hca presses pdgm legislative fix with seven key congressional … · free webinar dec. 6 two-part...

UPCOMINGPROGRAMS

Your Source for HOME CARE News Policy and Advocacy Vol 3 Issue 47| December 3 2018

INSIDE

HCA BootcampRegulatory ampCompliance Updatefor CDPAP FIsDec 5 (NYC)

Webinar for AgenciesNot Yet Using HCArsquosSepsis ToolDec 5

Tips and Tricks forWorking with Third-Party PayersFree WebinarDec 6

Two-Part WebinarSeries on OASIS DDec 11 and Dec 13

2019 Northeast HomeHealth LeadershipSummitJan 22-24 2019(Boston)

Register at httpshca-nysorgevents-educationupcoming-events

See PDGM p 2

See MOMENTUM p 5

HCA Presses PDGM Legislative Fix withSeven Key Congressional Offices

HCA met last week with the offices of seven New York Congressional Representatives whoserve on key Medicare committees presenting them with a single target message pass aseries of bills to protect home health services from $1 billion in cuts nationwide assumedunder the Patient-Driven Groupings Model (PDGM) A list of the offices we met with isprovided later in this article

HCA Presses PDGM Legislative Fix1Respond Now to HCArsquos Annual Finance Program Survey1Continuing the Momentum on National Home Care Month1Member Hiring Announcement4How Can Home Care Garner an Edge in New Models of Care5DOH Activates 2017 CHHA LTHHCP Hospice Stat Utilization Reports6DOH Provides HCA with Updates on 2017 LHCSA Stat Report Process6LTHHCPs Providers Tapped for Potential CFCO Program7HCA Welcomes New Program and Research Director Lauren Ford8Members-Only Webinar on Revised ldquoCall-in Payrdquo Regs Dec 189

HCA Tapped for National State Home Care Forum Executive Committee10CMS Provides Hospice Updates10RAC Issues Pertaining to Hospice11OMIG Posts Webinar on Compliance Certification Process Updates11HCA Attends Capital District North Country HEPC Meeting12LawTalk Reasonable Compensation for Executives in Not-for-profit Corps14PHHPC Establishment and Project Review Committee Meets15Important Upcoming Deadlines16Workersrsquo Compensation Appeal Forms Revised17OPWDD Releases FAQs on Managed Care17Health Resources18

Respond Now to HCArsquos AnnualFinance Program Survey

As announced in an e-mail alert this morningHCA needs your responses to our annualfinancial and program survey just todayfinalized for 2018-19

Please designate one person at yourorganization to complete the survey thoughthe process may require input from several

Continuing the Momentumon National Home CareObservances Connections

We mayrsquove turned the page onNational Home Care Month inNovember but we need to continuebuilding on the incredible momentumthat members put forward over thepast several weeks

See SURVEY p 4

CFCO OPTION

DOH pursues HCA-recommended approachfor CFCO services that weadvanced after HCAconsultation with MLTCplans provider members

PAGE 8

HCA WELCOMES LAURENFORD TO POLICY TEAM

HCA welcomes a newmember of our PolicyTeam Lauren Ford whowill concentrate on HCArsquosresearch functions

PAGE 7PAGE 6

REQUIRED REPORTS

DOH issues required Statisticaland Utilization Reports forCHHAs LTHHCPs and hospiceplus an update on LHCSAcompliance and sanctions fromNovember Stat Report deadline

PAGE 14

LAWTALK

The latest installment ofour LawTalk column fromattorneys at JacksonLewis discusses federalcompensation limitsdistinct from EO No 38

2

The Situation Report is a weeklypublication of the Home CareAssociation of New York State(HCA) Unless otherwise notedall articles appearing in TheSituation Report are the propertyof the Home Care Associationof New York State Reuse of anycontent within this newsletterrequires permission from HCA

Al CardilloPresident and CEO

acardillohcanysorg

Roger L NoyesDirector of CommunicationsEditor of The Situation Report

rnoyeshcanysorg

Patrick ConoleVice President

Finance amp Managementpconolehcanysorg

Andrew KoskiVice President

Program Policy amp Servicesakoskihcanysorg

Alyssa LovelaceDirector for Policy and Advocacy

alovelacehcanysorg

Lauren FordDirector of Program Research

Development and Policy

lfordhcanysorg

Laura Constable Senior Director

Membership amp Operationslconstablehcanysorg

Celisia StreetDirector of Education

cstreethcanysorg

Mercedes Teague Finance Manager

mteaguehcanysorg

Jenny KerbeinDirector of Governance amp

Graphic Designjkerbeinhcanysorg

Billi Wilson Manager Meetings amp Events

bwilsonhcanysorg

Teresa BrownAdministrative Assistant

tbrownhcanysorg

Home Care Association of New York State (HCA)388 Broadway 4th Floor Albany NY 12207

Tele 518-426-8764 Fax 518-426-8788 Website wwwhcanysorg

The Situation Report the Home Care Association of New York State Volume 3 No 47 December 3 2018

PDGM from p 1

The meetings were led by HCA Vice President for Finance andManagement Patrick Conole and our federal lobbyist Brett Heimovof Envision Strategies They coincided with a national push on thisseries of bills from the National Association for Home Care andHospice (NAHC) the Council of State Home Care Associations thePartnership for Quality Home Healthcare and other stateassociations

HCA has summarized the bills for you previously Please see ourbriefing paper which was shared with all of the Delegation officesoutlining HCArsquos arguments and the rationale for the bills herehttpshca-nysorgwp-contentuploads201811Co-Sponsor-and-Pass-Bipartisan-Bills-to-Protect-Medicare-Home-Health-Reimbursementpdf

