Healthy Indiana 2.0: “HIP Link” Information for Employers

Following Governor Pence's approval of HIP 2.0 earlier this year, the program has grown to include more than 293,000 Hoosiers. There are still hundreds of thousands more Hoosiers out there that can benefit from HIP 2.0.  The Healthy Indiana Plan (HIP) is a program for low income Hoosiers and was modeled after consumer-driven healthcare. HIP offers members a High Deductible Health Plan (HDHP) with a Personal Wellness and Responsibility (POWER) account to which members contribute.  Indiana replaced traditional Medicaid and expanded HIP to all non-disabled Hoosier age 19-64 with household incomes at or below approximately 138% of the federal poverty level.  Hoosiers with incomes of up to $16,436.80 annually for an individual, $22,246.25 for a couple are generally eligible to participate in HIP.  HIP 2.0 includes HIP Link, a new premium assistance program for eligible individuals with access to employer-sponsored insurance.

What is HIP Link?

• A new State program that is part of Indiana’s nationally recognized Health Indiana Plan model.  The Health Indiana Plan or “HIP” was expanded to provide health coverage to eligible Hoosiers with household incomes at or below approximately 138% of the federal poverty level.
• HIP Link offer premium assistance for HIP participants age 21 and older who choose to participate in their employers’ sponsored health plans.  Employees must meet HIP eligibility requirements.
• Spouses and/or eligible adults may also receive coverage if HIP-eligible.

What types of employers can participate in HIP Link?

• Employers that employ Indiana residents who are HIP eligible, agree to contribute at least 50% to the premium cost and offer plans that meet minimum benefits and cost requirements within the program’s limit.

Why should employers participate in HIP Link?

• More employees may be able to take advantage of commercial health insurance benefits.
  o An increase in employees may help to meet industry and marketplace participation rates or lower group premium rates.
• Employees can better manage healthcare costs with their HIP Link POWER Account and Health Reimbursement Account (HRA), if offered by employer.
• Potential to expand employee base and increase retention by being listed as an approved HIP Link Employer.
• Possible tax benefits for small employers using the Health Insurance Marketplace.
• HIP Link does not disrupt current employer-sponsored health insurance and can be incorporated at any time.

HIP Employer Overview
HIP Info For Employers

For more information regarding Eligibility, Key Concepts and FAQs, please click here.

To download the new kit and begin using its materials immediately, please click here.

Indiana Division of Aging Announces Dates for Long Term Services and Supports Public Forums

In 2014 the Indiana General Assembly passed House Enrolled Act (HEA) 1391 that charges the Office of the Secretary of the Family and Social Services Administration, in conjunction with the State Department of Health, and the Office of Management and Budget, with providing a written report to the general assembly before October 1, 2015, addressing a variety of issues concerning delivery of long term services and supports in Indiana (click here to read the list of items to be addressed).  The report was split into two parts, the first part of which has already been delivered to the general assembly and addressed nursing facility occupancy and the extent to which low occupancy is damaging to the state Medicaid program and quality of care.  The second part of the report, due this October 1st, is being developed now and a series of public hearings have been set to gather input from the public.

The Indiana Division of Aging has set up a website for the work on the 1391 Report, and that site includes past reports and versions of the current draft due October 1st.  An update draft is being released later this week and will be the foundation for the below scheduled public hearings.  We encourage you to participate. 

Indianapolis
July 22, 2015, 1:00-3:00
Crossroads Center, 4756 Kingsway Drive (Across from CICOA)
 
Batesville
July 31, 2015, 2:00-4:00  
Public Library
131 N. Walnut Street 47006

Vincennes
August 4, 2015, 1:00-3:00   
Vincennes University, ICAT Building, Room 142

Valpariso
August 5, 2015, 1:00-3:00 CT  
Pines Village Auditorium, Valparaiso

Fort Wayne
August 19, 2015, 1:00-3:00
Public Library, 900 Lirbary Plaza, 46802

New Albany
August 21, 2015, 1:00-3:00
Public Library, 180 W. Spring Street, 47150

CMS Issues Additional Guidance on Home and Community Based Service Setting Requirements

As you are aware CMS issued a new regulation more than a year ago that will change the landscape of home and community based services funded through Medicaid.  IHCA has reported on this in the past (click here).  Part of these changes include ensuring that recipients of home and community based services are in settings that are not “institutions” or have qualities of institutionalization.  Certain settings are presumed to have qualities of institutions, and while those settings are not permanently excluded from participating in HCBS Medicaid programs, they will have to meet a “heightened scrutiny” process.  CMS’s new guidance speaks directly to that heightened scrutiny process (click here to review).

