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A Weekly Publication Of HCAHCAHCAHCAHCAHome Care Association of New York State

Helping New YorkersFeel RightAt Home

ASAPVolume 18, No. 42 November 22, 2013

Inside Inside Inside Inside Inside ASAPASAPASAPASAPASAP

HCA’s offices will be closed on Noclosed on Noclosed on Noclosed on Noclosed on Novvvvvember 28 and 29ember 28 and 29ember 28 and 29ember 28 and 29ember 28 and 29for the Thanksgiving Holiday and we will not be publishingASAP on November 29. We will next publish ASAP onDecember 6. HCA wishes you a safe and happy holiday.

HCA Policy Council Brings FIDA Issues into FocusDiscussion yields next steps in HCA action plan for FIDA implementation

HCA’s Policy Council met on Monday, with a focus on the state’s Fully IntegratedDuals Advantage (FIDA) Demonstration project.

For this important discussion, Monday’s meeting had the benefit of bringing togetherstate officials, including Medicaid Director Jason Helgerson and principal central healthstaff from the Senate and Assembly; Association leaders from HCA, the Healthcare

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Dedicated FIDADiscussion at PolicyCouncil meeting yieldskey updates aboutstate’s plans for majorsystem change

See FIDA p. 2

Home Health PPS Final Rule Due by Next WeekPPS rebasing cuts, copayments, and other fiscal threats remain in the mix as Congress also preparesrecommendations for mid-December budget committee deadline

The U.S. Centers for Medicare and Medicaid Services (CMS) is set to finalize its 2014 home health prospectivepayment system (HHPPS) rates by this coming Wednesday, November 27.

As extensively reported to the membership, CMS’s proposed 2014 HHPPS rule, issued in July, would beginthe process of home health rebasing over four years. The cumulative effect of this proposed rebasing plan and

See PPS p. 7

Home Health PPS Final Rule Due by Next Week.................................1

HCA Policy Council Brings FIDA Issues into Focus............................1

HCA Letter Urges Dedicated State Funding for Wage Parity...........9

Managed Long Term Care Update..................................................10

Health Bills Signed By Governor.........................................................10

OIG Releases 2014-18 Strategic Plan..............................................11

Electronic or PDF Remittance Advice Request Form Revised.........11

HCA Webpages Offer Data, Mandatory Enrollment Resources....12

Financial Survey Response is at 25 Percent of HCA’s Goal.............12

PPS Webinar Will Cover Soon-to-be-released Final Rule..............13

HCA, DOH Meet on Major Reimbursement, Financing Issues........13

HCA, DOH Make Quality Connections............................................15

1115 Waiver Amendment Webinar Rescheduled Again.................15

OMIG Holds Webinar on Compliance Certification........................16

Addendum Issued to HRA Home Care Services RFP.......................17

CHHA RFA Discussed at PHHPC Committee Meeting....................18

Exploring New Opportunities for Your Business and Patients......18

Protected Healthcare Information Advisory...................................19

Changes Made to HCS.....................................................................19

NAHC to Hold Hospice Webinar on Data Reporting Changes......20

Further Guidance on ABN for Dual Eligible Patients.....................20

‘People First’ Waiver Update...........................................................21

Publications.........................................................................................22

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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, jcunningham@hcanys.org

Roger L. Noyes, Director of Communications, rnoyes@hcanys.org

Al Cardillo, Executive Vice President, Policy & Programs, acardillo@hcanys.org

Patrick Conole, Vice President, Finance & Management, pconole@hcanys.org

Andrew Koski, Vice President, Program Policy and Services, akoski@hcanys.org

Laura Constable, Senior Director, Membership & Operations, lconstable@hcanys.org

Lynda Schoonbeek, Director of Education, lschoonbeek@hcanys.org

Mercedes Teague, Finance Manager, mteague@hcanys.org

Jenny Kerbein, Director of Governance and Special Projects, jkerbein@hcanys.org

Billi Hoen, Manager, Meeting and Events, bhoen@hcanys.org

Teresa Brown, Administrative Assistant, tbrown@hcanys.org

President:

Editor:

388 Broadway, 4th Floor, Albany, NY 12207Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org

Volume 18, No. 42 November 22, 2013ASAP – a publication of the Home Care Association of New York State

FIDA continued from p. 1

Association of New York State (HANYS) and LeadingAge New York; technical consultants and health lawexperts; and HCA’s provider and health plan members.

This major new policy initiative – brokered under an agreement between the state and federal governments –will begin a process of enrolling a target population of dual-eligible beneficiaries into FIDA-approved ManagedLong Term Care (MLTC) plans for the coordination of both their Medicare and Medicaid benefits.

The FIDA demonstration is set to begin in July 2014 with an initial population of 150,000 dual-eligiblebeneficiaries in the FIDA region (New York City, Long Island and Westchester) who are: age 21 and older;entitled to Medicare Part A; enrolled under Medicare Parts B and D; and receiving Medicaid benefits.

FIDA-eligible individuals must also meet one of the following three additional criteria: 1) are nursing-facilityclinically eligible and receiving facility-based long term supports and services (LTSS); 2) are eligible for theNursing Home Transition and Diversion (NHTD) waiver; or 3) require community-based LTSS for morethan 120 days.

Individuals will have the option of enrolling into a FIDA plan of their choice; however, eligible beneficiarieswho do not actively enroll into a plan will be “passively enrolled” at a later time. For passive-enrollment selection,the state has said it will rely on a process called “conversion-in-place,” under which dual-eligibles already inMLTC plans will see the Medicare benefit added to their MLTC’s coverage in cases where the individual’sexisting MLTC is FIDA-approved.

Enrollees will be able to opt out of FIDA at the time of “passive enrollment” and choose, instead, to separatelyreceive their Medicare benefits through Medicare fee-for-service and their Medicaid benefits through an MLTCplan. HCA is looking into whether enrollees can opt-out of FIDA from the outset, when they receive the initial

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Volume 18, No. 42 November 22, 2013ASAP – a publication of the Home Care Association of New York State

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Mark your calendars now for HCA’s 2014 StateAdvocacy Day on January 27 January 27 January 27 January 27 January 27 in Albany at theEmpire State Plaza.

This is a must-attend event for home careproviders to bring our message to Albany.

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Continued on next page

enrollment letter, or whether the opt-out opportunity is triggered only during passive enrollment – one ofseveral critical issues discussed by the Policy Council and guest speakers at Monday’s meeting.

Mr. Helgerson began the meeting with an update on the FIDA waiver status as well as goals and expectations forthe new initiative. HCA President Joanne Cunningham and Executive Vice President Al Cardillo were thenjoined by HANYS Executive Vice President for Policy Valerie Grey and LeadingAge New York President JamesClyne on a discussion of FIDA issue areas across the continuum, providing context from the hospital sector’sexperience with the transition to managed care during the 1990s and perspectives on FIDA from the long termcare community broadly.

The meeting concluded with a panel of technical experts offering insights and considerations for provider andplan FIDA readiness. Panelists included Herb Fillmore, Vice President of Strategic Innovations at TreoSolutions; Koy Dever, Principal at Loeb and Troper; and Carla Williams, Director of the Healthcare ConsultingGroup at O’Connell and Aronowitz.

Home care central to FIDA success

While FIDA is designed to net savings in both the Medicaid and Medicare programs, state officials expect themost significant savings will likely occur in the Medicare program, especially through anticipated reductions inhospitalization and emergency room use rates – a key area of home care expertise – that result from better carecoordination to dual-eligibles.

Indeed, one major theme on Monday was the centrality of home care in the anticipation of FIDA’s overallsuccess. This home care role was reinforced by data, presented at the meeting, which showed that the FIDApopulation primarily exhibits a need for interventions addressing functional status – more so than diseasestatus – which fit squarely within the domain of home care service goals and practices.

More broadly across the entire FIDA-affected system, the discussion also focused on procedural issues andquestions related to FIDA implementation and enrollment, and especially the critical need for both regulatoryclarity and relief to eliminate administrative redundancies or obstacles that are prohibitive for providers andplans operating under FIDA – a key focus of the HCA, LeadingAge New York and HANYS presentations.

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Volume 18, No. 42 November 22, 2013ASAP – a publication of the Home Care Association of New York State

The Association leaders and other PolicyCouncil members especially stressed the needfor per-member per-month premium rates toMLTC plans that are adequate for meeting theneeds of a chronic care population whilesupporting Wage Parity levels and othercosts, including disease managementtechnologies like home telehealth andsystems that can share patient data andmedical records compatibly.

Other key updates

The following are some additional key updatesand insights that emerged from Monday’sdiscussion:

• Approximately 25 FIDA plans (26including a plan for the Office forPeople With DevelopmentalDisabilities community) are now inthe process of undergoing state review.This process includes a desk review ofsubmitted applications, to befollowed by network validation, on-site review by state and federalofficials, and testing of the plans’systems. Preliminary draft rates werepresented to plans last week anddevelopment of three-way contractsare underway between plans, NewYork State and CMS – a process thatwill continue over the next severalmonths.

