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Legislative Issues Public Policy News
A Weekly Publication Of HCAHCAHCAHCAHCAHome Care Association of New York State
Helping New YorkersFeel RightAt Home
ASAP
Inside Inside Inside Inside Inside ASAPASAPASAPASAPASAP
HCA Members Visit
Legislators, Governor’s Staff
to Voice Home Care Message
on Advocacy DayHCA Board meeting discussion with MedicaidDirector Helgerson yields key updates
HCA members from throughout the state visitedAlbany for legislative visits during our 2014 StateAdvocacy Day on Monday. The program wasfollowed by a special Board Meeting discussionwith State Medicaid Director Jason Helgerson onTuesday, and other related events.
Throughout Monday’s program, HCA’s Policyand Government Relations teams joined membersfor dozens of appointments with Senate andAssembly representatives. The meetings includedspecial HCA Board of Directors appointmentswith key Senate and Assembly staff and legislativeleaders.
Volume 19, No. 5 January 31, 2014
See ADVOCACY p. 2
HCA Members meet with Senator Dean Skelos,the Republican Conference Leader, TemporaryPresident and co-Leader of the State Senate’sMajority governing coalition during HCA’sAdvocacy Day on Monday.
HCA Members Visit Legislators, Governor’s Staff on Advocacy Day....1
HCA Report Chronicles Ongoing Financial Distress..........................7
DOH Issues DAL on CoP Trigger for Home Care in Managed Care.....8
“DSRIP” Program, Provider Collaboration Emphasized.................9
Home Care Due Dates.....................................................................11
CMS Begins Audits of Face-to-Face Encounter Documentation...12
In Memoriam: Martha Patterson.....................................................12
Programs Scheduled for Home Care Council Members.................13
CHHA Actions Taken at PHHPC Committee Meeting.....................14
Register Today for Downstate LHCSA Forum on Feb. 12.............14
Home Health, Personal Care Spending Remain Below Cap...........15
January Medicaid Update Includes Important Information..........16
NGS Updates.............................................................................17
eMedNY to Extend Provider Testing Environment for ICD-10......18
Health Care Resources....................................................................18
2
ASAP is a weekly publication of the Home Care Association of NewYork State (HCA). Unless otherwise noted, all articles appearing inASAP are the property of the Home Care Association of New YorkState. Reuse of any content within this newsletter requires permissionfrom HCA.
Joanne Cunningham, [email protected]
Roger L. Noyes, Director of Communications, [email protected]
Al Cardillo, Executive Vice President, Policy & Programs, [email protected]
Patrick Conole, Vice President, Finance & Management, [email protected]
Andrew Koski, Vice President, Program Policy and Services, [email protected]
Laura Constable, Senior Director, Membership & Operations, [email protected]
Lynda Schoonbeek, Director of Education, [email protected]
Mercedes Teague, Finance Manager, [email protected]
Jenny Kerbein, Director of Governance and Special Projects, [email protected]
Billi Hoen, Manager, Meeting and Events, [email protected]
Teresa Brown, Administrative Assistant, [email protected]
President:
Editor:
388 Broadway, 4th Floor, Albany, NY 12207Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
ADVOCACY continued from p. 1
Continued on next page
HCA’s advocacy messages
In all of the meetings on Monday, HCA members and staff described the economic and systemic pressurestheir agencies face and posed the following important question to lawmakers: What can the Legislatureand Governor do in this year’s budget to support home care? The answer to this key question wasencapsulated in a simple, four-part message communicated in several HCA resource documents sharedwith members on Advocacy Day:
1. Regulatory streamlining is needed for efficient provision and payment ofservices under managed care.
2. Services, including mandated wage laws and regulations, must be appropriatelyfunded and reimbursed.
3. Budget language is needed to support innovative hospital-home care models forpatient services, system improvement and community health.
4. “Essential Personnel” status is vital for supporting home care and hospicepersonnel during emergencies.
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
3
More information on HCA’s four-part advocacy message is in our Home Care Priorities in the 2014-15Budget document at http://www.hca-nys.org/documents/HomeCarePriorities20142015Budget.pdf. Thispiece provides succinct background for each of HCA’s four legislative “asks” and can be shared withlegislative offices.
Why these message points in particular?
HCA carefully chose these four messages for several reasons.
First, leading up to Advocacy Day, we identified areas that presented the most urgent needs in home care.Clearly those areas are: 1) regulatory streamlining, and 2) funding support in home care and managed care,especially to meet the wage levels mandated by the wage parity law for 2014.
Secondly, HCA also felt it necessary to build on the strength of past legislative initiatives for home caresupport that also had the benefit, simultaneously, of being compatible with core priorities articulated in theGovernor’s State of the State and his 2014-15 budget proposal.
As reported extensively in the past, HCA had already advanced “essential-personnel” legislation (S.4719/A.6530) and home care-hospital collaboration legislation (S.5258/A.7899) during the 2013 legislativesession. Not only did these initiatives enjoy legislative support in 2013, but they are also in synch with theGovernor’s budget focus on emergency preparedness as well as his proposed reinvestment and shared-savings programs through the Delivery System ReformIncentive Program (DSRIP) and other vehicles. (Seerelated p. 9 story on DSRIP.)
While highlighting these four areas ofneed as part of our Advocacy Daymessaging, HCA members and staffalso shared with legislators ourpositions on the budget, includingseveral areas where theGovernor’s proposal echoesconcerns already otherwisevoiced in our four-partadvocacy strategy.
HCA is continuing to pursuefurther information on all of theGovernor’s budget proposalsaffecting home care, many of whichwill require additional shaping and
Assembly Majority Leader JosephMorelle greets HCA Board Membersduring legislative meetings at the stateCapitol on Monday.
Continued from p. 2
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Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
Budget & ABudget & ABudget & ABudget & ABudget & Advdvdvdvdvocacocacocacocacocacy Guides ay Guides ay Guides ay Guides ay Guides at t t t t YYYYYour Four Four Four Four Fingeringeringeringeringer tipstipstipstipstips
HCA offers several important documents to assist you in yourbudget and legislative advocacy.
