medicaid update

Medicaid UpdateUHCA Conference April 14, 2021

John Curless

Funding

• NF Fundingo Assessment Increase of ~$100,600o ~$304,800 Total Funds for rateso Increase based upon request to stay near the

6% assessment limit

Note: Final numbers may vary from the above draft figures

Funding

• NF Assessment rate update to UAC R414-401

o From $27.56 to $27.63 (draft)o Monthly assessment reporting Be sure to use the fillable PDF form created last

year Anyone have feedback about the new form? https://medicaid.utah.gov/stplan/longtermcarebar/

FCP Deadlines

• We are planning to propose a change to the State Plan related to the FCP submission deadlines

• The current deadline is August 31st with one possible 15-day extension, if approved, for “extenuating circumstances”

• The potential change would be for the deadline to be September 30 with no extensions (effectively, this date would give two 15-day extensions)

• If FCPs are late, payments to the facility may be withheld as currently allowed

MDS

• Impact on UPL

• CMS has not provided any additional guidance since approving our UPL methodology

• We are waiting for any additional guidance CMS may give…

QII(2) – Potential Updates

• COVID-19 has prompted us to seek CMS approval to add a new option for giving staff $50 if they get fully vaccinated against COVID-19

• Environmental management program (e.g., water management, disinfectant fogger)

• Proposed changes are pending CMS approval

Legislative Update

• HB 333 – Medicaid Amendments‒ creates limitations on the number of beds that can be certified by the Medicaid

program at intermediate care facilities for individuals with intellectual disabilities;

‒ creates an exception for certain time limits in a state or national emergency that affects an intermediate care facility for individuals with intellectual disabilities

• HB 365S01 – State Agency Realignment‒ Combines the Departments of Health and Human Services into one

Department‒ Carves out certain Medicaid eligibility functions from Medicaid and adds them

to the Department of Workforce Services

ICF/ID Update

• Assessment‒ The legislature added $250,000 to the assessment‒ Assessment rate to go from $8.28 to $9.51 (draft)‒ Bed reductions over past several months have days anticipated to

be down about 10%‒ The sponsor noted intent of the funds

ICF/ID Update

• Capital Improvement Incentive ending‒ Get improvements done and applications in before 6/30/2021‒ At end of program, unspent funds will be allocated, if possible, to

facilities having spent more than the base maximum allowable‒ Must be a current Medicaid-certified provider

• Funding for new Quality Improvement Incentive‒ Trent will give the details of the draft proposal…

Questions ?

Medicaid UpdateUHCA Conference April 14, 2021

Ed DeinertReimbursement Analyst

MDS Oddities• Oddities will continue on a monthly basis until August

• After August reports will be sent on a weekly basis

• People are doing a good job of responding to the monthly reports

• If appropriate, payments may be withheld

Quality Improvement Incentive (QII) Programs

NF QII (2)• $4,275,900 pool – available to NF’s who submit:

• Complete application form

• Invoice

• Check/Proof of Payment

• If seeking reimbursement for more than one item on a single application, please attach a spreadsheet detailing each item

NF QII (2)• SFY 2021 YTD (as of xx/yy/zz):

• QII(2) monies paid – $585,185.37

• Number of the NF’s achieving max payout• 1

• Number of applications received/rejected (140/4) of 2.8571% rejection rate

NF QII (2)• Be smart with your QII(2) reimbursement

• Is it more effective to submit one or two “big-ticket” items or twenty “small-ticket” items (knowing the rejection rate)?

• One facility submitted 13 separate applications totaling 60% of eligible amount.

Example QII(2) Application

NF QII (3)• Unused QII(2) monies fund this QII• Qualifications

– QII(1) – 100%– QII(2) – at least one approved– Resident choice program

• Requires specific evidence of:– Awake time– Meal time– Bath time

See: https://medicaid.utah.gov/stplan/longtermcarenfqi/

Friendly Reminders

• QII applications must be submitted by May 31st

• The UPL website has detailed information on the gap, days, and dollars (going back many years).

Questions ?

Reimbursement ContactsNF Rates: Ed Deinert edd@utah.gov

Manager: Trent Brown trentbrown@utah.gov

Director: Matt Ohrenberger mohrenberger@utah.gov

Bureau Director: John Curless jcurless@utah.gov

NF NSGO QI Program Update

Trent Brown, MOT, OTR/L, ATP, BCGReimbursement Unit Manager

General Information

• Proposed ICF/IID Quality Improvement Incentive 2• $3,710,000• QII2(1) Patient Dignity

$30,000 per de-licensed and de-certified bed The proposal shall include the following elements: Resident privacy; Resident choice surrounding furnishings and environment;

and Resident choice with awake, bed, and relaxation times and

environmental preferences for those times.

General Information

• QII2(2)o ICF/IID chooses 2 of 5 programs to complete employment, vocational, or life skills training opportunity

program, uniquely tailored to each individual work assessment program community integration program staff education program Covid-19 staff incentive program

o ~$4,107.53 per bed

General Information

• QII2(3)o Any unused monies from QII2(2) to facilities who achieved

100% in QII2(2)

Note: Unspent monies from QII2(1) will not be paid out

General Information

NF NSGO UPL QII program

• Calendar Year (CY) 2021,14 or more QI points is requiredo minimum of 7 QI points in Direct Resident Services

(R414-516-6)

R414-516

• R414-516-3(4)(a) states: “Each program shall submit to the Division a compliance form, using the current Division form, on or before January 31 following the end of the calendar year...”

