Legislative Issues Public Policy News A Weekly Publication Of HCA HCA HCA HCA HCA Home Care Association of New York State Helping New Yorkers Feel Right At Home A S AP Volume 20, No. 44 December 18, 2015 Inside Inside Inside Inside Inside ASAP ASAP ASAP ASAP ASAP See SURVEY p. 3 See FLSA p. 2 This is the last issue of ASAP for 2015 as we head into the holiday and New Year season. We will send you e-mail alerts as needed over the next two weeks and will publish ASAP again on January 8. Our offices will be closed from December 25 through January 3, reopening on January 4. HCA wishes you a joyous end to the year. HCA Appeals to Governor to Restore EPS Funding HCA Needs Your Response to Fiscal Survey So We are Armed with Impact Data HCA met with officials of the Governor’s office and state Department of Health (DOH) on Wednesday urging the restoration of Episodic Payment System (EPS) funding for home care to the agreed-upon, state budgeted levels. DOH this October reduced EPS funding by two-to-three times the cut level built into the 2015-16 budget. The budget had established a projected impact of EPS rebasing this year that agencies have been relying upon in their forecasting, at odds with the levels later implemented by DOH. FLSA Funding Update Late last Friday, after ASAP went to press, HCA met with state Department of Health (DOH) finance staff to obtain more information about the state’s plan to provide funding to managed care plans and home care providers to help them with new costs under the recently adopted changes to the federal Fair Labor Standards Act (FLSA). Have You Had a Chance to Complete HCA’s Financial Survey Yet? HCA’s State Advocacy Day is February 2: details coming soon! HCA wanted to check in again and make sure you saw the message and ASAP article last week about completing our 2015 Home Care Financial Condition online survey. See EPS p. 5 HCA Appeals to Governor to Restore EPS Funding..........................1 Have You Completed HCA’s Financial Survey Yet?...............................1 FLSA Funding Update..........................................................................1 Important Dates to Take Note Of…....................................................2 Don’t Forget to Renew Your HCA Membership...................................4 Member Hiring Announcements…......................................................4 FLSA Changes Highlighted at January 6 Program...............................6 CMS Releases New Home Health Utilization, Payment Dataset.…..6 Forums for Upstate LHCSAs, Downstate HCC Members…...............7 Early Bird, Hotel Deadline Extended for HH Leadership Summit.......8 Deadline Extended to Jan. 4 for HCA’s Board Nominations................9 Value Based Payment Subcommittees Submit Recommendations....9 Governor Vetoes Fiscal Intermediary Licensure Bill..........................10 DOH Eyes Revisions, Testing of Emergency Preparedness Survey ....10 HHCAHPS Preview Reports with Star Ratings Available..................11 Upcoming Recertification for DDE Users….......................................12 Q&As Posted on Nonprofit Capital Investment Program.................12 FIDA Update…...................................................................................13 DSRIP Update.....................................................................................13 OMIG Posts Compliance Webinars’ Q&As........................................13 NGS Closed on Christmas and New Year’s..................................…..14 Publications.................................................................................................14
Transcript
Legislative Issues Public Policy News
A Weekly Publication Of HCAHCAHCAHCAHCAHome Care Association of New York State
This is the last issue of ASAP for 2015 as we head into theholiday and New Year season. We will send you e-mail alertsas needed over the next two weeks and will publish ASAPagain on January 8. Our offices will be closed from December25 through January 3, reopening on January 4. HCA wishesyou a joyous end to the year.
HCA Appeals to Governor to Restore EPS FundingHCA Needs Your Response to Fiscal Survey So We are Armed with Impact Data
HCA met with officials of the Governor’s office and state Department of Health (DOH) on Wednesday urgingthe restoration of Episodic Payment System (EPS) funding for home care to the agreed-upon, state budgetedlevels.
DOH this October reduced EPS funding by two-to-three times the cut level built into the 2015-16 budget. Thebudget had established a projected impact of EPS rebasing this year that agencies have been relying upon in theirforecasting, at odds with the levels later implemented by DOH.
FLSA Funding Update
Late last Friday, after ASAP went to press, HCA metwith state Department of Health (DOH) finance staffto obtain more information about the state’s plan toprovide funding to managed care plans and home careproviders to help them with new costs under therecently adopted changes to the federal Fair LaborStandards Act (FLSA).
Have You Had a Chance to Complete
HCA’s Financial Survey Yet?HCA’s State Advocacy Day is February 2: details comingsoon!
HCA wanted to check in again and make sure you sawthe message and ASAP article last week aboutcompleting our 2015 Home Care Financial Condition
online survey.
See EPS p. 5
HCA Appeals to Governor to Restore EPS Funding..........................1Have You Completed HCA’s Financial Survey Yet?...............................1FLSA Funding Update..........................................................................1Important Dates to Take Note Of…....................................................2Don’t Forget to Renew Your HCA Membership...................................4Member Hiring Announcements…......................................................4FLSA Changes Highlighted at January 6 Program...............................6CMS Releases New Home Health Utilization, Payment Dataset.…..6Forums for Upstate LHCSAs, Downstate HCC Members…...............7Early Bird, Hotel Deadline Extended for HH Leadership Summit.......8Deadline Extended to Jan. 4 for HCA’s Board Nominations................9Value Based Payment Subcommittees Submit Recommendations....9Governor Vetoes Fiscal Intermediary Licensure Bill..........................10DOH Eyes Revisions, Testing of Emergency Preparedness Survey....10HHCAHPS Preview Reports with Star Ratings Available..................11Upcoming Recertification for DDE Users….......................................12Q&As Posted on Nonprofit Capital Investment Program.................12FIDA Update…...................................................................................13DSRIP Update.....................................................................................13OMIG Posts Compliance Webinars’ Q&As........................................13NGS Closed on Christmas and New Year’s..................................…..14Publications.................................................................................................14
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ASAP is a weekly publication of the Home Care Association of NewYork State (HCA). Unless otherwise noted, all articles appearing inASAP are the property of the Home Care Association of New YorkState. Reuse of any content within this newsletter requires permissionfrom HCA.