Mr. Helgerson said the state does nothave a target number for how manyof these applicant FIDA plans willultimately be finalized to begin servingthe initial population of 150,000beneficiaries, or that would ultimatelycomprise the ongoing FIDA options.During the meeting, several providersoutside the FIDA region asked aboutthe expectation for FIDA to beexpanded throughout the entire state.Mr. Helgerson indicated that such an

expansion beyond the demonstration region (of NewYork City, Westchester and Long Island) is desired bythe state but would likely require CongressionalAction.

• The state will be contracting with Maximus for “third-party, conflict-free assessments” – a requirement of thefederal rules for FIDA under the state’s Memorandumof Understanding with the U.S. Centers for Medicareand Medicaid Services (CMS). The assessments willbe conducted to determine if the enrolling individualrequires community-based long term services for atleast 120 days; it is a separate process from theassessment conducted via the Uniform AssessmentSystem tool.

Although it was acknowledged that conflict-freeassessments add another layer to the FIDA enrollmentprocess, CMS has insisted on such independent third-party oversight for determining FIDA eligibility.Members of the Policy Council asked for further clarityon who is responsibility for reassessments – specifically,whether this function falls to Maximus, the plan, orthe provider. HCA will be following up with stateofficials on this issue. Meanwhile, Mr. Helgerson saidthe state has generally accelerated its migration toconflict-free assessment for all MLTC cases – not justfor FIDA enrollees – with the expectation of achievingthis goal by the middle of 2014 (earlier than the initiallyplanned 2015 timetable).

• The state will also be contracting with an independent,conflict-free entity to serve as a “participantombudsman.” This entity would provide enrollees withfree assistance in accessing care, understanding theirrights and responsibilities and appealing decisions;however, this structure will supplement, not replace,the current fair-hearing process, Mr. Helgerson said.The state hopes to issue a Request for Applications forthe ombudsman by the end of this year.

• FIDA plans will be required by December 1, 2014 (withimplementation no earlier than January 2015) todevelop a plan for fully integrated payment systemsthrough which providers would no longer be paid on atraditional fee-for-service basis but would instead bepaid on an alternative basis, including pay for

Continued from p. 3

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performance, bundled payments, shared savings, etc. Many speakers noted that this is an opportunityfor plans and providers to work together on reimbursement, but providers also sought assistancewith such collaborative efforts.

• All speakers agreed on the opportunities and potential benefits for further collaboration betweenhome care and other sectors on improving transitions of care.

• The FIDA demonstration includes savings built into the reimbursement – 1 percent in year one, 1.5percent in year two, and 3 percent in year three – and also quality “withholds” that range from 1 percentto 3 percent over the life of the demonstration.

• HCA and Policy Council members sought clarification on whether the source of payment (Medicareor Medicaid) to downstream network providers would be differentiated as Medicare-sourced versusMedicaid-sourced or whether, based on encounter data collected by FIDA plans, the payor source(again, Medicare versus Medicaid) would be “blind” to the network provider with straight paymentsmade for services rendered. HCA stressed, in particular, the need for an unencumbered paymentprocess for FIDA services.

Mr. Helgerson indicated that all existing provider regulations would still apply under FIDA, but heemphasized the importance of continued discussions on regulatory relief – an ongoing area of HCAinquiry and advocacy with state officials through the Home and Community-Based Care Workgroupand in other venues. Many participants noted that the FIDA policy structure (and mandatoryenrollment generally) is moving in one direction while the regulatory structure remains largely fixed toa fee-for-service paradigm. Mr. Helgerson agreed that further discussion was needed on a range ofregulatory issues, including an examination of the roles of providers and plans, and a discussion aboutlongstanding policies with respect to procurement of physician orders.

• Monday’s discussion also made clear the need for more clarity of roles in the current Third PartyLiability (TPL) appeals process that would apply under FIDA but also under the MLTC paradigmgenerally. Mr. Helgerson indicated the expectation that TPL would largely be a health plan responsibilitybased on the encounter data that plans submit to the state and federal governments. Providerinvolvement in this process under FIDA – especially cases where providers are still billing Medicarefee-for-service to beneficiaries who have opted out of FIDA – is an area that needs additionalclarification with the state.

HCA appreciates the insights and perspectives provided by our guest speakers and by Policy Council membersas we fashion the next steps in our advocacy plan for the upcoming FIDA demonstration.

Monday’s meeting provided a vital exchange of ideas and issue areas among provider and plan representativesand state officials that will set the stage for important next follow-up steps as HCA works with HANYS,LeadingAge New York, the Legislature and Executive on further policy direction, clarification, regulatorychange and program refinement. This discussion will also help inform our education activities on behalf of ourcollective memberships.

For more information, please contact a member of HCA’s Policy staff.

UnUnUnUnUnderstanding Companionship Exemption Final Rule and Executive Order 38derstanding Companionship Exemption Final Rule and Executive Order 38derstanding Companionship Exemption Final Rule and Executive Order 38derstanding Companionship Exemption Final Rule and Executive Order 38derstanding Companionship Exemption Final Rule and Executive Order 38December 4 Webinar

This program will provide details on the final rule covering the federal “companionship exemption” and state Executive Order38, which establishes limits on executive compensation and administration expenses.

Home Health PPS Updates: Prepare Now to Succeed in 2014Home Health PPS Updates: Prepare Now to Succeed in 2014Home Health PPS Updates: Prepare Now to Succeed in 2014Home Health PPS Updates: Prepare Now to Succeed in 2014Home Health PPS Updates: Prepare Now to Succeed in 2014December 12 Webinar

Presenter Trish Tulloch will review and help you understand the 2014 PPS final rule.

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This program will cover what it means to provide person-centered care and how that can lead to greater client satisfactionand better agency outcomes.

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Does your home care agency need shaping up? Our army of experts will get you back on track with these exclusiveteleconferences. Register for one or all of the following sessions.

Dec. 18: HiringFeb. 19: Lean ThinkingApril 16: Leadership

Northeast Home Health Leadership SummitNortheast Home Health Leadership SummitNortheast Home Health Leadership SummitNortheast Home Health Leadership SummitNortheast Home Health Leadership SummitJanuary 21 to 23 – Boston

This program offers cutting-edge information to prepare you for the future of home care, the opportunity to enhanceleadership skills, and time to network with other executives. Visit the conference website at www.nehomehealthsummit.com.

The Art of ICD-10-CM Coding for Home HealthThe Art of ICD-10-CM Coding for Home HealthThe Art of ICD-10-CM Coding for Home HealthThe Art of ICD-10-CM Coding for Home HealthThe Art of ICD-10-CM Coding for Home HealthFebruary 6 & 7 – Albany

This newly developed two-day diagnostic coding workshop is structured to foster basic ICD-10-CM coding skills and goodhabits crucial to coding success. Appropriate for all levels of coders.

BlueprinBlueprinBlueprinBlueprinBlueprint ft ft ft ft for Oor Oor Oor Oor OASIS AASIS AASIS AASIS AASIS Accurccurccurccurccuracacacacacy — y — y — y — y — TTTTTrrrrransition tansition tansition tansition tansition to Oo Oo Oo Oo OASIS-C1ASIS-C1ASIS-C1ASIS-C1ASIS-C1April 8 & 9 WorkshopApril 10 COS-C Exam

This two-day OASIS workshop on Data Collection Rules and Guidance includes education on OASIS C-1 changes, with optionalCertificate for OASIS Specialist-Clinical (COS-C) exam.

HCA is holding the following education programs in the coming months. Registration for all of these programs isavailable on the education page of our website at www.hca-nys.org/events.cfm.

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other payment changes scheduled under the rulewould result in a net Medicare home health reductionof 1.5 percent, or $290 million, nationally comparedto 2013.

The New York State impact of rebasing is estimatedat $12.5 million, putting New York among 13 stateswhose Medicare margins would plunge deeper intothe red as a result of the proposed cuts, according toan analysis by Avalere Health and Dobson DaVanzo& Associates.

HCA has extensively advocated for a morereasonable approach to rebasing that uses accuratedata and recognizes the true financial profile of homecare providers in New York State and nationally. InAugust, HCA submitted comments to CMS wherewe objected to the scale and methodology of CMS’sproposed Medicare reductions, as well as its faultydata projection of provider operating margins,especially at a time when many providers in NewYork and nationally continue to struggle withnegative operating margins.

The broader home care community’s effortsnationally to oppose rebasing have resulted inCongressional outreach to CMS, most tangiblyin a bipartisan letter opposing the proposedreductions. The letter, initiated in the House byReps. David McKinley (R-WV) and Doris Matsui(D-CA) and in the Senate by Senator DebbieStabenow (D-MI), states: “We firmly believe inensuring the accuracy of all Medicare reimbursement… However, we are concerned that the proposedrule may fall short of this goal due to its reliance onincomplete data and analysis that results in the under-counting of home health agencies’ costs per episodeof care, and an inappropriately high rebasingadjustment.”

Once the final HHPPS rule is issued by next week,HCA will immediately engage in a thorough analysisto see what changes have been made from theproposed rule, and we will be issuing a very detailedMemorandum to the membership on all aspects ofthe final HHPPS, which will go into effect onJanuary 1.

