Value-Based Payment and CFCO Discussed at Managed Care Plan Meeting
The March meeting between managed care plans and the Department of Health (DOH) included a discussion of value-based payment (VBP) targets and reporting requirements and the establishment of new workgroups to support the launch of the Community First Choice Option (CFCO) expansion in July. The meeting also addressed provider enrollment requirements and cost report deadlines. The VBP slides are available here, and the CFCO and provider enrollment slides are available here.
DOH reiterated that by April 2019, partially-capitated managed long term care (MLTC) plans must make at least 50 percent of their payments to providers through Level 1 or higher VBP arrangements and at least 5 percent of payments through Level 2 or higher arrangements. Fully-capitated Medicaid Advantage Plus (MAP), Fully Integrated Duals Advantage (FIDA), and Program of All-Inclusive Care for the Elderly (PACE) plans must make at least 50 percent of payments to providers in Level 1 or higher arrangements and 15 percent in Level 2 or higher. In April 2020, the minimum threshold of Level 2 or higher arrangements for partially-capitated plans rises to 15 percent, and for fully-capitated plans, it rises to 35 percent.
The Department stressed the importance of accurate and timely reporting by managed care plans of VBP penetration via the VBP Tracking Report (VBPTR), which must be completed by May 2nd. The 2018-19 annual files will be available the first week of April. Recent changes in reporting include a requirement to report the names of the providers with agreements at each level. The Department reminded plans that Level 2 arrangements require a minimum penalty or “risk” of 1 percent of total annual expenditures if the provider fails to satisfy performance targets for potentially avoidable hospitalizations and at least one other approved MLTC quality measure. In addition, Level 2 arrangements must include at least one social determinant of health (SDH) intervention that is not included in the MLTC benefit package, and MLTC plans must contract with at least one Tier 1 community-based organization (CBO). The Tier 1 CBO may not be a Medicaid billing provider but may be an MLTC network provider, such as a home-delivered meals vendor. Further, the Tier 1 CBO contract need not be paired with the SDH intervention. MLTC plans must submit their Level 2 contracts to DOH here. DOH is receiving VBP questions here.
The slide deck’s appendix includes examples of MLTC SDH interventions. These interventions include, among others, homelessness prevention services, volunteer companion care services, social transportation, asthma assessments and home remediation, financial literacy and life skills education, and chronic disease management classes. DOH noted that slides from the recent MLTC VBP refresher webinar are available here.
Plan representatives asked for an extension of VBP deadlines and reporting requirements given various obstacles to implementation. Some plans noted that there are no Tier 1 CBOs in certain counties. Plans also asked how to implement Level 2 VBP arrangements with nursing homes when a home has less than 30 residents in any given plan. LeadingAge NY raised the issue of conflict of interest prohibitions in the person-centered services planning guidelines and asked how to reconcile these prohibitions with providers’ need to conduct assessments and care management for purposes of Level 2 VBP arrangements. In addition, we again noted that the conflict of interest provisions will disrupt existing delegated assessment and care management relationships regardless of VBP arrangements. DOH staff indicated that they would look into these issues.
The meeting also covered next steps in CFCO implementation. CFCO training webinars hosted by DOH and draft rates are available here. DOH noted that these rates have not yet been approved by the Centers for Medicare and Medicaid Services (CMS). DOH is creating two CFCO workgroups that will begin meeting next week and will meet for approximately four weeks. The first workgroup will address outstanding issues related to contracting and credentialing, and the second will address issues related to billing, encounter data, and reporting. An email will be sent to the government relations contacts at all plans by March 15th asking for the subject matter experts to be included in each workgroup. CFCO readiness reviews will begin in late May, and more detailed information regarding the readiness reviews will be provided in the next couple of weeks.
The Department noted that 2018 managed care cost report forms have been released and are available through the Health Commerce System (HCS). They are due on April 10th. In addition, DOH provided a series of steps to complete Provider Network Data System (PNDS) submissions for provider enrollment purposes.
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