ASAP – a publication of the Home Care Association of New York State Volume 20, No. 44 December 18, 2015
FLSA from p. 1
As covered in last week’s (and prior) newsletters, the state intendsto increase the managed care plan rates by the state share of $.34per hour to account for new overtime, travel and live-inrequirements and also provide an increase to Medicaid fee-for-service rates. The state has not decided how the money will flowfrom the managed care plans to their contracted home careproviders; for instance, if the funds will be passed through on allhome care hours or if the plans will have leeway in distributing anaggregate amount. DOH intends to issue instructions on such a“pass-through” once it finalizes the method.
At last Friday’s meeting, DOH confirmed that in January it hopesto adjust plans’ rates for the period October 1, 2015 through March31, 2016 to account for the FLSA changes. For April onward,Mercer (the state’s contracted actuary for managed care rates) willuse a data-collection survey to solicit home care providers’ actualcosts and then make a prospective adjustment to the plans’ rates.
DOH is also still considering HCA’s proposed set-aside/stop-loss poolmechanism to better finance overtime and other new labor costs.
HCA continues to emphasize the impact of these new costs andadvocate that the state provide money to plans and their home careproviders as soon as possible. We will keep members informed of thestate’s actions.
For more information, contact Andrew Koski at (518) 810-0662 [email protected].
Take Note: Important Dates
Minimum Wage Increase from $8.75to $9.00 per hour: December 31, 2015
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Volume 20, No. 44 December 18, 2015
We realize that these surveys can take time to complete, but they are the best way for us to obtain and trendcurrent data on your experience with the fiscal and regulatory environment of home care in New York State.
If you completed the survey, thank you. If not, please do so as soon as you can. The survey has 30 questions.All answers will be used in the aggregate and no agency-specific identifying information will be shared.
The survey due date is January 15, but we ask for your responses as soon as possible so that we can startreviewing the data and preparing our resource documents for our February 2 State Advocacy Day.
A PDF of the survey is published at the back of this week’s ASAP, and you are welcome to e-mail or fax itback to HCA’s Communications Director Roger Noyes at [email protected] or (518) 426-8788. You canalso complete the survey online at https://www.surveymonkey.com/r/2015HomeCareFinCondSurvey.
If you have any questions, do not hesitate to contact Roger Noyes at [email protected].
We will be sending further information about our State Advocacy Day next week, once the programagenda is finalized, and once we’ve gotten firm commitments from state elected officials and other speakerswho have been invited to address advocates.
The program will begin the night before, on February 1, where we’ll hold a Political Action Committee(PAC) reception in Albany, followed by a meeting of our Board of Directors and legislative visits onFebruary 2.
Like last year, HCA is asking our Board of Directors to come to Albany for this program, as theassociation’s leadership core, to engage in legislative visits with key staff, but we welcome other non-Board
HCA member leaders to join us for this important opportunity to meet face-to-face with key legislatorsand staff of the Governor’s office at the Capitol.
Please stay tuned for an e-mail alert next week with registration and agenda details. Below is a brieftimeline-at-a-glance.
HCA’s State Advocacy Day Timeline: What you Need to Know Now
• Before January 15: Complete HCA’s Financial Condition Survey
• Next Week: Look for an agenda and registration for our Advocacy Day program
• Late January: HCA will circulate Advocacy Day resource documents
• February 1: Join us for our PAC reception in Albany
• February 2: HCA members and HCA staff will participate in prescheduled visits with theLegislature and Governor’s office.
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HIRING
Patient Relations Manager
Americare, New York’s leader in home health care, seeksa high energy, dynamic, self-starter for an exciting careeropportunity in its patient relations department. ThePatient Relations Manager’s primary responsibility will beto develop relationships and educate MDs about homecare and the benefits to their patients. The idealcandidate will have 2-3 years home care orpharmaceutical experience. An excellent compensationand benefits package is offered, including: 401K withcompany match, medical, dental and direct deposit.
Title: Director of Patient ServicesOrganization: Winthrop University Hospital HomeHealth Agency
Winthrop seeks a Director of Patient Services for theCHHA, which services Nassau, Suffolk and Queens. The DPSis responsible for the administrative, professional andclinical operations of the agency. Minimum qualificationsinclude: BSN, NYS RN license, two years of professionalnursing experience, two years of supervisory experience ina CHHA or related program, Master’s degree preferred.
HCA Membership in 2016It’s easy, just complete a simple form and you areready to continue your membership in 2016
HCA reminds members to renew yourmembership in HCA before the year closes out.We’ve made the process simple for you, by askingyou to complete an online form with simplecontact information and any changes in yourdues level.
By now, your agency’s key member contact shouldhave received a link to our online forms forrenewal. We’ve republished those links below.
