct messaging” tools; and other operational issues. Please be sure to forward this survey to the appropriate person who has the information to respond. For questions, please contact HCA’s Director of Public Policy Alex Fitz Blais at ablais@hcanys.org.
HCA Data Webpage Now Includes 2015 Medicare Hospice Cost Report Data This week, HCA staff posted to our HCA Data website an HCA-developed spreadsheet of the federal fiscal year (FFY) 2015 Medicare hospice cost report data in the state. Important: HCA Data is a members-only page that provides data reports to assist home care and hospice providers and managed care plans in their benchmarking efforts, understanding of system-wide trends, and access to reimbursement and premium rates. The page is not visible on our site unless you are logged in with an HCA member website account. Our log-in page is here: http://hca-nys.org/login. Upon login, the HCA Data link will appear in the site menu at the top right. You can also enter your e-mail address to obtain your password. Or, simply e-mail HCA’s Communications Director Roger Noyes at rnoyes@hcanys.org if you do not yet have an HCA website account or don’t remember your login information. HCA has recently submitted a freedom of information law (FOIL) request for the 2015 Medicaid Cost Reports for all non-hospital based CHHAs and LTHHCPs in the state. Upon receipt of this data, HCA will prepare a spreadsheet summarizing key CHHA & LTHHCP data, including such items as: total operating
10
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
revenue by payor, total operating expenses, operating margins, unit costs, patient utilization data by payor source, and more. HCA’s Data page also currently has 2015 Medicaid Managed Care Operating Reports (MMCOR) data available to members and hopes to have fourth quarter 2016 data available sometime in June. For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.
DSRIP Update In response to the final Delivery System Reform Incentive Payment (DSRIP) Mid-Point Assessment Recommendations, as voted upon by the Project Approval and Oversight Panel (PAOP), the Performing Provider Systems (PPSs) were required to submit Mid-Point Assessment Action Plans to the Independent Assessor (IA) by March 10, 2017. Three PPSs – Community Care of Brooklyn PPS, Staten Island PPS and New York Presbyterian/Queens PPS – did not have any recommendations and therefore do not have action plans. These action plans are now posted for public view on the DSRIP website at http://www.health.ny.gov/ health_care/medicaid/redesign/dsrip/pps_map/midpoint/index.htm. The action plans can be found at the bottom of each individual PPS section. Provider comment opportunity The action plans will be open for a public comment period from Monday, March 20, 2017 through Friday March 31, 2017. During this period, any comments regarding the PPS action plans can be sent to dsrip_midpoint@pcgus.com. Home care agencies should take this opportunity to share their comments. The IA will consider any comments received during this period as part of its review and feedback provided to the PPSs. The IA will work with the PPSs to address any items requiring additional information or revision within the action plans with the goal of having all action plans fully approved by the IA by no later than April 30, 2017. The full timeline for the Mid-Point Assessment Action Plans is as follows:
Activity
Date
PPSs Submit Mid-Point Assessment Action Plans to IA
March 10, 2017
Mid-Point Action Plans posted to DSRIP Website
March 20, 2017
Public Comment Period Opens
March 20, 2017
Public Comment Period Closes IA provides feedback to PPSs
March 31, 2017 April 7, 2017
PPSs respond to IA feedback
April 19, 2017
IA finalizes approval of Mid-Point Assessment Action Plans
April 30, 2017 Continued on next page
11
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Continued from previous page Regulatory Waivers The state Department of Health (DOH) has announced that regulatory waiver requests for DSRIP projects will be open and processed on a quarterly basis throughout the DSRIP Demonstration Years in order to facilitate ongoing project implementation. These request windows are grouped quarterly throughout the year to ensure all relevant waiver requests are accommodated as soon as possible. At this time, PPS leads are invited to submit additional applications for Regulatory Waiver Requests by May 1, 2017. Responses to these requests will be sent to the PPS leads by July 1, 2017 and posted on the DSRIP website. Additional information, including past Waiver Requests and the Regulatory Waiver Request Template, can be found here: https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/ reg_flex_guide_res_prog_stat_waiver_resp_approvals.htm. In September 2014, DOH, the Office of Mental Health (OMH), the Office of Alcoholism and Substance Abuse Services (OASAS), and the Office for People with Developmental Disabilities (OPWDD) issued guidance to Performing Provider Systems (PPSs) interested in seeking regulatory waivers in connection with DSRIP and the Capital Restructuring Financing Program. More information is at https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/ regulatory_flexibility_guidance.htm.