HCHCHCHCHCAAAAA’’’’’s Stas Stas Stas Stas Stattttte Budget Memore Budget Memore Budget Memore Budget Memore Budget Memorandumandumandumandumandum. This memo provideseverything you’d want to know about the Governor’s 2014-15 State Budget and its impact on home care.http://www.hca-nys.org/documents/Memo201415ExecutiveStateBudget.pdf
Home Care Priorities in the 2014-15 BudgetHome Care Priorities in the 2014-15 BudgetHome Care Priorities in the 2014-15 BudgetHome Care Priorities in the 2014-15 BudgetHome Care Priorities in the 2014-15 Budget. Please sharethis document with legislative offices to explain what theLegislature can do in this year’s budget to support homecare.http://www.hca-nys.org/documents/HomeCarePriorities20142015Budget.pdf
A CharA CharA CharA CharA Char t Explaining HCt Explaining HCt Explaining HCt Explaining HCt Explaining HCAAAAA’’’’’s Ps Ps Ps Ps Position on the Gosition on the Gosition on the Gosition on the Gosition on the Gooooovvvvvernorernorernorernorernor ’’’’’sssssBudgetBudgetBudgetBudgetBudget. With the Governor’s recent budget release,lawmakers will want you to explain the home carecommunity’s position on key health care provisions. Thisreference guide will help you do so.http://www.hca-nys.org/documents/201415BudgetItemsAnalysisMatrix.pdf
New New New New New YYYYYork’ork’ork’ork’ork’s Stats Stats Stats Stats State of Home Ce of Home Ce of Home Ce of Home Ce of Home Cararararare – A Special HCA Re – A Special HCA Re – A Special HCA Re – A Special HCA Re – A Special HCA Reporeporeporeporeporttttt.This report provides legislators and their staff with an up-to-date briefing on all of the major changes occurring in homecare, supported by the findings of HCA’s provider survey.http://www.hca-nys.org/documents/NewYorkStateofHomeCare.pdf
HCAHCAHCAHCAHCA’’’’’s 2014 Stats 2014 Stats 2014 Stats 2014 Stats 2014 State Ae Ae Ae Ae Advdvdvdvdvocococococacacacacacy Day Message Py Day Message Py Day Message Py Day Message Py Day Message Pointsointsointsointsoints. Thisdocument contains brief statements to guide you on whatto say to legislators during advocacy visits. Please follow thesimple four-step instructions on the first page of this piece.http://www.hca-nys.org/documents/MessagePoints2014AdvocacyDay.pdf
HCHCHCHCHCAAAAA’’’’’s Stas Stas Stas Stas Stattttte Budget Ce Budget Ce Budget Ce Budget Ce Budget Confonfonfonfonferererererencencencencence Ce Ce Ce Ce Call.all.all.all.all. On February 6 at 3p.m., HCA is holding a conference call to brief members onthe state budget. To register, please complete the onlineform at https://www.surveymonkey.com/s/ExecutiveBudget
reaction from the home care community.These include the Governor’s proposal toadjust rates for Certified Home HealthAgencies (CHHAs) and Long TermHome Health Care Programs(LTHHCPs) for wage parity costs – aprovision which, the Executive states,will include Managed Long Term Care(MLTC) rate adjustments madeadministratively (although, there are nospecific line appropriations in the budgetdetailing these funding increases).
While this particular budget proposalfor wage parity is a positive response tourgent funding needs that broadly agreewith HCA’s legislative asks, furtheranalysis is required to see if the proposedadjustment level and payment methodsallow for wage parity compliance andwhether they provide an appropriatechannel of funds to direct-care workersemployed by Licensed Home CareServices Agencies (LHCSAs). More information on the core home carebudget provisions and HCA’s position/analysis are in the chart at http://www.hca-nys.org/documents/201415BudgetItemsAnalysisMatrix.pdf.A detailed policy memo on the budget isat http://www.hca-nys.org/documents/Memo201415ExecutiveStateBudget.pdf.
Board meeting with Jason Helgerson
In connection with Advocacy Day,HCA’s Board of Directors also met onTuesday to discuss follow-up advocacyactivities and other matters. After theregular Board meeting, Board Membershosted a special discussion with StateMedicaid Director Jason Helgerson totalk about: perspectives, insights anddetails related to the Governor’s budget
Continued from p. 3
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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provisions affecting home care; the progress of the state’s $10 billion federal reinvestment waiver request;next steps in the state’s Medicaid Redesign process; and HCA’s advocacy “asks.”
During the meeting, Mr. Helgerson emphasized the opportunities for home care under the Governor’sDSRIP proposal in the budget (see related p. 9 story), especially the provision allowing for regulatorywaivers, which Mr. Helgerson credited HCA for helping to advance as part of our ongoing policy discussionswith the Cuomo Administration about ways the home care infrastructure can meet the goals of MedicaidRedesign.
Related to DSRIP, a big focus of policymaking for 2014, Mr. Helgerson said, is addressing hospitalreadmissions, noting that “home care providers are the boots on the ground when it comes to addressing thatissue.”
HCA staff and Board members agreed about theprimacy of this issue and urged the Executive toincorporate provisions similar to our legislativeproposal for home care-hospital collaboration as aspecific element of the state’s waiver reinvestment planaimed at avoiding readmissions.
Regarding the waiver, Mr. Helgerson indicated thatthe state hopes to have its application finalized byFebruary, which means that proposed projects forDSRIP – or any other funding vehicle under thewaiver – will go into “quick-start” mode as the statemoves fast on the implementation process.
The waiver as a whole remains a key political pressurepoint – not to mention the subject of news headlines inrecent weeks – as the Cuomo Administrationcontinues to press the federal government for aquicker resolution on the state’s application.According to media reports, New York SenatorCharles Schumer assisted the state’s effort on thefederal level by contacting U.S. Health and HumanServices Secretary Kathleen Sebelius this week for aprogress report on the waiver. According to pressreports, Ms. Sebelius indicated to Senator Schumerthat a decision on the waiver would be made within 30days.