Simply find your organization type/categoryand complete the online form at one of the linksbelow. Please pick only one link that relates toyour organization type:
Note: These links are for member renewalsonly. If you are not yet an HCA member orneed more information, contact our Director ofMembership Laura Constable [email protected] or (518) 810-0660.
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EPS from p. 1
HCA requested this week’s meeting toask the state to restore the remainingfunds (the difference between the DOHlevel and the levels assumed in the statebudget) on the heels of GovernorCuomo’s recent veto of legislation thatwould have ensured funding at the budgetlevel by limiting any cut from rebasing toexceed the adopted budget amount.
In a letter to the Governor, legislativesponsors Senator Kemp Hannon andAssemblyman Richard Gottfriedrequested the Governor to restore thehome care EPS funding level to thebudget agreement regardless of whetherhe signed or vetoed their codifying bill –aligning EPS rebasing with the budgetprocess and the agreement with theLegislature.
However, in Wednesday’s meeting,DOH officials argued in favor of their full cut level on the basis that, since EPS’s inception in 2012, themigration of home care patients into managed care has decreased the actual expenditure levels under EPS to theamounts reflected in the new base, thus “justifying” their action.
HCA, joined by the leaders of several HCA providers, contested the Department’s action, explaining the widegaps between the costs and methods reflected in the DOH-derived base year for EPS and actual costs borne byhome care providers. HCA specifically listed for the Executive many of the currently unrecognized, unreimbursedcost-inputs that are critical to home care’s functioning, access, stability and, ultimately, its ability to fulfill itssought-after role in the changing health care system.
HCA and providers further profiled the already-serious financial condition of home care agencies across thestate, and gave specific examples of the DOH EPS cut’s impact on agency operations and services. We alsounderscored the conflict between these cuts and the state’s reliance on home care for the success of its newpolicies, reforms and models of care.
At the meeting’s conclusion, the Executive continued to stand firm on its EPS cut level, irrespective of the budgetagreement or the argued impact on home care. However, State Medicaid Director Jason Helgerson expressedwillingness to consider, and to work with HCA toward, potential future revisions in the methodology thatwould better reflect home care agency costs and needs in the evolving system. We appreciate that overture andopportunity for progress resulting from this meeting.
In next steps, HCA will follow-up to present the Executive with proposals for improving the state’sreimbursement levels and methods for home care, as well as continue to reach out to the state Legislature forfurther support and proposals for remedy.
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As you renew your HCA membership for 2016,check out a recent video message from HCAPresident Joanne Cunningham about all that HCAhas in store for the coming year. Just click the boxabove or view the video directly on Youtube athttps://youtu.be/eZT4Apr9kTw
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Continued from previous page
Important: your HCA Financial ConditionSurvey responses will help this effort
In last week’s ASAP and in two alerts to themembership, HCA circulated our 2015 HomeCare Financial Condition survey which asksseveral questions about CHHA EPS rebasingand other fiscal impacts for CHHAs and otherhome care agencies over the past year.
Your answers to this survey are vital to our
advocacy on your behalf. The survey is availablefor completion online, but we have published anentire PDF version of the survey at the back ofthis week’s ASAP, and you are welcome tocomplete it by hand on a printed PDF – and fax itback to HCA – or complete the online version ofthe survey at https://www.surveymonkey.com/r/2015HomeCareFinCondSurvey.
We greatly appreciate your attention to thiseffort during a time when your organization isfocused on so many other major priorities. Pleasecontact any of the HCA Policy staff or HCACommunications Director Roger Noyes
([email protected]) if you have any questions orconcerns related to your completion of the survey.
HCA will hold another program on the recent FairLabor Standards Act (FLSA) companionshipexemption changes that is similar to a well-attendedprogram we had on December 15.
The January 6 program will review the FLSA changesconcerning overtime, travel and live-in cases; otherhome care labor issues; and ways for agencies to protectthemselves from lawsuits over these and otherpractices.
The program will be led by the Littler Mendelson lawfirm, attorneys that have years of experience inrepresenting home care agencies in lawsuits, including oneof the plaintiffs in the legal challenge to the FLSA rule.
Members who attended the December 15 programfound the information on compliance very valuable andleft with a lot of good tools to help them in this verycomplicated area.
We urge you to register for the January 6 event beforeit gets filled.
Registration is at http://hca-nys.org/wp-content/uploads/2015/11/January-6-Survival-Bootcamp-Companionship-Registration-Form-2.pdf.
CMS Releases New Home Health Utilization and Payment Dataset
The U.S. Centers for Medicare and Medicaid Services (CMS) this week released a new dataset: the HomeHealth Agency Utilization and Payment Public Use File (Home Health Agency PUF).
This data set, which is part of CMS’s Medicare Provider Utilization and Payment dataset, detailsinformation on services provided to Medicare beneficiaries by home health agencies (HHAs). These new datainclude information on 11,062 HHAs, over 6 million claims, and over $18 billion in Medicare payments for2013.
The data is posted on the CMS website at: https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/Medicare-Provider-Charge-Data/HHA.html.
The data set identifies individual HHAs using their 6-digit identification number. Services furnished by theseHHAs are grouped according to case-mix groupings, or home health resource groups (HHRGs). For each
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HHA and HHRG, the data set has the total number of episodes that were provided, distinct number ofbeneficiaries served, the HHA’s total and average charges, the total and average Medicare payments, and thetotal and average Medicare standardized payments.
