AHHA
MANAGED CARE UPDATES
HCA RENEWALS
COUNTY CODES REQUIRED
The State Register includes a final version of the Advanced Home Health Aide rule, including DOH responses to comments on nurse supervision requirements and more.
The latest DOH managed care meeting includes updates on LHCSA contracts, minimum wage, Community First Choice Option, and more.
Have you reviewed HCA’s renewal packet yet? The packets were mailed earlier this month and we encourage you to rejoin for 2019 as soon as possible.
Medicare will require all claims to have a county code as part of the changes to the home health rural add-on. Importantly, all providers (whether rural or not) must enter the code starting Jan. 1.
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UPCOMING PROGRAMS Free Members-Only Webinar on NYS DOL Revised "Call-in Pay" Regulations: Dec. 18 2019 Northeast Home Health Leadership Summit Jan. 22-24, 2019 (Boston) WCEI 5-Day Onsite Skin and Wound Management Course March 4-8, 2019 (Herkimer, NY) Editor's Note: This is the final edition of The Situation Report for 2018. We will notify you of any pressing updates by e-mail and resume publication on January 7, 2019. Also, HCA's offices will be closed for the holidays from December 24 to January 1, reopening on January 2.
Your Source for HOME CARE News, Policy and Advocacy
Vol. 3, Issue 49| December 17, 2018
Turnover Rates, Wage and Labor Pressures, and More: Your Responses Needed on Vital Industry Survey! HCA reminds members to complete our financial and program trends survey as soon as possible so that we can keep on track towards achieving a statistically sound sample of at least 80 to 100 organization responses. We know this survey takes time to complete. HCA greatly appreciates your commitment to answering this call (thank you, especially, if you have already completed the survey). See SURVEY p. 2
Ten Years & Counting: Why HCA’s Board Chair Attends the Northeast Home Health Leadership Summit -A Special Message from HCA Board of Directors Chair Susan Larman, BSN, MBA and CEO of VNA Home Health/Visiting Nurses Home Care I’m thrilled to be attending the Northeast Home Health Leadership Summit next month in Boston, as I have done for the past ten years. There are many reasons why I look forward to this regional, yet national-class, program each year. I hope you will find similar reasons to join me as I return in 2019.
INSIDE Your Responses Needed on Vital Industry Survey.............................................1 Why HCA’s Board Chair Attends the Northeast Leadership Summit.....................1 Member Hiring Announcement...................................................................3 LHCSA Registration Must be Completed by January 1, 2019................................4 Senate Committee Assignments: Sen. Gustavo Rivera to Chair Health................4 DOH Releases Final AHHA Regulations; Guidance Expected in the Near Future....5 Monthly Managed Care Meeting Yields Key Updates...........................................6 Guidance Issued to MLTC Plans on LHCSA Contract Limitations...........................7 HCA to Host Webinar Tomorrow on “Call-in Pay” Regulations.............................8 HCA Capitol Report: Issue 1................................................................................9 Home Care, Hospice and MLTC News Clips Straight to Your Inbox.........................9 It’s HCA Membership Renewal Time..............................................................9 NYeC Multi-Sector Association Call Reviews Highlights, Priorities..............10 House Extends MFP, Spousal Impoverishment Protections..........................11
See CHAIR p. 3 HHA Claims Must Contain a County Code Starting Jan. 1, 2019........................12 HHAs May Continue to Provide Part B Infusion Therapy in 2019-2020.............13 Emergency Preparedness Update................................................................13 Suffolk County Enacts Salary History Ban..................................................15 Westchester Passes Bill Regarding Criminal History and Employment..........16 2019 Medicaid Levels Announced...............................................................16 PHHPC Acts on Home Care and Hospice Applications.....................................17 HHS Seeks Input on Improving Care Coordination, HIPAA Regs........................18 2017 National Health Expenditures Released.............................................18 NGS Announces Upcoming Annual Logon ID Recertification...........................20 NGS Closed on Christmas and New Year’s.....................................................20 CMS Forum on Changes to Level II HCPCS......................................................20 IRS Issues Standard Mileage Rates for 2019..................................................21 Important Deadlines and Due Dates...............................................................22 Health Resources......................................................................................23
The Situation Report: the Home Care Association of New York State
SURVEY from p. 1 At HCA’s Board of Directors meeting last week, much of the conversation dealt with the challenge of effectively telling our sector’s story to legislators, including the pressures facing the industry. Many of the potential message points that were discussed at the meeting are able to be captured by our survey, such as your staff vacancy rates, the cost impact of wage and labor law changes on your organization, your turnover rates, financial margins, and more. To be effective in our advocacy, we need this data, which gives substance to our messaging and allows us to tell a story. Here are some tips:
It doesn’t matter how you complete the survey. Please choose the easiest way possible. If you want to handwrite your responses into a printed PDF (which you can scan and e-mail/fax back to HCA), please feel free to do so and we will enter the data into our reporting software. A link to the PDF version of the survey is below. You may need to involve several staff to complete the survey, from your CEO to your CFO, to your clinical and operational leaders. By printing or circulating the PDF internally, you can delegate those component parts of the survey to relevant members of your team and then enter the cumulative data into the online survey link or, again, just fax/e-mail us the completed survey.