Under PDGM the US Centers for Medicare and Medicaid Services(CMS) is assuming that providers will change their behavior(through coding and other means) as a way of receiving higherpayments than are otherwise intended by the new PDGM paymentmethodology set to go into effect in 2020

This cut is called a ldquobehavioral adjustmentrdquo It would be levied atthe onset of PDGM and it is built on the assumption that providerswill change their behavior in the future rather than CMS basingpayment adjustments on observed empirical evidence This cutaffects providers regardless of whether they are expected tomaintain or exceed their current financial performance under PDGMas compared to the present Home Health Prospective PaymentSystem (HHPPS)

The three bills under consideration (HR 6932 S3545 and S3458)would require CMS to institute rate adjustments based on observedevidence not conjecture They would also limit rate adjustments tono greater than 2 percent per year (Under the proposed rule forPDGM CMS called for a ldquobehavioral assumptionrdquo rate cut of 642percent though the final rule does not specify a number)

Why Now

With the midterm elections settled Congress is finishing up onend-of-year priorities before a new Congress commences in January(also known as the ldquolame duckrdquo session) At this time the prioritiesfor advocacy need to be focused on those items that could possibly

3


Continued from previous page

make their way into a final omnibus package byyearrsquos end and these PDGM-related bills are onesuch priority

During last weekrsquos meetings the New YorkDelegation offices were very receptive to ourarguments with some offices signaling that theywould be signing on as co-sponsors to the PDGMbills This co-sponsorship will help further build onthe billsrsquo momentum toward passage as NAHC thePartnership the Council and other stateassociations similarly weigh in

Who We Met With

HCA met with offices of the following memberswho are expected to assume leadership positionsor who are current or expected members of theHouse Ways amp Means Energy amp Commerce andAppropriations Committees which havejurisdiction on Medicare issues Rep Adriano Espaillat Rep Paul Tonko Rep Tom Reed Rep Brian HigginsRep Sean Patrick Maloney Rep Grace Meng and Rep Eliot Engel

HCA will keep you apprised of all developments on this national advocacy push

HIRING RN Staff Development Education Supervisor ndash Home Health

Full Time 9 am-5 pmDriven to Be the Best

NYU Winthrop Hospitalrsquos Home Health Agency ranks as a top-performing US Home Health Agency Come join our stellar teamof nurses therapy professionals and social workers who provide home health care to our maternal child and adult population

We have an exceptional opportunity for a Staff Development Education Supervisor to be responsible for home health staffeducation development and professional growth including orientation program (didactic and practical components)Collaborating with the Director of Quality ManagementStaff Development and the departmentsrsquo management team you willidentify develop and plan appropriate staff development programs to support agency needs to provide optimum patientoutcomes Working with the Administrator and the Director of Patient Services you will research coordinate and establish newprograms for the agency

We require

NYS Registered Nurse License BSN with 2 yearsrsquo experience in Education in a Certified home care agency Masterrsquos degree in Nursing preferred 2-3 years clinical nursing practice 2 yearsrsquo community health nursing Good communication and basic computer skills knowledge of agency clinical and business functions

To apply for our Staff Development Education Supervisor position visit httpsjobswinthroporgjob8799934registered-nurse-staff-development-supervisor-home-care-mineola-ny

An EOE mfdv

HCA Vice President Patrick Conole meets with MollyCarey JD Legislative Director for Rep Sean PatrickMaloney in Washington last week


4

SURVEY from p 1

staff in various roles (this is why we encourage you to print a PDF of the survey first have relevant staff fill-inthe answers and then input the data online or e-mailfax the PDF according to the instructions in the surveylink below)

Your aggregate results coupled with other data analysis will culminate in our centerpiece home care MLTCand hospice financial and program trend report This report will be presented to policymakers and the media inearly 2019 coinciding with our advocacy agenda

The survey can be completed online at httpswwwsurveymonkeycomr201819industrysurvey We ask for yourresponses as soon as possible but no later than January 7

Our survey is directed at HCArsquos home care provider members but we are supplementing this effort by alsoseparately analyzing other reports that provide a picture of the financial experiences of hospices and MLTCplans including cost reports statistical reports and Medicaid Managed Care Operating Reports

No agency-specific (just aggregate) data will be shared and we ask that you complete as much of the survey aspossible to the best of your ability

All the information you need is on the survey start page but if you have any questions about this process donot hesitate to contact HCArsquos Communications Director Roger Noyes at rnoyeshcanysorg

To see last yearrsquos report based on member survey responses in 2017 to 2018 please visit httpshca-nysorgpolicy-positionshome-care-hospice-and-managed-long-term-care-financial-and-program-trends-2018

How Can Home Care Garner a Winning Edge in New Models of Care Learn how at the Northeast Home Health Leadership Summit register by the end of today for the early-birddeadline

A wave of new federal care models has cascaded through the health care system in the past decade Many ofthese multi-billion-dollar projects flow from one source the Centers for Medicare and Medicaid Innovation(CMMI) at the US Centers for Medicare and Medicaid Services (CMS) The Northeast Home Health Leadership Summit on January 22-24 in Boston is thrilled to present CMMIrsquosDivision Director for Health Care Payment Models Claire Schreiber who will discuss the intersection of homehealth with this patchwork of CMMI initiatives These initiatives include new models that you have surely heard about others that you may be participating inndash and all of which you need information on Accountable Care Organizations (ACOs) the Bundled Payments forCare Improvement (BPCI) initiative Value Based Purchasing (VBP) and the Comprehensive Care for JointReplacement Model (CJR) Schreiber will provide a briefing on current and future plans for home healthrsquos participation in upcoming CMMIprojects Shersquoll also share current results from VBP and the Medicare Care Choices (MCC) models highlighting thebest opportunity areas for home health to help you prioritize projects that are most suitable for your organization Register today at httpnehomehealthsummitcomregistration or visit the conference website (httpnehomehealthsummitcom) to read the full brochure see our sponsors get hotel information and more