As far as other pending MRT initiatives, Mr.Helgerson said the mandatory MLTC enrollmentimplementation plan will continue to press forward
with the transition of recipients in most of the upstate urban areas of the state by the end of 2014 and fullstatewide completion by 2015. The Board and HCA Policy staff also asked Mr. Helgerson about specific
State Medicaid Director Jason Helgerson spokeat length with HCA’s Board of Directors onTuesday about the progress of MRT initiatives,the Governor’s State Budget proposals forhome care, and the state’s effort to obtainfederal waiver dollars for Medicaidreinvestment.
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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areas of the Governor’s budget, such as the wage parity funding proposal and the LHCSA Vital AccessProgram funds for streamlining and consolidation of agencies, which, Mr. Helgerson said, wouldentertain proposals specifically linked to a plan for applicants to become more efficient or to seektemporary operating assistance to merge with another entity and become sustainable.
The Board also urged support for HCA’s overall budget requests, including the need for regulatorystreamlining generally and funding support for wage parity while additionally raising concerns about arecently issued Dear Administrator Letter regarding the applicability of federal regulations to home careservices under managed care. (See related p. 8 story.)
HCA is working to compile as much information as possible on all of these issues and will provideupdates to the membership. On the budget specifically, the best way for members to gain the latestinformation is to register for HCA’s February 6 Statewide Budget Conference Call (3 p.m.). Toparticipate, please complete the online form at https://www.surveymonkey.com/s/ExecutiveBudget.
HCA thanks Mr. Helgerson for his receptivity on key budget, regulatory and legislative issues, and welook forward to working with him throughout the coming months of the legislative session.
We also thank participants of HCA’s advocacy program this week, and we urge all members to continueusing HCA’s Advocacy Day message points and resource documents in your ongoing outreach tolegislators. Please see the resources on our Power of Home Care website at http://powerofhomecare.org/advocacy-reports-and-resources/.
Looking ahead to next week, the Legislature has scheduled joint legislative hearings on the proposedbudget, including a Hearing on the Health and Medicaid Budget scheduled for this coming Monday,February 3 at 9:30 a.m. in the Legislative Office Building in Albany. HCA will testify, as will state officialsand others with concerns and comments on the budget. We will let the membership know of any specificadvocacy needs related to this hearing.
Please also mark your calendars for local district advocacy activities during the week of February 17. Thisis the week when the State Legislature is adjourned for the President’s Day holiday, and many legislatorswill be home in their district offices where they will be available to meet with you and other constituentslocally.
This local presence gives you an opportunity to meet with your representatives away from the bustlingatmosphere of Albany politics – where you and your staff can bring a real focus to the needs of New York’shome care community using HCA’s message points and other resource documents as your guide.
Now is the time to begin scheduling these local appointments, and let HCA know if we can be ofassistance in this effort.
For more information, please contact a member of HCA’s Policy staff.
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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HCA State of Home Care Report Chronicles Ongoing Financial Distress
For our State Advocacy Day this week, HCA releasedthe results of a home care financial condition survey anddata analysis in a report entitled New York’s State ofHome Care, available at http://www.hca-nys.org/documents/NewYorkStateofHomeCare.pdf.
New York’s State of Home Care tells the story aboutrecent policy developments in home care and theirimpact on providers. The report specifically explains theevolution of Medicaid payment changes, a primer onmandatory enrollment and key activities related to it,the Wage ParityLaw, the CertifiedHome HealthAgency Request forApplicationsprocess, and theeffect of all thesechanges onprograms andservices.
HCA thanks the 85members whocompleted HCA’ssurvey andsubmitted keyfinancial data that made this report possible. Inaddition to the survey sample of financial data, HCAalso separately analyzed all of the 2011 Medicaid CostReports submitted by Certified Home Health Agencies(CHHAs) and Long Term Home Health CarePrograms (LTHHCPs) in the state, as well as managedcare plan operating and finance data submitted by plansin their Medicaid Managed Care Operating Reports(MMCOR).
Among the key findings of our report:
• Over 70 percent of home care providers hadnegative operating margins in 2011 and 2012.
• 12 percent of home care agencies plan to closetheir doors as a result of recent policy changes;53 percent of LTHHCPs plan to do so.
• 42 percent of Managed Long Term Care(MLTC) plans had negative premium incomes in
2012 – a shortfall that financially squeezesboth the plans and their rates of payment todownstream home care providers who arealready coping with the impact of prior-year cuts, mandates like the Wage ParityLaw, and other issues. On average,providers who have already negotiatedMLTC contracts are receiving Medicaidrates 7.45 percent below their fee-for-service rates.
• More than two-thirds of providers said theredundancy or lack of clarity in stateregulations has had a “large cost impact” ontheir organization in the managed carecontracting environment.
• In 2014, when wage parity requirementsincrease dramatically, about 40 percent ofagencies in HCA’s survey expect to have toreduce the hours of direct-care staff and asimilar percentage expect to reduce direct-care staff overtime, while 25 percent ofagencies plan to lay off other agency staff.
• Almost 80 percent of survey respondentshave seen an increase in administrativecosts due to state and federal audits alone.
How to use this report
HCA designed this report for our 2014 advocacyefforts, and to help reinforce the need for our fourprimary legislative “asks” (see related p. 1 story). Weencourage members to continue sharing this reportwith your legislative representatives while usingHCA’s other advocacy resources to complement thereport.
You may also want to share this report orsummarize its findings for your organization’sBoard of Directors and/or community partners sothat they can see how your organization’sexperiences compare to trends happening in thehome care system statewide.
For more information, please contact a member ofHCA’s Policy staff.
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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DOH Issues Letter on CoP Trigger for Home Care Services under Managed CareHCA to hold statewide member conference call on this issue Monday The state Department of Health (DOH) on Tuesdayformally posted a Dear Administrator Letter (DAL), datedJanuary 24, to address repeated and long-lingeringquestions by home care providers and health plans on theapplicability of state and federal regulations to theprovision of home care services under managed care. Theletter can be downloaded http://www.hca-nys.org/documents/DALCOPs012414.pdf.
