Nursing Home Reimbursement Update
The monthly associations meeting with the Department of Health (DOH) on Medicaid reimbursement issues was brief but yielded several important pieces of information. Highlights are provided below.
CMI Methodology. DOH staff formally unveiled the State’s intent to again try to move away from the “picture date” methodology and instead use all assessments filed during a six-month period to calculate case mix index (CMI) adjustments to nursing home Medicaid rates. DOH hopes to shift to the new approach starting with the next rate update by basing the CMI calculations in the July 2021 rates on all Minimum Data Set (MDS) assessments filed from October 2020 through March 2021. The previous attempt to move to this methodology was blocked by the State Supreme Court, largely on procedural grounds (info here). While the Department intends to publish updated regulations, the version published in early 2020 is here, and our comments in oppositions are here. Even though it requires additional time and effort to focus on MDS items with potential CMI impact in addition to clinical and care planning items, members may want to ensure that each assessment done for a Medicaid resident is treated as if it will be used in the CMI calculation process.
CMI for January 2021 Rates. This Friday, May 14th, is the deadline to submit the Operator Certification for the MDS verification process used to establish the CMI for January 2021 rates. DOH requests that members submit that form (available here) as soon as possible. The certification should be submitted by email to MDSBRHCR@health.ny.gov with "2020-2 MDS Certification" in the subject line. Any providers that mailed the form (pursuant to the instructions still appearing on the certification form provided by DOH) are asked to submit it by email as well. This matching cycle appears to have been successful, with fewer than a dozen homes that have not finalized their match. Please note that this process does not apply to specialty facilities and units since case mix updates are not currently being made to specialty rates.
2020 Cost Report. The Department is finalizing the software for the 2020 Residential Health Care Facility (RHCF) Cost Report and expects to post it on the Health Commerce System (HCS) in the coming weeks. DOH reports that there are no major changes, but the changes that were made will be detailed in the Cost Report Dear Administrator Letter (DAL). The due date is anticipated to be two months after the software is released, suggesting a mid-to-late July due date.
Additional 1 Percent Supplement. With the five-year Universal Settlement having been completed, DOH has filed a Medicaid State Plan Amendment to repurpose approximately $70 million of assessment-generated settlement funding to make an additional reinvestment in nursing home Medicaid funding. This would be in addition to the 1 percent supplement that moves in tandem with the Nursing Home Quality Initiative (NHQI) and would supplement Medicaid rates starting on Nov. 1, 2020. Payments would be made as a lump sum and likely include managed care volume in the same way as is done with the current supplemental payments and NHQI adjustments.
MDS Audits. The Office of the Medicaid Inspector General (OMIG) continues to work on 2017 MDS audits and has completed 157 exit conferences.
2021-22 State Budget Items. DOH is holding internal discussions regarding the implementation of nursing home reform State Budget provisions and has no information to share at this time.
Please let us know if you have questions or concerns.
Contact: Darius Kirstein, dkirstein@leadingageny.org. 518-867-8841