DOH Takes Another Run at ALP Minimum Wage Reconciliation
The Department of Health (DOH) has notified Medicaid Assisted Living Program (ALP) providers that it intends to reconcile five years worth of minimum wage funding. The reconciliation is based on two provider surveys, one covering 2017 through 2019 and the other spanning 2020 through 2021. The Department’s intent is to reconcile the minimum wage add-on payments that were paid based on projections to actual need as reported on the reconciliation surveys. Because minimum wage add-ons are cumulative (i.e., a 50 cents add-on in 2017 would be continued and potentially increased in each subsequent year through 2021), some minimum wage liabilities are significant. In addition, due in part to the minimum wage reconciliation hold, DOH never implemented the 1.5 percent across-the-board reduction that impacted almost all other Medicaid provider payments for the last two years, recently sunsetting on March 31, 2022. As a result, it appears that DOH is including this cut retroactive to 2020 along with the minimum wage reconciliation, ensuring that most ALP providers are facing a sizable negative adjustment.
Although not mentioned in the Dear Administrator Letter (DAL), the calculation sheets seem to indicate that payment adjustments reflecting the 1.5 percent cut will be included in Medicaid rate cycle 2333 (check release date of May 25th), which will also contain the updated 2017 through 2021 ALP minimum wage rates. Because the rate changes are likely to result in recoupments and A/R balance increases, DOH will apply the standard recoupment of 15 percent to all payments beginning in cycle 2333.
For providers with outstanding liabilities from the rate changes processed on March 11, 2021 (Medicaid payment cycle 2273), any positive rate adjustment in cycle 2333 will be applied in full to the existing liabilities. If the positive adjustment in cycle 2333 exceeds the liability balance, you will be paid the excess in cycle 2333. If the positive funds in cycle 2333 are less than the liability balance, recoupment will commence on the remaining balance at 15 percent per week starting in cycle 2333.
The DAL is available here, while the back-up calculations are under “ALP Minimum Wage Reconciliation,” available here.
LeadingAge NY is reviewing the calculations and recommends that ALP providers do the same to ensure that the rates listed in the reconciliation workbook accurately reflect the rates that you were paid during recent years. We are seeking further discussion with DOH on this issue and will keep members updated on any developments. If you encounter data discrepancies or have questions, please contact us.
Contact: Darius Kirstein, firstname.lastname@example.org, 518-867-8841