Links Download a PDF survey at https://hca-nys.org/wp-content/ uploads/2018/12/201819HCAHomeCareIndustrySurvey.pdf. Complete the survey online at https://www.surveymonkey.com/r/201819industrysurvey. We know this is a lot to ask of our members, but it is very important and very much appreciated during this especially busy time of year. Thank you. Home Care Association of New York State (HCA) 388 Broadway, 4th Floor, Albany, NY 12207 Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org
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The Situation Report is a weekly publication of the Home Care Association of New York State (HCA). Unless otherwise noted, all articles appearing in The Situation Report are the property of the Home Care Association of New York State. Reuse of any content within this newsletter requires permission from HCA. Al Cardillo President and CEO acardillo@hcanys.org Roger L. Noyes Director of Communications, Editor of The Situation Report rnoyes@hcanys.org Patrick Conole Vice President, Finance & Management pconole@hcanys.org Andrew Koski Vice President, Program, Policy & Services akoski@hcanys.org Alyssa Lovelace Director for Policy and Advocacy alovelace@hcanys.org Lauren Ford Director of Program Research, Development and Policy lford@hcanys.org Laura Constable Senior Director, Membership & Operations lconstable@hcanys.org Celisia Street Director of Education cstreet@hcanys.org Mercedes Teague Finance Manager mteague@hcanys.org Jenny Kerbein Director of Governance & Graphic Design jkerbein@hcanys.org Billi Wilson Manager, Meetings & Events bwilson@hcanys.org Teresa Brown Administrative Assistant tbrown@hcanys.org
The Situation Report: the Home Care Association of New York State
Volume 3, No. 49 December 17, 2018
CHAIR from p. 1 Every year, this program elevates and responds to the biggest policy issues facing home care leaders and their organizations. The upcoming Summit is no exception, with a pre-conference dedicated to the PatientDriven Groupings Model, the Home Health Prospective Payment System, and other dominant federal landscape issues for the industry. Secondly, this Summit always offers an uplifting series of leadership sessions that renew my optimism. Going beyond generic leadership principles, these sessions are thematically distinctive for home care and the specific concerns we face. Lastly, while we may think of New York’s home care concerns as unique (and in many cases they are), we share a regional connection with colleagues in the other northeast states attending this premier conference. I always find the networking opportunities to be informative and inspiring. In fact, this kind of regional networking can be an asset, as you’ll get to meet with peer agencies from entirely different marketplaces, which makes the exchange of ideas feel a bit freer. You may even find a peer leader whose agency demographics, workforce and culture mirror your own organization in ways that you don’t find closer to home in New York — and you can learn from them. I look forward to seeing you in Boston on January 22 to 24 for exceptional professional development and networking opportunities, as well as policy insights from some of the brightest minds in the field. Sincerely, -Susan Larman, BSN, MBA Chief Executive Officer, VNA Home Health/Visiting Nurses Home Care Chair, HCA Board of Directors Editor’s note: registration for the summit is available on the Summit website at http://nehomehealthsummit.com/. HIRING: RN / Staff Development Education Supervisor – Home Health Full Time 9 am-5 pm Driven to Be the Best. NYU Winthrop Hospital’s Home Health Agency ranks as a top-performing US Home Health Agency! Come join our stellar team of nurses, therapy professionals and social workers who provide home health care to our maternal, child and adult population. We have an exceptional opportunity for a Staff Development Education Supervisor to be responsible for home health staff education, development and professional growth, including orientation program (didactic and practical components). Collaborating with the Director of Quality Management/Staff Development and the departments’ management team, you will identify, develop and plan appropriate staff development programs to support agency needs to provide optimum patient outcomes. Working with the Administrator and the Director of Patient Services, you will research, coordinate and establish new programs for the agency. We require:
NYS Registered Nurse License BSN with 2 years’ experience in Education in a Certified home care agency; Master’s degree in Nursing, preferred 2-3 years clinical nursing practice 2 years’ community health nursing Good communication and basic computer skills, knowledge of agency clinical and business functions
To apply for our Staff Development Education Supervisor position, visit https://jobs.winthrop.org/job/8799934/registerednurse-staff-development-supervisor-home-care-mineola-ny/ An EOE m/f/d/v.
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LHCSA Registration Must be Completed by January 1, 2019 HCA reminds member Licensed Home Care Services Agencies (LHCSAs) that they must complete the new Registration process by January 1, 2019; if not, they will be terminated from managed care plan networks and not be able to operate or receive reimbursement from any source. While HCA has worked closely with the state Department of Health (DOH) and LHCSA members to ensure that they have completed the Registration process (which is part of the 2017 LHCSA Statistical Report), there are still some members who have not registered certain branches/offices. HCA has reached out to these LHCSAs and advised them to immediately contact DOH and work to address their particular situation; otherwise, they may face termination of their managed care plan contracts as of January 1, 2019. DOH has sent, and will continue to send, lists of non-registered LHCSAs to MLTC plans so that they can know which LHCSAs have not registered. For more information, contact Andrew Koski at akoski@hcanys.org or (518) 810-0662.
Senate Announces Committee Assignments; Sen. Gustavo Rivera to Chair Health Committee On Tuesday, December 11, the state Senate announced the following committee chair assignments:
Senate Aging Committee: Rachael May (Syracuse) Senate Finance Committee: Liz Krueger (Manhattan) Senate Health Committee: Gustavo Rivera (Bronx) Senate Insurance Committee: Neil Breslin (Albany) Senate Labor Committee: Jessica Ramos (Queens) Senate Mental Health Committee: David Carlucci (New City) Senate Rules Committee: Andrea Stewart-Cousins (Yonkers) Senate Social Services Committee: Roxanne Persaud (Brooklyn) Senate Transportation Committee: Tim Kennedy (Buffalo) Senate Veterans Committee: John Brooks (South Shore, Eastern Nassau and Suffolk Counties)
In January, the state Senate will be under Democratic control. In late November, Democrats named Senator Andrea Stewart Cousins as Majority Leader. Last week, Senator Stewart-Cousins identified 38 out of 40 conference members to serve as committee chairs in 2019. The Democrats now hold 40 of the 63 seats in the Senate. Also announced today was the appointment of Crystal Peoples-Stokes (Buffalo) as Majority Leader in the state Assembly. HCA will be meeting with the newly appointed chairs in the coming weeks to discuss the Association’s budgetary priorities that will impact home care, hospice and managed long term care plans. Members are also encouraged to engage with those chairs and their elected Senators who serve patients in their districts as part of HCA’s upcoming advocacy initiatives. A full list of committee chair appointment is at https://dingo.telicon.com/NY/library/2018/20181211ZZ.PDF.
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DOH Releases Final AHHA Regulations, Guidance Expected in the Near Future The December 12 State Register includes a Notice of Adoption from the state Department of Health (DOH) on the advanced home health aide (AHHA) designation. The final DOH AHHA regulations are at https://docs.dos.ny.gov/info/register/2018/december12/ rulemaking.pdf (page six) and are the same as the proposed regulations at https://docs.dos.ny.gov/info/register/2018/may30/rulemakings.pdf. The state Education Department (SED) adopted its own version of the AHHA regulations earlier this year. These should be read in tandem with DOH’s final regulations. SED’s AHHA regulation is at http://www.regents.nysed.gov/common/regents/files/918ppca2.pdf. In order for the AHHA to be implemented by interested providers, the regulations must first be adopted by both state agencies and further guidance is also necessary on the development of AHHA training programs. Included in DOH’s AHHA Notice of Adoption were responses to public comments. HCA submitted comments to both DOH and SED on the proposed rule earlier this year. The Notice of Adoption included the following responses from DOH to HCA and other stakeholders’ questions and concerns:
For the requirement of an RN “visit” to supervise the AHHA once every two weeks, both DOH and SED interpret this to mean an “in-person” visit.