Several possible scenarios exist. For instance, the rulecould be left unchanged from its proposed version, orthe yearly proposed payment cuts could be scaled backbased on comments and reaction from the home careindustry nationwide and the urging of Congress.

To discuss the rebasing outcome and related next steps,the National Association for Home Care and Hospice(NAHC) is hosting a free teleconference on Monday,December 2, from 1 to 2 p.m. The number to call in is1-877-757-0919 and the code is 351087. (Please e-mailblake@nahc.org to reserve your place on the call.)

HCA is also ready to provide you with immediateeducation on this important new development during aDecember 12 webinar on Home Health PPS Updates.

Beyond the issue of rebasing, this program, led byPatricia Tulloch, Senior Consultant at RBC Limited,will present the nuts and bolts of the PPS updates andexplain how they may impact your agency’s operation,including a thorough review of case-mix diagnoses,documentation requirements and best practices.(Registration is at http://www.hca-nys.org/documents/PPSUpdateFlyer12-12-13.pdf.)

Other fiscal issues on the horizon:Your advocacy urgently needed!

The looming package of proposed HHPPS reductionscomes among several other fiscal threats to home careas Congress must also meet a mid-December deadlinefor recommending budget proposals.

These proposals are being fashioned in the heat ofpolitical debates raging over the past several monthsthat have tipped the scale sharply in favor of deepspending reductions and/or revenue changes to addressthe federal debt and meet a mid-January deadline forfunding the government.

The Congressional Budget Office (CBO) recentlyreleased a report that outlines several actions thatCongress could take to reduce the federal deficit between2014 and 2023. For health care, some of the optionsinclude: bundled Medicare payments, changes to the

PPS continued from p. 1

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cost-sharing rules for Medicare and restrictions in Medigap Insurance, caps on federal spending for Medicaid,converting Medicare to a premium support system, raising the Medicare age of eligibility from 65 to 67, andincreasing premiums for Parts B and D of Medicare. (The full report is at http://cbo.gov/sites/default/files/cbofiles/attachments/44715-OptionsForReducingDeficit.pdf.)

One area of major concern is the possibility that Congress will pursue a home health beneficiary copayment.While this proposal is not mentioned in the CBO report, the notion has certainly gained legs in discussions on theHill over the past several weeks. HCA has steadfastly advocated against a Medicare home health copayment as apossible deficit-reduction or revenue measure and continues to do so as Congress grapples with the upcomingDecember 13 deadline for a conference committee to make recommendations on budget goals before the temporaryfunding resolution lapses in mid-January.

Those deliberations will also involve discussions about physician payment reform legislation and how it would bepaid for, including through possible reductions in other areas of health care, posing yet additional threats to homecare.

In the end of October, HCA visited Congressional leaders to discuss concerns about copayments, rebasing,additional provider cuts, the Medicare face-to-face requirement, and other issues. As we continue these discussionswith Congress, we ask that providers also contact your federal elected representatives using the message posted toour Legislative Action Center at http://www.congressweb.com/NAHC-NY/19.

Please also call your Congressional representatives today with the message points below:

• Thank you for your work to prevent Congress from approving a Medicare home health copayment. Unfortunately,the home care community has learned that Congress is again considering copayments, Medicare cuts and othernegative impacts to home care as part of budget negotiations.

• In the 40 years since Congress eliminated home health copayments, lawmakers have recognized that theseregressive penalties only make it harder for older Americans to obtain services needed to recuperate and preventa worsening health condition. A vast majority of Medicare beneficiaries live on fixed incomes, and many wouldopt to forgo home health services rather than pay this “sick tax.” Thus, copayments are a financial disincentivethat leads to higher-cost services, as patients do not get the preventive care they need to avoid a hospital visit.

• During the past several years, home care patients and programs nationally have been subjected to billions ofdollars in cuts under the Affordable Care Act and sequestration. Soon, home care will be threatened again byupcoming changes in the way Medicare reimbursement is calculated: a process called rebasing, which alone willcut home care by $290 million nationally.

• This deluge of cuts has already taken a toll. On average, Medicare home care providers in New York State havebeen operating in the red for eleven years in a row. Under rebasing cuts now on the horizon, the NationalAssociation for Home Care and Hospice estimates that 77 percent of agencies in New York will have Medicareoperating margins at or below zero in 2014.

• More cuts or a copayment will only reduce access to cost-effective services. Please continue your opposition tocopayments and help protect vulnerable New Yorkers from any further home health program cuts that jeopardizeaccess to services.

For more information, contact the HCA Policy staff.

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HCA Letter Urges Dedicated State Funding for Wage Parity LawWage parity certification forms due December 1

Citing a new cost impact analysis of wage parity, HCA President Joanne Cunningham this week sent a letter toState Medicaid Director Jason Helgerson urging the Department of Health (DOH) to adjust provider and healthplan payment levels to support the “serious gap” in Medicaid reimbursement needed to meet the state-mandatedhome care aide compensation levels. The letter is part of an effort by the home care community broadly to assist providers affected by the Wage ParityLaw, which has added substantial new labor costs since its implementation starting in 2012. Those cost levels willescalate under new rates announced by DOH for 2014. (See the November 15 edition of ASAP for details.)

A new analysis conducted by a coalition of home care provider, health plan and labor participants shows thatagencies will have combined direct and administrative costs exceeding $21 per hour under the state wage paritylevels in 2014 coupled with new overtime pay requirements caused by the removal of home care aide services fromthe Fair Labor Standards Act (FLSA) “companionship exemption.” “Both the wage parity and mandatory managed care enrollment laws are policies of the MRT which, to succeed,require the provision of adequate provider/health plan financing,” writes Ms. Cunningham in the letter. “HCAmember home care agencies and health plans are committed to making these policies work for the system and mostimportantly for the patients. But the premiums and rates paid must meet the fiscal realities of these policies.” She adds: “HCA emphasizes that the home care/managed care system cannot simply incur these new added costs,on top of the costs of other new added mandates and system changes, by further cutting or otherwise redirectingexisting dollars from one source to another ...There must be a dedicated financing mechanism or funding adjustmentto address this growing and serious disparity.” Members can read HCA’s letter at http://www.hca-nys.org/documents/HCAWageParityLettertoJasonHelgerson.pdf. Wage parity relief has been a top advocacy issue for HCA. HCA had submitted an affidavit supporting a state-level legal challenge to the law filed by the Concerned HomeCare Providers, a coalition of home care agencies, in state Supreme Court. That challenge was dismissed by ActingSupreme Court Justice Roger D. McDonough on September 7, 2012. In December 2012, the plaintiffs filed anappeal of that decision in the Appellate Division, Third Department of the State Supreme Court, and HCAsubmitted an amicus brief in support of the appeal. In July 2013, the State Supreme Court Appellate Divisionvoted to uphold the state’s Wage Parity Law. A further appeal to the State Court of Appeals is planned. In early October, the U.S. District Court Northern District of New York issued a decision on a separate federalchallenge to the law. The judge declared that one provision of the law (subdivision 4) is preempted by the EmployeeRetirement Income Security Act (ERISA) and could not be enforced, but the court upheld the rest of the law. Certification forms due December 1

HCA reminds members that the next state-required vendor Home Care Worker Wage Parity Law certificationforms are due December 1 for Licensed Home Care Services Agencies (LHCSAs) and other entities that contractwith Certified Home Health Agencies (CHHAs), Long Term Home Health Care Programs (LTHHCPs) and/or managed care organizations (MCOs) who serve New York City, Long Island and Westchester.

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CHHAs, LTHHCPs and/or MCOs that contract with LHCSAs arerequired to obtain written certification on a quarterly basis from theLHCSA or other entity which attests to the LHCSA’s or other entity’scompliance with the state’s Home Care Worker Wage Parity Law fordefined certification periods and on a prospective basis. The form dueDecember 1, 2013 covers the period December 1, 2013 throughFebruary 28, 2014 and is sent to the CHHA, LTHHCP and/or MCO,not the state Department of Health (DOH).

Certification forms developed by DOH are available at http://www.health.ny.gov/health_care/medicaid/redesign/2013-02-21_wage_parity_alert.htm (see attachment B-4). In completing theform, HCA recommends adding a date after the signature and notingon the form that the certification covers the December 1, 2013 toFebruary 28, 2014 period.

In New York City, for the period March 1, 2013 to February 28, 2014,the minimum home care aide total compensation rate is $9.50 per hourwith a supplemental benefit rate of $1.43 per hour.

For Long Island and Westchester, during March 1, 2013 to February28, 2014, the minimum home care aide total compensation rate is $9.00per hour with a supplemental benefit rate of $1.35 per hour.

Additional information on the Wage Parity Law, including the newrequirements for the period March 1, 2014 through February 28, 2015,is at http://www.health.ny.gov/health_care/medicaid/redesign/mrt_61.htm. HCA is updating, and will soon release to themembership, our Home Care Wage Parity Guidebook, which explainsall the key definitions, calculations and requirements of the law to assistyou in your compliance efforts.

For more information, contact Andrew Koski at (518) 810-0662 orakoski@hcanys.org.