IHCA is continually engaging the Indiana Medicaid program and Division of Aging on how it will change Indiana’s HCBS waivers to comply, and how those changes will impact Indiana providers.

AHCA Submits Comments to CMS on the 2016 SNF PPS Rule

Click here to view the comments submitted by AHCA to CMS on the 2016 SNF PPS Rule.  The comments cover a wide range of issues included int his year’s rule including the Market Basket adjustment, Wage Index, SNF Value Based Purchasing Program, Health Information Exchanges, SNF Quality Reporting Program, and Staff Reporting Requirements.

CMS Issues Medicare Shared Savings Program Rule

CMS issued a final rule to update the Medicare Shared Savings Program (MSSP), which governs the activities of more than 400 ACOs across the country. This rule represents the first significant update to the Medicare ACO program since the first rules were finalized in November of 2011. The 592-page rule makes numerous modifications to the ACO program, including:

• Creates a new "Track 3" for MSSP ACOs that looks very similar to the Pioneer ACO program model, including higher rates of shared savings, prospective assignment of beneficiaries, and the opportunity to use new care coordination tools;
• Streamlines data sharing between CMS and ACOs, which will allow ACOs to more easily access data on their patients;
• Establishes a waiver of the SNF 3-day stay requirement for those ACOs who opt into Track 3; and
• Refines the policies for resetting ACO benchmarks to help ensure that the program continues to provide strong incentives for ACOs to improve patient care and generate cost savings.

ISDH Requires Census Reporting as of July 1, 2015

ISDH sent out a newsletter on June 29, 2015 indicating that it intends to require nursing facilities to report their actual facility census as of July 1, 2015 through the ISDH Gateway no later than July 15, 2015.  The data is needed as of each January 1 and July 1 to determine county and statewide occupancy in order to implement a portion of the nursing facility moratorium legislation.  This announcement is a surprise in terms of timing, but not in terms of substance.  Since the passage of the nursing facility moratorium legislation IHCA knew that the ISDH was going to require mandatory reporting of census, was under the impression it would not begin this until January 1, 2016 since the law is not even effective on July 1, 2015 (but becomes effective on July 2, 2015).  The ISDH is also, apparently, requiring this data for residential care facilities as well.  It is unknown right now what penalty/citation, if any, would follow if a facility did not report this data.

ISDH Proposing Changes to the Report Card Score

IHCA was recently informed that the ISDH wants to change the way Report Card Scores (RCS) are calculated.  In short, the ISDH use a higher score to indicate better regulatory compliance (today, the lower score equals better compliance).  The scoring would start all facilities would with 300 points then points would be deducted based on each tag received during any survey.  The ISDH wants to score to reflect all tags and from all surveys over the past 30 month period, excluding life safety code tags and substantial compliance tags (A, B and C).  No extra points would be deducted for IJs or SSQC tags. Click here for a description from the ISDH.

IHCA has obtained a facility by facility breakdown of the current scores and the proposed scores (click here to access that report).  This breakdown is very preliminary and IHCA is examining the data sources for this report.  We are concerned with a few items within this concept, and have found a few examples that validate those concerns.  First, in some cases tags get cited twice during a complaint investigation that is done during an annual survey.  Said another way, two 2567s are generated, one for the complaint and one for the annual survey, and the same tags cited in the complaint get cited in the annual.  This improperly penalizes the facility, especially if all tags will be used in a new report card score methodology.  Next, we are concerned with the point allocation proposed by the ISDH, D-E-F citations get 3 points, then the scale jumps to 20 points for any G-H-I citations.  We think this is confusion and we want the ISDH to look at both scope and severity when allocating points, like in the current system.  There are a couple of other issues and questions within ISDH’s process that we are examining, such as frequency of scores being updated and how to account for geographic variation in surveys.  That said, we are encouraged by the new system’s design that only looks back at the most current 30 months of surveys, thereby allowing facilities to improve in their scores without having to wait for the next annual survey to be completed, as in the current system.