When an individual declines services by an AHHA, the regulations authorize services to be provided by an RN. DOH will consider whether a licensed practical nurse (LPN) could provide an appropriate level of care in the future.
In response to whether home health aides and personal care aides should be supervised by LPNs, the Department indicated that supervision of home health aides and personal care aides must be conducted by an RN, according to federal regulations. AHHAs may only be supervised by an RN.
Supervising RNs must be employed by the same entity which employs the AHHA. The minimum total hours of annual in-service training for AHHAs is 18 hours under the regulation. This includes the initial 12 hours for initial home health training.
Clarification will be provided in future guidance regarding criminal history record check provisions applying to all unlicensed staff that have regular face-to-face interactions with residents.
DOH indicated that an RN who engages in improper behavior while supervising an AHHA should be reported to the Department.
HCA spoke with DOH on Friday, December 14 to discuss the state’s plan to communicate the latest Notice of Adoption to providers. DOH indicated that it will issue guidance on the AHHA program in the near future.
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Monthly Managed Care Meeting Yields Key Updates on Requirements, Implementation of Budget Measures The state Department of Health’s (DOH) monthly meeting with Managed Long Term Care (MLTC) plans and associations focused on the status of state requirements and implementation of state budget actions. The meeting’s main points follow. LHCSA Registration According to DOH, required registrations have been received from nearly all LHCSAs, though over 200 are still outstanding. DOH advised MLTCs to continue emphasizing the urgency of registration to those contractors who must register in order to continue their contracts and services to the Medicaid population. HCA circulated yet another alert to LHCSA members on Friday stressing in the strongest terms the need for all LHCSAs to register (including any branch offices) in order to avoid disrupting care, reimbursement, contracts and, ultimately, the LHCSA’s eligibility to operate in the state. Community First Choice Option (CFCO) Delayed CFCO implementation continues to be unresolved and a start date will be delayed beyond January 1, as DOH explores options and solutions to issues raised by plans as well as HCA. The December 4 edition of The Situation Report outlined a consolidated approach that HCA had recommended, enabling CFCO to be implemented in a manner that could relieve logistical problems for MLTCs and support provider delivery of the service package. DOH will hold a December 20 webinar to give local districts and plans a status update on CFCO progress to date and next steps for 2019. Minimum Wage DOH is reviewing the weekly survey of MLTCs to ensure that provider contracts and Consumer Directed Personal Assistance Services (CDPAS) Fiscal Intermediary Administrative Agreements reflect wage adjustments for minimum wage. This review will continue until the end of the year. DOH said it will then determine whether to extend the survey period. In the meantime, DOH asked that submissions and questions be directed to HCWorkerParity@health.ny.gov. Value Based Payment (VBP) DOH is hosting a December 21 webinar, from 11 a.m. to noon, providing MLTCs with further guidance for VBP Year 2. DOH released revised dates for the Potentially Avoidable Hospitalization (PAH) measure. These dates were changed to January-June 2017 for the 2019 VBP year. DOH indicated that organizations should write to nysqarr@health.ny.gov if requesting final results of MLTC VBP Category 1 measures at a provider level for the July-December 2016 or January-June 2017 periods.
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Continued from previous page Enrollment Update Below are the enrollment statistics by managed care category, as of the end of November, for the total population of 244,006 enrollees:
MLTC partial capitation: 220,725 PACE: 5,776 Medicaid Advantage: 12,227 FIDA: 3,640 FIDA IDD: 1,138
Two important meetings are coming up later today (December 17) after The Situation Report editorial deadline. They include a meeting on the future of FIDA and DOH’s plans for future integrated care models, as well as a state finance meeting for MLTCs and member associations following up the November meeting. Please stay tuned for any further substantive updates.
Guidance Issued to MLTC Plans on LHCSA Contract Limitations The state Department of Health (DOH) has issued further guidance to Managed Long Term Care (MLTC) plans on the state budget change that imposes limits on the number of Licensed Home Care Service Agencies (LHCSAs) that MLTC plans can contract with. The guidance is at https://hca-nys.org/wp-content/uploads/2018/12/LHCSA_Reporting_Requirement.pdf. It includes two spreadsheets to be completed by MLTCs: “LHCSA Network Survey” and “Continuity of Service and Continuity of Care Reporting.” The first of these should detail current contracts and those that are being terminated. The second spreadsheet should be completed with all single case agreements entered on the appropriate tab. These spreadsheets should be submitted to LHCSAExceptions@health.ny.gov by December 20, 2018. In August, the state issued guidance on the LHCSA contract limits, as well as exceptions for when a LHCSA contract may be excluded from the count towards the maximum number. The guidance is posted at: https://www.health.ny.gov/health_care/medicaid/redesign/mrt90/mltc_policy/lhsca_contract_guidance.htm. DOH stresses that the completion of these spreadsheets does not replace the process for plans to request exceptions to the maximum number of contracted LHCSAs based upon the need for adequate access to services. Such exceptions must still be submitted to DOH as described in the previous guidance. A statutory exception allows plans to extend a contract with a LHCSA for up to three months in order to assist with continuity of care, but there are other continuity-of-care provisions. According to DOH, an enrollee’s current provider and services are to be maintained for 90 days when Medicaid recipients are transitioned from fee-for-service to MLTC. There is also a 120-day of continuity-of-care provision under MLTC Policy 17.02 (https://www.health.ny.gov/health_care/medicaid/redesign/mrt90/mltc_policy/17-02.htm) for enrollees
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transferring to a new plan due to plan closure, service area reduction, or merger/acquisition or similar transaction. Single case agreements created for the purposes of providing continuity of care (as in the situations mentioned earlier) must be reported to DOH, and plans are permitted to exclude them from their calculations of the LHCSA network cap during the applicable continuity-of-care period. After the requirement for continuityof-care has elapsed, whether that is 90 or 120 days, the contract will be counted into the ratio. DOH advises that there is not an option for an additional three-month continuity-of-service exception once the continuity period is finished for a single case agreement that was entered into for the purposes of continuity-of-care. DOH plans to separately send out an Annual Certificate of Compliance, to be completed by the plans and returned to DOH, attesting that their LHCSA contracts are within the mandatory ratios for their region.