The DAL was issued during a time of ongoing discussionsamong HCA, other stakeholders, and DOH on thecontent of a draft version, including steps to mitigate anyundesired consequences for providers, health plans, directcare workers and patients. Immediately after the letter’srelease on Tuesday, HCA raised our continuing questions,concerns and expressed the need to work in common toaddress possible implications. The DAL refers to the State Operations Manual (section2202.3A) and states that “home health agencies providingservices under Medicaid’s home health benefit must meetthe Conditions of Participation (CoPs) for Medicare.” CoP applicability includes services provided undercontract with managed care, in which case the contractinghome care provider must be Medicare-certified, accordingto the Department. “Health maintenance organizations serving Medicare/Medicaid patients can either provide home health servicesthemselves or can contract out for those services,” the DALstates. “If they provide home health services themselves,they must meet the Medicare home health CoPs. If theycontract out for home health services, they must contractwith a Medicare-approved home health agency in order toserve Medicare/Medicaid patients.” The DAL defines home health services, under 42 CFR440.70(b), as follows: “nursing service, as defined in theState Nurse Practice Act, that is provided on a part time orintermittent basis by a home health agency; home healthaide service provided by a home health agency; and physicaltherapy, occupational therapy, or speech pathology andaudiology services provided by a home health agency.”
A draft version of this letter had been in widecirculation informally over the past severalweeks. The final version posted on Tuesdayintends to restate federal regulations inresponse to questions from the provider, healthplan and association communities regardingthe applicability of regulations in managedcare. These questions have become all the morepressing as thousands of patients aretransitioned to managed care under mandatoryManaged Long Term Care (MLTC)enrollment. The Department’s written statementconcerning CoP applicability follows publicstatements by DOH officials at conferences, inmeetings of the Home and Community-BasedCare Workgroup convened by the Legislature,and in other venues, responding to questionsraised by providers and health plans duringboth the lead-up and initiation of mandatoryMLTC enrollment. Prior DOH guidelines, as well as statementsfrom DOH officials about the intendedresponsibilities and requirements of home careproviders and managed care plans in the newmandatory enrollment system, had varied onthe issue of regulations, including CoPapplicability and provider-type, prompting thisweek’s formal interpretation. State officials also acknowledge that thislingering CoP question is projected to havemajor cost implications for the managed care-home care system, not to mention implicationsfor continuity of services and providers,existing managed care contract arrangements,and other impacts, as policies, practices andcontracts must ensure conformance to theserequirements.
See CoPs p. 9
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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Indeed, this year’s Executive StateBudget proposal includes a $17 millionappropriation for new costs attributableto CoP applicability. A legislativebriefing document on the budgetdescribes this appropriation as follows:“CMS clarified that all skilled home careservices in Managed Care settings mustbe delivered by agencies that are incompliance with the federal Conditionsof Participation.” HCA will also be seeking furtherinformation on how the proposed $17million budget appropriation wascalculated and will be advocating for anyfurther increases that we identify areneeded to meet this new guidance. Conference Call on Monday
To discuss this DAL further and itsimplications for home care and managedcare, HCA has scheduled a specialstatewide conference call for this comingMonday, February 3 at 4 p.m. where wewill provide the membership with thelatest information and next steps relatedto the DAL. Simply complete the online form athttps://www.surveymonkey.com/s/DALConferenceCall and dial-ininformation will be sent to you onMonday in advance of the call. You mustbe an HCA member to participate in thiscall.
According to DOH, questions on theDAL can be sentto [email protected] asks that you send us copies of anyquestions sent to DOH.
For more information, please contact theHCA Policy staff.
CoPs continued from p. 8“DSRIP” Program, Provider
Collaboration Emphasized
The Governor’s budget message, the state’s $10 billionwaiver proposal, remarks stressed again this week by theState Medicaid Director – all of these have emphasizedthe Cuomo Administration’s intent to pursue healthsystem change through integration, collaboration andpayment reform. The Administration has said it plans tomove quickly and vigorously in this direction.
To promote this goal, the Administration is pursuing afederal Medicaid waiver to invest significant dollarsthrough the federally-channeled “DSRIP” or DeliverySystem Reform Incentive Payment program.
In remarks to HCA’s Board of Directors on Tuesday, StateMedicaid Director Jason Helgerson especially emphasizedthe opportunity areas for home care under this proposal.
DSRIP stresses improved outcomes and systemfunctioning by reducing preventable hospital admissions,readmissions, emergency room use and incentivizing otherpositive public health goals.
To prepare for federal action on the waiver, expected withinthe month, the Cuomo Administration’s 2014-15 statebudget includes several priority proposals that wouldchannel funds and regulatory flexibility to providers forsystem reform through DSRIP. The budget proposes amajor $1.2 billion capital component, regional pilotprojects and regulatory waivers.
DSRIP/Waiver Background
New York’s DSRIP plan includes 25 programs dividedinto three focus areas:
• Hospital transition, public hospital innovation,primary care expansion, Vital Access Providers(VAP)
• Long term care transformation
• Public health innovation
Continued on next page
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Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
Through innovations in these three focus areas,the statewide DSRIP plan seeks to reduceavoidable hospitalizations by 25 percent over fiveyears. (HCA members can view the Department’spresentation with further detail on DSRIP ath t t p : / / w w w. h c a - n y s . o r g / d o c u m e n t s /20131218webinarpresentation.pdf.)
Provider participation strongly encouraged
As noted earlier, State Medicaid Director JasonHelgerson, addressing the HCA Board Directorsearlier this week, encouraged home care providersin the strongest terms to explore participation inDSRIP. Such collaboratives include home care,hospitals and primary care, as well as furtherinterdisciplinary, supportive and allied careentities, such as behavioral health, communityservices and others. Mr. Helgerson emphasizedthat the wider and stronger the coordination andintegration proposal, the better the prospects forstate funding and support.
On DSRIP, Mr. Helgerson cited HCA’s workwith hospital sector partners, specifically theIroquois Healthcare Alliance (IHA), oncollaborative initiatives of the type exemplifiedunder DSRIP. He noted that aspects of theseHCA-IHA initiatives were ultimatelyincorporated into the Executive budget proposal– specifically the DSRIP provisions for waiversand regulatory flexibility.
HCA has spent months working closely withallies in the hospital community to explore anddevelop collaborative solutions that support thehealth care infrastructure, offer more effectiveservice delivery, and promote community health.Top state health officials, including State HealthCommissioner Dr. Nirav Shah, Mr. Helgerson,Deputy Health Secretary Courtney Burke, andstate legislative health leaders have repeatedlyconferenced with HCA to discuss proposals andencourage pursuit of these ideas. (See the January10 edition of ASAP.)