The HHA provider dataset also has additional information on low-utilization payment amount (LUPA)episodes and outlier payments. The data set does not contain any individually identifiable information aboutMedicare beneficiaries. To further protect the privacy of Medicare beneficiaries, any aggregated records whichare derived from 10 or fewer claims are excluded from the Home Health Agency PUF. The data also allowsfor many types of analyses to be performed, including, for example, summary analyses by HHRG and state.
For further information, contact HCA’s Patrick Conole at (518) 810-0661 or at [email protected].
Forums Scheduled for Upstate LHCSAs & Downstate HCC Members
In January, HCA is holding two members-only Forums: the first for our upstate LHCSA members on January
14, and the second for our Home Care Council (HCC) of HCA Members on January 28.
Both sessions will address discrete issue areas of concern to both segments of our membership, including someoverlapping issue areas such as the companionship exemption changes for overtime
and the state's proposed funding mechanism; the proposed$15/hour minimum wage and HCA advocacy in this area;regulatory issues; and more.
The Upstate LHCSA forum will include a discussion of regionalLHCSA-specific concerns and opportunities/challenges underthe Delivery System Reform Incentive Payment (DSRIP)program and value-based payment. The HCC Forum will alsodelve into regional issues related to the companionship exemptionchanges and the Human Resources Administration.
Details for both meetings are below; registration/agenda informationis at http://hca-nys.org/events-education/upcoming-events.
Upstate LHCSA Forum
January 14, 201610 a.m. to 12:30 p.m.Location: VNA Homecare, 1050 West Genesee Street,Syracuse, NY 13204All HCA-member upstate LHCSAs are invited.
Home Care Council of HCA Member Forum
January 28, 201610 a.m. to 12:30 p.m.Hunter College Brookdale Campus425 East 25th Street(Between 1st Ave. and FDR Drive)The Osborn Room (Mezzanine Level)New York, New York 10010All HCC of HCA Members are invited.
Home care vendors, consultants,providers and business associates: Haveyou seen HCA’s new 2016 MarketingProspectus? It offers a range ofsponsorship and exhibiting opportunitiesfor 2016. Check out a short, 2-minutevideo about the prospectus at https://youtu.be/thQbgk9VU-M, or download theprospectus directly from our website athttp://hca-nys.org/events-education/sponsors-exhibitors.
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Due to Overwhelming Response Rate, Early Bird and Hotel
Deadline Extended for Northeast Home Health Leadership SummitEarly-bird rate extended to December 23, and hotel rate extended through January 4!
With so many people joining the home health leadership “go team” at the NortheastHome Health LeadershipSummit, participatingassociations have extendedthe early-bird deadline toDecember 23 (close ofbusiness) and the hoteldeadline has extended toJanuary 4 or until the roomblock sells out.
Now you have more time toregister for the discountedrate at this premierconference of home healthexecutives in the northeast.
If you haven’t checked out our fun, 2-minute video about the conference, we encourageyou to do so as you get primed for this first major conference of 2016. Click the imageabove or go directly to youtube at: https://youtu.be/SmMe4o3UF8Y.
To register, please visit the summit website at http://nehomehealthsummit.com/where you can find online registration, a brochure and a list of our sponsors.
Volume 20, No. 44 December 18, 2015ASAP – a publication of the Home Care Association of New York State
Value Based Payment Subcommittees Submit RecommendationsCore Committee Begins Review Over the past several weeks, various subcommittees meeting under the value-based payment (VBP) initiativehave concluded their round of work and submitted recommendations to the state Department of Health on theirtopical areas.
Yesterday, DOH convened its overall core VBP steering committee, of which HCA is a member, to review thesubcommittees’ recommendations and provide initial comment. The Department has invited core committeemembers to provide written comments by December 24, and DOH intends to then further review with thesubcommittees and core committee before proceeding with a final proposal package.
HCA invites our home health, hospice, and managed care plan members to review the latest material and provideyour comments, perspectives and recommendations to us to consider for our written comments next week. TheDOH slides and a consolidated summary embodying the recommendations can be viewed here:
The core committee will meet again in early January to consider the balance of recommendations not discussed atyesterday’s meeting. DOH also plans to convene the committee at various intervals throughout the spring toconsider further issues, design elements and implementation matters, as well as to establish a further set ofsubcommittees to delve more deeply into areas that the current subcommittees examined but felt needed additionalanalysis and discussion.
Meanwhile, at HCA’s suggestion, DOH will prepare a matrix showing all of the various recommendations andchanges proposed for VBP and the particular route by which each change or planned step would be implemented(i.e., legislatively, by regulation, contract change, administrative procedure, or budget).
HCA will also continue our efforts in providing state-level advocacy for home care in value based payment, technicalassistance to providers, and additional information and education to assist providers as this process moves forward.
HCA continues to strongly encourage providers to be as familiar as possible with the VBP construct, especiallythe areas targeted by the state and the subcommittees, so that you can identify and advance your capabilities andvalue-proposition to potential partners (including managed care plans, hospitals, physicians, behavioral healthproviders and others).
For further information, please contact Al Cardillo at [email protected].