HCA to Host Webinar Tomorrow on “Call-in Pay” Following DOL’s Revised Proposed Regulations Last week, HCA alerted members that the state Department of Labor (DOL) posted revisions to alreadyproposed employee scheduling (“call-in pay”) regulations. In response to the revised regulations, HCA will host a free members-only webinar tomorrow, December 18 from 11 a.m. to noon outlining the new “call-in pay” regulations. The webinar will compare and contrast the updates and changes of the originally proposed rule with the current proposal. The program will be presented by Benjamin Wilkinson, Principal at Hinman Straub, HCA’s contracted government affairs firm. To register for this event, please complete the online form at https://www.surveymonkey.com/r/callinpaywebinar. Background DOL alerted HCA in late November that the proposed changes would be issued in the December 12, 2018 State Register. The newly proposed rule can be found on the DOL website at https://www.labor.ny.gov/workerprotection/laborstandards/pdfs/employee-scheduling-proposed-rule.pdf. An initial version of these regulations was proposed on November 22, 2017, requiring employers to provide additional pay when a shift is cancelled or not scheduled within a certain advanced time requirement. It would also mandate additional pay for employees who are required to be in contact with the employer about a possible upcoming shift. HCA commented and delivered testimony on the original proposals earlier this year (see https://hca-nys.org/general-news/4547). The revised regulations will trigger yet another comment period where HCA will reiterate our call for the state to carve-out the home care, hospice and MLTC sectors from the proposed regulations should they be adopted. For a summary of the revised regulations, please see last week’s alert at https://conta.cc/2RQxDUS. Continued on next page
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Continued from previous page HCA has prepared a document that compares the previously proposed regulations with the newly released regulations. It is posted at https://hca-nys.org/wp-content/uploads/2018/12/Call-in-Pay-side-by-side.pdf. HCA will also submit comments to DOL now that the proposed rule has been released in the December 12, 2018 State Register, which will include a 30-day comment period on the newly proposed regulations from the December 12 publication date. HCA encourages providers to submit language for inclusion with our comments. Please write to HCA’s Public Policy staff by December 28, 2018. Members may also submit comments directly to the state by the January 11, 2019 deadline via e-mail to hearing@labor.ny.gov.
HCA Capitol Report: Issue 1 As previewed in last week’s edition of The Situation Report, HCA has a new monthly e-newsletter that we’ve begun circulating to the State Legislature called the HCA Capitol Report. Our inaugural issue went out last week and was sent to HCA members as well as state legislators and key staff. If you missed it, you can check out the December 2018 edition of the HCA Capitol Report at https://tinyurl.com/ydhn37gc. As we build a bank of newsletter issues, we’ll post an archive to our website in the coming months.
Home Care, Hospice and MLTC News Clips Straight to Your Inbox Each Wednesday and Friday, HCA sends a morning news clips distribution to executives in our database. If you receive these clips, we encourage you to circulate them within your organization. If you aren’t receiving the clips, but would like to, please notify HCA’s Communications Director Roger Noyes (rnoyes@hcanys.org), given that the subscription list is different from our newsletter list. The clips include articles from legal sources on regulations and compliance, trade publications, as well as general news sites reporting on home care, hospice and MLTC news so you can see how the issues you care about are being framed in the public sphere, which is important for your own PR purposes and understanding of the public conversation about your work. HCA has created a page on our website where we are posting archives of the news clips from the past week, and will continue to do so, allowing you to catch up if you missed any of our distributions. Visit the news clips archive today at https://hca-nys.org/headlines.
It’s HCA Membership Renewal Time By now your organization should have received HCA’s membership renewal packets in the mail, as we head into a new and exciting membership year for 2019. There’s a lot new happening at HCA: new policy staff; new program areas under development; exciting education offerings; new upcoming communications vehicles; and other work to fulfill our mission on behalf of the membership. Continued on next page
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Continued from previous page Your renewal packets included a letter from HCA’s Senior Director of Membership and Operations Laura Constable, along with an invoice and our annual member value statement, which, this year, highlights some of the ways that members have rated HCA’s offerings. You can read our Value Statement online at https://hca-nys.org/wp-content/uploads/2018/12/2019-HCA-Value-Statement.pdf. Please return your membership renewals as soon as possible. If you have any questions, or did not receive the materials to renew, contact Laura Constable at (518) 810-0660 or lconstable@hcanys.org.
NYeC Monthly Multi-Sector Association Call Reviews 2018 SHIN-NY Highlights and 2019 Priorities Representatives from HCA recently participated in the third installment of the New York State eCollaborative (NYeC) multi-sector association workgroup. As previously reported, this monthly workgroup is designed to facilitate ongoing communication between NYeC and each health care sector represented by the association. NYeC is New York State’s designated entity for Health Information Exchange (HIE) and the state Department of Health’s (DOH) prime contractor for the Statewide Health Information Network for New York (SHIN-NY). This workgroup is also part of a larger stakeholder engagement initiative being used to successfully implement SHIN-NY’s 2020 HIE Roadmap to “Improving Health in our Communities.” NYeC’s 2020 Roadmap can be found here: http://www.nyehealth.org/nyec16/wp-content/uploads/2017/07/SHIN-NY-2020-Roadmap_July-2017.pdf. According to NYeC Executive Director Valerie Gray, SHIN-NY usage has increased 50 percent since last year. Also highlighted were the creation of an enhanced statewide security system with HITRUST, the expansion of statewide alerts, improved quality measurement reporting, new Qualified Entity (QE) performance metrics, clarification on research consent requirements, and the expansion of the Data Exchange Incentive Program (DEIP) to include home care and hospice connections. The National Opinion Research Center (NORC) has been awarded funding to design, administer and analyze SHINNY Usage & Customer Satisfaction (UCS). It will be used as a metric for inclusion in QE Performance-Based Contracting. NYeC plans to identify representatives from each association to assist with administering surveys to participating members. More information on the UCS process will be released as it becomes available. Reminder: Sign up for DEIP! We remind all HCA members that DEIP funding has been extended for home care and hospice providers through September 2020 (or until funding is exhausted). This extension is a valuable opportunity for providers to gain funds that will enable them to connect and exchange critical health information with other providers. (See https://hca-nys.org/wp-content/uploads/2018/09/DEIP-Article-36-40-September-2018.pdf.) SHIN-NY allows for connectivity among providers for the electronic exchange of information through your electronic health records (EHR). This state-run system helps providers improve patient outcomes, reduce
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unnecessary and avoidable tests and procedures, and lower costs through your connection to any of the eight QEs, which are regional hubs participating in SHIN-NY for the sharing of information. While there are charges for connecting to the QE in your region, the state and federal governments have authorized this now-extended incentive program to help defray the costs of participation through two payments of $2,000 and $11,000 per-connection, on the basis of providers applying for connectivity and meeting certain milestones. The fact sheet linked earlier in this article includes DEIP eligibility requirements for providers seeking funds, including a menu of options for meeting EHR privacy and security requirements, cybersecurity assessment criteria, or confidentiality and privacy audit outcomes (i.e., an SOC 2, Type II audits with no material findings). In addition to the eligibility requirements, providers must meet two milestones, which should be completed by September 30, 2020, as outlined in the DEIP document. Funds are available on a rolling basis, and providers receiving funds must agree to exchange certain data elements.