5

Whether or not you marked the occasion in a definitive way we consider November as a launchingpoint for a year-long effort to help raise the profile of home care and hospice while connectingwith lawmakers and the public about the services you provide

In this vein HCA today sent a letter to all members of the State Legislature marking the recentobservance of National Home Care Month and further reinforcing HCA as a resource for new andreturning state legislators

We also flagged their attention to an upcoming Home Care 101 session that HCA is planning inJanuary for legislative offices (A formal invite will be delivered soon) The session is designed forlegislative offices to learn the basics about home care operations issue areas and ways HCA canbe a resource for constituents or in the legislative process Look for more details on this sessionsoon (You can read the full letter from HCA President Al Cardillo here httpshca-nysorgwp-contentuploads201812HCAPresidentAlCardilloLettertoLegislaturepdf)

Throughout the past several weeks HCA has also worked one-on-one with several legislativeoffices who reached out to us after we circulated a publication about veterans in home care Thisoutreach resulted in a citation recognizing four HCA members in Senator John DeFranciscorsquosdistrict along with other recognition efforts that continue to take shape

Our veteransrsquo recognition work was also shared nationally by the National Association for HomeCare and Hospice and the Visiting Nurse Associations of America in their member publications lastweek further raising the profile of HCArsquos New York members

HCA also continues to work with the New York State Office for the Aging (NYSOFA) on ways ofreaching their service networks and area offices for the aging about home care including througha recent column written by HCA President Al Cardillo and shared last week with NYSOFA fordistribution across its various distribution channels You can read it here httpstinyurlcomy7efrlqd

NYSOFA is additionally working to finalize a public service announcement featuring Mr Cardillo andNYSOFA Director Greg Olsen discussing sepsis and the specific risksthreat that this conditionposes for elder populations This video public service announcement yet further links uprecognition of home care with public education about the work providers are doing to save livesand prevent health care catastrophes

Recent posts about our National Home Care Month celebrations are on a dedicated sitewwwnationalhomecaremonthcom We look forward to engaging you for further work in themonths ahead on public relations and legislative connections about your services staff patientsand role in the health care continuum

MOMENTUM from p 1


6

DOH Activates 2017 CHHA amp LTHHCP Statistical Report and 2017 Hospice Cost andUtilization Report The state has activated the 2017 statistical report for Certified Home Health Agencies (CHHAs) and Long TermHome Health Care Programs (LTHHCPs) as well as the 2017 Cost and Utilization Report for Hospices

A Dear Administrator Letter (DAL) announcing the postings to the Health Commerce System (HCS) is availableat httpshca-nysorgwp-contentuploads201812DAL_CHHA-Statistical-Report_2017_112818pdf Each of the reports will be activated and available for completion from December 3 through February 12019 After February 1 2019 these reports will no longer be available on the HCS DOH collects qualitative and quantitative information in these reports to make policy decisions regarding thehome care and hospice industry All CHHAs LTHHCPs and Hospices are required to complete and submit the 2017 reports Failure to submit allrequired information in the appropriate format will subject the agency or provider to an enforcement actionunder Section 12 of the Public Health Law (PHL) resulting in the agency being liable for civil penalties ofviolations of Article 36 (for CHHAs and LTHHCPs) or Article 40 (for Hospice) of the PHL and New York StateMedical Facilities Code Hospice and home care administrators should be aware that the DOHrsquos ability to make an affirmativestatement to your agencyrsquos character and competence will be negatively impacted in the event of anenforcement action for failure to submit Furthermore any pending certificate of need applications will not beprocessed for agencies determined to be delinquent for this submission DOH and HCA encourage home care and hospice providers to enter and submit data as early as possibleProviders that wait until the last week to enter data may encounter extended system delays on the HCS andwait times for support due to limited system and personnel resources Attached to DOHrsquos DAL are instructions for completing and submitting the statistical reports HCA members with questions on the Statistical Reports can e-mail DOH at HCStatRptshealthstatenyus

DOH Provides HCA with Updates on 2017 LHCSA Statistical ReportProcess Status

On November 27 the state Department of Health (DOH) hosted a conference call for HCA and other home care andassisted living associations to discuss the status of the 2017 LHCSA Statistical Report process thus far

This year the Department revamped the 2017 Statistical Report and added a registration component for allLHCSAs as per provisions in the enacted state budget DOH indicated that it intends to post information onthose LHCSAs that have completed the registration process

As of Tuesday approximately 1200 LHCSA Statistical Reports had been filed with about 300 Statistical Reports leftunfiled The Department said it has completed phone calls to approximately half of the non-submitters Their


7

Continued on next page

outreach will continue until all non-responders have been contacted HCA is also in possession of the list ofnon-submitters and has conducted outreach to those organizations to ensure compliance

During the call DOH asked for suggestions from the associations in an effort to make next yearrsquos processmore defined HCA suggested that the state develop a Frequently Asked Questions (FAQs) document that isinclusive of all of the Departmentrsquos clarifications as opposed to multiple FAQ documents being posted atdifferent times

In addition in response to HCArsquos suggestion DOH indicated that next yearrsquos Report will allow for providers tosupply exact rate information in contrast to this year where providers were instructed to round down whenreporting monetary values DOH also agreed to our request that it reconvene the LHCSA Statistical Workgroupso that it could relay any concerns about this yearrsquos Statistical Report and begin conversations about the2018 LHCSA Statistical Report process

HCA also recommended that LHCSAs with multiple branchessites be allowed to submit only one StatisticalReport instead of one report for each site but DOH said it wants one report for each site as the area andpopulation served by each site differs and this information is needed