As you may be aware, the ISDH RCS is used by Indiana Medicaid to determine a large portion of the Value Based Purchasing Add-on within the Medicaid rate.  There have not been any discussions as of yet on how this newly proposed RCS would or would not be used in the add-on.  IHCA is meeting with Indiana Medicaid representatives on an ongoing basis regarding the Medicaid rate setting methodology and will be discussing this issue very soon with Indiana Medicaid.  In addition, IHCA’s Payment/Reimbursement Committee will discuss this at its next meeting on June 17th.

ISDH Revising the Incident Reporting Policy

IHCA sent out a member alert in June concerning the ISDH’s draft revisions to the Incident Reporting Policy.  With the great work from the IHCA Regulatory/Clinical Committee, IHCA joined with LeadingAge and HOPE to submit comments to the ISDH’s original draft (click here to view those comments).  IHCA has met with the ISDH since submission of those comments and we are pleased to report that the latest draft of the policy incorporated nearly all of the suggestions we made (click here to see revisions).  Subsequently, IHCA submitted a second set of comments on the revised draft (click here for the second set of comments).  The revised draft is not the final version of the policy and is included here for your information only. 

ISDH continues to work on finalizing the policy.  IHCA understands that the ISDH is working towards a release date for a final policy on or around July 15, 2015 with a 30-day implementation window for an effective date of August 15, 2015. Stay tuned for more!

Mandated Use of ISDH Gateway for Incident Reporting Effective July 1, 2015

As previously reported, and announced again by the ISDH on June 30, 2015, incident reporting to the ISDH is required to go through the ISDH Gateway System.  This is the same system used for survey reports.  The linked ISDH newsletter link you to a instructions on how to use the system and well as FAQs.

The ISDH newsletter includes instructions for reporting that will be part of a new Incident Reporting Policy that is still being revised and is likely to be released later in July.  Even though the revised policy is not final and released, the instructions in the ISDH newsletter are valid and to be followed.

Residential Care Citation Update

The ISDH issued 37 tags at the Deficiency level and 3 tags at the Offense level to Residential Care Facilities in May.  No new trends emerged in May, but the normal patterns seen for a past few years continue with citation for Tag 0273 (Food prep and service areas), Tag 0241 (Medication administration by licensed nursing or QMA), Tag 0217 (Qualified staff conducting service planning and resident/representative signing and dating the plan), and Tag 0217 (Sufficient staff to provide for 24 hour needs of residents).

To review a summary of the May citations, click here.

IJ/SSQC Citation Update

There was one IJ citation issued by the ISHD in May.  F 155 was issued for failure to ensure a resident’s right in self-determination regarding implementation of the formulated advance directive and staff failed to initiate CPR as indicated.  This is the third time F 155 has been cited as the IJ level in 2015, and the fifth time in the last 7 months that a citation has been issued at the IJ level for failures surrounding advance directives and administration of CPR.  In the May event, the resident was found lying on the floor and had clearly passed on.  The resident was totally purple in the upper body and was still slightly warm to the touch.  No pulse, blood pressure or respirations were noted.  However, the resident was full code.  The RN in charge at the time indicated that the chart was not checked for code status as she felt there was no effort that could bring the resident back.  Even if the resident was not full code, which she was, the facility has a policy that requires resuscitation efforts, via an AED, unless a valid Advance Directive or DNR order states not to.  This citation was past-noncompliance and the IJ was lifted after a complete audit for code status was performed, all staff were inserviced on code response, two mock drills were performed, staff involved in resuscitative efforts were CPR certified, and education and disciplinary action were taken with the RN.

To review a summary of the 2015 IJ/SSQCs and the May 2567, click here.