House Approves Bill to Extend ‘Money Follows the Person’ and Spousal Impoverishment Protections The U.S. House of Representatives on December 11 passed the IMPROVE Act (H.R. 7217), which extends two Medicaid programs for older adults and people with disabilities and establishes a new Medicaid program designed to move pediatric patients with medically complex conditions from institutional settings into community settings. The bill will now proceed to the Senate for its consideration. The IMPROVE ACT is at https://www.congress.gov/bill/115th-congress/house-bill/7217/text. It extends the Medicaid Money Follows the Person (MF) Demonstration program for three months, preventing a further lapse in funds at the end of December and setting up the next Congress to consider a full reauthorization in early 2019. First authorized in the Deficit Reduction Act of 2005, MFP was officially launched in 2007 and is designed to help with rebalancing care from institutional to non-institutional settings. Funds are eligible to be used on home modifications, equipment, and services, such as home care, to keep people in their homes. Similarly, the IMPROVE Act temporarily continues the guarantee of spousal impoverishment protections for older adults and people with disabilities when one is receiving Medicaid coverage for home and community-based services (HCBS). Set to expire on December 31, these protections allow married couples to protect certain assets while seeking Medicaid coverage for home and community-based services (HCBS). Spousal impoverishment protections were initially established to allow the spouse (community spouse) of a Medicaid recipient (institutional spouse) to maintain specified levels of assets and income when the
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institutional spouse was admitted to a skilled nursing facility within Medicaid. The Affordable Care Act extended these protections to situations where the institutional spouse was receiving HCBS.
HHA Claims Must Contain a County Code Starting Jan. 1, 2019 Requirement relates to rural add-on, though all providers must complete the county code The U.S. Centers for Medicare and Medicaid Services (CMS) will require all Medicare home health claims to include the county code, even if they are not subject to the rural add-on payments. Change Request No. 10782 (https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/ 2018Downloads/R4106CP.pdf) provides instructions to the Medicare Administrative Contractors (MACs) on the rural add-on payments for home health agencies (HHAs) that go into effect January 1, 2019. Changes to the rural add-on payments were included in the 2018 Bipartisan Budget Act (BBA) and later included in the final 2019 Home Health Prospective Payment System Rule (HHPPS). This provision also requires that, beginning January 1, “the claim contains the code for the county (or equivalent area) in which the home health service was furnished.” Therefore, CMS will require all home health claims to include the county code, even if they are not subject to the rural add-on payments. CMS received approval for a new value code (85) to be placed on claims, defined as “County Where Service is Rendered.” This is in addition to the CBSA code, value code 61, on the claim. To view the state and county Federal Information Processing System (FIPS) code list, go to https://www.census.gov/geographies/reference-files/2017/demo/popest/2017-fips.html. As a reminder, the rural add-on amounts were revised by the 2018 BBA as follows:
Low Population Density Home Health Agencies (counties with 6 or fewer people per square mile, also known as “frontier” counties): 4 percent add-on in 2019; 3 percent add-on in 2020; 2 percent addon in 2021; and 1 percent add-on in 2021
High Utilization Counties (top quartile of utilization on average): 1.5 percent add-on in 2019 and 0.5 percent add-on in 2020
All Other Rural Areas: 3 percent add-on in 2019; 2 percent add-on in 2020; and 1 percent add-on in 2021
Based on an HCA analysis, Hamilton County will fall under the “Low Population Density” or “frontier” category, while the remaining 23 rural counties in New York will fall under the “All Other” category. In response to this requirement, the MACs have been instructed to:
Accept value code 85 and an associated FIPS State and County Code on home health claims, Type of Bill (TOB) 032x, received on or after January 1, 2019. Continued on next page
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Continued from previous page
Apply rural payment rates based on whether the FIPS State and County Code is in the list of codes associated with one of three categories of rural counties.
Return the claim for correction when the FIPS State and County Code is missing or invalid.
HHAs May Continue to Provide Part B Infusion Therapy in 2019-20 The National Association for Home Care and Hospice (NAHC) reports that Medicare will allow home health agencies to continue providing Part B infusion therapy services as currently structured while the system transitions (2019-2020) toward the new, separate home infusion therapy benefit. The 21st Century Cures Act (Act) included a provision that called for a new home infusion therapy benefit under Medicare Part B. The benefit would provide professional services to beneficiaries receiving home infusion therapy through a pump that is an item of durable medical equipment (DME). Medicare presently covers a limited number of home infusion drugs under the Part B, DME benefit when the drug requires infusion by a pump. These drugs include chemotherapy, inotropic medications, certain pain medications, immunoglobulin therapy, and anti-fungal medications. The U.S. Centers for Medicare and Medicaid Services (CMS) has established a new Medicare supplier designation called “Home Infusion Therapy Suppliers” to administer the new benefit. These qualified suppliers are defined as a pharmacy, physician, or other provider licensed by the state where services are provided. Home health care and hospice providers are eligible to be accredited as home infusion therapy suppliers when the benefit becomes a permanent program. The new benefit includes: the professional service, such as nursing services, under a physician established plan of care that is periodically reviewed; training and education on infusion therapy; remote monitoring; and 24/7 availability by the supplier. CMS would permit remote monitoring to be follow-up telephone calls or onsite visits. Full implementation of the home infusion therapy benefit will begin in 2021, once the benefit becomes a permanent program; at this time, beneficiaries will only be able to receive the services through a home infusion therapy supplier.