Star Rating Preview Reports Available Preview Reports reflecting results from the Home Health Care CAHPS (HHCAHPS) Survey from October 2015 through September 2016 (quarter 4 of 2015 to quarter 3 of 2016) are now available on https:// homehealthcahps.org under the “For HHAs” tab. You must be logged into the website to view your report. These same data will be updated on Home Health Compare (HHC) on www.medicare.gov in April 2017. The Preview Reports present the publicly reported results with Star Ratings for those agencies with a sufficient number of completed interviews to receive Star Ratings. Agencies must have data for 40 or more patient surveys in the reporting period in order to have Star Ratings. To access your agency’s HHCAHPS Preview Report, log into the HHCAHPS website using your username and password. Select the “Preview Reports” link under the “For HHAs” tab. If you have forgotten your password, click the Login link, type in your username, click “Reset Password,” and you will be emailed a “password reset link.” Follow the instructions provided in the e-mail message to reset your password. If you have comments about your HHCAHPS Star Ratings on the Preview Report, please e-mail the following information to the HHCAHPS Coordination Team at hhcahps@rti.org by April 7, 2017:
12
Your name, your facility name, your CMS Certification Number (CCN), and your contact information. Continued on next page
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Continued from previous page
Your comments about your preview report.
If you believe your HHCAHPS Star Ratings are not correct, submit evidence showing why the Star Ratings are incorrect. Note that if you have historically had higher ratings than are shown, this is not considered evidence. You must provide information showing that the data submitted by your vendor for the most recent quarter are incorrect and, therefore, may have impacted the assigned HHCAHPS Star Ratings for your agency.
For more information about the Preview Reports, refer to this document on the HHCAHPS website, accessible once you are logged in: https://homehealthcahps.org/LinkClick.aspx?fileticket=rEmqINcxYK8%3d&tabid=277. For more information about HHCAHPS Star Ratings, including Frequently Asked Questions, go to https:// homehealthcahps.org/GeneralInformation/StarRatingsInformation.aspx. If you have any questions about the HHCAHPS Star Ratings or your HHCAHPS Preview Report, contact the HHCAHPS Survey Coordination Team via e-mail at hhcahps@rti.org or (866) 354-0985.
HCA Communications Director Roger Noyes Writes Book About Early Red Cross Nursing Leader Noyes will present leadership and advocacy session, drawing from the book, during segment at May 3-5 HCA Annual Conference HCA’s Communications Director, Roger Noyes, has written a new biography of his Great-Great Aunt, Clara Noyes, who directed the Red Cross Nursing Division during World War I, enrolling 20,000 nurses for duty to serve sick and dying troops. The book, Clara D. Noyes, R.N.: Life of a Global Nursing Leader, comes out on the centennial of the U.S. entrance into World War I next month (on April 6). At HCA’s Annual Conference, during National Nurses Week, Roger Noyes will be presenting a session with insights on leadership and advocacy strategies drawing from this period of nursing history. The book explores how nursing – and, specifically, the structure of relief organizations like the Red Cross – provided a unique avenue for women to hold influential executive positions in early twentieth century America. Clara Noyes also worked to deploy Red Cross nurses to the Mississippi Flood of 1927 (one of the largest natural disasters in U.S. history) and the Influenza Epidemic of 1918. Her political activism, alongside President Taft, helped pass legislation granting Army rank to nurses. This work also overlapped with the suffrage movement and other advocacy wins on behalf of women that were achieved in large part from her perch as an early President of the American
13
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Nurses Association (ANA), which was at the time the largest organized body of professional women in the world. Her early work at Bellevue Hospital in New York City also included frequent interactions with fellow nursing leader Lillian Wald, founder of the Henry Street Settlement, a precursor to HCA member organization the Visiting Nurse Service of New York. Clara Noyes also founded the first not-for-profit school for midwives in the United States at Bellevue, published extensively on nursing issues of the day and worked in the post-war period to oversee nursing relief activities in Europe and to develop schools of Nursing in France, Bulgaria, Czechoslovakia and Poland. “Roger Noyes has written a biography of a woman who wielded power and authority at a moment in time when few did,” says University of Pennsylvania School of Nursing Professor Patricia D’Antonio, PhD, RN, FAAN in her review of the book. The book is now on Amazon.com (http://tinyurl.com/lnpmpp2) and other sites, and copies will be available during HCA’s Annual Conference. Register today for May 3-5 Annual Conference HCA has an exciting lineup of speakers, opportunities to meet vendors, networking, a PAC reception and festivities at our 2017 Annual Conference in Saratoga Springs. A full brochure and online registration are available on the conference website at www.hcaannualconference.com, along with hotel information and an agenda at-a-glance. Don’t miss it!
Delays Announced in Medicare Payment Models The U.S. Centers for Medicare and Medicaid Services (CMS) has announced delays in certain Medicare bundled payment programs. Through an interim final rule, with comment period, CMS proposes to:
Delay the implementation of the mandatory cardiac bundle program and cardiac rehabilitation program from July 1 to October 1.
Postpone the expansion of the mandatory joint replacement bundle program to include other treatments for hip and femur fractures in addition to hip replacement from July 1 to October 1.
Further delay the effective date of a final rule to implement the joint replacement bundle initiative, the cardiac rehabilitation incentive payment model and the initiative to advance care coordination through episode payment models from March 21 to May 20.
