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DOH Provides MLTC Rate Update

Earlier today, staff from the Department of Health (DOH) Division of Finance and Rate Setting presented an update on Managed Long Term Care (MLTC) rates and fielded questions from plans and associations. Partially Capitated plans should expect to see the retroactive adjustments reflecting new rates back to April 2018 in Medicaid cycle 2136, which has a check release date of Aug. 15th. Rates for Medicaid Advantage Plus (MAP) and Fully Integrated Dual Advantage (FIDA) plans are in process for approval by the Division of the Budget (DOB). April 2018 rates for Programs of All-Inclusive Care for the Elderly (PACE) are still in draft stage, with DOH hoping to distribute those before the end of the month.

DOH is hoping to issue revised April 2017 and July 2017 Partially Capitated rates in September and is working to update nursing home resident counts based on newer survey data and calculate high cost nursing home pool distributions. The updated rates will also reflect high cost/high need (HC/HN) pool distributions, although work continues on finalizing the distribution methodology that will be used. While the pools do not apply to MAP and FIDA rates, DOH will review nursing home enrollment data and update MAP and FIDA rates for these time periods if needed. In response to expressed concerns, DOH agreed to take a look at the possibility of treating the HC/HN pool differently in upstate versus downstate regions. Comments on the HC/HN proposal recently circulated are still being accepted. Additionally, DOH is ready to convene a risk adjustment workgroup meeting in September and has received nominees for the group representing plans statewide. Guided by the HC/HN survey data, the group will discuss updating the risk model for 2019 as well as how to best reflect HC/HN members in risk adjustment.

The Department expects to revise the new April 2018 rates as well. The revision will reflect minimum wage for transportation providers, newer nursing home resident counts, risk score updates based on a more recent enrollment snapshot (March) using the same UAS data, and, possibly, the rate impact of state budget actions. Additional rate updates will be done in January 2019 to reflect Community First Choice Option (CFCO) implementation and the impact of state budget provisions and possibly in October 2018 if necessary based on data review.

During initial rate briefings, there was discussion of the marked decrease in the care management component of the April 2018 draft rates. While DOH did investigate this and believes that a possible cause may be inconsistencies in cost reporting, which they have discussed with targeted plans, they will make no changes this year while examining the issue when developing next year's rates. In response to questions, DOH indicated that the state spending plan envisioned MLTC enrollment growth of 4.5 percent compared to the continuing 12 percent growth rate.

While there have been no firm decisions on how or when state budget impacts will be incorporated in the rates, it is increasingly clear that DOH intends to achieve the $27 million from the Licensed Home Care Services Agency (LHCSA) contract limit provision and the $56 million from the Social Adult Day "efficiency" provision through rate decreases. DOH has not decided whether the Social Day provision will be implemented uniformly across all plans or in a targeted manner. Participants pointed out that the magnitude of the rate cuts, especially if concentrated during the second part of the fiscal year, would likely require contract renegotiation with providers. This could become especially problematic given the minimum wage funding dynamics.

Along with other plan representatives, LeadingAge NY has been seeking clarifications on a number of minimum wage questions and provided suggested revisions to the Department to their recent minimum wage FAQ document. In response to concerns regarding the decrease in mid-2018 minimum wage funding, DOH intends to issue updated FAQs and will hold a webinar on the topic later this month that will target both plans and providers. DOH is working with Deloitte to provide clearer information on minimum wage funding for all stakeholders.

At the same time, the State is poised to reconcile plan minimum wage funding for State Fiscal Year (SFY) 2016-17. To achieve this, DOH will update the 2016-17 Schedule F with actual enrollment to arrive at the total funding each plan received and will compare it to the funding that plans reported paying to providers on cost reports and surveys. DOH is also finalizing QIVAPP award amounts for 2017-18 and expects to have results at the end of the summer.

We will continue to work with DOH and other associations to address concerns regarding minimum wage funding and how budget provisions are reflected in the rates. A copy of the presentation slides is available here.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841