Emergency Preparedness Update Last week, HCA met with state Department of Health (DOH) officials from the Office of Emergency Preparedness (OHEP) and the Office of Primary Care and Health Systems Management (OPCHSM) as part of a monthly meeting with the state’s home care associations – HCA and the New York State Association of Health Care Providers (HCP) – who receive funding to work with all home care and hospice providers to support their roles in emergency preparedness. Continued on next page
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Continued from previous page Toolkit The group discussed a recently released Emergency Preparedness Toolkit that was developed for home care and hospice providers, their patients and families. The toolkit is available at https://issuu.com/hcanys/docs/emergency_preparedness_toolkit?e=0. HCA and HCP compiled the toolkit, with the assistance of a workgroup of providers and DOH. The toolkit is a compilation of resources for agencies to use in assisting patients and families on preparations for any type of emergency situation. The information within the toolkit can be provided to patients and their families at the time of admission to an agency so that the planning process is begun and in place as intended – well before an emergency event takes place. The resources address a variety of issues and considerations necessary for effective preparedness planning. This toolkit should also assist agencies and patients under the new federal Conditions of Participation for emergency preparedness, which require patient-specific emergency plans. The toolkit can be shared in its entirety with staff, patients and families, or an agency can select from among the resources provided that best fit the needs of their staff and clients. IOC/CST/MCM Exercises From February through May 2019, OHEP will hold regional Interoperable Communications (IOC), Coalition Surge Tests (CST) and Medical Countermeasures (MCM) exercises outside of New York City (NYC). Home care providers can, but are not required to, participate in the drills and can use them to meet one of their federal and/or state emergency preparedness requirements. The IOC/CST drills will involve an emergency that causes a number of hospitals to evacuate a certain amount of patients and seek placement in other acute care hospitals, nursing homes or to someone’s home with home care. The Medical Countermeasures drill will consist of a simulated anthrax dispersal and distribution of medications to prophylax the community. At this time, the dates for the drills are:
Central NY MCM – February 27 Western NY & Finger Lakes MCM – April 3 Capital District MCM – April 11 Long Island MCM – April 18 Lower Hudson Valley MCM – May 9
The IOC/CST drills at the above locations are expected to be one or more days prior to the MCM exercise. HCA requested, and DOH agreed to provide, a webinar on the upcoming IOC/CST/MCM drills. Continued on next page
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Continued from previous page For the upcoming IOC/CST/MCM drills, agency contacts in the Health Commerce System (HCS) will receive the drill approximately 90 minutes prior to the drill being activated, and they will have 60 to 90 minutes to complete the exercise. HCA will alert members once drills have been activated. Note: in the past, these drill alerts were sent to certain individuals in the HCS communications directory, not by e-mail directly to agencies, so it is important not only to keep your HCS directory listings up-to-date. At the DOH meeting, HCA reviewed some of the issues encountered by members in the fall IOC/CST drills. These issues included home care providers that were not notified about the drills because they have offices in New York City but they serve Long Island and/or Westchester (where the drills were in effect). Providers also needed assistance completing the After-Action Reports and additional further education. The group also reviewed other deliverables that the home care associations are responsible for this year, including participating in Health Emergency Preparedness Coalition (HEPC) meetings, holding an All-Partners emergency preparedness networking program on Long Island (which occurred on November 8), distribution of the Emergency Preparedness Toolkit, and more. Long Island HEPC Meeting On December 6, HCA attended the Long Island HEPC meeting, which covered partner updates and presentations on: 1) the services and patients in various adult care facilities, including adult homes, Assisted Living Programs, and Assisted Living Facilities; 2) shelters and other services of the American Red Cross; 3) a Hospital Active Shooter exercise; 4) the emPOWER and Social Vulnerability Index; and 5) the HEPC Surge Test Exercise. HEPCs are coalitions of health care providers, local and state emergency management and local public health preparedness officials that develop and coordinate emergency preparedness across the continuum, including readiness among individual health sectors, holding exercises and ‘hot washes,’ conducting hazard and vulnerability assessments and other important activities. HCA consistently has encouraged members to participate in their local HEPCs so agencies can develop a network of community partners and resources which will assist in the preparation and response for emergencies. A listing of upcoming HEPC meetings is in the December 3 edition of The Situation Report. For more information, contact Alyssa Lovelace at (518) 810-0658 or alovelace@hcany.org; or Andrew Koski at (518) 810-0662 or akoski@hcanys.org.
Suffolk County Enacts Salary History Ban The Suffolk County Legislature has unanimously enacted a bill that will prohibit employers and their agents from inquiring about a job applicants’ wage or salary history during the hiring process or rely upon such information in setting a new employee’s compensation. The Restricting Information on Salaries and Earnings Act (the “RISE Act”) goes into effect on June 30, 2019 and can be accessed at https://www.scnylegislature.us/DocumentCenter/View/57524/Introductory-Resolution1856-18-PDF?bidId. Continued on next page
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Continued from previous page The legislation applies to employers with four or more employees. It will not apply to any actions taken by employers, employment agencies or employees pursuant to any federal, state or local law that requires the disclosure or verification of salary for employment purposes. In addition, it will not apply to the exercise of any rights under a collective bargaining agreement. According to the Littler Law Firm, similar legislation has been enacted in New York City, Westchester and Albany. Home care providers in Suffolk County should review their employment policies and hiring practices to make any necessary changes to meet the requirements of this new law.
Westchester Passes Legislation Regarding Criminal History and Employment The Westchester County Board of Legislators passed legislation on December 3 that would prohibit employers from inquiring about an applicant’s criminal conviction or arrest record in employment applications. The law is at http://westchestercountyny.iqm2.com/Citizens/FileOpen.aspx?Type=4&ID=19985. If signed by the County Executive, it will go into effect 90 days after being signed. The law also bans employment advertisements, solicitations, or publications containing any “limitation, or specification in employment based on a person’s arrest record or criminal conviction.” After submission of an employment application, an employer may inquire about the applicant’s arrest or conviction record “in accordance with New York State Executive Law section 296(16).” Notably, the law does not apply “to any actions taken by an employer pursuant to any state, federal or local law that requires criminal background checks for employment purposes or bars employment based on criminal history.” Agencies that serve Westchester should check with their counsel to ascertain the effect of this law on their practices and to determine if they need to change any policies and procedures.