Managed Long Term Care Update

During today’s Managed Long Term Care (MLTC) ImplementationAdvisory Group meeting, the state Department of Health (DOH)provided an update on the mandatory enrollment of individuals duallyeligible for Medicare and Medicaid (“dual eligibles”) that require morethan 120 days of community-based long term care into MLTCs.

Some new information includes:

• In December, DOH plans to start the transition of duals thatrequire more than 120 days of community-based long termcare into MLTCs in Albany, Onondaga, Monroe and Erie

Health Bills Signed by

Governor

Last week, Governor Cuomosigned into law a series ofhealth bills. Some of theseincluded the following:

• Managed Care Reform– requires utilizationreview agents tosubstantiate pre-authorizationselectronically, exceptwhere not currentlypracticable, and extendsthe provider externalappeal timeframe from45 days to 60 days.Current law requiresplans to pay for all pre-authorized care andnotification of suchauthorization withinthree business days; thisnew law requires plansto provide suchnotificationelectronically.

• Hospice Residences –increases from eight to16 the number ofallowable beds in ahospice residence andpermits these hospiceresidences to havedually-certified hospiceinpatient beds up to 25percent of theresidence’s patientcapacity.

For more information, pleasecontact a member of HCA’sPolicy staff.

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counties. Recipients who are currently receiving such serviceswill be sent initial announcement letters sometime in the firstweek of December to inform them about the mandatoryenrollment policy. Unlike in New York City, where separatemailings were sent based on which services a person receives,the mailings will go to recipients in all programs (personalcare, Long Term Home Health Care Program, ConsumerDirected Personal Assistance, adult day health care, privateduty nursing, etc.).

• The “front door” to Medicaid fee-for-service long term caresupports won’t be closed for new dual eligibles that requiremore than 120 days of community-based long term care inAlbany, Onondaga, Monroe and Erie counties until the localdepartments of social services (LDSS) are ready for thischange. This will occur soon after the first announcementletters are sent.

• Sometime in December, DOH plans to release a 2014timetable that will list the dates that mandatory enrollmentinto MLTCs will be required for dual eligibles in othercounties. DOH does not intend to expand mandatoryenrollment in any new counties during January, February orMarch 2014.

• DOH is working to address those Medicaid-only recipientsin mainstream Medicaid managed care plans who becomeeligible for Medicare, need long term care services, and haveto enroll into MLTCs.

• DOH reiterated that for personal care providers whosepatients transition to MLTCs, the MLTCs are required topay the New York City Human Resources Administration(HRA) or local county rate until March 1, 2014 (in allmandatory counties).

• DOH is developing a policy to address those residents ofnursing homes who want to return to the community andenroll into the Nursing Home Transition and Diversion orTraumatic Brain Injury waiver programs and havedifficulties being assessed for services from their LDSS.

• MLTCs are reminded that they have to complete the compliancecertification forms on the Office of Medicaid Inspector General(OMIG) website (see separate story, p. 16).

The next meeting of the Advisory Group is scheduled for December10 at 10 a.m.

For more information, contact Andrew Koski at (518) 810-0662 orakoski@hcanys.org.

OIG Releases 2014-18

Strategic Plan

The federal Office of InspectorGeneral (OIG) has released its2014-18 Strategic Plan. It outlinesOIG’s vision, goals and prioritiesincluding future audits andevaluations contained in OIG’sannual Work Plan.

The Plan is at http://go.usa.gov/WdbV.

It focuses on four goals: fight fraud,waste and abuse; promote quality,safety and value; secure the future;and advance excellence andinnovation.

Under each goal are some of thefollowing priorities: holdwrongdoers accountable andmaximize recovery of public funds;maximize value by improvingefficiency and effectiveness;promote the secure and effective useof data and methodology; fostersound financial stewardship andreduction of improper payments;and leverage leading-edge tools andtechnology.

Electronic or PDF

Remittance Advice

Request Form Revised

eMedNY has revised theElectronic or PDF RemittanceAdvice Request Form.The revised form is at https://www.emedny.org/info/ProviderEnrollment/allforms.aspx.

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HCA Webpages Provide Data Reports, Mandatory Enrollment Resources

HCA has updated two resource webpages to help you navigate the mandatory enrollment transition and reviewHCA-developed data reports for home care and managed care.

Both of these pages can be found by clicking associated buttons on the left-hand side of HCA’s website home pageat www.hca-nys.org.

Mandatory Enrollment Resources Page (http://www.hca-nys.org/MandatoryEnrollmentResources.cfm)

HCA has updated our Mandatory Enrollment Resources webpage with the latest links, including: state policydocuments; consumer enrollment resources; provider and managed care plan directories; model contracts; ManagedLong Term Care (MLTC) frequently asked questions; reports and other documents.

HCA DATA Page (http://www.hca-nys.org/data.cfm)

HCA DATA is a members-only page with reports to assist home care and hospice providers and managed careplans in their benchmarking efforts, understanding of system-wide trends, and access to reimbursement and premiumrates for Medicare, Medicaid and MLTC plans. It includes links to HCA-developed reports and spreadsheets aswell as data resources from the state Department of Health, National Government Services, the National Associationfor Home Care and Hospice, and other sources.

For more information, please contact HCA’s Communications Director Roger Noyes at rnoyes@hcanys.org.

With One Week Left, Financial Survey Response is at 25 Percent of HCA’s Goal

HCA again reminds members to complete our 2013 Home Care Financial Condition Survey before the November

30 deadline. We are currently about one-quarter of the way to our provider response goal for this important survey,the results of which will be a central component of our fast-approaching State Advocacy Day on January 27 inAlbany. Links to the survey are below.

We remind all providers of this important survey tool, which will assist HCA in gaining a complete understandingof the financial issues affecting you and your peers as we approach the state budget season and legislative session.

Please help us reach 100 percent of our goal by completing this survey as soon as time permits. The survey isdesigned to take approximately 35 to 40 minutes to complete.

Again, the survey deadline is November 30. Please let HCA know if there is any way we can make this surveyprocess easier for you or otherwise accommodate your completion of this important survey.

Links

PDF Version of the Survey: http://www.hca-nys.org/documents/2013financialsurvey.pdf

Online Version of the Survey: https://www.surveymonkey.com/s/financialconditionsurvey2014

Reference Document to Assist in Completing the Cost Report Section of the Survey:http://www.hca-nys.org/documents/CostReportReferencesFinancialSurveyOct2013.pdf

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Home Health PPS Webinar Will Cover Soon-to-be-released Final Rule

The U.S. Centers for Medicare and Medicaid Services (CMS) will soon be releasing its Prospective PaymentSystem (PPS) final rule. (See p. 1 story.) HCA is ready to provide you with immediate education on thisimportant release of new reimbursement changes during a December 12 webinar on Home Health PPS Updates.Please register today to assure your slot in this timely program.

Patricia Tulloch, Senior Consultant at RBC Limited, will present on the nuts and bolts of the PPS updates andexplain how they may impact your agency’s operation. She will review case-mix diagnoses and documentationrequirements and review best practices. A PPS Updates Reference Guide and a revised 2014 Case Mix Diagnosestool will be offered as well.

Webinars are a convenient and cost-effective way to learn about the new PPS rule, which is set to go into effecton January 1. The December 12 session will be held from 11 a.m. to 12:30 p.m. Agency leadership, clinicians,billers, educators and performance improvement staff may want to participate together through one phone line.

Registration is encouraged by December 5. Please see the flyer athttp://www.hca-nys.org/documents/PPSUpdateFlyer12-12-13.pdf.

HCA, DOH Meet on Major Reimbursement, Financing Issues

HCA and state Department of Health (DOH) reimbursement officials met this week to focus on several majorreimbursement issues for the home care/managed care system.

Adequacy of premium and reimbursement

HCA has been consistently making the case for premium and reimbursement adequacy to health plans andproviders to reflect the core service needs and costs of the transitioning system, including operational,infrastructure, personnel and regulatory expenses.

This week, HCA especially focused on premium/rate funding necessary for the crucial increases in home careworker wage parity levels taking effect in 2014, as well as expenses associated with new overtime compensationrequirements and new transitional expenses. HCA presented DOH with a letter requesting support for theseneeds (see related page 9 story), and provided further detail on both the justification and urgency for funding.

A second, critical fiscal issue raised again by HCA is the financing level needed by health plans and providers inthe wake of the Department’s current review and reiterations of regulatory structures governing home care andmanaged care.

HCA has written extensively on this issue for the membership. Specifically, DOH’s Office of Health SystemsManagement (OHSM) has repeatedly stressed federal regulations which stipulate that a Medicaid (or Medicare)recipient receiving home nursing or therapy services must receive those services by an entity which meets thefederal Conditions of Participation.

However, certain policies of the Department, and practices that have been permitted to occur within the currentsystem, appear at odds with this standard reiterated by OHSM, with ramifications for the financial basis of the

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Department’s managed care premium calculations. HCA has not seen any separate written statements by theDOH Office of Health Insurance Programs addressing this issue programmatically or financially.

HCA stressed our serious concerns about this issue, particularly the uncertainties it has created in the marketplace,and stressed that adequate financing for health plans and providers must accompany any reset to the regulatorystructure for home care delivery under managed care based on the standards reiterated by OHSM.

