DOH Discusses Minimum Wage Guidance, Reconciliation
Last Friday, the Department of Health (DOH) hosted a webinar to discuss minimum wage funding guidance for Medicaid managed care plans and home care providers. The presentation reiterated information in previously issued guidance and Frequently Asked Questions documents (posted on the DOH minimum wage site here), stressing that:
- there is no specified amount of funding that plans must pass to each provider;
- plans are required to allocate funding to ensure their providers are able to pay workers consistent with the law;
- while the funding attributable to 2018 decreased when viewed on a calendar year basis, funding is paid on a state fiscal year (SFY) basis, which did increase;
- the Office of the Medicaid Inspector General (OMIG) and the Department of Labor (DOL) will ensure provider and plan compliance;
- plans should be able to track and demonstrate the amounts of minimum wage funding paid; and
- the Department recommends that minimum wage contract amendments for 2019 be in place by Nov. 1st.
Currently, DOH is in the process of reconciling SFY 2016-17 minimum wage funding. This funding was for minimum wage increases effective Jan. 1, 2017 for the period Jan. 1, 2017 through March 31, 2017. For partially capitated plans and Fully Integrated Duals Advantage (FIDA) plans, this funding was distributed through rates effective October 2016 through March 2017. DOH will use data collected on the Supplemental Minimum Wage Reconciliation Cost Report to determine whether a plan was overfunded or underfunded and issue appropriately revised rates. Once approvals from the Centers for Medicare and Medicaid Services (CMS) and the Division of the Budget (DOB) are received, the revised rates will be uploaded to eMedNY and generate reconciliation payments or withholds.
For Programs of All-Inclusive Care for the Elderly (PACE), the rate revision will impact the entire 2016-17 SFY, since minimum wage funding for these plans was spread across 12 months. For Medicaid Advantage Plus (MAP) plans, the rate period impacted will be January through March 2017. The Department will issue updated Schedules F showing reconciled amounts as well as revised Schedules B for plans whose rates are revised.
DOH is also migrating away from the Health Commerce System (HCS) and to the New York State Office of Pool Administration (OPA) website as the platform for collecting quarterly minimum wage reconciliation reports. This change is expected shortly, and plans will be provided instructions on how to access the OPA site through the HCS cost report system.
The slides used during the presentation are available here.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841