2019 Medicaid Levels Announced The state Health Department has posted the 2019 Medicaid income and resource levels. They are at https://www.health.ny.gov/health_care/medicaid/publications/pub2018gis.htm (see GIS 18 MA/ 015). The new amounts are:
Monthly Medicaid Income levels: $859 for individuals (up from $842 in 2018) and $1,267 for couples (up from $1,233); Continued on next page
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Resource levels: $15,450 for individuals (up from $15,150) and $22,800 for couples (up from $22,200), plus individuals can set aside $1,500 for burial purposes and couples can set aside $3,000 for burial expenses;
Community spouse minimum monthly maintenance needs allowance: $3,160.50 (up from $3,090);
Maximum federal Community Spouse Resource Allowance: $126,420 (up from $123,600); and
The home equity limit for Medicaid coverage of nursing facility services and community-based long-term care: $878,000 (up from $858,000).
PHHPC Acts on Home Care and Hospice Applications On December 13, 2018, the Public Health and Health Planning Council (PHHPC) met and acted upon a number of applications by Certified Home Health Agencies (CHHAs), Hospices and Licensed Home Care Services Agencies (LHCSAs). The following applications were approved:
One Certified Home Health Agency (CHHA) to merge with another CHHA;
One CHHA to establish one entity as its parent and another entity as its grandparent;
One hospice to merge with another hospice;
One Licensed Home Care Services Agency (LHCSA) for a change in ownership (under the moratorium exception for applications that address a serious concern such as lack of access to home care services in a geographic area or special needs services);
Two entities to become LHCSAs affiliated with an Assisted Living Program (ALP); and
One LHCSA affiliated with an ALP for a change in ownership.
The PHHPC disapproved an application by one CHHA for a 3-year extension to its limited life operating certification. The agenda and supporting documents are at https://www.health.ny.gov/facilities/public_health_and_health_planning_council/meetings/2018-12-13/. All meetings of the PHHPC and its committees can be viewed via webcast at https://www.health.ny.gov/events/webcasts/.
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HHS Seeks Input on Improving Care Coordination & Reducing HIPAA Regulatory Burdens The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently issued a Request for Information (RFI) seeking input on how the Health Insurance Portability and Accountability Act (HIPAA) rules, especially the HIPAA Privacy Rule, could be modified to further promote coordinated, valuebased health care. HIPAA rules are designed to protect individuals’ health information privacy and security interests, while permitting information sharing needed for important purposes. However, in recent years, OCR has heard calls to revisit aspects of the rules that may limit or discourage information-sharing needed for coordinated care or to facilitate the transformation to value-based health care. The RFI requests information on any provisions of the HIPAA rules that may present obstacles to these goals without meaningfully contributing to the privacy and security of protected health information (PHI) or patients’ rights. In addition to broad input, the RFI also seeks comments on specific areas of the HIPAA Privacy Rule, including:
Encouraging information-sharing for treatment and care coordination.
Facilitating parental involvement in care.
Addressing the opioid crisis and serious mental illness.
Accounting for disclosures of PHI for treatment, payment, and health care operations as required by the HITECH Act.
Changing the current requirement for certain providers to make a good-faith effort to obtain an acknowledgment of receipt of the Notice of Privacy Practices.
The RFI may be downloaded from the Federal Register at https://www.govinfo.gov/content/pkg/FR-2018-1214/pdf/2018-27162.pdf and public comments on the RFI will be due by February 11, 2019.
2017 National Health Expenditures Released The Office of the Actuary at the U.S. Centers for Medicare and Medicaid services (CMS) completed an analysis on the 2017 National Health Expenditures. It is estimated that health care spending in the U.S. grew at a rate of 3.9 percent to $3.5 trillion in 2017, equal to $10,739 per person. Health expenditures accounted for 17.9 percent of Gross Domestic Product (GDP) share, almost matching its 2016 growth of 18 percent and showing signs of share stabilization. The data is available at https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-andReports/NationalHealthExpendData/NationalHealthAccountsHistorical.html. While GDP shares have stabilized, 2017 presented much slower growth in health care spending compared to previous years. On a per-capita basis, national spending grew by only 3.2 percent, a decrease compared to
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the growth of 4 percent in 2016. The deceleration in spending costs is primarily attributed to the slower growth in hospital care, physician and clinical services, and retail prescriptions drugs. Home Health Care Overview Making up 3 percent of the GDP share, freestanding home health care agency spending grew by 4.3 percent in 2017, the same as 2016, to $97 billion. Slower growth in Medicaid spending and private health insurance spending was offset by faster Medicare spending and out-of-pocket spending. Together, Medicare and Medicaid made up 76 percent of home health care spending nationally in 2017. (See chart below.) Making up the remaining 24 percent were private health insurers, out-of-pocket costs, third-party payers, and other health insurance programs. Private health insurance reached $10.8 billion in spending, showing minimal growth from 2016 and continuing its steady decline in growth since 2013. Out-of-pocket spending hit $9 billion, growing 4.6 percent and reaching its highest spending point since 2013. Medicaid spending ended 2017 at $35 billion, slowing its overall growth to 3.7 percent compared to 4.4 percent growth in 2016. This decline has expanded the spending distribution gap between Medicaid and Medicare. Medicare now accounts for 40 percent of the spending, growing at a rate of 4.8 percent, reaching $38.8 billion.
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NGS Announces Upcoming Annual Logon ID Recertification National Government Services (NGS), New York’s principal Medicare Administrative Contractor (MAC), will begin the Fiscal Intermediary Standard System Direct Data Entry (FISS DDE) logon recertification beginning the week of January 7, 2019 for New York and Connecticut Medicare providers. The recertification process must be completed by January 21, 2019 for New York or else FISS DDE access will be removed. Those logon IDs will be required to submit additional paperwork to have access restored. Users who have an active logon ID with access to Part A or Home Health and Hospice will be issued an access code by e-mail. The e-mail will be sent to the current authorized address on file with NGS’s electronic data interchange (EDI). All logon IDs must complete the recertification process within ten business days of receiving the access code. Any logon ID that has been assigned new or reinstated after December 31, 2018 will not be required to recertify until the following year’s recertification. NGS recommends that FISS DDE users watch their e-mail beginning the week of January 7, 2019 and complete the recertification per the instructions provided along with your access code. If you do not receive an email by Wednesday, January 9, 2019, you should submit a Recertification Inquiry Form at: https://enrolledi.ngsmedicare.com/recertinquiry.