HCA thanked DOH for its repeated communications to LHCSAs about the need for completion of theStatistical Report and for working with the associations to ensure a high completion rate

The 2017 LHCSA Statistical Report was originally due Friday November 16 but can still be submitted byDecember 31 2018 (and face penalties) For those entities that do not submit the Report the state has theauthority to implement the following penalties

bull $500 if not submitted by November 16 another $500 if not submitted by December 1 and another$500 if not submitted by January 1 2019

bull Any LHCSA that has not submitted the Statistical Report by January 1 which includes the newregistration process will not be able to operate or receive reimbursement from any source

LHCSAs are encouraged to file their Statistical Reports as soon as possible to avoid additional penalties Ifyou are unsure if your agency submitted a Statistical Report or have any questions about the report pleasecontact Andrew Koski at akoskihcanysorg or Alyssa Lovelace at alovelacehcanysorg

LTHHCPs Providers Tapped for Potential CFCO ProgramDOH exploring HCA recommendation to assist MLTCs by tapping waiver providers for CFCO

The state Department of Health (DOH) has circulated a November 28 letter and survey to Long Term HomeHealth Care Program (LTHHCP) providers to gauge their interest and readiness to provide the new CommunityFirst Choice Option (CFCO) as partners to managed care and local social services districts

CFCO is a federal option program that New York State agreed to implement as a waiver service packagesimilar to a portion of those services that had been offered under the LTHHCP Several years ago theDepartment elected to pursue the CFCO option entered into an agreement with the federal government toprovide it and has been exploring approaches to implement it


8

To date DOHrsquos approach on CFCO has sought to directly infuse it into the managed long term care (MLTC)and mainstream managed care Organization (MCO) benefit package cost structure and operatingprocedures

As concerns have mounted about this approach HCA has sought to recommend an alternative route thatwould enable the state and managed care plans to tap existing resources relieve MLTCsMCOs of what hasotherwise been a bewildering and incompatible mandate and help fulfill goals of the program

Serving on the CFCOMLTCMCO steering committee HCA President Al Cardillo offered a proposal nowconceptually embraced by DOH whereby plans could opt to deliver services under consolidated ldquoCFCOprovidersrdquo Under this concept providers would put the CFCO package together and act as a consolidatedcontracted partner to MLTCs and MCOs to provide them This would be distinct from the current modelwhich has sought to mandate that the MLTCs and MCOs directly locate broker negotiate and arrange foreach discrete CFCO service in addition to the MLTCMCO standard benefit package MLTCs have repeatedlyvoiced their extensive concerns about nearly every element of the DOH model HCA has echoed thoseconcerns and received affirmation from member MLTCs to put our new concept on the table

HCA encourages LTHHCPs to consider the possibilities outlined in the DOH letter for your agency MLTCMCO partners patients and community The letter and survey are on the Health Commerce System

For further information contact Al Cardillo at acardillohcanysorg

HCA Welcomes New Program and Research Director Lauren Ford

By HCA President Al Cardillo

On behalf of the entire association Irsquom thrilled to welcome Lauren Ford in the new HCA position of Directorof Program Research Development and Policy Lauren joins us today December 3

Lauren will be spearheading this new critical HCA function elevating the incorporation of data evidence-based research and program outcomes in support of advocacy member service education programdevelopment and policy She will also be working directly to lead andor co-lead an array of HCA programareas

Lauren brings outstanding personal professional and leadership qualities and experience to HCA Shecomes to HCA from her most recent position managing carecoordination functions for a regional comprehensive clinicalmanagement program She previously spent seven years workingwith HCA member Living Resources Corporation where she mostrecently served as the Assistant Director of ResidentialServices She has a Master of Social Work (MSW) degree from theUniversity at Albany where she was the honored recipient of theStephanie Wacholder Endowed Scholarship and the FrankFilippone Hillside Scholarship in 2017 and 2018

We look forward to the critical enhancement she will add to HCAand the membership in this new role You can connect with her directly at lfordhcanysorg


9

Free Members-Only Webinar on DOLrsquos Revised ldquoCall-in Payrdquo Regulations Dec 18

As reported in an alert last week the state Department of Labor (DOL) will be revising its proposedemployee scheduling (call-in pay) regulations on December 12 2018 at which time the 30-day commentperiod begins At the close of the comment period DOL will evaluate the submitted comments and pursuenext steps HCA is holding a members-only webinar on December 18 from 11 am to noon outlining the newlyproposed rules following their posting HCA expects multiple changes in the upcoming December versionof the proposed rule and this webinar will compare and contrast those updates or changes with thecurrent proposal already posted by DOL

You must register in advance by completing the online form at httpswwwsurveymonkeycomrcallinpaywebinar HCA will send you the webinar information in advance of December 18

More background

This upcoming revision to the proposed rule will follow the initial round of comments and testimonyprovided by HCA and others in response to the first iteration of the proposed regulations that DOLreleased on November 22 2017 As HCA informed members through numerous programs the current iteration of the proposed rule wouldrequire employers to pay their employees for a certain number of additional hours if shifts were notscheduled 14 days in advance shifts were canceled within 72 hours of the scheduled start timeemployees were required to be available to report to work and more Donrsquot miss this members-only opportunity to learn how the upcoming December 12 proposed rule willaffect home care providers The program will be presented by Benjamin Wilkinson Principal at HinmanStraub HCArsquos contracted government affairs firm About the Presenter Benjamin Wilkinson joined Hinman Straub in January of 2016 Mr Wilkinson represents clients inaddressing issues that arise in and out of the workplace and in litigation matters Prior to joining HinmanStraub Mr Wilkinson was a litigation associate at a downstate law firm concentrating on employmentlaw creditorsrsquo rights and collection and general civil litigation in state and federal courts He has represented clients in administrative matters before the Equal Employment OpportunityCommission (EEOC) and NYS Division of Human Rights (NYSDHR) and federal and state courts regardingclaims of alleged unlawful employment actions In addition Mr Wilkinson has litigated a variety of civilmatters including personal injury premise liability foreclosure and commercial litigation