Deadline Extended to Jan. 4 for HCA’s Board of Directors Nominations
The HCA Nominating and Governance Committee is seeking applications for members on HCA’s main governingunit, our Board of Directors, which is an exceptional opportunity for a visionary home care leader to influence thestrategic direction of our organization and serve with distinction on behalf of New York’s entire home careindustry. Applicants should have demonstrated leadership potential, a strong interest in public policy and advocacy,and commitment to promoting and implementing a vision and strategic policy direction for the home care industryand the Association.
The deadline has been extended until January 4, so get your nominations in as soon as possible by downloading theform at http://hca-nys.org/wp-content/uploads/2015/12/2016-HCA-Board-Nomination-Application-3.pdf.
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Governor Vetoes Fiscal Intermediary Licensure Bill
Governor Cuomo has vetoed legislation that would have required a new licensure process for entities providingfiscal intermediary (FIs) services to patients receiving consumer directed personal assistance services (CDPAS).
HCA had raised a number of issues with the legislation (S.5565B/Hannon; A.7535B/Gottfried), including, amongother concerns:
• The fact that there is no need for licensure, as home care agencies and other FI entities are already licensed bythe state and face strict oversight and do not need to undergo a duplicative process;
• FIs already have to follow state regulations and state Department of Health (DOH) guidance documentsthat were recently updated;
• The lack of DOH resources to administer a new licensing process and anticipated delays in approval fornew FIs and the adverse impact on consumers.
The Governor’s veto message supported some of our concerns by recognizing that FIs already need to obtain aMedicaid number which subjects them to additional oversight by the federal government, DOH and the state Officeof the Medicaid Inspector General, and that DOH has clarified the conditions under which MLTC plans may signan administrative agreement with an FI to administer CDPAS services.
In his veto message Governor Cuomo also indicated that:
The next step toward ensuring that all fiscal intermediaries are held to the same compliance standard is todevelop a statewide regulatory and licensure program. However, the statewide licensure program proposedby this bill poses significant fiscal challenges which must be carefully evaluated and negotiated as part ofthe budgeting process. For these reasons, I am constrained to veto this bill. In the interim, however, I amdirecting the Department to work collaboratively with the Department of Financial Services, the bill’ssponsors, and interested stakeholders to develop a fiscally-sound framework for regulating fiscalintermediaries that best serves the needs of persons utilizing [CDPAS].
HCA will reach out to DOH so that we are included in future discussions about further regulating the FIs.
For more information, contact Andrew Koski at (518) 810-0662 or [email protected].
DOH Planning Revisions, Testing of Emergency Preparedness Surveys HCA participated in a meeting yesterday with state Department of Health (DOH) officials to review DOH-revised survey instruments for home care agencies and hospices for completion and tracking during public emergencies. Specific parts of a multipart survey process are designed by DOH to be put into motion in emergencies dependingon the nature, extent and details of the emergency.
The sections of the survey include basic agency and patient information, agency surge capacity resources and/orassistance needs, evacuation and repatriation information, and others.
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The Department also reviewed a survey intended for completion by hospice providers to determine the statusand extent of hospice emergency preparedness planning.
The Department plans to issue in the next several months a Dear Administrator letter reminding, clarifying andstipulating for providers the required contact persons and roles for indication on the Health Commerce System(HCS). HCA reminds providers to check their agency’s contacts currently listed/required for the HCS to besure that all such individuals and related information are accurate and up to date.
HCA has posted a version of this story on our website with six links to the draft surveys. Please see this storyon our “General News” feed at http://hca-nys.org/category/general-news and provide HCA with any furthercomments on the surveys, which we, in turn, will add to our feedback to the Department.
DOH plans an HCS emergency preparedness drill this spring using the revised survey tools. HCA requestedand DOH agreed to conduct a webinar, likely to be held in February, providing a walk-through of the surveysand an opportunity for exchange with the home care sector.
For further information, please contact Al Cardillo at [email protected].
HHCAHPS Preview Reports with Star Ratings Available
Preview Reports reflecting results from the Home Health Care Consumer Assessment of Healthcare Providersand Systems (HHCAHPS) Survey from July 2014 through June 2015 (third-quarter 2014 to second-quarter2015) are now available on https://homehealthcahps.org under the “For HHAs” tab.
Home health agencies (HHAs) must be logged into the website to view their reports. These same data will beupdated on Home Health Compare (at www.medicare.gov) in late January 2016.
The Preview Reports present the publicly reported results with Star Ratings for those agencies with a sufficientnumber of completed interviews to receive Star Ratings. Agencies must have data for 40 or more patient surveysin the reporting period in order to have Star Ratings.
To access an agency’s HHCAHPS Preview Report, log into the HHCAHPS website using your usernameand 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 “Forgot Password,” and follow the directions to have yourpassword sent to you via e-mail.
If you have comments about your HHCAHPS Star Ratings on the Preview Report, please e-mail the followinginformation to [email protected] by December 31, 2015:
• Your name, your facility name, your CCN, and your contact information.
• Your comments about your preview report.
• If you believe your Star Ratings are not correct, submit evidence showing why. If you have historicallyhad higher ratings than are shown, this is not considered evidence for incorrect ratings; you must
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provide information showing that the data submitted by your vendor for the most recent quarter areincorrect and therefore may have impacted ratings.
For information about the HHCAHPS Preview Reports, refer to the March 23, 2012 announcement at https://homehealthcahps.org/GeneralInformation/Announcements/tabid/269/EntryId/142/HHCAHPS-Preview-Reports.aspx.