In addition, HCA submitted, and previouslyshared with the membership, an array of specific
recommendations to the state for consideration in itsDSRIP plan negotiated with CMS. Theserecommendations included care transition initiatives,special care training, home care-hospital-physicianintegration initiatives, regulatory flexibility, investmentsin technology and workforce, and others. HCA membersare encouraged to examine these proposals in preparationfor opportunities on the horizon for potential DSRIPprojects.
The HCA-Iroquois efforts also led Senate HealthChairman Kemp Hannon and Assemblywoman AileenGunther to introduce legislation (S.5258/A.7899) thatwould provide a foundation for policy, program andfinancial support for collaborative care programsinvolving hospitals, home care, physicians and otherpotential partners. This legislation has provided anegotiating point offering language for possible furtherdevelopment in HCA’s state budget advocacy.
Advocacy Day messaging on collaboration models
HCA has already begun our budget focus on collaborationproposals as part of our State Advocacy Day meetingsthis week. (See related p. 1 story.)
During these meetings, HCA and provider members gavestrong support for the inclusion of collaboration vehiclesin the state budget – one of four pillars articulated in ourAdvocacy Day message documents.
In addition to testimony at this coming week’s LegislativeBudget Hearings, scheduled for Monday, February 3,HCA will be working to offer policymakers with examplesof successful models from the field and other informationto lend support for the adoption of effective budgetinitiatives.
Planned outreach and provider education
HCA will also continue working with our partners in thehospital sector as well as with other association allies toprovide further information and education to memberson DSRIP, the budget proposals, and other guidance forparticipation in the waiver and collaborative initiatives.Look for information on these joint efforts coming soon.
For further information, please contact Al Cardillo [email protected].
Continued from p. 9
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Home Care Due DatesHome Care Due DatesHome Care Due DatesHome Care Due DatesHome Care Due Dates
The following chart provides information on upcoming deadlines for reporting and regulatoryrequirements over the next several months. Please be sure to take note of these deadlines and check outthe resource links for additional information.
Requirement Date Explanation Resources
Metropolitan Commuter Transportation Mobility Tax (MCTMT)
Jan. 31, 2014
Certain businesses within NYC, Long Island, Westchester, Rockland, Orange, Putnam and Dutchess must pay a tax
http://www.tax.ny.gov/bus/mctmt/emp.htm
Uniform Assessment System (UAS)
Feb. 1, 2014
Home care agencies providing certain services must use UAS for patients in New York City, Long Island and Westchester
http://www.health.ny.gov/health_care/medicaid/redesign/uniform_assessment_system/index.htm
Annual wage notice
Feb.1, 2014
All employers must give certain wage information to their employees, including rate of pay, how the employee is paid (per hour, week, etc.), and other information
http://www.labor.ny.gov/workerprotection/laborstandards/employer/wage-theft-prevention-act.shtm
Wage Parity Certification
March 1, 2014
CHHAs, LTHHCPs, and Managed Care Organizations (MCOs) serving downstate must certify to the state for March 1, 2014 to February 28, 2015 that the services they provide or arrange for are in compliance with the wage parity law
http://www.health.ny.gov/health_care/medicaid/redesign/2013-02-21_wage_parity_alert.htm
Wage Parity Certification
March 1, 2014
LHCSAs who contract with CHHAs, LTHHCPs, and/or MCOs downstate must certify to their contractors for March 1 to May 31, 2014 that they are in compliance with the wage parity law
http://www.health.ny.gov/health_care/medicaid/redesign/2013-02-21_wage_parity_alert.htm
Wage Parity Law: NYC
March 1, 2014
Aides must be paid $14.09 in “total compensation” consisting of a “base wage” of at least $10 per hour, “additional wages” of up to $1.69 per hour and “supplemental wages” of up to $2.40 per hour
http://www.health.ny.gov/health_care/medicaid/redesign/docs/2013-10-31_wp_notice_re_nyc_comp.pdf �
Wage Parity Law: Long Island and Westchester
March 1, 2014
Aides must be paid $9.50 per hour if health benefits are included or $10.93 without health benefits
http://www.health.ny.gov/health_care/medicaid/redesign/docs/2013-10-31_wp_notice_re_westch.pdf
Personnel Influenza Vaccination Report
Spring 2014 – Date TBA
Home care and other agencies must submit Influenza Vaccination Report at end of influenza season
http://www.health.ny.gov/diseases/communicable/influenza/seasonal/providers/prevention_of_influenza_transmission/
ICD-10 Codes Oct. 1, 2014
Medicare and Medicaid claims with dates of service on or after October 1, 2014 must be submitted with ICD-10 codes
http://www.cms.gov/Medicare/Coding/ICD10/index.html?redirect=ICD10
https://www.emedny.org/icd/index.aspx
Volume 19, No. 5 January 31, 2014ASAP – a publication of the Home Care Association of New York State
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In Memoriam: Martha Patterson
HCA was greatly saddened to learn this week about the recent passing of friend, home care nursingprofessional, and home care advocate Martha Patterson.
In 2011, Ms. Patterson retired from the Visiting Nurse Association (VNA) of Albany following a 30-plus-year career at the VNA where she was a major part of the HCA community, participating in severalHCA programs and capacities over the years.
She started her career in nursing in 1974 at Columbia Presbyterian Hospital in New York City, and laterat Albany Medical Center. At the VNA, she had most recently served as Director of Patient Services.
Calling hours will be held on Friday, February 14 from 4 to 7 p.m. at Calvary UMC Church, 15 RidgePlace, Latham. A memorial service celebrating Martha’s life will be held at Calvary Church on Saturday,February 15, 2014 at 11 a.m. In lieu of flowers, the family requests donations be made in Martha’s nameto Calvary United Methodist Church, 15 Ridge Place, Latham, NY 12110 or the VNA Foundation ofAlbany, 35 Colvin Ave., Albany, NY 12206.
HCA extends our deepest condolences to Martha’s family and friends as well as her colleagues at theVNA of Albany.