10

HCA Tapped for National State Home Care Forum Executive Committee

HCA President Al Cardillo has been asked to serve as a member of the Executive Committee of the NationalForum of State Home Care Associations

The Forum is comprised of the Executives of all state home care associations across the country andoperates in conjunction with the National Association for Home Care and Hospice (NAHC)

With the pressing federal challenges and opportunities to the field HCArsquos close work with the Forumprovides a critical voice in this national arena It also opens further channels for insight back into ourmembership and our statersquos home care and hospice system from the experiences and expertise of peerassociations and fellow Executive Committee members

ldquoWith so much at stake and so much for home care that needs to be paved at the federal levelrdquo Mr Cardillosaid that he is ldquoprivileged and eager to accept this role on behalf of HCA and New Yorkrdquo

Jane Kelly is the Chair of this National Forum She is also Executive Director of the Kansas Home Care andHospice Association and a member of the NAHC Board of Directors

CMS Provides Hospice Updates

The US Centers for Medicare and Medicaid Services (CMS) has issued the following hospice updates

Hospice Item Set (HIS) and CAHPS Provider Preview Reports Available on December 1

CMS reminds providers that HIS and Consumer Assessment of Healthcare Providers and Systems (CAHPS)Provider Preview Reports were available on December 1 2018 Providers will have 30 days (December 12018 through January 2 2019) to review their data Requests for CMS review of HIS or CAHPS data must besubmitted by 1159 pm PST on day 30 (January 2 2019) of the preview period

CAHPS Hospice Survey State Scores Available

The CAHPS Hospice Survey State Score document for the upcoming public reporting period (first quarter of2016 through the fourth quarter of 2017) is available on the CMS CAHPS Survey website at httpswwwhospicecahpssurveyorgenscoring-and-analysis

Registration Open for 1213 Webinar on Updates to Public Reporting in Fiscal Year 2019 HospiceComprehensive Assessment Measure and Data Correction Deadlines

CMS will host its next training event on December 13 2018 from 1 to 230 pm This two-part webinar willcover two different topics Part one will focus on the ldquoComprehensive Assessment at Admissionrdquo compositeprocess measure (National Quality Forum No 3235) including the background of this measure how thismeasure is calculated and how providers can use their Certification and Survey Provider Enhanced ReportingQuality Measure Reports (CASPER QM Reports) to understand their performance on this measure Part twoof the training will review the 45-month data correction deadline for public reporting policy that wasfinalized in the fiscal year 2019 final payment rule (83 FR 38622 see pages 38638-38640) including how thisnew policy change will be implemented and its implications (Register at httpsengageveventcomindexjspeid=3536ampseid=1296)

11


Recovery Audit Contractor (RAC) Issues Pertaining to Hospice The US Centers for Medicare and Medicaid Services (CMS) recently posted the following Recovery AuditContractor (RAC) issues pertaining to hospices and the patients they serve

Physician Services During Hospice Period

Durable Medical Equipment (DME) While in Hospice and

Outpatient Hospice-Related Services CMSrsquos RAC Contractor is Performant Its RAC webpage shows all active issues and further information aboutthe RAC audits (See httpsperformantraccomaudit-regionsregion-5page4order=ascampampfilter=provider_type) Each of the three issues above looks at non-hospice providers and whether the reason for the service isrelated to the hospice diagnosis Under the Medicare Hospice Benefit services related to a hospice terminaldiagnosis provided during a hospice period are included in the hospice payment and are not paid separately Even though hospice providers are not directly part of these approved RAC issues these areas affect therelationships with possible partner entities and it is possible that a RAC audit could result in a non-hospiceprovider questioning a hospice as to whether it is paying for all of the services it should be paying for underthe Medicare Hospice Benefit or even to ask the hospice for money that the provider has to pay back as partof the RAC audit findings

OMIG Posts Webinar on Updates to the 2018 Compliance Certification Process

Last week the state Office of the Medicaid Inspector General (OMIG) posted a webinar entitled OMIGrsquosCertification Process which provides updates to the Social Services Law Section 363-d and 18 NYCRR Part521 compliance program certification form (SSL Certification) as well as tips for completing the 2018 form

This webinar can be accessed at httpsomignygovinformationwebinars

The updated state Certification form and Frequently Asked Questions document are available athttpsomignygovssl-certification

State law requires that health care providers certify annually (in December) that they have adoptedimplemented and maintain an effective compliance program that meets eight elements These elementsare reviewed at httpsomignygovimagesstoriescompliancecompliance_program_review_guidancepdfand httpsomignygovimagesstoriescompliancecompliance_program_self_assessment_form_021215doc

As referenced in OMIGrsquos 2018-2019 Work Plan providers (who are already enrolled in Medicaid) subject tothe mandatory compliance program obligation are required to complete an annual certification using theirProvider Identification Numbers (Provider IDs) rather than their Federal Employer Identification Numbers(FEINs) Agencies without Provider IDs will be advised to use their FEIN



12

OMIG recommends that providers test the operation of their compliance program now and make anyadjustments necessary so that the Medicaid provider is prepared to certify compliance with the staterequirements

Applicable providers that fail to certify in December (or fail to adopt implement and maintain a requiredcompliance program) may be considered to have engaged in an unacceptable practice under the Medicaidprogram and may be subject to potential administrative actions