If you have any questions about HHCAHPS Star Ratings on your HHCAHPS Preview Report, [email protected] or (866) 354-0985.
More information on Star Ratings is at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIHomeHealthStarRatings.html.
Upcoming Recertification for DDE UsersProcess impacts All NGS Jurisdiction 6 DDE Users
All users who access the Direct Data Entry (DDE) systems are required by the U.S. Centers for Medicare andMedicaid Services (CMS) to recertify their access annually.
NGS will begin the annual recertification for logon IDs in the coming weeks, with a few process changes fromlast year. NGS will divide the logon IDs by Jurisdiction 6 ( J6) contract. Each NGS workload (New York is in theWisconsin workload) will be required to recertify during a preselected month.
The recertification process for New York (under the Wisconsin workload) will begin January 2016. Any userwho currently has access to the Part A Wisconsin Fiscal Intermediary Shared System (FISS) DDE will be issuedan access code by e-mail. The e-mail containing the access code will be sent to the current authorized e-mailaddress on file with NGS’s Electronic Data Interchange (EDI). All Logon IDs will be required to have completedthe recertification process within two weeks of receiving the access code.
Any new or reinstated logon ID on or after December 1, 2015 will not be required to recertify until the followingyear’s recertification. NGS EDI will provide more information in the coming weeks.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
Q&As Posted on Nonprofit Infrastructure Capital Investment ProgramSubmission Deadline Extended
As reported in last week’s ASAP, the state has posted Questions and Answers (Q&As) on the NonprofitInfrastructure Capital Investment Program (NCIP), a potential source of funding for HCA’s nonprofit members.
The Q&As are at http://www.dasny.org/Libraries/RFP_-_461/Questions_Answers_12-11-15.pdf.
The 61-page document covers many issues including: eligibility of home care agencies, hospices, and MLTCplans; multiple applications by one entity; eligibility of entities that receive Delivery System Reform IncentivePayment (DSRIP) program funds; use of funding for technology upgrades, electronic health records, mobilephones, tablets, and consultants; eligibility of consortiums; use of funds for staff training and development; andothers.
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HCA advises members who plan to seek funding to review the Q&As.
The due date for applications has been extended from December 23 to January 29, 2016.
More information is at http://www.dasny.org/RFP-BidOpportunities-Solicitations/Details.aspx?id=a24a6852-ee2f-45ab-be48-eaa6e10796d7. Please also see last week’s ASAP for additional information.
FIDA Update
The state Department of Health will provide an update on the recent changes to the Fully Integrated DualsAdvantage (FIDA) program on Tuesday, December 22, 2015, from 1 to 2 p.m.
You can register for the webinar at: https://attendee.gotowebinar.com/register/4668963248353531393.
The changes were described in last week’s ASAP and are available at https://www.health.ny.gov/health_care/medicaid/redesign/mrt_101.htm (the same site where the webinar’s materials will be posted).
DSRIP Update
On Thursday, January 21 and Friday, January 22, the Delivery System Reform Incentive Payment (DSRIP)Project Approval and Oversight Panel (PAOP) will meet the downstate-based DSRIP Performing ProviderSystems (PPSs).
The meeting will be held in the Eisner & Lubin Auditorium located within the NYU Kimmel Center for UniversityLife (60 Washington Square South) in New York City.
The meeting is open to the public, but there will be no public comment period at these meetings. No pre-registrationis required. Please contact Brooke Weinstein at [email protected] by January 11 for furtherinformation.
Thursday, January 21 will be a full-day meeting from 10:30 a.m. to 4:30 p.m., structured as an update session forthe panel members, and an opportunity for the panel members to check in with each of the PPSs. Friday will startat 9 a.m. and end at 2 p.m. The meetings will be webcast and can be viewed live at:http://www.health.ny.gov/events/webcasts/.
OMIG Posts Compliance Webinars’ Q&As
The state Office of the Medicaid Inspector General (OMIG) has posted on its website “Follow-up Questions andAnswers” related to the Compliance Elements Webinar Series (Webinars no. 26 through 34). Launched in November 2015, the nine-part webinar series on New York’s mandatory compliance program includesthe Introductory Webinar (Webinar no. 26), which outlines the eight elements required of mandatory compliance
ASAP – a publication of the Home Care Association of New York State
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Volume 20, No. 44 December 18, 2015
programs, identifies who is required to have a compliance program, and details the areas of a Medicaid provider’soperations to which compliance programs must apply. The series continues with eight individual webinars (webinars no. 27 through 34), each dedicated to one of the eightelements required of Medicaid providers’ mandatory compliance programs. The webinars: identify a specificcompliance element’s statutory and regulatory requirements; outline what OMIG’s Bureau of Compliance looksfor when it assesses a Medicaid provider’s compliance program; and detail compliance-related tools and resourcesavailable on OMIG’s website to assist provider compliance. The Compliance Elements Webinar Series as well as the “Follow-up Questions and Answers” are at https://www.omig.ny.gov/resources/webinars.
The “Questions and Answers” address: whether companies that submit providers’ Medicaid billing files are requiredto have a compliance plan; the amount and types of evidence necessary to demonstrate an agency’s complianceactivities; whether the OMIG’s compliance program assessment form must be submitted; which staff (andconsultants) are covered by an agency’s compliance plan; and which criteria should be used to select a complianceofficer.
