Rehab Committee Meeting September 17, 2018 Melissa Dehoff - - PowerPoint PPT Presentation
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Rehab Committee Meeting September 17, 2018 Melissa Dehoff Director, Medical Rehabilitation Services Division mdehoff@paproviders.org Michael Lane Director, Medicaid Policy and
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Rehab Committee Meeting September 17, 2018 Melissa Dehoff Director, Medical Rehabilitation Services Division mdehoff@paproviders.org Michael Lane Director, Medicaid Policy and Finance mlane@Wojdak.com
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
SLIDES FROM – A member-only educational webinar offered by
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Today we will cover:
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Pennsylvania’s Medicaid Program – The Department of Human Services
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
What is a provider assessment?
A provider assessment – also called a tax - is a state law that authorizes collecting revenue from specified categories of providers. In most states, it is used as a mechanism to generate new state funds and match them with federal funds so that the state obtains additional federal Medicaid dollars. Ideally, much of the cost of the tax is paid back to providers through an increase in the Medicaid reimbursement rates for their patient treatment and services, although federal regulations prohibit a dollar-for-dollar return to hospitals
their assessment payment.
reimbursement
generate federal dollars
to stave off Medicaid cuts
tests/rules that must be met for approval THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
State Reliance on Provider Assessments
become reliant on assessments
assessment
always looking to close perceived loopholes
some form of a provider assessment
to approve an assessment
provider assessment
have targeted the reduction of using provider assessment dollars
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Pennsylvania’s Reliance on Provider Assessments
In Pennsylvania there are four main assessments that generate significant money to the state.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
There are limits on Medicaid spending:
Additionally there are limitations in the managed care “rate-range” and new federal regulations governing rate-setting and “pass-through” payments. There is also a maximum tax rate – currently 6% of net patient revenue
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
FFS UPL
DSH Allotment Hospital-Specific UPL
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Quality Care Assessment – basic structure
taxed?
taxed?
Rehabilitation hospitals
LTCHs, Out of State hospitals, Cancer hospitals
CAHs, Rehabilitation hospitals, Out of State hospitals
Some hospitals are not taxed but receive payments from the QCA
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Quality Care Assessment – Freestanding Rehabilitation Hospitals
receive?
statistical tests
benefit as a class
Some hold a position of largely break-even status with help from an outside HAP-run program Freestanding rehabilitation hospitals pay $15.1 million in tax and receive $23.6 million in payments A small $8.5 million net benefit to the entire rehab industry.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
and MCO
Inpatient and Outpatient
supplemental payments (5)
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Payments made under the Quality Care Assessment
adjustment
payments
The Reauthorized Quality Care Assessment –Fiscal Year 2019
Quality Care Assessment Available for Federal Match Payment to Hospitals Net Benefit
State Take $915 million % of IP and OP NPR $295 million $620 million $758 million $1.673 billion THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
The introduction of the provider assessment has changed financing:
a portion of payments
quality, APR-DRGs etc.)
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
PA political and state agency dynamics
The assessment should be viewed as Medicaid improvement, but some view it as a windfall for hospitals
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Reduction to DSH Allotments Medicaid Managed Care Rule Provider Assessment Reductions FFS Oversight
Limits DSH payments to hospitals Threatens provider assessments Redistributes payments Increases oversight and scrutiny Creates potential new mandates
Federal CMS Action(s)
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Did you know…? Not all rehabilitation hospitals receive more in payments than they pay in assessment THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Under the Quality Care Assessment, Rehabilitation Hospitals:
hospitals included in the tax.
million funding pool, solely for freestanding rehabilitation hospitals based on:
Medicaid revenue as reported in the hospital's fiscal year 2008 Medicaid cost report.
funding increase under the reauthorization agreement. Did you know …? part 2 Rehabs receive $25 million out of $1.7 billion in assessment payments (1.5%)
Several Potential Options for Exploration Include:
Quality Incentive programs
Value-based purchasing
Increasing the Managed Care rate range
Spending up to the DSH allotment
Reclassifying current DSH and supplemental payment with a Managed Care component in its calculation.
Creating a new assessment
Lowering the assessment paid
Exempting a class of providers THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Opportunities for Freestanding Medical Rehabilitation Hospitals
DHS has implemented a quality incentive program funded through the hospital assessment. Specific Rehabilitation measures could be explored and developed that measure quality reporting metrics at first, then process measures in future years.
Likelihood of Success – High Consideration would need to be given to the types of measures that rehabilitation hospitals could successfully implement in order to receive additional Medicaid funding.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Quality incentive programs
Likelihood of Success – High Consideration would need to be given to a scenario in which rehabilitation hospitals could participate in reporting of quality metrics. What value-based purchasing arrangements do rehabs currently participate in with payors ?
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Value-based purchasing arrangements through Managed Care
DHS’s actuary, Mercer, creates rate ranges to support payment of the per- member per-month amount that is paid to plans in a given HealthChoices zone, which enable the plans to contract with
care rates are at the lower end of the rate range, thereby potentially allowing additional payments to be supported through this mechanism.
Likelihood of Success – Moderate Consideration would need to be given to the Medicaid managed care program and how rehabilitation hospitals currently contract with MCOs
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Utilize managed care rate range room for improvements
The state is not likely spending up to its federal DSH allotment which could allow additional DSH to be paid. Other opportunities exist in reclassifying the managed care portion of DSH or supplemental payments to the managed care rate range, thereby freeing up UPL room to make additional payments.
Opportunities / Advantages
(1)New DSH funds can be paid, or improvement to existing pools can be calculated.
(2) UPL room would be increased for more payments to be made on FFS side, while those same payments are reclassified into managed care.
Would not require a waiver.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE State’s DSH allotment and reclassifying current DSH and/or supplemental payments
Likelihood of Success – Low Consideration would need to be given to a scenario in which pass- through payments would not be
risk on the hospital end.
Since freestanding rehabilitation hospitals have their own licensing designation, it may be possible to create separate assessment.
Likelihood of Success – Moderate Consideration would need to be given to interrelation of the Quality Care Assessment and any new tax. An extensive review of CMS rules and the state’s current payment limit parameters would also need to be reviewed.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Creating a separate assessment for Rehabilitation hospitals
There is precedent for exempting a class of providers and still making payments to them – Critical Access Hospitals. There is also precedent for exempting Cancer Hospitals years after assessment implementation
Likelihood of Success – Low Consideration would need to be given to CMS tests and the ability for the overall QCA program to met those tests. Additionally rehabs do contribute approximately $15 million to the assessment base
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Lowering the assessment or exempting a class of providers
Similar to action taken under Act 92 of 2015, the Rehabilitation funding pool could be increased.
Likelihood of Success – Moderately High Consideration would need to be given to updating the base year of distribution criteria and identifying additional tax proceeds that can be used.
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE Increasing the current Rehabilitation assessment funding pool
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
Should any options be eliminated from consideration? Are there other ideas that should be considered? Other questions?
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE
THE STATEWIDE HOSPITAL ASSESSMENT PAYMENT AND POLICY LANDSCAPE