Federal Compliance Requirement

In addition entities that receive at least $5 million in Medicaid payments during a federal fiscal year mustsubmit a certification form showing compliance with the federal Deficit Reduction Act (DRA) of 2005 (Theamounts an individual or organization may receive through its contract with a Medicaid managed careorganization should not be counted when calculating the $5 million in payments)

By law such entities must have written policies and procedures informing their employees contractors andagents about federal and state false claim acts and whistleblower protections

More information on the DRA certification is at httpsomignygovimagesstoriesprovider_compliancedra_faqspdf

Any questions can be directed to OMIGrsquos Bureau of Compliance at (518) 408-0401or complianceomignygov

HCA Attends Capital District North Country HEPC Meeting in Saranac LakeEmergency Preparedness Toolkit Available Online

Last Monday HCArsquos Public Policy Director Alyssa Lovelace attended the second quarter Capital DistrictNorth County Health Emergency Preparedness Coalition (HEPC) meeting with representatives from the stateDepartment of Health Office of Emergency Preparedness (OHEP) local and state emergency preparednessofficials and coordinators as well as other health and home care industry stakeholders

The meeting began with a briefing on the statersquos recent hospital HEPC Coalition Surge Test (CST) During thebriefing Pat Anders of OHEP discussed the outcomes and importance of the exercises Throughout thediscussion participants suggested additional stakeholder and community involvement in order to bettermeet the statersquos deliverables and to ensure compliance with emergency preparedness requirements acrosshealth care sectors Providers can anticipate another CST in the first quarter of 2019

For this upcoming CST agency contacts in the Health Commerce System (HCS) will receive the drillapproximately 90 minutes prior to the drill being activated and they will have 60 to 90 minutes to completethe exercise HCA will alert members once drills have been activated

Later in the meeting Carol Killian of OHEP provided an overview of emPOWER data supplied by the USDepartment of Health and Human Services (HHS) The HHS emPOWER Map 30 provides statistics related toelectricity-dependent Medicare individuals in each state territory county and ZIP code HEPC meetingparticipants discussed how this data could be used in determining how to best meet the needs of electricity-


13

dependent Medicare and non-Medicare beneficiaries residing in the community who would need assistanceduring an emergency

Throughout the meeting HCA discussed the importance of emergency preparedness strategies as it relatesto individuals utilizing home care and hospice services HCA in conjunction with the New York StateAssociation of Health Care Providers (HCP) and OHEP recently developed an Emergency PreparednessToolkit which was released earlier this fall We stressed that the toolkit could be used by home healthagencies individuals and their families when preparing for an emergency The toolkit is available athttpsissuucomhcanysdocsemergency_preparedness_toolkite=0

Upcoming HEPC Meetings

HCA encourages representatives from home care hospice and managed care organizations to participate intheir regional HEPC meetings

For a full list of HEPC meetings in your area see httpswwwurmcrochestereduemergency-preparednesscalendarnys-hepc-master-calendaraspx

Below is a list of upcoming HEPC meetings

HCA and HCP work together under a grant from DOH OHEP with all home care and hospice providers tosupport their roles in emergency preparedness including participating in HEPC meetings across the state


HEPC Meeting Date

Lower Hudson Valley December 5 2018

Long Island December 6 2018

Finger Lakes Region

Finger Lakes Northern Area January 7 2019

Finger Lakes Eastern Area February 11 2019

Finger Lakes Southern Area February 25 2019

Western Region (WR)

WNY Northern Area January 14 2019

WR HEPC January 21 2019

WNY Southern Area February 1 2019

WNY Urban Area February 8 2019


WNY Eastern Area February 15 2019

Central New York (CNY) Region HEPC Meetings

CNY Eastern Region December 3 2018

CNY Northern Region December 4 2018

CNY Western Region December 5 2018

CNY Southern Region December 6 2018

CNY Regional February 20 2019


14


Is Your Agencyrsquos Contact Information Updated in the Health Commerce System

As a reminder home care and hospice providers are required by law to keep their HCS contact information up-to-date The Department of Health frequently populates the HCS with time-sensitive information related toemergency preparedness drills and exercises as well as real-time information related to storm emergenciesand other provider-specific information To learn more about these requirements please review theDepartmentrsquos HCS Dear Administrator Letter at httpshca-nysorgwp-contentuploads201806DAL_HCS_Requirements_020316pdf

December Aware Prepare Now Available In other emergency preparedness news the December 2018 issue of the statersquos Aware Prepare update is nowavailable online The Update contains upcoming preparedness trainings such as webcasts webinars and in-person trainings as well as archived exercises and on-demand e-learning You can access this monthrsquos AwarePrepare update at httpshca-nysorgwp-contentuploads2018122018_December_APpdf

LawTalk Reasonable Compensation for Executives in Not-for-profit CorporationsBy Frank Fanshawe Principal and Ashley Solowan Law Graduate Jackson Lewis PC

Many organizations are familiar with New York Statersquos Executive Order No 38 regulations which generallylimit the amount of compensation an organization can pay its executives if the organization derives a certainamount of its funds directly or indirectly from the state (See httpsexecutiveorder38nygov) There hasbeen much focus on the state regulations including high profile litigation and appeals going all the way up tothe New York Court of Appeals But it is important to remember that federal laws and regulations also governhow tax-exempt organizations are permitted to compensate their executives

Tax-exempt organizations such as some home health agencies MLTCs and hospices are limited by federallaw and regulations in the amount of compensation they can pay their executives (eg individuals who runcontrol the organization) Tax-exempt organizations are allowed to pay executives ldquoreasonable and fairrdquocompensation for their work although there is no definitive way to measure this

However the Internal Revenue Service (IRS) has outlined three requirements that if met would create atleast a rebuttable presumption of ldquoreasonable and fairrdquo compensation in other words the compensationwould be assumed ldquoreasonable and fairrdquo under these three conditions unless evidence is presented by theIRS to prove otherwise These three requirements are

