Nursing homes should expect to see rate updates and adjustments in upcoming Medicaid remittances that include reconciliation of the 2015 cash receipts assessment payments, updated 2017 operating and capital rates, and Advanced Training Initiative (ATI) funding for those homes that qualify. Department of Health (DOH) rate staff provided details on these and other issues in a meeting with LeadingAge NY and other associations last week.

2017 Medicaid Rates

The Jan. 1, 2017 Medicaid rates have been approved by the Division of the Budget (DOB) and are being forwarded to eMedNY. They reflect a case mix index calculated using MDS assessments from the July 2016 “picture date” as well as facility-specific minimum wage adjustments for those homes that indicated on the DOH minimum wage survey that they have workers being paid at the minimum wage. The minimum wage adjustment blends the facility’s reported figures with regional data and is shown on line 13, "Misc. Per Diem Adjustments," on the first page of the rate sheet for those homes receiving funding.

Because 2017 marks the full implementation of the nursing home pricing methodology after a five-year phase-in, no stop-loss/stop-gain is applied to the rates. Last year, increases and decreases to a home’s Medicaid rate were capped at 10 percent when compared to the home’s July 2011 Medicaid rate on a case mix neutral basis. As a result of the elimination of the stop-loss/stop-gain adjustment, the starting direct price increased by $0.51 for free-standing homes with fewer than 300 beds and by $0.56 for hospital-based homes and homes with 300 or more beds. The indirect price rose by $0.26 for free standing homes and by $0.29 for hospital-based homes and homes with 300 or more beds. While the changes to the starting prices affect all homes, the individual impact will vary based on facility-specific wage adjustments and case mix.

For all but 49 homes that submitted acceptable capital attestations, the 2017 capital component will reflect the attested-to figure. The 49 homes whose attestations DOH is still reviewing will have their capital updated to their attested-to amount in a capital update schedule DOH intends to issue in approximately two months if the attestation is deemed acceptable. Of the 340 attestations DOH received, 61 were not approved and 29 brought up operational issues. DOH had suggested that they might request all homes to file attestations, including those that agree with the capital as calculated by DOH, but clarified that this requirement would begin next year.

DOH is contemplating changes to the attestation process for next year to help ensure that final rates are issued by Jan. 1^st. The state intends to require all homes to attest to their capital calculation, whether they are submitting corrections or accepting the DOH calculation. Along with preparing a webinar to be held shortly to help educate providers on capital issues DOH has encountered in the attestation process, DOH intends to begin the process earlier next year, which may require an earlier cost report submission date than the July 15^th date used for the last two years. DOH was amenable to suggestions to revisit an earlier initiative to streamline the cost report by eliminating unneeded schedules, as well as recommendations that the Office of the Medicaid Inspector General (OMIG) be involved in the attestation education to ensure that auditors are aware of the requirements presented to homes.

Rates Reflecting MDS Audits

DOH has reissued updated rates dated Jan. 1, 2013 and April 1, 2013 to reflect the impact of OMIG MDS audit findings as well as the removal of any remaining CMI constraints. Rate sheets have been posted, and rate adjustments have been made. Please note that for some hospital-based homes, the negative amount on line 14 (bed-hold related cut) of their updated April 1, 2013 rate sheet changed. This amount should NOT have changed from the amount shown on the previously-issued April 1, 2013 rate sheet, and DOH is processing a correction for affected homes.

DOH is now in the process of reissuing updated rates dated July 1, 2013 and Jan. 1, 2014 to reflect the impact of OMIG MDS audit findings as well as the removal of any remaining CMI constraints. These adjustments will be included in Medicaid payment cycle 2056 (check release date of Feb. 1^st) or 2057 (check release date of Feb 8^th). OMIG is in the process of issuing draft audit reports for the July 2014 and newer rate periods. Updates to these rate periods are not expected until later in the year. 

Other Rate Adjustments

The 2015 cash receipts assessment reconciliation has been completed, and results have been sent to eMedNY for payment, which will be included in cycle 2056 or 2057. Homes expecting year two Advanced Training Initiative funding should receive a lump sum payment of the state and federal share in Medicaid payment cycle 2056, which has a check release date of Feb. 1^st.

The reinvestment of $70 million per year from the 0.8 percent assessment (to be effectuated as a 1 percent rate add-on) retroactive to April 2014 awaits federal approval. Regulations are in review. The carve out of transportation from the rate retroactive to April 2016 has received federal approval. Regulations are in the development process.

Federal approval has been received for the 2015 quality pool, although payments are on hold pending resolution of litigation. DOH is eager to resolve and has been in contact with the court. State regulations have been published and are being finalized. The score sheets with 2016 quality pool results have been posted for homes to review prior to being made public.

Refinancing Shared Savings

With CMS having approved the state’s ability to share a portion of the money saved through mortgage refinancing with the nursing home, DOH is developing policies around the initiative and will issue guidance shortly. Refinancings finalized on or after April 1, 2015 are eligible, but DOH stresses that all refinancing arrangements need to be approved by DOH. They have cleared the backlog and review refinancing requests within 30 days. DOH is discussing whether loan modifications would qualify for shared savings and will include a discussion on refinancing in the capital attestation webinar.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841