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Nursing Home Reimbursement Update

Although still subject to final internal review and approval by the Division of the Budget (DOB), the case mix index (CMI) reflected in the Jan. 1, 2019 nursing home Medicaid rates was calculated using the same methodology as in past years. Department of Health (DOH) staff shared this and other reimbursement updates during a meeting with LeadingAge NY and other associations this week. Highlights of the discussion are outlined below.

January 2019 Medicaid Rates

Members will recall that the 2018-19 State Budget required the State to achieve savings related to case mix that would have reduced Medicaid rates by $15 million. DOH required homes to upload rosters related to an unexpected April 2018 picture date along with the customarily used July 2018 picture date and had indicated that the case mix adjustment that would be used in the January 2019 rates would represent some form of blend of the two dates. At this point, DOH reports that the Jan. 1, 2019 rates they have calculated and are circulating for review include a CMI based on the July picture date and do not reflect any blending. Please note that these rates still require sign-off by the Medicaid Director as well as the approval of DOB prior to advancing to the payment system.

Proposed Case Mix Cut

DOH indicated that if this year’s State Budget proposal to change how case mix is measured were to be enacted, it would be implemented starting with July 2019 Medicaid rates. The proposal is projected to reduce case mix funding by $246 million annually. We continue to work with policymakers and legislators to prevent what would be a catastrophic cut averaging more than $9 per Medicaid day and urge members to join the effort to help educate their legislators about case mix and nursing home reimbursement. More information is available in our weekly Legislative Bulletins.

The Department has indicated that the proposal was driven by two primary concerns: large variation in case mix depending on the date on which it is calculated as well as a significant increase in CMI during the last three years. DOH arrived at the $246 million impact estimate by comparing July 2018 rates with rates calculated using a CMI that averaged the April 2018 and July 2018 picture date CMIs.

Other Outstanding Adjustments

Several other Medicaid rate or payment adjustments are in the works. A 1.5 percent increase to the operating rate to reflect increased staffing costs is effective on Nov. 1, 2018. DOH has submitted a Nov. 1, 2018 rate schedule to DOB for approval and will submit it to eMedNY for payment once approved. The 1.5 percent adjustment is calculated based on the July 2018 operating rate and is expected to remain in the rate as a fixed dollar amount through March 31, 2022. Members would have seen this adjustment on their draft initial Jan. 1, 2019 rate sheets.

Reconciliation of the 2017 cash receipts assessment has been calculated but is still in review, as are July 2015 and January 2016 rate adjustments reflecting any MDS audit findings and the release of the 5 percent constraint.

Minimum Wage Reconciliation

DOH expressed appreciation to nursing homes for completing the 2017 minimum wage reconciliation survey. The results are being analyzed, and any resulting adjustments will be made once DOH has completed their internal discussions to ensure a consistent approach across all sectors.

Other Issues

The State continues to discuss the change in the nursing home benefit in Managed Long Term Care (MLTC) with the Centers for Medicare and Medicaid Services (CMS), and no implementation date has been set. The 2018 Nursing Home Quality Initiative (NHQI) results await resolution of SPARCs data issues, and it remains unclear when the review reports will be posted. The filing date for the 2018 Medicaid cost report is not yet determined, although DOH is leaning toward maintaining the July due date.

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