1 The compensation arrangement must be approved as reasonable and fair in advance by an authorizedbody of the applicable tax-exempt organization which is composed of individuals who do not have aconflict of interest concerning the transaction

2 Prior to making its determination the authorized body obtained and relied upon appropriatecomparability data that demonstrates the compensation is reasonable and fair and

3 The authorized body adequately and timely documented the basis for its determination concurrentlywith making that determination


15


The IRS has further detailed what the authorized body should include in its documentation when authorizingan executive compensation arrangement The authorized body should include the terms of the transactionthe date of its approval the members of the authorized body present during the debate the vote on thetransaction the comparability data obtained and relied upon any conflicts of interest of the authorized bodyand documentation of the basis for the determination Appropriate documentation of these issues is animportant step toward meeting the rebuttable presumption

Complying with the IRS requirements avails the tax-exempt organization of the rebuttable presumption ndash thatthe executive compensation is reasonable and fair The IRS may only refute the presumption ofreasonableness if it develops sufficient contrary evidence to rebut the value of the data relied upon by theauthorized body

If a tax-exempt organization does not qualify for the rebuttable presumption it still has the ability to provethat the executive compensation was fair and reasonable However the burden shifts to the tax-exemptorganization to prove this The IRS will review the compensation on a facts and circumstances analysis andmay issue sanctions if the compensation is found to be excessive

Before a tax-exempt organization approves an executive compensation arrangement it should make sure thearrangement can withstand scrutiny by the IRS Qualifying for the rebuttable presumption is an importantstep in protecting your organization in the event of an IRS challenge

LawTalk is a series of monthly articles written by attorneys at Jackson Lewis the firm for HCArsquos counselPlease note that HCA LawTalk articles are for general informational purposes are not legal ldquoadvicerdquo and donot create an attorney-client relationship Because each case is unique the information provided should beconsidered to be general in nature and should never be considered a substitution for legal counsel Readersshould not take or refrain from taking any action based on information in this article without first seekinglegal advice from competent counsel

PHHPC Establishment and Project Review Committee Meets

The Public Health and Health Planning Council (PHHPC) Establishment and Project Review Committee met onNovember 29 and took action on a series of applications which will now go to the full PHHPC forconsideration at its December 13 meeting

The applications include

One Certified Home Health Agency (CHHA) to merge with another CHHA

One CHHA for a 3-year extension to its limited life operating certification

One CHHA to establish one entity as its parent and another entity as its grandparent

One hospice to merge with another hospice

One Licensed Home Care Services Agency (LHCSA) for a change in ownership (under moratoriumexception for applications that address a serious concern such as lack of access to home careservices in a geographic area or special needs services)



16


Two entities to become LHCSAs affiliated with an Assisted Living Program (ALP) and

One LHCSA affiliated with an ALP for a change in ownership

The agenda and supporting documents are at httpswwwhealthnygovfacilitiespublic_health_and_health_planning_councilmeetings2018-11-29

All meetings of the PHHPC and its committees can be viewed via webcast athttpswwwhealthnygoveventswebcasts

Upcoming Deadlines and Due Dates

RequirementChangeEffective

Due DateMore Information

Transition Period for Using

Health Insurance Claim Number

(HICN) or new Medicare

Beneficiary Identifier (MBI)

April 1 2018 to

December 31

2019

httpswwwcmsgovMedicareNew Medicare Cardindexhtml

Medicare Open Enrollment

Beneficiaries can change their

Medicare coverage from

managed care plan to fee for

service or vice versa and can

join or switch prescription drug

plan

October 15 to

December 7 2018wwwmedicaregov

2017 LHCSA Statistical Report

Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018

httpscommercehealthstatenyuspublichcs_loginhtml

LHCSA Registration Process

Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines


MLTC Enrollment Lock In Starts December 1 2018httpswwwhealthnygovhealth_caremedicaidprogramupdate201

82018 06htmmltc

OASIS D for Certified Home

Health AgenciesJanuary 1 2019

OASIS D Guidance Manual

httpswwwcmsgovMedicareQuality Initiatives Patient Assessment

InstrumentsHomeHealthQualityInitsHHQIOASISUserManualhtml


17


Workersrsquo Compensation Appeal Forms Revised

The Workersrsquo Compensation Board has revised certain appeal forms

These include the Application for Board Review (Form RB-89) Rebuttal of Application for Board Review(Form RB-891) Application for ReconsiderationFull Board Review (Form RB-892) and Rebuttal ofApplication for ReconsiderationFull Board Review (Form RB-893) to add clarifying information to theinstructions

The Board has also prepared a Guidance Document on the Proper Application of Board Rule 30013 (httpwwwwcbnygovcontentmainforms30013_Guidancepdf) The document sets forth the existing rulesand the correct completion of Items 11 through 15 on Form RB-89 and Items 13 through 15 on Form RB-892 A companion document titled Supplement Decisional Examples (httpwwwwcbnygovcontentmainformsSupplement_Decisional_Examplespdf) provides examples item by item as to how theserules are applied

The Board will continue to accept the prior version of the form (01-18) until February 1 2019 After thatdate any prior version of the application form will be subject to a denial of review

More information is at httpwwwwcbnygovcontentmainSubjectNossn046_1119jsp

OPWDD Releases FAQs on Managed Care

The state Office for People With Developmental Disabilities (OPWDD) has released Frequently AskedQuestions (FAQs) about the transition to managed care

The FAQs are at httpshca-nysorgwp-contentuploads201811Frequently-Asked-Questionspdf