HCA and association health association colleagues have also testified to the Home and Community Based CareRegulatory Workgroup (established by this year’s state budget legislation) on the need to clarify, streamline andadequately finance these regulatory requirements – a position we have also raised with program officials atDOH.

Need for eMedNY flexibility on signed physician orders

HCA also presented new information on HCA’s longstanding request for flexibility within eMedNY to addressreimbursement for agency services in cases where signed copies of physician orders are not received by agencies intime for the state’s 90-day billing limitation.

Several months ago, DOH reimbursement officials agreed to raise the issue with eMedNY representatives. HCAwas then recently asked by DOH to provide a current status report of the problem, along with its scope andimpact, and the experiences of other states’ home care systems with this issue.

HCA presented these findings to the Department. DOH officials indicated some of the barriers to a change inbilling, which will require further HCA advocacy within the Department.

Need for revisions to EPS guidance on coverage of Medicare-Medicaid recipients

HCA and DOH also continued discussions on the need for revision of the published DOH guidance on Medicarecoverage “assumptions” prior to Medicaid coverage under the Episodic Payment System (EPS) for CertifiedHome Health Agencies (CHHA).

HCA and member providers contend that the current DOH guidance (when EPS was first implemented) includesan interpretation by the Office of the Medicaid Inspector General (OMIG) that mistakenly inflates assumptionsof Medicare coverage, particularly its characterization that Medicare coverage of up to 35 hours of aide servicesper week is the threshold prior to eligibility for Medicaid aide services.

However, in early February, OMIG, following discussions with HCA, published revised audit protocols forCHHAs that contained Medicare coverage assumptions at up to 8 hours each day – or up to 28 hours per week– unless the CHHA can provide documentation otherwise, which is more closely (though not exactly) aligned tothe federal Medicare parameters. HCA in turn asked that the EPS guidance assumptions be revised accordingly.

Following discussions in October, DOH worked with OMIG on proposed revisions to HCA’s concerns andrecommendations. At this week’s meeting, HCA, after vetting the proposal with CHHAs, offered edits to theproposed language, which DOH is taking back into review.

HCA appreciates the Department’s efforts to work toward more accurate and amenable language on thisimportant coverage issue.

For further information, please contact Al Cardillo at acardillo@hcanys.org or Patrick Conole at pconole@hcanys.org.

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HCA, DOH Make Quality Connections

HCA met this week with representatives of the stateDepartment of Health’s (DOH) Office of Quality andPatient Safety to present the HCA Quality Committee’sanalyses, recommendations and initiatives.

HCA and a Committee subgroup provided DOH’sQuality Director Patrick Roohan and staff, RainaJosberger, with the Committee’s input, developed overseveral months, on the system for quality measurement,reporting and care in the managed care-home careparadigm.

The Committee began this work in a special meeting inJuly which brought together Mr. Roohan, the NationalCommittee for Quality Assurance, IPRO, and providerand health plan quality specialists for an intensivediscussion on quality measurement and benchmarking.

In the months that followed, the Committee’s work delveddeeper with a subgroup of members who, along withHCA, analyzed the quality metrics for managed care andhome care, identified gaps, stressed areas forsynchronization, and brought preliminaryrecommendations to the full Committee in mid-October.

Some of the areas addressed in the Committee’spresentation to the Department included:

• Validation and risk adjustment of the quality data.

• Assignment of relative weights to the differentquality performance measures/categories.

• Inclusion of critical “process” measures inherentto quality.

• Reconciliation of the different quality andconsumer satisfaction measurement andreporting metrics, instruments, and requirementsused in home care and managed care, as well asreconciliation of the potential new qualitymeasures under the new Uniform AssessmentSystem with those currently employed under theSemi-Annual Assessment of Members (SAAM),Outcome Assessment Information Set (OASIS),

1115 Waiver Amendment

Webinar Rescheduled Again

The state Department of Health (DOH) hasannounced that its webinar on the status of its1115 Waiver amendment has been rescheduledagain from November 26 to December 4 at 3p.m.

Those already registered for the November 26date do not need to re-register. Those who neverregistered can now register for the December 4webinar at https://www1.gotomeeting.com/register/271562744.

Under this amendment submitted to the federalgovernment, New York is seeking approval toreinvest $10 billion in federal Medicaid dollarsthat, officials say, are part of the $17.1 billion inanticipated savings from initiatives of the state’sMedicaid Redesign Team (MRT).

Areas of investment under the 1115 waiveramendment would include: primary careexpansion, Health Home development, new caremodels, expansion of the Vital Access/SafetyNet Provider Program, new models of care forthe uninsured, Medicaid supportive housingexpansion, a Managed Long Term CarePreparation Program, capital stabilization forsafety net hospitals, hospital transition,workforce training, public health innovation,regional health planning, and others.

As reported in previous editions of HCA’sASAP newsletter, HCA has advocated onnumerous fronts with DOH and the CuomoAdministration that the waiver needs to includefunds to help home care providers withrealignment costs (technology, medical records,contracting, compliance, etc.) as a result of thetransition to managed care.

More information on the waiver amendment isat http://www.health.ny.gov/health_care/medicaid/redesign/mrt_waiver.htm.

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and the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS).

• Material associations or correlations to quality among certain elements of design or service, such ascorrelation of service and utilization patterns to outcomes, and “high touch” versus “low touch” caremanagement, as well as other additions (e.g., skin integrity) or clarifications (e.g., medication compliance)to the data being measured and reported under the DOH system.

• Increased efficiency of the quality audit process for providers and plans.

• Access to “real-time” quality data.

HCA and Committee members also previewed the Committee’s draft multi-tiered plan for home care qualityadvancement that was initially formulated and refined at the October 18 Quality Committee meeting. Thedraft plan covers a comprehensive array of facets related to quality care that HCA intends to be the basis of itspromotional, developmental and educational efforts with the provider and plan community, as well as its stateand federal advocacy.

As a next step, the Department plans to consider the details and possibilities while further discussing ideas foradditional collaborations with the Committee.

Representing HCA and the Committee at this week’s meeting were: HCA President Joanne Cunningham;Executive Vice President Al Cardillo; HCA Board Chair and Senior Vice President of Jewish Home Lifecare,Bridget Gallagher; HCA Board member and Assistant Vice President of Winthrop Hospital Home Care,Anne Calvo; HCA Board member and Administrator of Clinical Operations for Montefiore Medical CenterHome Care, Pam Joachim; Director of Quality Improvement/Education for HHH Choices Health Plans,Lauren Huber; and Vice President for Clinical Operations for Dominican Sisters Family Health Services,Louis Harris. HCA extends special thanks to these Board and Committee members and the full committee fortheir hard work and expertise on these important quality initiatives.

For further information, please contact Al Cardillo at acardillo@hcanys.org.

OMIG Holds Webinar on Compliance Certification Requirements

This week, the state Office of the Medicaid Inspector General (OMIG) held a webinar on the compliancecertification process and soon-to-be-released revised certification forms.

The materials are at http://www.omig.ny.gov/images/stories/Webinar/webinar_18_112113.pdf.

Since 2007, the federal government has required Medicaid providers who bill, order or receive more than $5million annually to certify, under the Deficit Reduction Act (DRA), that they have written policies and proceduresinforming and educating their employees, contractors and agents about DRA provisions related to the FalseClaims Act and laws to prevent and detect fraud, waste and abuse. This must take place by January 1 annually.

OMIG addresses this mandate by also monitoring a provider’s certification of compliance status and conductingcompliance program reviews. The current certification form and a related frequently-asked-questions (FAQs)document are on OMIG’s website at www.omig.ny.gov/compliance. In addition, under state law, home care

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and other providers are required to have compliance programs andto certify in December of each year that they have “adopted,implemented and maintained an effective compliance program.”

Each compliance program must include the eight elements outlinedat http://www.omig.ny.gov/images/stories/compliance/compliance_program_assessment_form-revised.doc and http://w w w. o m i g . n y . g o v / i m a g e s / s t o r i e s / c o m p l i a n c e /20130724_best_practices_list.pdf.

Additional information on the certification requirements is at http://www.omig.ny.gov/compliance/certification. OMIG will be postingboth updated certification forms on December 1.

Most of the data collected on the updated certification forms is notnew. One change is that the DRA form will have an option forproviders to identify the federal fiscal year they are certifying.

OMIG advises providers to:

• Submit both certifications in early December to avoid anydelays in submission at the end of the month;

• Ensure their firewalls and security settings allow for thecertification process to be completed;

• Use the correct federal employer identification number(FEIN);

• Submit certification forms for each FEIN that bills orreceives Medicaid payments; and

• Refrain from recertifying if they certify and cannot locatetheir confirmation page. (Instead they should request a copyby sending an e-mail to compliance@omig.ny.gov.)

Questions on the certification process webinar can be sent toElana.Andrew@omig.ny.gov before noon on November 25 so thatthey can be included in an upcoming frequently-asked-questionsdocument. After that date, questions about the certification formscan be directed to OMIG’s Bureau of Compliance at (518) 408-0401(or your legal counsel).