R414-516 Amendments

• The original excel spreadsheet and signed (PDF) version

R414-516: Audit Requests

• Requests received later than 30 calendar days from receipt will have all audited QI points removed.

QI Audit Results CY 2020

• All 64 facilities met the requirements of R414-516

• Number of QI programs completed 976 (15.3/facility)

• Number of programs audited 363 (37.2%)

2020 QI Audit Issues

READ THE RULE:

• The majority of QI points removed during the audit were from the Direct Resident Services category (R414-516-6) and the Quality Metrics category (R414-516-7)

• Remember, R414-516 is the definitive source of the QI program. Many facilities claimed, “I heard…” or “last year we…”

2019 QI Audit Issues

CASPER vs. Quality Metrics

What are the differences?

2020 QI Audit Issues

What are the differences?

Quality Metrics (R414-516-7)

• All Data is imported from the CMS Archive website• https://data.cms.gov/provider-data/archived-data/nursing-

homes/

2020 QI Audit Issues

What are the differences?• Date (Report Period)

o 10/1 – 9/30 (CASPER)o 1/1 – 12/31 (Quality Metrics)

• Columno Comparison Group National Percentile (CASPER)o Facility Adjusted Percent (Quality Metrics)

• Categoryo Any Long Term (L) measure (CASPER)o The six defined measures (Quality Metrics)

2020 QI Audit Issues

Quality Measures CASPER

2020 QI Audit Issues

What are the differences?• How to earn QI Points

o CASPER: Improvement in any two categories comparing previous year to current year

(for this upcoming year comparing 10/1/2019 – 9/30/2020 to 10/1/20 –9/30/2021)

o Quality Metrics Score better than industry average in distinct measures (3,4, or > 4 of 6) Improve in 3 or more categories compared to previous CY

2020 QI Audit Issues

What are the differences?• Review of CASPER QI points

o Improvement of at least 20% in two categories

2020 QI Audit Issues

Review of Quality Metrics QI points

o Better than industry averageo Improvement in 4 or more categories compared to previous CY Hi-risk Press Ulcer Falls w/Maj Injury UTI Adjusted Nursing hours Quality Measure rating from 5-star Scope and Severity of Deficiencies (Survey)

found on Casper report or CMS website

2020 QI Audit Issues

2020 QI Audit Issues

Review of Quality Metrics QI pointso Adjusted Nursing Hours

2020 QI Audit Issues

Review of Quality Metrics QI pointso QM rating on 5-star measure

2020 QI Audit Issues

Review of Quality Metrics QI pointso Scope and Severity (average of tags)

***If a facility receives more than one survey in a CY, all surveys must be included in the calculation

2020 QI Audit Issues

Self Check in Quality Metricso Was the quality measure rating for the CMS 5-star rating for my facility

> 3.62?o Was the overall percentage of residents with UTIs in my facility < 6.68%?o Was the overall percentage of residents with pressure ulcers in my facility

< 6.15%o Was the overall percentage of residents who experienced a fall resulting in

major injuries in my facility < 4.17%o Was the overall adjusted nursing staff hers per resident per day in my

facility > 3.81?o Was the average survey deficiency scope and severity in my facility <

3.57?

2020 QI Audit Issues

Consistent Assignment (CA)• Verification of CA must include:

o Map/chart and explanation of area where consistent assignment occurred

o Nurse or C N A who received credit for consistent assignmento Verification of actual worked hours [unless receiving points for

schedule only (R414-516-6(5)(a)]

2019 QI Audit Issues

Consistent Assignment

2019 QI Audit Issues

2020 QI Audit Issues

Consistent Assignment (CA)

***Not required for “schedule only” QI point

Consistent Assignment (CA)

***Not required for “schedule only” QI point

2020 QI Audit Issues

When Department initially requests documentation for Resident choice, activities, ROM, or walking program, a blank copy of that documentation is acceptable

2020 QI Audit Issues

When Department requests a secondary follow-up with distinct resident documentation verification, that is when the documentation must be completed

Additional Audit/Compliance Helps

• FRV Age is found on the website:

https://medicaid.utah.gov/stplan/longtermcarenffcp

Make sure your FRV information is current/updated if you are looking to claim those points

• QI Program not required for residents with a LOS < 14 days

Future of UPL QI program

• For several years, the division and industry has contemplated a shift to metrics only

• Those discussions will begin in earnest this Summer/Fall

• Updates to the program will be revised in R414-516 for calendar year 2022 effective date

Conclusion

• As UPL dollars increases, so has the scrutiny from many sources (e.g., CMS, UOIG, GOMB, legislature, OIA)

• Annual amounts in excess of $100 million

• As the UPL program has accelerated, the QI Program is a way the division can measure quality and quantify the effectiveness of the UPL program to interested parties

Questions ?

Trent Browntrentbrown@utah.gov