CMS is seeking comment on a potential further delay of the programs to January 1, 2018. CMS states that the additional three-month delay in the final rule is “necessary to allow time for additional review, to ensure that the agency has adequate time to undertake notice and comment rulemaking to
14
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
modify the policy if modifications are warranted, and to ensure that in such a case participants have a clear understanding of the governing rules and are not required to take needless compliance steps due to the rule taking effect for a short duration before any potential modifications are effectuated.” In the January 3, 2017 Federal Register, CMS published a final rule entitled “Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model” which implements three new Medicare Parts A and B EPMs and a Cardiac Rehabilitation (CR) Incentive Payment model, and implements changes to the existing Comprehensive Care for Joint Replacement model. Under the three new episode payment models, acute care hospitals in certain selected geographic areas will participate in retrospective EPMs targeting care for Medicare fee-for-service beneficiaries receiving services during acute myocardial infarction, coronary artery bypass graft, and surgical hip/femur fracture treatment episodes. All related care within 90 days of hospital discharge will be included in the episode of care. Under the CR Incentive Payment model, acute care hospitals in certain selected geographic areas will receive retrospective incentive payments for beneficiary utilization of cardiac rehabilitation/intensive cardiac rehabilitation services during the 90 days following discharge from a hospitalization treatment of an acute myocardial infarction or coronary artery bypass graft surgery. More information is at https://www.gpo.gov/fdsys/pkg/FR-2017-03-21/pdf/2017-05692.pdf.
NGS Creates Home Health Certification Job Aid National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), recently announced the release of a new “Job Aid” which was created to provide home health agencies (HHAs) with an example of a complete certification statement in your home health documentation. NGS created the Job Aid (which can be downloaded at http://hca-nys.org/wp-content/uploads/2017/03/ Home-Health-Certification-Statement.pdf) particularly for HHAs still using U.S. Centers for Medicare and Medicaid Services (CMS) Form 485, which NGS has stated is not endorsed by CMS and does not contain a complete certification statement. Additionally, CMS recently published information regarding certifying patients for the Medicare Home Health Benefit. It can be downloaded at: https://www.cms.gov/Outreach-and-Education/MedicareLearning-Network-MLN/MLNProducts/Fast-Facts/2017-03-02-Home-Health-Care.html. NGS will continue to provide additional information to its website in the future on home health certification to assist HHAs with their compliance. NGS also reminds providers of the following:
15
April 2017: Release Dark Days for the Common Working File (CWF) Hosts – In anticipation of the April 2017 release, the CWF hosts will not process claims beginning Friday, March 31, 2017 through Sunday, April 2, 2017. During this period, which is commonly referred to as “dark days,” the CWF
The Situation Report: the Home Care Association of New York State
Volume 2, No. 13 March 27, 2017
Hosts will install the April 2017 Release, complete weekly, monthly, quarterly processing activities, and perform scheduled data center maintenance. These dark days will limit access to information provided by NGS’s Interactive Voice Response (IVR) system and to NGS’s portal, NGSConnex. Providers may also experience limited or no access to claims, eligibility, claim overlap, patient status, check inquiry, reopening/redetermination status, offset information, and financial claim information. For further information, contact HCA’s Patrick Conole at (518) 810-0661 or at pconole@hcanys.org.
HHQI Resources Reflect QAPI Requirements of New CoPs Among other major changes, the newly published final rule revising the home health Conditions of Participation (CoPs) includes a requirement that home health agencies must have a Quality Assurance & Performance Improvement (QAPI) program – including Performance Improvement Projects – in order to receive payments from Medicare. The Home Health Quality Improvement (HHQI) campaign reports that it has developed and posted QAPI implementation resources for providers based on the draft CoPs. Those resources are at http:// www.homehealthquality.org/Education/QAPI-Resources.aspx. The materials have been updated to incorporate minimal changes reflecting the now-final version of the CoP rule, including the addition of Infection Prevention & Control information to the Home Health QAPI Fact Sheet. HHQI also announced that its HHQI University offers courses utilizing these materials and additional information on QAPI and Performance Improvement Project (PIP) development. The courses provide continuing education credits for nurses. More information is at http://www.homehealthquality.org/ Education/HHQI-University.aspx. HCA CoP Program: April 5 HCA encourages providers to attend our daylong program that will drill deep into the CoPs on April 5, featuring clinician expert Trish Tulloch, a sought-after home care operational management consultant who works with multiple health care organizations to meet regulatory and accrediting standards. Registration is at http://hca-nys.org/wp-content/uploads/2017/02/Unpacking-the-New-Home-Health-CoPs-RegistrationForm.pdf.
Resources
“Home Health (HH) Language in Pub. 100-8,” by the U.S. Centers for Medicare and Medicaid Services https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R704PI.pdf
“Medicaid Eligibility Verification System (MEVS) and Dispensing Validation System (DVS) Provider Manual,” by eMedNY (updated March 2017) https://www.emedny.org/ProviderManuals/5010/MEVS/MEVS_DVS_Provider_Manual_(5010).pdf
For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
16