To stay informed on compliance issues, providers should subscribeto OMIG’s listserv at http://www.omig.ny.gov/omig-email-list-subscriptions.

For more information, contact Andrew Koski at (518) 810-0662 orakoski@hcanys.org.

Addendum Issued to HRA

Home Care Services RFP

The New York City HumanResources Administration (HRA) hasissued an addendum to its Home CareServices Request for Proposal (RFP).

The addendum notes that the termsof the contract were revised to coverthe period April 1, 2014 to March31, 2017, and includes a series ofQuestions and Answers that covermany issues, includingreimbursement rates, Medicaidsurplus cases, number of cases, anyrequired special training forpersonal care aides, services toTraumatic Brain Injury patients,and others.

The RFP, issued in early November,seeks contractors to directly provide,under two separate programs, andnot through subcontracts: 1)Housekeepers (Personal CareServices Level I), Home AttendantServices (Personal Care ServicesLevel II), Emergency andExceptional Home AttendantServices (also known as Difficult toServe Home Attendant Service, orDTS) to Medicaid-eligibleindividuals who are medically and/or physically disabled and/or frailelderly; and 2) Consumer DirectedPersonal Assistance Program(CDPAP) services to Medicaid-eligible individuals who aremedically and/or physically disabledand/or frail elderly.

Proposals are due December 18.

For more information, contact AndrewKoski at (518) 810-0662 orakoski@hcanys.org.

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CHHA RFA Discussed at PHHPC Committee Meeting

At this week’s Public Health and Health Planning Council (PHHPC) Establishment and Project ReviewCommittee meeting, the state Department of Health (DOH) gave an update on the recent approved process forCertified Home Health Agency (CHHA) establishments and expansions.

Though the Committee’s agenda had no new establishment or expansion CHHA applications, DOH reportedthat the CHHA request for proposals (RFP) process has not been completed yet. DOH is still re-reviewing someapplications to ensure that all are reviewed using the same criteria. DOH said it hopes to bring some of theoutstanding applications to the next PHHPC Committee and full Council meetings and is working to develop aprocess to address those applications not approved. It said the PHHPC should expect no new certificate of need(CON) applications until after the existing approvals are operational and a new need methodology has beenestablished.

DOH hopes to present a revised and updated CHHA need methodology at a future PHHPC meeting. HCA pastBoard Chair Vicky Hines, President and CEO of Visiting Nurse Service of Rochester and Monroe County and aPHHPC Establishment and Project Review Committee member, urged that no new methodology be releaseduntil we can determine the effect of the current RFP which has resulted in more than a doubling of new andexpanded CHHAs.

At this week’s meeting, approval was given to: the sale of a CHHA that serves Brooklyn, Manhattan and Queens;the partial transfer of ownership of a hospice serving Bronx, Brooklyn, Manhattan, Queens and Nassau counties;and applications by 17 entities to establish Licensed Home Care Services Agencies (LHCSAs) and two existingLHCSAs for a change of ownership.

In addition, DOH provided information on a hospice rule that would change the definition of terminally ill fromsix to twelve months for Medicaid purposes and revise the state regulations to incorporate changes in the federalhospice conditions of participation.

The recent CHHA establishments and expansions were the result of an RFP issued by DOH in January 2012 aswell as a special provision in the 2012-13 State Budget for Long Term Home Health Care Programs (LTHHCPs)to provide a CHHA.

HCA’s updated chart of approved CHHA applications and expansions is athttp://www.hca-nys.org/documents/CHHARFARecommendationschart10101313.pdf.

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

Exploring New Opportunities for Your Business, and Enhanced Care for Your Patients

Interested in exploring new opportunities to partner with other organizations, improve your business model orenhance the care you provide to patients?

If so, then you won’t want to miss a special pre-conference session on new health care models which will be offeredat the three-day Northeast Home Health Leadership Summit in Boston. This pre-conference session, on January21, will showcase a handful of thought-provoking program models that can strengthen your business and enhanceyour quality-improvement goals. Continued on next page

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Opening this insightful pre-conferencesession, Tracey Moorhead, President andCEO of the Visiting Nurse Associations ofAmerica, will show you how to develop newpartnerships through community-basedcare. She will also share elements of existingpilot and demonstration programs and newcare models that focus on qualityimprovement.

In addition, Marcia Reissig, RN, MS, CEOof Sutter Care at Home, one of the nation’slargest not-for-profit community-basedhealth care networks, will show how herorganization successfully implemented acare-management model that employsevidence-based principles of carecoordination and transitions, palliative careand patient self-management for individualswith advanced illnesses.

Our third featured program model willprovide a lesson on how to transition yourorganization from traditional home care toan integrated system incorporating palliativecare. Jeanne Ryan, Executive Director atVNA & Hospice of Cooley Dickinson/Cross-Continuum Services, who was apopular presenter at last year’s Summit, willhelp you determine if palliative services areright for your organization.

The pre-conference session is only $129extra for those registering to attend the fullSummit. A slightly higher registration feewill apply for those who want to attend thepre-conference session only.

This informative afternoon is a great way toset the stage for the rest of the Summit byreinforcing some of the key decisions thatyou and other home health leaders will needto consider at your organizations as youprepare for the future. Learn more atwww.nehomehealthsummit.com.

Protected Healthcare

Information Advisory

The state Department of Health (DOH) has issued areminder to ePACES users of their responsibility forappropriate use and disclosure of beneficiary ProtectedHealthcare Information (PHI).

Since ePACES users have the ability to use and discloseMedicaid beneficiary PHI, DOH advises such users tonever share their ePACES user ID and password withanyone. If you are sharing your ePACES user ID andpassword with another individual(s), you and the otherindividual(s) should contact your ePACESAdministrator immediately to have unique User IDscreated for each.

Federal guidance on health information privacy can befound here: http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/minimumnecessary.html.

Changes Made to HCS

The state Department of Health (DOH) has announcedsome changes to the Health Commerce System (HCS).These changes are intended to restore the speed andreliability needed by providers.

The announcement is athttps://commerce.health.state.ny.us/public/hcs_login.html.

One change is that the “Important Health Notifications”portal is moving to an “on-demand” model, where userswill need to click the “Health Alerts” button first in orderto view these notifications. Under this change,personalized information will be loaded when the userrequests it, rather than being loaded for all users uponlog in.

DOH is undertaking a complete overhaul of the HCSportal and will be providing more information in thefuture.

Continued from p. 18

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NAHC to Conduct Hospice Webinar on Upcoming Additional Data Reporting

Since the release of Change Request (CR) 8358 (Additional Data Reporting Requirements for Hospice Claims)in July 2013, hospices and hospice industry stakeholders have been struggling with how to capture the newlyrequired data on the claim. Given the amount and type of data that must be reported beginning April 1, 2014, it’snot too early for hospice programs to begin tackling the significant challenges associated with CR 8358 compliance.

The National Association for Home Care and Hospice (NAHC) is hosting a webinar on Wednesday, December

4 at 1 p.m. on this important topic for both NAHC and non-NAHC members.

This webinar will:

• Review the four categories of additional data• Review the six data elements required• Discuss the many outstanding questions• Provide practical tips to be used in meeting the new requirements

Faculty will focus on the data elements that are required in order to have a 5010-compliant claim but that are notnecessarily evident in the CR, with special emphasis on the drug reporting requirements.

The registration fee per site is $125; a recorded version of the webinar will also be available for purchase. CEs willbe provided.

HCA hospice members interested in registering for the webinar can do so at http://online.krm.com/iebms/reg/reg_p1_form.aspx?oc=10&ct=0018682&eventid=20996 and those interested in purchasing a CD of the webinarcan do so at http://online.krm.com/iebms/reg/reg_p1_form.aspx?oc=10&ct=0018682P&eventid=20996.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Further Guidance on ABN for Dual Eligible Patients

The U.S. Centers for Medicare and Medicaid Services (CMS) has provided additional clarification for homehealth agencies (HHAs) on completion of the new Advance Beneficiary Notice of Noncoverage (ABN) when thehome care patient has both Medicare and Medicaid.

CMS clarified to the National Association for Home Care and Hospice (NAHC) that agencies should includeinformation regarding Medicaid coverage in the “Additional Information” section and that the forms may be pre-typed. CMS also clarified that if the full cost of care will be covered by another payer, the agency can list theamount in section F (Estimated Cost) as $0.

CMS specifically states that the “option choices for dual eligibles will vary depending on your State Medicaiddirective” and provides two scenarios. The scenario that captures New York State’s Medicaid policies is as follows:“If your State Medicaid office does NOT want a claim filed with Medicare prior to filing a claim with Medicaid,the patient should choose Option 2.” CMS further states that home health agencies may pre-type information in

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the “Additional Information” area for those ABNs that are issued to dual eligibles in order to help them understandthat Medicaid will pay for the service.

CMS adds: “If Option 2 is chosen based on State guidance, but the HHA is aware that the State sometimes asksfor a Medicare claim submission at a later time, the HHA must add a statement in the ‘Additional Information’box such as ‘Medicaid will pay for these services. Sometimes, Medicaid asks us to file a claim with Medicare. Wewill file a claim with Medicare if requested by your Medicaid plan.’”