CMS Begins Audits of Face-to-Face Encounter Documentation
HCA learned this week that randomly selected home health agencies (HHAs) across the country – including inNew York – began receiving additional documentation request (ADR) letters from Strategic Health Solutions,LLC, which is a Medical Review Contractor for the U.S. Centers for Medicare and Medicaid Services (CMS), tospecifically review physician face-to-face (F2F) encounter documentation.
Effective April 1, 2011, Section 6407 of the Affordable Care Act (ACA) established a F2F encounter requirementfor certification of eligibility for Medicare home health services, requiring the certifying physician to documentthat he or she, or a non-physician practitioner (NPP) working with the physician, has seen the patient and toverify the patient needs home health services.
According to the ADR letter, before the F2F mandate went into effect, the U.S. Office of the Inspector General (OIG)found that only 30 percent of Medicare beneficiaries had at least one F2F visit with the physician that ordered homehealth care. Based on this information, and now that the F2F rule is in effect, CMS has directed Strategic HealthSolutions to perform post-payment review of Medicare Part A claims billed for home health services.
HHAs receiving the letter have been asked to submit the following information for each claim requested:
• Copy of the claim bill;• Physician’s order for home health services, applicable to the dates of service;• Physician’s certification statement;• Plan of Care, applicable to dates of services;• Documentation of the F2F encounter performed by the certifying physician or NPP, applicable to dates of
services;Continued on next page
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• Signature log(s) or attestation statement(s), ifapplicable; and
• If electronic signatures are used, documentation toverify the entries are appropriately authenticated anddated.
Agencies receiving the letter are asked to submit the requesteddocumentation within 45 days. The letter purposefully statesthat Medicare does not reimburse for the cost associated withcopying medical records. According to HHAs receiving theletter, Strategic Health Solutions has been asking for fiveADR medical records per agency.
HCA is aware of at least two providers in New York receivingsuch a letter. If your agency has also received this letter, HCAwould be interested in knowing so that we can track theincidence of F2F-related ADR requests. Please do so by sendingan e-mail to [email protected]. HCA is also very interestedin learning your specific experiences with the process ofresponding to and preparing documentation for the requests.
It should be noted that these types of audit letters appear tobe new and are completely separate from the ongoingRecovery Audit Contractor (RAC), Comprehensive ErrorRate Testing (CERT) and other CMS Medicare audits.
Advocacy on the F2F issue remains a major priority of HCA.As extensively reported in the past, HCA has engaged NewYork’s Congressional Delegation to press for a morestreamlined F2F documentation process. Rep. Tom Reed andRep. Paul Tonko led a delegation letter to CMS on this effort.To learn more, please see the press release at http://reed.house.gov/press-release/reed-letter-urges-simpler-process-more-access-home-health-services.
HCA President Joanne Cunningham, in her role as chair ofthe Forum of State Home Care Associations, worked withpartners nationwide on a survey and summary paper detailingthe enormous administrative and cost burden of F2F. Thisdocument, available at http://www.hca-nys.org/documents/ForumFacetoFaceSurveyResultsOnePager.pdf, has been akey feature of HCA’s continued advocacy with federalpartners seeking a more workable approach to F2F.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
Programs Scheduled for Home
Care Council Members
As part of the new partnership betweenHCA and our Home Care Council (HCC)members, HCA is planning a number ofprograms specifically for HCC agencies.
HCA has invited participants to a February4 meeting in New York City to introduce ourstaff and services to HCC members so thatthey can become familiar with all theassistance we provide. We will discuss futureeducation programs, membership meetingsand legislative initiatives for the coming year.
Then on March 11, we will be holding aprogram in New York City for HCCmembers and Managed Long Term Care(MLTC) plans to discuss procedures forbilling to MLTC plans and any problematicareas that impede payment.
In addition, on March 27, we will hold aForum for HCC members at which we willprovide a briefing on the state budget, otherlegislative activities, recent regulatoryguidance and changes, and allow time formembers to report on their experiences andpressing issues.
These are just a few programs that have beenscheduled, and we will work with HCCmembers to provide additional ones.
As mentioned in last week’s ASAP, Andrew
Koski, Vice President for Program Policyand Services at HCA, and Joseph
Campanella, special HCA consultant andformer HCC Executive Director, aremeeting individually with HCC members. Ifyou want to schedule a meeting with Mr.Koski and Mr. Campanella, participate inany of the above programs, or have anyquestions, please contact Mr. Koski [email protected] or (518) 810-0662.
Continued from p. 12
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CHHA Actions Taken at PHHPC MeetingRFA process now completed
This week’s Public Health and Health Planning Council (PHHPC)Establishment and Project Review Committee discussed Certified HomeHealth Agency (CHHA) applications that resulted from the Request forApplications (RFA) issued in January 2012 as well as some proposals fora change of ownership.
First, the state Department of Health (DOH) summarized the responseto the RFA over the past two years. There were 137 applications receivedand 55 applicants were approved. These included: 17 establishmentapplications that include 4 new CHHAs; 4 Special Needs CHHAs wereapproved to convert to general purpose CHHAs; 22 existing CHHAswere approved for expansions; 10 Long Term Home Health CarePrograms (LTHHCPs) were approved to establish a CHHA; and 2LTHHCPs were approved to convert to a CHHA.
DOH announced that it will have completed the RFA process once theapplications from the PHHPC Committee meeting are considered by thefull PHHPC, and any of the remaining applicants will be notified thatthey have not been recommended for approval. In addition, DOH intendsto make recommendations for changing the CHHA certificate of need(CON) process in the future. HCA has in the past testified on the CONprocess for home care, recommending procedures and changes at the timethat the state was considering its RFA process and its opening of the CHHAmoratorium two years ago. HCA will be revisiting those recommendationsand others for possible next stages of the state’s CON discussions goingforward.
At this week’s meeting, the Committee approved an application by oneCHHA to expand to Rockland county and establish a separate CHHA toserve Erie and Niagara counties; deferred an application by a Special NeedsCHHA to convert to a general purpose CHHA; approved an applicationby a downstate CHHA to acquire two other CHHAs; approved anapplication by an existing CHHA to establish a separate CHHA to servefive upstate counties (Orange, Putnam, Sullivan, Dutchess and Ulster),but did not approve an application by the same CHHA to establish anotherCHHA to serve eight other upstate counties (Delaware, Fulton, Hamilton,Herkimer, Montgomery, Oneida, Onondaga and Otsego).
