DSRIP Weekly Update-Nov. 4, 2014
LeadingAge NY has been hard at work this past week, providing formal comments to the State on the Delivery System Reform Incentive Payment (DSRIP) program application and the capital funding initiative. In addition, as the deadline for DSRIP applications approaches, Performing Provider Systems (PPSs) are consolidating, and DOH is releasing new information.
Capital Restructuring Financing Program
Last week, LeadingAge NY submitted comments on the Capital Restructuring Financing Program (CRFP). A total of $1.2 billion is available through the CRFP over the next six years for capital projects that will “…enhance the quality, financial viability and efficiency of the health care delivery system in New York State . . . by transforming the system into a more rational patient-centered care system that promotes population health and improved well-being for all New Yorkers.” Our comments were aimed at creating more opportunities for our members to access these funds, including ideas for how to provide bonus points in the DSRIP application. We discussed the significant need for capital investments for both DSRIP and non-DSRIP purposes, and the concern that the direction of this initiative may prevent Long Term and Post-Acute Care (LTPAC) providers from ultimately accessing this funding. Click here to view our comments, and here for more information about CRFP.
A competitive Request for Applications for CRFP funding will be released soon. An applicant conference for the CRFP will be held on Nov. 21 from 1-4 p.m. at the Empire State Plaza, Concourse Level, Meeting Room 6 in Albany. Those planning to attend must email CRFP@health.ny.gov with the subject line: “November 21, 2014 CRFP Meeting Attendance” and provide a list of persons attending the conference. This meeting can also be viewed via live webcast here. A recording of the webcast will be available within a week of the event.
Draft DSRIP Project Plan Application
LeadingAge NY submitted comments on the Draft DSRIP Project Plan Application, highlighting ways in which the application can be improved to incentivize the inclusion of LTPAC providers. We provided recommendations on ways to explicitly name LTPAC provider types that would be integral in achieving the stated objectives of each relevant project. In addition, we raised concerns about the level of health information technology and exchange that is expected by year 3 for certain projects, and the need for greater investments for LTPAC providers. Click here to view our comments.
VAP Applications Posted for Public Comment
DOH has begun posting for public comment the Vital Access Provider (VAP) Exception applications that have been submitted. Comments will be accepted by email at bvapr@health.ny.gov until Dec. 3, 2014. The VAP exception is essentially another pathway to become designated as a Safety Net Provider. LeadingAge NY worked to ensure that members that did not receive Safety Net designation pursued this process, with particular focus on new certified home health agencies (CHHAs) that did not yet have enough data to demonstrate Safety Net status. We urged DOH to consider their unique circumstance throughout this process. VAP approvals are contingent on approval from the Centers for Medicare and Medicaid Services (CMS). Click here for more information.
DOH Wants to Know What is on Your Regulatory Waiver Wish List
DOH is eager to hear ideas for regulatory waivers for DSRIP projects! LeadingAge NY met with the Department last week, where they discussed some concepts that they are already exploring, such as waivers of need methodologies and establishment regulations. While DOH acknowledged that this is likely to be an evolving process, they hope to identify as many possible waiver options before DSRIP PPS begin their work. In addition, while some reforms may be applicable to the broader provider community, the statutory authority is limited to regulations specific to DSRIP projects. We encourage members to talk with their PPS leads, and with LeadingAge NY, so that we can help develop as many opportunities for flexibility for members as possible. Remember that the waivers must relate to DSRIP objectives. More information on this opportunity is below:
PPS Consolidation
DOH has been working to encourage PPS to consolidate in areas where there are multiple PPS. It was shared last week that consolidation has occurred in Central NY, Hudson Valley, and Long Island. We encourage member feedback for those members who are engaged in PPS in those regions, as there may be adjustments to the direction and project selection of the PPS.
Measure Specification and Reporting Manual Comments Due Nov. 10
The DSRIP Measure Specification and Reporting Manual contains information about the measures required for the DSRIP projects, the reporting mechanisms, timeframes, and details about the information the PPS will be required to provide. The manual also contains information about the performance goals and the methods used to establish annual improvement targets and determine high performance. DOH is accepting comments by email until Nov. 10, 2014 at dsrip@health.ny.gov. Click here to view the manual.
DSRIP Audio Conference for LeadingAge NY Members
On Nov. 10, 2014 from 10 - 11:30 a.m., LeadingAge NY is providing members with a free, members-only audio conference, DSRIP: An Overview and Legal Implications for Non-Lead Providers. Tracy E. Miller, counsel, Bond, Schoeneck & King will provide an overview of a host of legal considerations for our members who plan to participate in a DSRIP PPS. This program will be recorded if you are unable to participate at the scheduled time. Click here for more information.
Governance Resources
An effective governance structure is required for a successful PPS. The governance structure will determine how major decisions are made, such as the roles and responsibilities of participants and the distribution of incentive payments. Resources have been developed to help guide PPSs in this area: the “Governance How-To” document and DSRIP How to: PPS Governance webinar. The resources give key considerations when developing a governance structure, and three sample models intended to prompt thinking on the best approach for your PPS. In addition, LeadingAge NY counsel, Hinman Straub, has developed guidance on DSRIP governance issues, which can be accessed here.
On a related note, DOH has published proposed regulations governing Accountable Care Organizations (ACOs). Under the proposed regulations, a clinically-integrated network of independent health care providers that meets specified standards could apply for and obtain an ACO certificate of authority. It is anticipated that some DSRIP PPSs may elect to become certified as ACOs. Click here for more information.
Financial Stability Test Materials Revised, Due Date Extended
DOH has posted a revised DSRIP PPS Lead & PPS Lead Financial Stability Test Excel Tool to the DSRIP website to provide technical clarifications on the requisite financial ratios. There has been no change in the criteria or established benchmarks of the Financial Stability Test, but rather clarification to provide the PPS Leads with the necessary understanding of the various line items. Entities must pass this test in order to be a PPS lead. Click here for more information. The application deadline has been moved to Nov. 10, as a result of this update.
LeadingAge NY is in regular contact with DOH and other stakeholders regarding DSRIP. Let us know how things are going, so we can advocate effectively and get you the answers you need!
Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828