These instructions are similar to an earlier clarification (see November 1 ASAP) that HCA obtained fromNational Government Services (NGS). Originally, NGS had cited instructions by CMS that home health agencieswere to select Option 1 on the ABN when the agency believes Medicare will not cover a service and the patient hasMedicare and Medicaid. However, HCA and members pointed out that selecting this option will result in aprospective Medicare “demand bill” which is contrary to current third-party liability (TPL) practices in New Yorkwhich involve retrospectively submitting a Medicare demand bill upon request from the Office of the MedicaidInspector General.

NGS then issued the following clarification:

In states that instruct HHAs to not send a claim to Medicare, the beneficiaryshould be directed to choose Option 2. In the “Additional Information” section,HHAs should pre-print information to further explain the payment and billingprocess such as “We will bill your Medicaid plan (the state’s Medicaid program).We will bill Medicare only if your Medicaid plan instructs us to do so.”

As reported in previous editions of ASAP, the ABN – which is now used by physicians, suppliers and hospiceproviders – is replacing the Home Health Advance Beneficiary Notice (HHABN) Option Box 1 form forbeneficiary liability notices, and the Home Health Change of Care Notice (HHCCN) is replacing the currentHHABN Option Box 2 and Option Box 3 forms for change of care notifications.

The new ABN and HHCCN must be used by December 9, 2013, but can be used now.

HCA has revised its Memorandum on these new forms to incorporate this clarification. It is available athttp://www.hca-nys.org/policy_memos/documents/MemoNewABNForm.pdf.

‘People First’ Waiver Update

The Office for People with Developmental Disabilities (OPWDD) recently provided an update on the PeopleFirst Waiver and OPWDD’s System Transformation.

OPWDD had previously submitted amendments to section 1915 of the Social Security Act to the U.S. Centersfor Medicare and Medicaid Services (CMS) for implementation of the People First Waiver. One amendmentwould establish a managed care service system structure to deliver services, and OPWDD continues its discussionswith CMS related to the waiver amendments, deliverables under its “Transformation Agreement,” and reform ofOPWDD’s rate methodology.

Under the transformation agreement, New York plans to utilize its existing Money Follows the Person program tomove more individuals into community settings and the new Balancing Incentive Program (BIP) to implementperson-centered planning; establishing “No Wrong Door” access to OPWDD supports and services; and ensuring

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Volume 18, No. 42 November 22, 2013ASAP – a publication of the Home Care Association of New York State

that its new coordinated assessment system integrates with New York’s efforts to establish a uniform assessmentsystem, and ensuring “conflict-free” case management. The Transformation Agreement also emphasizes expandingself-direction, increasing the number of individuals employed, moving more people out of institutional settings,and expanding community residential options.

The state has submitted a new rate setting methodology to CMS for its approval. The outcome of OPWDD’snegotiations around rate reform will determine the actual timeline for initiating managed care with voluntaryenrollment into Developmental Disability Individual Support Care Coordination Organizations (DISCOs)that will provide coordinated health and long term care services and enrollment into the Fully Integrated DualsAdvantage (FIDA) program that is geared specifically to OPWDD consumers (see separate page 1 story onFIDA in this ASAP).

Meanwhile, OPWDD has been: examining the possibility of providing support for DISCO start-up costs througha grant program using BIP funds; developing a Memorandum of Understanding to support the specializedDevelopmental Disabilities FIDA; and defining quality improvement review processes.

Lastly, OPWDD continues to implement its ‘Front Door’ initiative which is intended to: improve the way thatpeople learn about OPWDD and available service options; better connect individuals to services; and give peoplemore opportunities for self-direction.

More information is at http://www.opwdd.ny.gov/node/4898.

Publications

• “Findings and Lessons from the Improving Management of Individuals with Complex Health Care NeedsThrough Health IT Grant Initiative,” by the Agency for Healthcare Research and Qualityhttp://healthit.ahrq.gov/sites/default/files/docs/page/findings-and-lessons-from-improving-management-of-individuals-with-complex-health-care-needs-through-health-it-grant-initiative.pdf

• “DMEPOS Competitive Bidding Program Grandfathering Requirements for Non-Contract Suppliers(revised),” by the U.S. Centers for Medicare and Medicaid Serviceshttp://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/DME_Grandfathering_Factsheet_ICN900923.pdf

• “Employed Family Caregivers Providing Complex Chronic Care,” by the AARP Public Policy Instituteand United Hospital Fundhttp://www.aarp.org/content/dam/aarp/research/public_policy_institute/health/2013/employed-family-caregivers-providing-complex-chronic-care-AARP-ppi-health.pdf

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

HCA developed the following survey to assess the financial condition of New York's home care industry. It is extremely important that you complete this survey so that HCA has up­to­date information for our 2014 advocacy efforts. All agency­specific responses will be kept strictly confidential. This survey is designed for HCA's home care service provider organizations specifically.

The survey is divided into three sections:

l SECTION 1 (which takes less than five minutes to complete) asks for basic demographic information about your organization (3 questions).

l SECTION 2 (which should take 15 minutes to complete) asks for financial information submitted in your Medicaid cost report and other financial/regulatory information. Please have your CFO complete or provide the information in this section. To assist you, HCA has provided a resource guide in this section (12 questions).

l SECTION 3 (which takes ten minutes to complete) asks what is happening to your agency as a result of payment cuts and state policies (10 multiple­choice questions).

IMPORTANT INFORMATION

Please answer this survey to the best of your ability and, as needed, use the comment box accompanying many of the questions.

For numerical entries, do not use dollar signs ($), commas (,), decimal points (.), percent signs (%) or other characters, just the raw number. Please round up or down if your answer involves a decimal point.

If your organization has a CHHA, LTHHCP and/or LHCSA, please complete this survey separately for each organization type since your cost report information and other responses will differ on this basis.

NOTE: We recommend that you print a PDF of this complete survey, fill­in the information by hand and then enter the information electronically, since you may need to have different staff complete various sections of this survey. A printable PDF version of the survey is available at:

http://www.hca­nys.org/documents/2013financialsurvey.pdf

Please complete the survey by November 30.

Contact HCA's Communications Director Roger Noyes at 518­810­0665 or rnoyes@hcanys.org if you have any difficulties. Thank you.

Introduction

1. List your contact information

2. Home Care Provider Type (Please check only one answer)

3. My agency is (Please only check one answer)

SECTION 1: Demographic Information

*Organization

Your Name

Your Title

Your E­mail

Your Phone Number

*

*

CHHA

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LHCSA

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LTHHCP

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Voluntary

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Proprietary

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Public

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Questions 4 & 5 should be completed by CHHAs and LTHHCPs only. Your answers can be taken directly from your 2012 Medicaid Cost Reports that were recently submitted to the state Department of Health (DOH). Your Finance Director/Chief Financial Officer can assist you in completing this section, which should only take 10­15 minutes to complete. To make it easier, we have created a reference chart, available at the following link:

http://www.hca­nys.org/documents/CostReportReferencesFinancialSurveyOct2013.pdf

This chart lists the exact citations on the cost report where each line­item can be found. Simply pull your report, and enter the data based on the citations at this link.

Questions 6 to 15 should be completed by all home care providers.

Again, all agency­specific information provided to us will be kept confidential and will only be used in the aggregate. By completing this section of the survey, you will be helping to provide HCA with the most up­to­date financial profile of New York's home care industry.

REMEMBER ... For numerical entries, do not use dollar signs ($), commas (,), decimal points (.), percent signs (%) or other characters, just the raw number. Please round up or down if your answer involves a decimal point. HCA will be calculating agency operating margins based on the data you submit since some margins will be in the negative and our survey system does permit the collection of negative numbers.

For questions 4 & 5, if your organization has a CHHA and a LTHHCP, please complete this survey separately for each organization type since your cost report information will differ on this basis.

4. Are you answering the cost report section of the survey (question 5) for your CHHA or LTHHCP? If you do not have a CHHA or LTHHCP, please go to question 6.

SECTION 2: Financial Data

CHHA

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LTHHCP

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5. Provide the following data from your 2012 Cost Report.

6. For the past few years providers have been operating with a 0% Medicaid trend factor despite rising costs. Assuming that your costs have increased in the last year, please rate the impact of each cost factor below on your increased costs.

No. of Full Time Employees (FTEs)

No. of Contracted FTEs

Medicaid Revenues

Medicare Revenues

All Other Payor Revenues (Managed Care, Private Pay, etc.)

Total Patient Service Revenues

All Other Non­Payor Revenues

Total Revenue

Total Operating Expenses

All Other Non­Operating Expenses

Bad Debt ­ Total Visits

Bad Debt ­ Total Revenues

Free / Charity Care (Total Visits)

Free / Charity Care (Total Revenues)

No Impact Minimal Impact Medium Impact Large Impact Largest Impact

Wage Costs nmlkj nmlkj nmlkj nmlkj nmlkj

Benefits Costs nmlkj nmlkj nmlkj nmlkj nmlkj

Fuel Costs nmlkj nmlkj nmlkj nmlkj nmlkj

Unfunded Mandates (e.g. Flu vaccination requirements, TPL, face­to­face requirement)

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Capital Costs nmlkj nmlkj nmlkj nmlkj nmlkj

Other Administrative Costs nmlkj nmlkj nmlkj nmlkj nmlkj

Other (please specify)

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7. If your Medicaid revenues have decreased between 2011 and 2012, please rate the impact of the following factors for this change in your Medicaid revenues.