Prior to the meeting, an application by another Special Needs CHHA toconvert to a general purpose CHHA and to expand to Staten Island wastaken off the agenda. Those applications (approved and not approved)now go to the full PHHPC for consideration at its February 13 meeting.
For more information, contact Andrew Koski at (518) 810-0662 [email protected].
Join HCA for Feb. 12
LHCSA Forum
HCA will be holding ourDownstate LHCSA Forum on
February 12 from 9:30 a.m. to 2p.m. at Selfhelp CommunityServices, Inc. at 520 Eighth Ave.in New York City.
This is a members-only forum,offering you critical updates onLHCSA-specific issues includinginformation related to theproposed state budget, the statusof Wage Parity and ExecutiveOrder No. 38, the recent DearAdministrator Letter regardingrequirements for Conditions ofParticipation in home careprovided under managed care,the mandatory Managed LongTerm Care enrollment process,the Fully Integrated DualsAdvantage program and more.
In addition to HCA Policy staff,HCA is pleased to have PhilRosenberg, Partner at NixonPeabody, and Anthony Fiori,Director at Manatt Health,discuss the Wage Parity Lawsuitand Executive Compensation(Rosenberg) and the MLTCtransition (Fiori).
To cover the cost of meetingmaterial, food and refreshmentsfor this robust LHCSA-specificprogram, there is a nominal fee of$40 to register. Please see theregistration form at the back ofthis week’s ASAP for additionaldetails, and please be sure to joinus for this important members-only policy and program update.
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November Report: Home Health, Personal Care Spending Remain Below Cap
Total state Medicaid expenditures through November of the 2013-14 fiscal year are $59 million (or 0.5 percent)less than the amount projected under the state’s Medicaid Global Cap, according to the November 2013 MedicaidGlobal Spending Cap Report issued last week by the state Department of Health (DOH). Spending throughthe month of November was $11.136 billion compared to the projection of $11.195 billion for this period.
For home care, personal care and assisted living – which the Department includes in the “Other Long Term Care”category of service – the report shows actual spending at $770 million, which is $56 million lower than theDepartment’s estimated spending of $826 million. DOH does state that the difference appears to be related tothe transition of certain fee-for-service populations into the Managed Long Term Care (MLTC) program.
Under this year’s state budget, the Medicaid Global Spending Cap increases from $15.9 billion to $16.4 billionin fiscal year 2013-14 – a 3.2 percent increase. The cap on Medicaid spending is currently effective throughMarch 2015. The Governor’s 2014-15 Budget proposes to extend the Medicaid Global Cap through March2016.
DOH’s November report also indicates that the accounts receivable (AR) balance for retroactive rates owed tothe state through the end of November is $227 million. This represents a reduction of $173 million since April2013.
In other report highlights, total Medicaid enrollment moved to 5,353,146 at the end of November 2013. Thisreflects an increase of roughly 102,068 enrollees, or 1.9 percent, since March 2013. Medicaid managed careenrollment in November 2013 reached 4,056,220 enrollees – an increase of 119,789 enrollees, or 3.0 percent,since March 2013.
Global cap shared-savings initiative
The Governor’s 2014-15 Executive Budget includes a proposed initiative to reinvest back into the providersystem savings achieved under the global cap, as well as to discontinue the 2 percent across-the-board Medicaidcut beginning April 1, 2014. Both of these proposals have been discussed during the meetings of the state’sGlobal Cap Workgroup, of which HCA’s Executive Vice President Al Cardillo is a member. HCA has activelyparticipated in the discussions on these proposals and HCA is very encouraged that the Governor includedthem in his proposed Executive Budget.
Also related to the global cap and other Medicaid cost analyses, HCA has entered into a license agreement withSalient Management Company, the state’s Medicaid data contractor, to access its powerful software for purposesof our data analysis. HCA will be devoting resources, time, energy and Board focus to understanding, analyzing,and synthesizing this rich data set which will allow us to create sophisticated reports analyzing billions ofvarious Medicaid transactions by diagnosis, cost, demographics and more, including further drilldowns ofanalyses like those in the state’s global cap reports. Expect more information on this exciting new tool in thecoming months.
The full Medicaid Global Spending Cap report is at: http://www.health.ny.gov/health_care/medicaid/regulations/global_cap/monthly/docs/november_2013_report.pdf.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
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January Medicaid Update Includes Important Information
The state Department of Health’s January Medicaid Update was posted today and includes important informationon many issues. These include the transition of the nursing home benefit and population into managed care;requests for documentation under the Payment Error Rate Measurement (PERM) program; issuance of IRSForm 1099; and the requirement that all providers register for electronic funds transfer (EFT) payments andeither Electronic Remittance Advice (ERA) or PDF remittances.
The Medicaid Update is at http://www.health.ny.gov/health_care/medicaid/program/update/2014/jan14_mu.pdf.
Nursing Home Population
Effective March 1, 2014, in New York City, Nassau, Suffolk and Westchester counties, all eligible recipients overage 21 in need of long term placement in a nursing facility will be required to join a mainstream Medicaid managedcare (MMC) or a Managed Long Term Care (MLTC) plan. The rest of the state is scheduled to transition beginningSeptember 2014 for both dual eligible and Medicaid-only populations.
All current long term custodial care beneficiaries in a Medicaid certified skilled nursing facility prior to anymanaged care phase-in date will remain in fee-for-service Medicaid and will not be required to enroll in an MMCor MLTC plan.
MMC and MLTC plans are required to pay the nursing home the current Medicaid fee-for service (benchmark)rate or a negotiated rate, acceptable to both plans and nursing homes, for three years after March 1, 2014 fordownstate counties, and for three years after January 1, 2015 for all other counties. After the transition period,nursing homes and managed care plans will negotiate a rate of payment for services.
Medicaid Provider Documentation
The U.S. Centers for Medicare and Medicaid Services (CMS), in partnership with the state Office of the MedicaidInspector General (OMIG), will measure improper payments in the Medicaid and State Child Health Insuranceprograms under the Payment Error Rate Measurement (PERM) program. This will be the third time New YorkState has participated.