NGS Closed on Christmas and New Year’s
National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC) will be closedDecember 25 and January 1 for the Christmas and New Year’s Holidays. This includes the Electronic DataInterchange (EDI) Help Desk, Provider Contact Center, Provider Enrollment Line, and Telephone ReopeningUnit.
Electronic claim files transmitted after 5 p.m. on Thursday, December 24 and Thursday, December 31 will have aclaim receipt date of Monday, December 28, 2015 or Monday, January 4, 2016, respectively. EDI front-endacknowledgement 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 25 and January 1 during regular hours.
Providers will be able to access NGSConnex and use the Interactive Voice Response (IVR) system at 1-866-275-3033 during the closure days.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
Publications
• “Access and Oversight Concerns for Home Health Services, Washington DC VA Medical Center,” by theDepartment of Veterans Affairs Office of Inspector Generalhttp://www.va.gov/oig/pubs/VAOIG-14-03823-19.pdf
• “MLTC Roll-Out – Overtime pay starts for aides, Two plans withdraw from MLTC coverage,” by the NewYork Legal Assistance Grouphttp://www.wnylc.com/health/news/41/
For more information, contact Andrew Koski at (518) 810-0662 or [email protected].
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
SECTION 1: Demographic Information
1. List your contact informationYour Organization
Your Name
Your Title
Your Email
Your Phone Number
2. Please check only one answer for your home care provider type, and please be sure tocomplete a separate survey for each type if you have multiple types of agencies.
3. My agency is ____ (Please only check one answer)
CHHA
LHCSA
LTHHCP
Voluntary
Proprietary
Public
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
SECTION 2: Financial Data
Questions 4 and 5 should be completed by CHHAs and LTHHCPs.
Question 6 should be completed by LHCSAs.
Your answers can be taken directly from your 2014 Medicaid Cost Reports or your 2013Statistical Reports. Your Finance Director/Chief Financial Officer can assist you.
To help, we have created a reference chart, available HERE. This document references the exactschedules on your cost reports and statistical reports for the information sought in questions 5and 6.
Again, all agencyspecific information provided to us will be kept confidential and will only beused in the aggregate.
REMEMBER ... For numerical entries, do not use dollar signs ($), commas (,), decimal points (.),percent signs (%) or other characters, just the raw number. Please round up or down if youranswer involves a decimal point.
4. If your agency filed a 2014 cost report, are you completing the cost report section of thissurvey for your LTHHCP or your CHHA? If you are a LHCSA, please skip to question 6.
5. Provide the following data from your 2014 Cost Report (for CHHAs or LTHHCPs). If youare a LHCSA, please skip to question 6.No. of Full Time Employees (FTEs)
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey6. For LHCSAs, please complete the following data from your 2013 LHCSA StatisticalReport. If you are not a LHCSA, skip to the next question.Total Cases
Unduplicated Patient Count
Number of Full Time Staffing (as of Oct. 1)
Total Contract Revenue
Total Direct Revenue
Total Costs
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
SECTION 3: Payment and Program Information
This section asks for your responses about the impact of billing, regulatory and payment issues.
7. Please estimate what % of your Medicaid managed care claims are paid within the"prompt" pay law timeframe for "clean" claims needing no edits (30 days for electronicclaims, 45 for paper). Please just enter a raw number: no percentage sign.___%
8. What is the average number of days that your revenues (from all payors) remain inAccounts Receivable? Please provide your best estimate.Days
9. What percent of your revenue in Accounts Receivable results in “bad debt” or notgetting paid?
0 – 10%
11 – 20%
21 – 30%
Over 30%
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
10. Assuming that your costs have increased in the last year, please rate the impact ofeach cost factor below on your increased costs. For any that have the "largest impact,"please tell us more about about the specific cost impact in the text box below.
Billing/Administrative ExpensesAssociated with Managed Care
Basic or advanced staff training
Emergency Preparedness andresponse
Staff time and partnershipdevelopment work onMLTC/DSRIP activities
Tell us more about your largest cost impacts
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey11. If your estimated Medicaid revenues have decreased between 2014 and 2015, pleaserate the impact of the following factors for this change in your Medicaid revenues.
No ImpactMinimalImpact
MediumImpact
LargeImpact
LargestImpact
Caseload change due to managed care transition
Effect of payment cuts/reimbursement changes (e.g.,CHHA EPS rebasing, GRT)
Inadequate managed care rates
Delay in managed care payments
Drop in Medicaid volume due to fewer referrals
Staffing cuts
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition SurveyNo Impact
MinimalImpact
MediumImpact
LargeImpact
LargestImpact
12. On October 1, the state implemented CHHA episodic payment system rebasing cuts.Please provide the average % reduction in your Medicaid revenue due to this initiative?(Remember: be sure to only enter the raw number: no percentage sign.)Avg. Percentage reduction (%)
Other (please specify)
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
13. If you have Medicaid managed care contracts (MCO and MLTC), please estimate theaggregate % differences between your Medicaid feeforservice (FFS) rates and yournegotiated managed care rates for the following service disciplines. (You may leave any ofthe boxes blank if the statement doesn't apply.)Our aggregate managed care nursing service rate is LESS than FFS by (__%)
Our aggregate managed care nursing service rate is MORE than FFS by (+__%)
Our aggregate managed care home health aide/personal care service rate is LESS than FFS by(__%)
Our aggregate managed care home health aide/personal care service rate is MORE than FFS by(+__%)
14. How have your overall contracted Medicaid managed care (MCO and MLTC) rateschanged between 2014 and 2015? Enter zero if your rates have not changed. (Also, be sureto only enter the raw number: no percentage sign.)Increased by ____%
Decreased by ____%
15. At any time over the past two years (2014 and 2015), have you had to use a line ofcredit or borrow money (including gappayment financing from parent organization) to payfor operating expenses?
