Summary of Buffalo Waiver Hearing


Buffalo Medicaid Waiver Hearing April 28, 2014—

SUMMARY:



The Medicaid Waiver program was reviewed as a transformative reimbursement methodology for all healthcare providers, to tie payments to performance on specific metrics, targeting specifically a 25 percent decrease in unnecessary hospitalizations and combining large numbers of healthcare and health-related and community service providers together in Performing Provider Systems (PPSs).



Waiver money will be set aside to help fill the gap between fee-for-service and outpatient and results-based Medicaid payments.



The Waiver programs’ PPSs are being viewed by state Medicaid Director Jason Helgerson as a permanent structure for receiving future Medicaid payments and potentially also private payer and Medicare payments. The program will stay focused on CMS’ Triple Aim with the theme of collaboration among varying types of healthcare provider organizations.



The state’s $8 billion Medicaid Waiver program has three distinct parts:

  • The $500 million Interim Access Assurance Fund to help stabilize critical health service providers (of this, $250 million will be dedicated to large public hospitals, and $250 million to non-public/safety net  hospitals in ‘severe financial distress’ who meet state safety net definitions – see presentation slides and website for details); 
  • the $6.42 billion Delivery System Reform Incentive Payment Program/DSRIP; and 
  • $1.08 billion for health home, Long-Term Care, workforce and behavioral health redesign programs.

Regulatory relief will also be a key part of this program, to support collaboration.  State agencies such as OMRDD, OASAS and DOH, will have the ability to waiver regulations as long as they smooth service delivery, and achieve the program’s goals without sacrificing patient safety, etc.



Application processes and scoring for the DSRIP program were discussed at some length, along with deadlines for applications:



Comments on the DSRIP and Interim Access Assurance Fund will be taken through April 29, at: 1115waivers@health.state.ny.us



The Medicaid Waiver presentation given April 28 by Mr. Helgerson can be found at:





More detail on the comment and application processes can be found on the state Health Department’s Waiver page, at: 
http://www.health.ny.gov/health_care/medicaid/redesign/medicaid_waiver_1115.htm


And the DSRIP web page:


May 15, 2014: Non-binding Letters of Intent (LOIs) regarding plans to participate in the DSRIP program will due to the state Health Department.

Mid-June: Planning Grant applications will be available from the state Health Department and will be due approximately 30 days from their issue (mid-July). The application and a pre-scoring tool will be available online at the DOH’s website, along with a sample ‘model application’ with sample scoring.

December 2014:  Final, formal PPS/DSRIP applications due.



Terms and conditions related to the Federal-State Health Reform Partnership Medicaid Section 1115 Demonstration can be found here:


Page 25 of the web document relates to pertinent Medicaid delivery systems/ care providers.



Regarding the separate, Medicaid Partnership Plan Extension program, Partnership Plan information can also be found on the state Health Department’s website, at this address:




Partnership Plan Special Terms and Conditions can be found here:


http://www.health.ny.gov/health_care/managed_care/appextension/partnership_plan/docs/special_terms_and_conditions.pdf



BUFFALO MEDICAID WAIVER HEARING SUMMARY, CONTINUED:



During the presentation, the scoring mechanism and timelines for the project were discussed. Likely the exact same or similar information given at each of these hearings.



50 SYSTEMS STATEWIDE AN ‘IDEAL’ NUMBER

At the Buffalo hearing, Dr. Gregory Young asked how many “Performing Provider Systems/Networks” are being considered an ideal number by DOH and Helgerson said 50. After the presentation Helgerson elaborated to say he would not like to see quite as many as 50 provider networks (Performing Provider Systems, or PPS’) in the New York City/Long Island area and would not like as many as 25 networks upstate. He is hoping that the Finger Lakes area might have just one network on its application, but allowed that it’s unlikely Western New York would have just one network/system.



STATE OPEN TO DISCUSSION ON SOUTHERN TIER & RURAL CHALLENGES

The challenges of the rural areas in the Southern Tier were discussed in questions and answers. Performance matrix scoring would be terribly skewed in areas with small numbers of Medicaid patients and could have a seesaw effect on payments for smaller rural providers. When confronted with the cross-border issues affecting some of our member hospitals, he suggested that there is no prohibition against an application including a Pennsylvania or Ohio provider — there is no requirement that the provider be New York State-based, only that the patients addressed be NYS residents. Therefore it is likely some out-of-state data will need to be collected if Medicaid patients travel across state lines for care. Mr. Helgerson is open to discussion on the difficulties of including rural hospital providers and rural providers in general in the DSRIP portion of the Waiver.



WNYHA ROLE IDENTIFIED

He also said he is open to including the WNY Healthcare Association as an information source for putting together hospitals with other providers. This will have to happen soon, as the Letter of Intent is due in May and the initial planning applications are due in mid-June. The applications will be returned with comments by July with formal, final applications due in December 2014. Names and numbers of providers included in each application can be changed up until the final application, but the sooner the list of applicants is finalized, the better, as DOH offered to preliminarily score such applications before December.



Another potential role for the Association is in convening groups of providers much as the NYS Partnership for Patients does now, to address specific approaches to identified issues being addressed successfully in one area, i.e. hospital admissions for asthmatics.



