AHCA has been asked by CMS to engage members to collect comments on three documents concerning CMS guidance on dementia care. The documents include a draft S&C memo and updates to Appendix P and Appendix PP and can be accessed in the Members Only section of the IHCA website. Please submit any comments you may have to Zach Cattell at zcattell@ihca.org or 317-616-9001 by October 2 or directly to Lyn Bently at lbentley@AHCA.org by October 3.
Wednesday, September 26, 2012
Focus on Improving Dementia Care and Reducing Antipsychotic Use
CMS has requested that all SSA surveyors inquire into a facilities plans and actions to improve dementia care and reduce antipsychotic medication use. ISDH has indicated that its surveyors will make such an inquiry on every survey, and record the responses. The responses are not used in the survey process, but CMS is wanting discussions surrounding dementia care and antipsychotic medication use to be prevalent as the issues are targeted for improvement.
Indiana Medicaid Recovery Audit Contractor (RAC) to Begin Work
Indiana Medicaid released a Banner Page on Tuesday of this past week formally announcing the approval of Health Management Systems (HMS) as the RAC vendor for Indiana long term care facilities. They will perform a comprehensive review of Medicaid claims spanning a four year period (with the most recent 12 months from the date of the start of the review excluded). Audits will focus on, but not be limited to, payments made for dates of service after discharge, duplicate payments, appropriateness of reporting of Medicare and third-party payments, and errors related to patient liability application or collection.
It is imperative that facility personnel recognize notices from HMS and elevate to the appropriate person in the company. Tight timelines apply to complying with records request from the HMS. The presentation from HMS that was provided to IHCA in June of this year and the Banner Page are available for access in the Members Only section of the IHCA website.
It is imperative that facility personnel recognize notices from HMS and elevate to the appropriate person in the company. Tight timelines apply to complying with records request from the HMS. The presentation from HMS that was provided to IHCA in June of this year and the Banner Page are available for access in the Members Only section of the IHCA website.
Monday, September 10, 2012
Partnership to Improve Dementia Care and reduce Unnecessary Antipsychotic Drug Use in Nursing Homes
CMS released a Survey & Certification Memorandum to State Survey Agencies regarding this new initiative. In 2012, Centers for Medicare & Medicaid Services (CMS) launched the Partnership to Improve Dementia Care in Nursing Homes to promote comprehensive dementia care and therapeutic interventions for nursing home residents with dementia-related behaviors. Stakeholders, such as AMDA and AHCA are sending letters to support the Partnership to Improve Dementia Care in Nursing Homes. The S&C Memo is available in the Member's Only section of the IHCA website, as is a list of Q&As related to the initiative that have been fielded by Region V staff.
In support of the initiative, IHCA will be sending data to its member facilities regarding their antipsychotic use rate. The data can also be sorted for an entire corporate entity, should you so desire that information. If you would like that aggregate data for all facilities in your company, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001.
In support of the initiative, IHCA will be sending data to its member facilities regarding their antipsychotic use rate. The data can also be sorted for an entire corporate entity, should you so desire that information. If you would like that aggregate data for all facilities in your company, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001.
Wednesday, September 5, 2012
Value Based Purchasing – Phase III
The new RFP for a contractor to administer the resident, family and staff satisfaction survey portion of the Value Based Purchasing (VBP) program is due to be released on September 9th, responses will be due on October 6th and the plan is to award a contract on December 6th. The Surveys would begin in January, be completed by March, and data would flow to M&S by April 1st. The goals is to being the VBP reimbursement add-on, that replaces the Report Card Score add-on, on July 1, 2013.
The VBP program is a 12-domain weighed methodology that that facilities across the State will measured against for purposes of qualifying for a performance and quality-based Medicaid add-on payment. IHCA has been very active with the State in development of the program and urging the State to correct certain deficiencies in the original methodology. That original methodology was first developed in 2012 by a group called the Clinical Expert Panel, comprised of resident advocates, industry representatives, and other clinical stakeholders.
For more information about VBP, please see the Spring Edition of the IHCA Magazine at http://www.nxtbook.com/nxtbooks/naylor/INHB0112/index.php?startid=6#/6, or please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org.
The VBP program is a 12-domain weighed methodology that that facilities across the State will measured against for purposes of qualifying for a performance and quality-based Medicaid add-on payment. IHCA has been very active with the State in development of the program and urging the State to correct certain deficiencies in the original methodology. That original methodology was first developed in 2012 by a group called the Clinical Expert Panel, comprised of resident advocates, industry representatives, and other clinical stakeholders.