16. Please rank from 15 the (actual or potential) impact of the following state regulatoryrequirements/initiatives (1=highest impact and 5=lowest impact).
Elimination of the "companionship exemption" for home care
Executive compensation/administrative limits
Medicaid ordering, prescribing, referring and attending (OPRA) edit
DSRIP
State Wage Parity requirements in New York City, Long Island, Westchester
Yes
No
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17. Which of the following actions does your agency plan to take in response to fiscalpressures, a changing health care environment and new models like DSRIP? (Pleasecheck all that apply.)
Merge with another agency
Collaborate as part of a Health Home, IPA, ACO, DSRIP/PPS or other health system
Technology upgrades (EHR, etc.)
Workforce retraining
Reduce staff and other expenses to become more efficient
Use LTHHCP in contracting capacity
Phaseout LTHHCP
Purchase a CHHA
Increase use of CHHA
Decrease use of CHHA
Apply to open a LHCSA
Increase use of LHCSA
Decrease use of LHCSA
Discontinue telehealth program
Close our organization
Other (please specify)
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey18. In your contracts with MLTCs/MCOs, how would you rate the overall impact of thefollowing issues or experiences? (Please check all that apply.)
No ImpactMinimalImpact
MediumImpact
LargeImpact
LargestImpact
Inadequate rates
Lack of timely authorizations/reauthorizations
Lack of timely payment (or increase in accountsreceivable)
Inconsistent billing codes
A lack of state policy clarity about the regulatoryrequirements (e.g. responsibilities for physician orders,plans of care, supervision)
I do not have a CHHA and the MLTC/MCO only wantsto contract with a CHHA
I do not have a LHCSA and the MLTC/MCO onlywants to contract with a LHCSA
The MLTCs/MCOs feel they already have a sufficientnumber of contracts
The MLTCs/MCOs plan to cancel our contract
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition SurveyNo Impact
MinimalImpact
MediumImpact
LargeImpact
LargestImpact
19. What % of your Medicaid receipts are FeeForService versus Medicaid Managed Care(MLTC/MCOs)?Feeforservice % is ____
Managed Care % is ____
20. What % of your Medicare receipts are FeeForService versus Medicare ManagedCare?Feeforservice % is ____
Managed Care % is ____
21. If you are contracting with an MLTC or MCO, please provide the percentage of yourMedicaid revenue derived from each of the following service/contract arrangements.(Simply enter a zero for any services that you do not provide.)Care management services to plan enrollees account for ___% of our Medicaid revenue fromplans.
Professional services (nursing, therapy) to plan enrollees account for ___% of our Medicaidrevenue from plans.
Aide services to plan enrollees account for ____% of our Medicaid revenue from plans.
Assessment services account for ____% of our Medicaid revenue from plans.
Other services account for ____% of our Medicaid revenue from plans.
22. Does your agency contract with MLTCs/MCOs for telehealth services?
Other (please specify)
Yes
No
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
23. If you answered "yes" to the previous question, is your payment for telehealth servicesadequate under managed care? (Please explain.)
24. If you are involved in a DSRIP Performing Provider System (PPS), what paymentarrangement are you involved in or expect directly from the PPS?
25. Has your agency yet received payment directly from a DSRIP PPS?
Feeforservice
Capitated payments
Bundled payments/ValueBased Payments
Specific project area funding
Unsure
Other (please specify)
Yes
No
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey26. If you answered "yes" to the previous question, how much payment has your agencyreceived from the PPS and for what purpose(s)? (Please explain in the box below.)
27. If you are involved in a DSRIP PPS, please rate the following experiences.StronglyDisagree
Disagree Don't Know AgreeStronglyAgree
N/A
Payment will adequately covercosts and makes participation inDSRIP worthwhile
My organization expectsincreased referral activity fromthe PPS
PPS committees understand therole of home care in meetingDSRIP goals
DSRIP participation offersopportunity for growth in homecare industry
I don't know how my agency willparticipate in DSRIP
28. By what percentage do you expect your costs will increase due to recent changes(implemented on Oct. 13, 2015) in the federal "companionship exemption" requirements?(Remember, enter only the raw number and no percentage sign.)Percentage Increase (%)
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey29. Has your agency calculated the potential impact of the proposed minimum wageincrease to $15 per hour? If yes, what were your findings and how did you arrive at thiscalculation?
30. Please rank from 110 which of the following are needed to support you in this currentfiscal, regulatory and program environment for home care (1=highest importance and10=lowest importance).
Policies that ensure adequate reimbursement
Uniform billing codes for managed care payments
Greater state clarity on the role and regulatory responsibilities for agencies
Regulatory relief
Capital and technology funding support
Staff recruitment or retraining funds
Agency/market data and cost analysis
Marketing materials and documentation showing the home care value proposition
Technical assistance through education programming on new models
Assistance in receiving timely authorization/payments
2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey2015 State Home Care Financial Condition Survey
THANK YOU
Thank you for completing this important survey. If you have any additional comments, pleasenote them in the text box below.