NGS Closed on Christmas and New Year’s NGS will be closed on December 25 and January 1 for the Christmas and New Year’s Holidays. This includes the Electronic Data Interchange (EDI) Help Desk, Provider Contact Center, Provider Enrollment Line, and Telephone Reopening Unit. Electronic claim files transmitted after 5 p.m. on Monday, December 24 and Monday December 31 will have a claim receipt date of Wednesday, December 26, 2018 or Wednesday, January 2, 2019, respectively. EDI frontend acknowledgement transactions will be created as expected as EDI claim files are received. The Direct Data Entry (DDE) Provider Online System will be available on December 26 and January 2 during regular hours and providers will also be able to access NGSConnex and use the Interactive Voice Response (IVR) system at 1-866-275-3033 during the closure days.
CMS Special Open Door Forum (ODF) on Level II HCPCS The U.S. Centers for Medicare and Medicaid Services (CMS) is hosting a Special Open Door Forum (ODF) tomorrow, December 18, to announce changes to CMS Level II Healthcare Common Procedure Coding System (HCPCS) Coding Procedures and HCPCS Code Application Procedures effective in the 2019-2020 HCPCS coding cycle. All stakeholders are invited to ask questions and learn more about these process changes as detailed on CMS’s HCPCS website at: http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/index.html.
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Continued from previous page CMS is also interested in adopting changes to the HCPCS process that facilitate the adoption of new technologies while balancing the burden on payers and providers. The following changes will be made to the HCPCS coding process for calendar year 2019: 1. Clarifying and updating website guidance associated with the application process to promote transparency and clarity. (See the HCPCS Code Application Form and Instructions 2020 at https:// www.CMS.gov/Medicare/Coding/MedHCPCSGenInfo/Application_Form_and_Instructions.html). 2. A new electronic application process and the first public beta test of this process with a limited number of stakeholders for the 2019 cycle. (See the announcement of CMS’s public beta test under “What’s New” on CMS’s General Info site at: https://www.CMS.gov/Medicare/Coding/MedHCPCSGeninfo/index.html). 3. Eliminating the three percent (of market) volume criteria for non-drug items. CMS will continue to collect marketing data on the application to support the establishment of a new code. 4. Providing more detailed responses to applications in order to provide for greater transparency and to assist the public in understanding CMS’s decision-making. 5. Providing for remote participation in HCPCS public meetings. Dial-in information for the call is below.
Participant Dial-In Number: 1-800-837-1935 Conference ID number: 3073759
IRS Issues Standard Mileage Rates for 2019 The Internal Revenue Service (IRS) recently issued the 2019 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes. Beginning on Jan. 1, 2019, the standard mileage rates for the use of a car (also vans, pickups or panel trucks) will be:
58 cents per mile driven for business use, up 3.5 cents from the rate for 2018;
20 cents per mile driven for medical or moving purposes, up 2 cents from the rate for 2018; and
14 cents per mile driven in service of charitable organizations.
The standard mileage rate for business use is based on an annual study of the fixed and variable costs of operating an automobile. The rate for medical and moving purposes is based on the variable costs.
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Upcoming Deadlines and Due Dates
22
Requirement/Change
Effective/Due Date
More Information
“LHCSA Network Survey” and “Continuity of Service and Continuity of Care Reporting” spreadsheets must be submitted by MLTC plans to state Department of Health
December 20, 2018
LHCSAExceptions@health.ny.gov
Transition Period for Using Health Insurance Claim Number (HICN) or new Medicare Beneficiary Identifier (MBI)
April 1, 2018 to December 31, 2019
https://www.cms.gov/Medicare/NewͲMedicareͲCard/index.html
2017 LHCSA Statistical Report Due
LHCSAs will face fines if submitted between November 16, 2018 and December 31, 2018
https://commerce.health.state.ny.us/public/hcs_login.html
LHCSA Registration Process
Must be submitted with LHCSA Statistical Report; if not submitted by January 1, 2019, agency will not be able to https://commerce.health.state.ny.us/public/hcs_login.html operate or receive reimbursement from any source
Federal Deficit Reduction Act Compliance Certification form
December 1 to December 31, 2018
https://omig.ny.gov/draͲcertification
State Mandatory Compliance Certification form
December 31, 2018
https://omig.ny.gov/sslͲcertification
Minimum Wage Increase
December 31, 2018
https://www.labor.ny.gov/workerprotection/laborstandards/work prot/minwage.shtm
Submission of marketing materials used prior to November 1, 2018 by Fiscal Intermediaries to state Department of Health under “amnesty” review process
December 31, 2018
https://www.health.ny.gov/health_care/medicaid/redesign/mrt90 /mltc_policy/docs/2018Ͳ10Ͳ22_fiscal_advert_policy.pdf
OASISͲD for Certified Home Health Agencies
January 1, 2019
OASISͲD Guidance Manual: https://www.cms.gov/Medicare/QualityͲInitiativesͲPatientͲ AssessmentͲ Instruments/HomeHealthQualityInits/HHQIOASISUserManual.html
Comments due on state Department of Labor proposed employee scheduling/callͲin pay rule
January 11, 2018
hearing@labor.ny.gov
2017 CHHA and LTHHCP Statistical Report
February 1, 2019
https://commerce.health.state.ny.us/public/hcs_login.html
2017 Hospice Cost and Utilization Report
February 1, 2019
https://commerce.health.state.ny.us/public/hcs_login.html
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Health Resources
“MACStats: Medicaid and CHIP Data Book,” by the Medicaid and CHIP Payment and Access Commission https://www.macpac.gov/wp-content/uploads/2018/12/December-2018-MACStats-Data-Book.pdf
“Trends in Postacute Care Spending Growth During the Medicare Spending Slowdown,” by the Commonwealth Fund https://www.commonwealthfund.org/publications/issue-briefs/2018/dec/postacute-care-spendinggrowth-medicare
For more information, contact Andrew Koski at akoski@hcanys.org or (518) 810-0662.
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