Some highlights include

In January 2019 ldquoearly adoptersrdquo will begin providing managed care of only medical andbehavioral health needs for people with developmental disabilities Early adopters are provider-ledmanaged care plans that provide non-OPWDD long term support services today and are now goingthrough the application process to become a certified mainstream managed care plan

In August 2019 voluntary managed care for all services including those funded by OPWDD willbegin to be offered in areas of the state where early adopters are approved to coordinate care

Beginning in 2021 everyone receiving OPWDD services will need to choose a managed careorganization to manage their supports

Individuals will choose a Managed Care Organization and Care Coordination Organization (CCO)CCOs are entities formed by OPWDD providers paid to provide care management for individualsrsquo

18


developmental disability medical and behavioral health needs based on their Life Plan ManagedCare Organizations work with CCOs to arrange services through their network of providers

One of the reasons that OPWDD is utilizing CCOs is to comply with federal requirements that thecoordination of a personrsquos supports be ldquoconflict freerdquo or separate from the direct provision of

services

More information on managed care for individuals in the OPWDD system is athttpsopwddnygovopwdd_services_supportsmanaged_care

Health Resources

ldquoTargeted Probe and Educate (Transmittal 2207)rdquo by the US Centers for Medicare and Medicaid

ServiceshttpswwwcmsgovRegulations-and-GuidanceGuidanceTransmittals2018-Transmittals-ItemsR2207OTNhtmlDLPage=1ampDLEntries=10ampDLSort=1ampDLSortDir=descending

For more information contact Andrew Koski at akoskihcanysorg or (518) 810-0662

2

The Situation Report is a weeklypublication of the Home CareAssociation of New York State(HCA) Unless otherwise notedall articles appearing in TheSituation Report are the propertyof the Home Care Associationof New York State Reuse of anycontent within this newsletterrequires permission from HCA

Al CardilloPresident and CEO

acardillohcanysorg

Roger L NoyesDirector of CommunicationsEditor of The Situation Report

rnoyeshcanysorg

Patrick ConoleVice President

Finance amp Managementpconolehcanysorg

Andrew KoskiVice President

Program Policy amp Servicesakoskihcanysorg

Alyssa LovelaceDirector for Policy and Advocacy

alovelacehcanysorg

Lauren FordDirector of Program Research

Development and Policy

lfordhcanysorg

Laura Constable Senior Director

Membership amp Operationslconstablehcanysorg

Celisia StreetDirector of Education

cstreethcanysorg

Mercedes Teague Finance Manager

mteaguehcanysorg

Jenny KerbeinDirector of Governance amp

Graphic Designjkerbeinhcanysorg

Billi Wilson Manager Meetings amp Events

bwilsonhcanysorg

Teresa BrownAdministrative Assistant

tbrownhcanysorg

Home Care Association of New York State (HCA)388 Broadway 4th Floor Albany NY 12207

Tele 518-426-8764 Fax 518-426-8788 Website wwwhcanysorg


PDGM from p 1

The meetings were led by HCA Vice President for Finance andManagement Patrick Conole and our federal lobbyist Brett Heimovof Envision Strategies They coincided with a national push on thisseries of bills from the National Association for Home Care andHospice (NAHC) the Council of State Home Care Associations thePartnership for Quality Home Healthcare and other stateassociations

HCA has summarized the bills for you previously Please see ourbriefing paper which was shared with all of the Delegation officesoutlining HCArsquos arguments and the rationale for the bills herehttpshca-nysorgwp-contentuploads201811Co-Sponsor-and-Pass-Bipartisan-Bills-to-Protect-Medicare-Home-Health-Reimbursementpdf

Under PDGM the US Centers for Medicare and Medicaid Services(CMS) is assuming that providers will change their behavior(through coding and other means) as a way of receiving higherpayments than are otherwise intended by the new PDGM paymentmethodology set to go into effect in 2020

This cut is called a ldquobehavioral adjustmentrdquo It would be levied atthe onset of PDGM and it is built on the assumption that providerswill change their behavior in the future rather than CMS basingpayment adjustments on observed empirical evidence This cutaffects providers regardless of whether they are expected tomaintain or exceed their current financial performance under PDGMas compared to the present Home Health Prospective PaymentSystem (HHPPS)

The three bills under consideration (HR 6932 S3545 and S3458)would require CMS to institute rate adjustments based on observedevidence not conjecture They would also limit rate adjustments tono greater than 2 percent per year (Under the proposed rule forPDGM CMS called for a ldquobehavioral assumptionrdquo rate cut of 642percent though the final rule does not specify a number)

Why Now

With the midterm elections settled Congress is finishing up onend-of-year priorities before a new Congress commences in January(also known as the ldquolame duckrdquo session) At this time the prioritiesfor advocacy need to be focused on those items that could possibly

3





Who We Met With







We require



An EOE mfdv



4

SURVEY from p 1











5









MOMENTUM from p 1


6








7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources




3





Who We Met With







We require



An EOE mfdv



4

SURVEY from p 1











5









MOMENTUM from p 1


6








7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





4

SURVEY from p 1











5









MOMENTUM from p 1


6








7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





5









MOMENTUM from p 1


6








7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





6








7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





7















8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





8













9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





9




More background



10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





10















11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources




11














12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





12














13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





13









HEPC Meeting Date



Finger Lakes Region




Western Region (WR)














14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources





14













15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources




15

















16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources




16













April 1 2018 to

December 31

2019








plan

October 15 to



Due

LHCSAs will face

fines if submitted

between

November 16

2018 and

December 31

2018



Must be

submitted with

LHCSA Statistical

Report if not

submitted by

November 16

2018 agency will

incur fines



82018 06htmmltc







17
















18




services


Health Resources




17
















18




services


Health Resources




18




services


Health Resources




hca presses pdgm legislative fix with seven key congressional … · free webinar dec. 6 two-part...

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