For more information about VBP, please see the Spring Edition of the IHCA Magazine at http://www.nxtbook.com/nxtbooks/naylor/INHB0112/index.php?startid=6#/6, or please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org.
IGT/UPL Calculation Changes
Last Wednesday, August 29th, the IHCA, along with Payment Committee co-chair Rick Mittman of BKD, Jim Leich (Leading Age) and Bob Decker (HOPE) met with representatives of Indiana Medicaid, the Division of Aging, and Myers & Stauffer (collectively, the “State”) on a number of outstanding reimbursement matters. Just before the meeting took place, the State added to the agenda an item about the IGT/UPL calculation for NSGO nursing facilities. IHCA learned that morning that that State would be filing notice that same day to amend the State Plan Amendment to provide for a new UPL calculation methodology for NSGO nursing facilities.
The State’s new methodology for UPL calculation will compare the difference of a facility’s Medicaid per diem rate and the reasonable estimate of the Medicare rate. The State will no longer use the proportional share pool distribution based on the percentage of a facility’s Medicaid days in relation to the total number of Medicaid days in the pool. There is no fiscal impact to the State, but as to individual facilities there is likely to be a difference in the UPL payments since it will now be based on the facility’s rate. This change is set to be effective 10/1/12. The notice may be found at http://www.in.gov/legislative/iac/20120829-IR-405120507ONA.xml.html.
IHCA has informed the IHCA Board of Directors and the IHCA Payment and Reimbursement Committee about the issue and will engage the State at the direction of our members. In addition, the State confirmed at last week’s meeting that they are having preliminary discussions about establishing quality metrics as conditions to participate in the IGT/UPL nursing facility program. Neither OMPP or Div. of Aging had any detail to share at that meeting. IHCA impressed upon them our interest in engaging the State on the concept so that any change is not a surprise and is a reasonable approach to incentivizing quality.
Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
The State’s new methodology for UPL calculation will compare the difference of a facility’s Medicaid per diem rate and the reasonable estimate of the Medicare rate. The State will no longer use the proportional share pool distribution based on the percentage of a facility’s Medicaid days in relation to the total number of Medicaid days in the pool. There is no fiscal impact to the State, but as to individual facilities there is likely to be a difference in the UPL payments since it will now be based on the facility’s rate. This change is set to be effective 10/1/12. The notice may be found at http://www.in.gov/legislative/iac/20120829-IR-405120507ONA.xml.html.
IHCA has informed the IHCA Board of Directors and the IHCA Payment and Reimbursement Committee about the issue and will engage the State at the direction of our members. In addition, the State confirmed at last week’s meeting that they are having preliminary discussions about establishing quality metrics as conditions to participate in the IGT/UPL nursing facility program. Neither OMPP or Div. of Aging had any detail to share at that meeting. IHCA impressed upon them our interest in engaging the State on the concept so that any change is not a surprise and is a reasonable approach to incentivizing quality.
Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
Field Audit Penalty
In late May 2012, the Office of Medicaid Policy and Planning (OMPP) released an Emergency Rule to implement changes to the State Plan Amendment resulting from the increase in the Quality Assessment Fee (QAF). Most of the changes found in the Emergency Rule were expected as the IHCA has been constantly engaged with the State to ensure that the benefits promised to the long term care profession and its residents were carried through. One provision that came as a surprise, however, was language instituting a 10% penalty on a providers per diem Medicaid rate if the provider failed to comply with certain documentation requests during a field audit of the provider’s books and records. IHCA engaged OMPP on this issue recently.
Although the State was not willing to reduce or eliminate the 10% penalty they put in place in the Emergency Rule, the IHCA was successful on a number of items within the details and implementation of the new rule. The State explained that only a very small number of providers would be subject to the penalty because of the State’s internal documentation request procedures. Those procedures provide for at least 135 days, and 165 days when a 30 day extension is requested, to respond prior to a 10% penalty being imposed. IHCA requested that these procedures be published and the State appeared willing to publish these procedures either on Myers & Stauffer’s website or as a Provider Bulletin.
