Indiana Value Based Purchasing Update

For the past 20 months, the Indiana Division of Aging and Indiana Office of Medicaid Policy and Planning (together, the “State”) have been writing a proposed rule to alter the methodology behind the currently named Report Card Score Add-on to the Medicaid reimbursement rate.  The State has proposed a multi-domain methodology to determine the amount of add-on a nursing facility could obtain, it is called the Value Based Purchasing Add-on (“VBP Add-on”).  The IHCA has been deeply involved in attempting to improve the State’s VBP Add-on proposal by advocating for fair measurement of the domains, allocation of points, and an overall system where improvement in score correlates to improvement in quality resident care.  To read more about the VBP system, see http://www.nxtbook.com/nxtbooks/naylor/INHB0112/index.php?startid=6#/6.

On December 19, 2012, the State published a proposed rule for VBP, in addition to other changes to the reimbursement system, that would be effective on July 1, 2013.  One difference between the proposed rule and the original design is that for 2013 the resident, family and staff satisfaction surveys will not be part of the VBP score.  While those surveys will be conducted this year, the data would not be available in time to analyze it and make a fair distribution based upon that data by July 1, 2013.  The satisfaction survey data will be collected in 2013 and incorporated into the payment add-on in 2014.  The State is currently negotiating a contract with Press Ganey to conduct the satisfaction surveys.  Once a contract is signed, IHCA will engage the State and Press Ganey to fully educate IHCA members on how the survey process will be conducted.

IHCA is currently writing formal comments to submit to the State at the January 15, 2013 public hearing on the VBP proposed rule.  IHCA continues to be concerned with a number of areas in the VBP proposal, including the lack of recognition of therapy hours when calculating hands on care per resident day (the State is only focusing on hours provided by RNs, LPNs, and CNAs).  In addition, IHCA is concerned with the Administrator and DON turnover measure being too strict and not taking into consideration the internal promotion of Administrators and DONs.  IHCA has also, and will continue, to express concern regarding the heavy reliance on staffing measures within the VBP program given the weak to moderate correlations to improved Report Card Scores.  Without stronger correlations between the measurements and improved quality (as measured by the Report Card Score) it is less likely that incentive payments will make any difference with quality improvement efforts.

To view the proposed rule, see  http://www.in.gov/legislative/iac/irtoc.htm?view=list&lsadocnum=12-279.