LeadingAge NY, Other Groups Urge CMS to Disapprove State’s Case-Mix Proposal

As recently reported in Intelligence, the Department of Health (DOH) requested federal approval to change the methodology used to adjust the direct component of the Medicaid rate for case-mix. The proposed Medicaid State Plan Amendment (SPA) was filed with CMS on June 28, 2019. LeadingAge NY and other associations have written a letter to CMS urging the agency to disapprove the proposed SPA.

Our letter contends that: (1) the State’s public notice did not include sufficient information to ensure that interested parties could provide meaningful input prior to SPA submission; (2) the proposed change in methodology is at odds with the New York State legislation which references it; (3) there is no evidence indicating that the State properly gathered and documented public input on how this change could affect access to care prior to submitting the SPA; and (4) the proposed SPA could negatively impact beneficiary access to quality care.

Based on the 2019-20 State Budget agreement, DOH is changing the way that case-mix is calculated starting with July 2019 rates to include all Minimum Data Set (MDS) assessments. DOH has indicated that the new methodology will average the case-mix scores of all MDS assessments submitted by a home for Medicaid beneficiaries during the period Aug. 8, 2018 through March 31, 2019.

In the SPA, the State requests federal approval not only to use this methodology for July 2019 rates, but also to continue the methodology for future rate periods. The case-mix for January 2020 rates would be based on all MDS assessments filed from April through September 2019, and the case-mix used in July 2020 rates would rely on assessment data from the October through March time period.

LeadingAge NY and its association colleagues are also reaching out to the New York congressional delegation and New York State legislators, asking them to urge CMS and the Governor, respectively, to disapprove this proposal. Please contact us with questions or if we can assist in calculating facility estimates.

Contacts: Dan Heim, dheim@leadingageny.org, 518-867-8383 or Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841