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DOH Provides Answers to Value-Based Payment Reporting and Penalty Questions

The Department of Health has provided answers to questions posed by LeadingAge New York in response to the Department's webinar for managed long term care plans on value-based payment tracking report (VBPTR) requirements. More information about VBTR requirements and slides from the webinar are available here. Plans that have opted to re-submit their VBPTRs for the period ending March 31, 2019 must do so by August 1, 2018. The questions and answers are set forth below:

1)    Slide 6: Will VBP penalties for rate year 18-19 and recoupment of stimulus funds be based on reported VBPTR data from Apr 2017-Mar 2018?

Answer: Yes

2).    When will those penalties and recoupments be calculated and incorporated into rates?

Answer: Penalties and recoupments will be calculated and incorporated into rates in October of rate year 18-19.

3)    Slide 8:  MLTC partial cap Level 2 is defined to include a “downside” or quality withhold of at least 1%.  The use of the term “withhold” implies a prospected retention of payments which may be paid after the measurement period based on performance. We assume that the downside may be implemented in a number of different ways, and need not be implemented as a “withhold.” Is that correct?

Answer: Yes

4)    Slide 9: Once the nursing home benefit limit is implemented, will the reporting of nursing home expenditures be eliminated from the VBPTR?

Answer: We are currently assessing if the Nursing Home spend will remain in VBP which dictates whether it will remain part of the VBP Tracking Report. To date however, NYS must account for all managed care expenditure in VBP which will include nursing home spend that remains in managed care.

5)    Slide 11:  This slide says, “If the contract was executed during any part of the reporting period . . .”  The first report in 2018 covers Apr. 17-Mar. 18 and includes the Dec. 2017 execution date of most partial cap VBP contracts. However, subsequent reports will be quarterly and will not include the execution of date of most contracts. We assume the instruction will change going forward to cover contracts “in effect” during any part of the reporting period. Is that accurate?

Answer: Yes, dollars should be reported as VBP Level 1, 2 or 3 if VBP contracts were 1) executed during the reporting period; or 2) already in effect during the reporting period, so long as they were not subsequently replaced by new contracts that fail to meet VBP requirements.

6)    Slides 11-12: We assume that “Dollars Paid” refers to dollars actually paid during the reporting period, not dollars that might be paid based on performance once the measurement period concludes. Is that correct?

Answer: Yes

7)    Slide 14: This slide says that PACE plans should report “all dollars in Level 3 VBP arrangements under Total Care for MLTC Subpopulation.” We assume this means all Medicaid dollars (i.e., excluding Medicare dollars). Please confirm that this is correct.

Answer: Yes

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124.