Aside from the penalty amount itself, if a penalty is put in place OMPP will limit the duration of that penalty to no longer than 12 months. Before IHCA’s engagement on this issue, a penalty could last indefinitely. In addition, OMPP will consider shortening the duration of the penalty to less than 1 month if the provider responds with adequate documentation within that period. Furthermore, OMPP will automatically grant a 30 day extension for time, will subject all documentation requests during a field audit to a materiality standard, and will require OMPP review of Myers & Stauffer’s documentation requests. Each of the above issues will be addressed by the IHCA in written comments once the permanent rule, which replaces the Emergency Rule, is published for comment.
Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
Although the State was not willing to reduce or eliminate the 10% penalty they put in place in the Emergency Rule, the IHCA was successful on a number of items within the details and implementation of the new rule. The State explained that only a very small number of providers would be subject to the penalty because of the State’s internal documentation request procedures. Those procedures provide for at least 135 days, and 165 days when a 30 day extension is requested, to respond prior to a 10% penalty being imposed. IHCA requested that these procedures be published and the State appeared willing to publish these procedures either on Myers & Stauffer’s website or as a Provider Bulletin.
Aside from the penalty amount itself, if a penalty is put in place OMPP will limit the duration of that penalty to no longer than 12 months. Before IHCA’s engagement on this issue, a penalty could last indefinitely. In addition, OMPP will consider shortening the duration of the penalty to less than 1 month if the provider responds with adequate documentation within that period. Furthermore, OMPP will automatically grant a 30 day extension for time, will subject all documentation requests during a field audit to a materiality standard, and will require OMPP review of Myers & Stauffer’s documentation requests. Each of the above issues will be addressed by the IHCA in written comments once the permanent rule, which replaces the Emergency Rule, is published for comment.
Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
Nursing Facility Reimbursement Appeals Reduction Plan
In 2011, the Indiana General Assembly passed legislation requiring the Office of Medicaid Policy and Planning (OMPP) to utilize portions of the increased Quality Assessment Fee (QAF) collected from nursing facilities to discharge provider liability for certain pending administrative appeal(s).
Last week, IHCA met with OMPP officials to review draft documents concerning the process for executing this requirement. OMPP has called the project the Appeals Reduction Plan.
The OMPP Office of General Counsel (OGC) presented draft documents concerning the process for withdrawal of audit and rate appeals filed for Rate Effective Dates on or before 7/1/11. In exchange for the withdrawal of the filed appeals, the provider’s potential liability from the audit adjustment will be discharged as the State will utilize the $20M in QAF to satisfy that potential liability. Obviously a provider’s decision to withdraw the appeal will be an individual choice based upon many factors. IHCA’s Payment and Reimbursement Committee has been very active in discussing this issue and is providing guidance to IHCA members.
The Appeals Reduction Plan is likely to begin with a small number of providers in about 4 to 6 weeks, once the draft documents are finalized. IHCA will have another opportunity to review the documents prior to the program’s start. OMPP is likely to meet with the first small group of providers and their counsel (at the provider’s choice) to walk through the process and iron out any issues before rolling the program out statewide. OMPP anticipates, in coordination with Myers & Stauffer, that the batch process will work backwards in time with the newest appeals being dealt with first, followed by older appeals.
IHCA staff will continue to work with the State and update IHCA members on the issue as new information becomes available. Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
Last week, IHCA met with OMPP officials to review draft documents concerning the process for executing this requirement. OMPP has called the project the Appeals Reduction Plan.
The OMPP Office of General Counsel (OGC) presented draft documents concerning the process for withdrawal of audit and rate appeals filed for Rate Effective Dates on or before 7/1/11. In exchange for the withdrawal of the filed appeals, the provider’s potential liability from the audit adjustment will be discharged as the State will utilize the $20M in QAF to satisfy that potential liability. Obviously a provider’s decision to withdraw the appeal will be an individual choice based upon many factors. IHCA’s Payment and Reimbursement Committee has been very active in discussing this issue and is providing guidance to IHCA members.
The Appeals Reduction Plan is likely to begin with a small number of providers in about 4 to 6 weeks, once the draft documents are finalized. IHCA will have another opportunity to review the documents prior to the program’s start. OMPP is likely to meet with the first small group of providers and their counsel (at the provider’s choice) to walk through the process and iron out any issues before rolling the program out statewide. OMPP anticipates, in coordination with Myers & Stauffer, that the batch process will work backwards in time with the newest appeals being dealt with first, followed by older appeals.
IHCA staff will continue to work with the State and update IHCA members on the issue as new information becomes available. Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.
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