8. If you have an MLTC contract(s), please estimate the average % difference between your Medicaid fee­for­service rates and your negotiated rates across all disciplines. (Please answer this without regard as to whether your contracted rates are fee­for­service, episodic or sub­capitated. Also, be sure to only enter the raw number: no percentage sign.)

9. If you have a managed care organization (MCO) contract(s), please estimate the average % difference between your Medicaid fee­for­service rates and your negotiated rates across all disciplines. (Please answer this without regard as to whether your contracted rates are fee­for­service, episodic or sub­capitated. Also, be sure to only enter the raw number: no percentage sign.)

10. If you have a Medicare Advantage contract(s), please estimate the average % difference between your Medicaid fee­for­service rates and your negotiated rates across all disciplines. (Please answer this without regard as to whether your contracted rates are fee­for­service, episodic or sub­capitated. Also, be sure to only enter the raw number: no percentage sign.)

11. At any time over the past two years (2012 and 2013), have you had to use a line of credit or borrow money (including gap­payment financing from parent organization) to pay for operating expenses?

No ImpactMinimal Impact

Medium Impact

Large ImpactLargest Impact

Effect of payment cuts/reimbursement changes (e.g. 2% across­the­board cut, CHHA EPS, GRT)

nmlkj nmlkj nmlkj nmlkj nmlkj

Transition to managed care nmlkj nmlkj nmlkj nmlkj nmlkj

Drop in Medicaid volume due to fewer referrals nmlkj nmlkj nmlkj nmlkj nmlkj

Focus on admitting patients from other (non­Medicaid) payors nmlkj nmlkj nmlkj nmlkj nmlkj

Staffing cuts nmlkj nmlkj nmlkj nmlkj nmlkj

MLTC rate is less, by (____%)

MLTC rate is higher, by (_____%)

MCO rate is less, by (______%)

MCO rate is higher, by (______%)

MA rate is less, by (____%)

MA rate is higher, by (_____%)

Yes

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No

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12. Has your agency seen an increase in administrative costs due to state and federal audits?

13. Please rate how the lack of receiving timely physician orders has financially impacted your agency/program:

14. If you provide services in NYC, Westchester and/or Long Island, check yes for any of the following impacts of the Worker Wage Parity law on your agency currently and whether those impacts are expected to occur in 2014. (If you do not provide services in these regions, please skip this question.)

15. Please rate the impact of the following regulatory requirements.

Yes, Current ImpactYes, 2014 Expected

ImpactN/A

Reduce hours of direct care staff gfedc gfedc gfedc

Reduce overtime of direct care staff gfedc gfedc gfedc

Lay off direct care staff gfedc gfedc gfedc

Lay off other agency staff gfedc gfedc gfedc

Negotiate higher rates with contractors gfedc gfedc gfedc

Stop accepting cases where the contractor rate is inadequate gfedc gfedc gfedc

No ImpactMinimal Impact

Medium Impact

Large Impact

Largest Impact

Medicaid ordering, prescribing, referring and attending (OPRA) edit nmlkj nmlkj nmlkj nmlkj nmlkj

Executive compensation/administrative limits nmlkj nmlkj nmlkj nmlkj nmlkj

Influenza vaccination/mask requirements nmlkj nmlkj nmlkj nmlkj nmlkj

Elimination of the "companionship exemption" for home care nmlkj nmlkj nmlkj nmlkj nmlkj

Yes

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No

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No Impact

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Medium Impact

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Large Impact

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Other (please specify)

The following multiple­choice questions relate to the effects of the major structural changes occurring in the home care system due to Medicaid funding reductions and the adopted recommendations of the Medicaid Redesign Team (MRT), including: the shift of dual eligible patients into managed long term care (MLTC) and non­duals into mainstream Medicaid managed care organizations (MCOs); the establishment of the CHHA episodic payment system; and other issues.

16. Which of the following actions has your agency ALREADY TAKEN in response to ongoing Medicaid funding reductions and MRT actions (check all that apply)?

17. Which of the following actions does your agency PLAN TO TAKE in response to ongoing Medicaid funding reductions and MRT actions (check all that apply)?

Section 3: Effects of Changes in Delivery & Financing of Home Care Services

*

*

Apply to obtain a CHHA license

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Apply to expand CHHA

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Apply to open a LHCSA

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Apply to become an MLTC

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Contract with an MCO

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Contract with an MLTC

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Merge with another agency

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Collaborate as part of a Health Home or other health system

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We have taken no actions

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Other (please specify)

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Apply to obtain a CHHA license

gfedc

Apply to expand CHHA

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Apply to open a LHCSA

gfedc

Apply to become an MLTC

gfedc

Contract with an MCO

gfedc

Contract with an MLTC

gfedc

Merge with another agency

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Collaborate as part of a Health Home or other health system

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Close your organization

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We are planning no actions

gfedc

Other (please specify)

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18. If you are contracting with MLTCs/MCOs, what are the issues that impact your organization? (Please check all that apply)

19. To what degree is the redundancy or lack of clarity in state regulations having a cost impact for your organization? (e.g. the responsibilities for obtaining physician orders, plans of care, supervision requirements, etc.)

Minimal Impact

Medium Impact

Large ImpactLargest Impact

N/A

Inadequate rates nmlkj nmlkj nmlkj nmlkj nmlkj

Lack of timely authorizations nmlkj nmlkj nmlkj nmlkj nmlkj

Lack of timely payment (or increase in accounts receivable) nmlkj nmlkj nmlkj nmlkj nmlkj

A lack of state policy clarity about the regulatory requirements (e.g. responsibilities for physician orders, plans of care, supervision)

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Only a small number of my patients are required to enroll into MLTCs or MCOs

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Contract negotiation issues nmlkj nmlkj nmlkj nmlkj nmlkj

I do not have a CHHA and the MLTC/MCO only wants to contract with a CHHA

nmlkj nmlkj nmlkj nmlkj nmlkj

I am a LTHHCP or CHHA and the MLTC/MCO only wants to contract with a LHCSA

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The MLTCs/MCOs feel they already have a sufficient number of contracts

nmlkj nmlkj nmlkj nmlkj nmlkj

Lack of timely DOH approval of our contract with MLTC/MCO plans nmlkj nmlkj nmlkj nmlkj nmlkj

Other (please specify)

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Minimal Impact

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Medium Impact

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Large Impact

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N/A

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If possible, please quantify this cost impact as a percentage of your operating revenue.

20. If you are contracting with an MLTC, what is the nature of your contract? (Check all that apply)

21. If you are contracting with an MCO, what is the nature of your contract? (Check all that apply)

22. Has your agency been able to successfully contract with MLTCs/MCOs for providing telehealth services?

We will conduct care management through our CHHA

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We will conduct care management through our LTHHCP

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We will conduct care management through our LHCSA

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We will deliver professional services through our CHHA

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We will deliver professional services through our LTHHCP

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We will deliver professional services through our LHCSA

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We will deliver home health aide or personal care aide services only

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We have a contract to provide supervision services

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We have a contract to provide assessment services

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N/A

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Other (please specify)

We will conduct care management through our CHHA

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We will conduct care management through our LTHHCP

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We will conduct care management through our LHCSA

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We will deliver professional services through our CHHA

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We will deliver professional services through our LTHHCP

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We will deliver professional services through our LHCSA

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We will deliver home health aide or personal care aide services only

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We have a contract to provide supervision services

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We have a contract to provide assessment services

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N/A

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Other (please specify)

Yes

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No

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If not, please describe what is happening with your telehealth program and/or patients.

23. As a result of the transition to managed care, what changes have you made or expect will occur at your organization? (Check all that apply)

24. Are you experiencing that MLTCs/MCOs would rather contract for home health aide services rather than personal care aide services?

25. Please rate which of the following are needed to support your transition to mandatory enrollment.

Not Important Somewhat Important Very Important

Payments similar to the Medicaid fee­for­service rate nmlkj nmlkj nmlkj

Greater state clarity on the role and regulatory responsibilities for agencies

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Regulatory relief nmlkj nmlkj nmlkj

Capital and technology funding support nmlkj nmlkj nmlkj

Staff retraining funds or support nmlkj nmlkj nmlkj

Staff recruitment funding nmlkj nmlkj nmlkj

Contract negotiation assistance nmlkj nmlkj nmlkj

Technology upgrades

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Workforce retraining

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An increase in the number of patients my agency will serve

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Reduce staff and other expenses to become more efficient

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Phase­out LTHHCP

gfedc

Increase use of CHHA

gfedc

Decrease use of CHHA

gfedc

Increase use of LHCSA

gfedc

Discontinue telehealth program

gfedc

New partnerships, growth and opportunities

gfedc

Other (please specify)

Yes

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No

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Other (please specify)

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Thank you for completing this important survey. If you have any additional comments, please note them in the text box below.

26. Comments

THANK YOU

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