COMMENTS WELCOME ON POTENTIAL DUPLICATE REPORTING MECHANISMS WITH PARTNERSHIP FOR PATIENTS/OTHER MEASURES FOR HOSPITAL PERFORMANCE

Helgerson was also open to discussion about duplicative reporting for providers and said quite pointedly that he would ‘welcome comments’ to that effect — it was noted that the reporting mechanism for this program is nearly identical to that for the NYS Partnership for Patients and measures many of the same items, but could create a double burden for providers participating in both programs.



Comments will be accepted through  April 29th for the DSRIP  and Safety Net programs, and through May 2nd for the Program Plan Extension.

——

Regarding specific questions and answers:



The many non-profits presented themselves as potential partners alongside asking their questions.

·         INSURERS NOT EXPECTED AS LEAD APPLICANTS



·         RURAL PROVIDERS SHOULD APPLY UNDER EXCEPTION CLAUSES IF APPROPRIATE



·         TOTAL PATIENT POPULATION METRICS WILL BE CONSIDERED VS. MEDICAID-ONLY, FOR SOME PROGRAMS

Q-Lisa Damiani asked whether the state was looking at Medicaid only or total population metrics for results.

A-Helgerson answered that for Domains two and three, Medicaid and Dual eligible will be looked at solely.  For Domain 4, Population Health will be considered, across the spectrum and reiterated that integrating non-qualifying providers is KEY to community outreach and population health portions of DSRIP/ the Waiver.



·         AGING OF DATA QUESTIONED BY CHS

Q-Rachel Neiss (sp-?) of Catholic Health asked about the scoring of DSRIP applications, questioning the rationale of a base set of data remaining as a static metric against which an entire five-year program will be measured, meaning the data will be quite old by the final year.

A-Helgerson acknowledged the validity of the question but reemphasized the importance of a good application and restated that applicants’ performance-based payments will be adjusted in accordance with their fluctuating performance throughout the five years, so that if they perform exceptionally well there is a possibility that they will earn a higher payment rate.





·         REQUEST MADE FOR STATEWIDE INFORMATION-SHARING DATABASE

Q-Ruth Spink of the Genesee County Office for Aging asked a question about Information sharing and the potential use of a uniform assessment tool for population-based data, and asked if some portion of the Statewide Database which her organization worked with DOH on in an RFP, could be made accessible to all providers.

A-Helgerson said DOH expects many participants will already be in RHIOs so they potentially have access to patient-level data through that route, Ms. Spink said she was thinking about a portal for providers and a Medicaid Date Warehouse.

Helgerson said it’s possible that the state will help to reinforce the Statewide Health Information Network/SHINY




·         ONE OR TWO APPLICATIONS PER GEOGRAPHIC AREA MEANS ONE OR TWO PER LARGE COUNTY OR ONE PER TWO OR THREE SMALLER-POPULATION COUNTIES, HELGERSON SAID

Q-Bruce Nisbet of Health Home Partners of WNY, and one of the heads of the local SNAPCAP, asked Helgerson for more guidance on how many DSRIP applications would be looked at per area, referring to Helgerson’s comment earlier that there would be one or two applications accepted per geographic area. Helgerson answered that he foresaw, one provider group, per county, and would hope for some multi-county applications, so one application per two or three counties.

A-He referred to the Finger Lakes HSA and the hope that it would be possible to ‘keep the number of applications down’ and to keep our region’s number of applications ‘very manageable’.



·         NEWLY CREATED PROVIDER ENTITIES MIGHT BE CONSIDERED DESPITE ABSENCE OF HISTORICAL DATA



·         ICR DATA OPEN FOR APPEALS PROCESS, HELGERSON SAID

Helgerson added that Safety Net Institutional Cost Report Data upon which determinations are based will also be open to an appeals process for individual institutions.

He also added that the fewer metrics or projects taken on by an individual Patient Provider group on a DSRIP, the more likely success could be.



·         LONG-TERM CARE WORKFORCE NEEDS SHOULD BE ADDRESSED

A-It’s important to include Long-Term Care in a Performing Provider System/network for a DSRIP application, Helgerson said. He pointed out that workforce retraining is a part of the Medicaid Waiver program, and that every application needs to have a workforce strategy.



·         PATIENT ATTRIBUTION WILL BE COMPLEX, SEPARATE WEBINAR PROGRAM PLANNED BY DOH

**Because of the complexity of the issue of patient attribution, DOH will hold a separate webinar on that issue, alone: patient attribution, Helgerson said.



·         RURAL PROVIDERS SHOULD INCLUDE THEIR TERTIARY PROVIDERS IN APPLICATIONS, HELGERSON SAID

Q-Gail Speedy of SNAPCAP/STHCS, who has a rural FQHC, asked about standards for rural PPS’s given the small numbers.

A-Helgerson replied that if a provider is too small, it will be difficult to prove success on specific metrics and these little variations based on small numbers of patients will impact a provider system’s payments significantly under the system set up by the state.  He added that rural providers should consider having tertiary centers included in their Performing Provider System/network and included as part of the DSRIP discussion.  He added that this complex issue may merit more discussion regarding rural providers.



·         HOSPITAL ASSOCIATIONS SOUGHT AS PART OF INFORMATION SHARING NETWORK FOR THIS PROCESS



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