March Plan Meeting Features Rate Walk-Through
The March Managed Care Policy and Planning Meeting featured a walk-through of the preliminary 2017-18 rate for single-capitated MTLC plans along with a program update and some discussion of DSRIP dashboards and Value Based Payment (VBP). Highlights of the discussions of greatest interest to MLTC members are provided below. Section titles link to relevant handouts; the meeting agenda is available here.
February 2017 MLTC enrollment stood at 191,820, up 0.9 percent relative to January’s figure. Partially capitated plans added 1,649 members, representing a slowing of the growth that the Department of Health (DOH) has observed in recent months. DOH reported that they are analyzing growth and service utilization patterns among plans and are observing some noticeable variation among plans within the same regions. They will examine these differences more closely and correlate the data with member acuity. Once complete, DOH intends to meet with plans to discuss the results.
The Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Waiver Transition Workgroup met on March 1st (more information here), with the next meeting tentatively scheduled for April 26th. DOH has posted a response to concerns expressed by The Alliance of TBI & NHTD Waiver Providers. The response addresses a number of implementation questions and is available here. DOH is considering establishing a similar workgroup structure for waiver transition as they have for CFCO and foresee eventually merging the two efforts. The next CFCO workgroup to meet will be the PACE group, whose meeting is scheduled for March 16th; the steering committee meeting is being scheduled.
DOH reported that the first FIDA plan serving Suffolk and Westchester counties (FIDA Region 2) is operational, with additional plans expected to follow in the spring. Staff are reviewing policy suggestions offered by FIDA plans in February and will be making decisions about policy changes based on the input within several weeks. The Centers for Medicare and Medicaid Services (CMS) is undertaking an evaluation of FIDA demonstrations nationwide. The stakeholder discussion of the future of integrated care in New York is still planned but not yet scheduled.
Andrew Segal provided the following insights in response to questions submitted by plans in advance of the meeting:
- DOH is developing a workplan for the transition of the ALP into managed care, with no final decisions made on the transition date.
- The policy document on the transition from mainstream to MLTC that was issued and immediately rescinded will be eventually reissued. It was pulled to ensure internal coordination between DOH units.
- DOH will evaluate their MLTC marketing ban proposal in light of the proposals that may be contained in the one-house legislative budgets and discuss from there.
- The Department is working on finalizing universal codes. A request was made that the effective date of the codes coincide with the start of a cost reporting period.
Partial Capitation Rates
Mercer staff reviewed the projected medical estimates they are using to develop 2017-18 rates for partially capitated MLTC plans. Although not all of the needed data is available yet, Mercer provided a comparison between this year’s and last year’s rate ranges. The changes reflect updating the community services base data to that reported on 2014 and 2015 cost reports (50/50 blend), making adjustments for program changes and applying inflation adjustments. Data for some of the program changes was not yet available so last year’s figures were used as a placeholder.
Mercer will update this data and apply program alignment calculations and risk scores to compute final partial capitation rates which they intend to do as early as April. Plans will receive the same rate schedules as usual which will detail the rate build-up and Mercer will provide the annual actuarial memo. Mercer is not updating the risk model so will be using the same weights as last year, and expects to use UAS data from Jan. through June of 2016 with a January snapshot to calculate risk scores.
It is most likely that any additional funding for minimum wage will be calculated for the entire 12 month rate period and reflected as a uniform amount for the entire year, instead of a separate rate being issued for January 2018, when the minimum wage increases.
The discussion led to some questions on minimum wage and separate rate cells which Medicaid Director Jason Helgerson addressed:
- CMS staff was strongly opposed to a nursing home rate cell and that staff is still the same despite new administration. Once political appointees are in place, DOH is not averse to revisit the rate cell discussion with CMS.
- Current attempts to define a high-need community rate cell based on amount of service provided is not acceptable. It must be based on disease, condition or other objective criteria that could be translated into actuarial standards.
- Any CFCO-related rate adjustments will be made in a future rate update as necessary.
- While the state will reconcile minimum wage payments to resolve underpayments and overpayments, overpayments are likely to be recovered by netting them against the payments for the following year. DOH is thinking that if recoupments are needed, the state would do so directly, not through the plans.
- DOH urges plans and providers to continue their current contracted amounts when it comes to minimum wage and issued a schedule for when various managed care program draft rates for 2017-18 reflecting minimum wage funding would be available.
VBP development for MLTC remains in the works, and the April VBP meeting is dedicated to reviewing the MTLC CAG. DOH indicated that the state will be making $60 million in VBP readiness grants to community behavioral health providers over the course of three years. We continue to point out that while the VBP incentive and readiness funding is being made available to assist providers with VBP partnerships with mainstream Medicaid plans, no funding is being made available for MLTC VBP activities.
The DSRIP update included discussion of the VBP dashboards that managed care organizations are able to access. While these dashboards are not yet available to MLTC plans, DOH is working on that in hopes that it will be a helpful care coordination platform. Once available, MLTC plans will need to go through a data agreement process to receive access.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841