Documentation for medical review of randomly selected claims will be requested by A+ Government Solutions,
Inc., the CMS contractor. About 350 claims across all health care sectors will be targeted for review.
If claims you submitted are selected, the CMS contractor will request from you, in writing, documentation tosubstantiate claims paid in federal fiscal year 2014 (October 1, 2013 to September 30, 2014). You will be askedto submit the specific medical documents for the patient to the CMS contractor with a copy to OMIG. Requestsfor documentation will begin in March 2014.
Failure to provide requested records will result in a determination of erroneous payment, and OMIG will pursuerecovery. Questions can be directed to PERM Project staff at (518) 486-7153.
IRS Form 1099
CSC, the eMedNY contractor for DOH, issues Internal Revenue Service (IRS) Form 1099 to providers at thebeginning of each year for the previous year’s Medicaid payments. The 1099s are issued for the individual provider’s
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social security number and/or for businesses, with the Federal Employer Identification Number (FEIN) registeredwith NY Medicaid.
IRS 1099s for the year 2013 will be mailed no later than January 31, 2014.
As with previous years, note that the IRS 1099 amount is not based on the date of the checks/EFTs; rather, it isbased on the date the checks/EFTs were released to providers. Due to the two-week check lag between the date ofthe check/EFT and the date the check/EFT is issued, the IRS 1099 amount will not correspond to the sum of allchecks/EFTs issued for your provider identification number during the calendar year.
Any questions should be directed to the eMedNY Call Center at (800) 343-9000.
EFT and ERA/PDF Remittances
Medicaid now requires all billing providers to register for EFT payments and either ERA or PDF remittances.
Billing providers who have not registered for EFT and ERA or PDF remittances will not be allowed to re-certifytheir Electronic Transmitter ID Number (ETIN). When the ETIN expires, a provider’s claims will be rejected byeMedNY and providers’ ePACES accounts will be disabled.
Questions may be directed to the eMedNY Call Center at (800) 343-9000.
NGS Updates
New York’s Medicare Administrative Contractor (MAC), National Government Services (NGS), has posted thefollowing news to its website.
• Annual User Recertification is Coming Soon – The U.S. Centers for Medicare and Medicaid Services(CMS) requires NGS to conduct an annual recertification of all current Medicare online system users forPart A Fiscal Intermediary Standard System (FISS) Direct Data Entry (DDE) providers and for DMEsuppliers.
For the FISS Part A Online (DDE) and/or DME-Jurisdiction B (CSI) systems, every user that has acurrently active User/Login ID to access one of these systems assigned prior to November 1, 2013 mustcomplete the recertification. Users that were assigned a User ID or had their ID reinstated after November1, 2013 will not need to recertify until the 2015 recertification.
For questions and/or concerns about this recertification process, feel free to contact the NGS EDI Helpdeskat (877) 273-4334.
• Advance Beneficiary Notice (ABN) of Noncoverage Webinar for Home Health Agencies – CMS ChangeRequest (CR) 8404 discontinues the use of the Home Health Advance Beneficiary Notice (HHABN)(CMS-R-296). All home health agencies are now required to use the Advance Beneficiary Notice ofNoncoverage (ABN) (CMS-R-131). On February 10, 2014, from 2 to 3:30 p.m., NGS will hold a webinarto discuss use of the ABN and how home health agencies should complete this form. To register, go to theHome Health & Hospice (HHA) page of NGS’s website at www.ngsmedicare.com and then click the“Register for Training” link on the top left side of the page.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
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eMedNY to Extend Provider Testing Environment (PTE) Availability for ICD-10
In response to some concerns that the current Provider Testing Environment (PTE) availability date ofAugust 25, 2014 does not provide sufficient time for ICD-10 testing prior to the October 1, 2014implementation date, the state Department of Health (DOH) and Computer Science Corporation (CSC) arededicating additional resources to the ICD-10 implementation project and have agreed to move availability ofthe PTE for ICD-10 testing to Monday, July 28, 2014.
HCA members should be aware that the www.emdny.org website contains ICD-10 information, includingmany frequently asked questions (FAQs) and answers.
For further information, contact Patrick Conole at (518) 810-0661 or [email protected].
Health Care Resources
Publications
“Statistics on Medicare Home Health Agencies,” by the U.S. Centers for Medicare and Medicaid Servicesw w w. c m s . g o v / R e se a r c h - St a t i s t i c s - Da t a - a n d - S y s te m s / St a t i s t i c s -Tr e n d s - a n d - R e p o r t s /MedicareMedicaidStatSupp/Medicare-and-Medicaid-Statistical-Supplement-Items/2013HHA.html
For more information, contact Andrew Koski at (518) 810-0662 or [email protected].
February 129:30am – 2:00pm
Location:
Selfhelp Community Services, Inc.520 Eighth Avenue
5th FloorNew York, NY 10018
Registration
Please FAX this completed form to: (518) 426-8788
DOWNSTATELHCSA FORUMPlease join your LHCSA colleagues, HCA staff and Board Members for this exchange of valuable information, advocacy concerns and recommendations for action.
Some of the vital issues to be covered include:
• Proposed State Budget• Worker Wage Parity• Executive Order #38• Dear Administrator Letters on Conditions of
Participation and Managed Care and on Physician Orders
• MLTC Mandatory Enrollment• FIDA (Fully Integrated Duals Advantage) program
Phil Rosenberg, Partner, Nixon Peabody will join us to discuss the Worker Wage Parity lawsuit as well as Executive Compensation. In addition, Anthony Fiori, Director, Manatt Health will review the MLTC Mandatory Enrollment transition.
This forum is for HCA Members Only.
There is a fee of $40 for attending the LHCSA Forum to cover the cost of meeting material, food and refreshments.
If registering multiple participants, please complete a registration form for each additional person.
$40 per person
This is an HCA members-only forum.
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Cancellation PolicyCancellations received by February 5, are refundable less a 25% administrative fee. Cancellations must be received in writing via e-mail to [email protected]. No refunds after this date or for no shows. Substitutions are permitted.
