URGENT: Training for Virginia Providers participating in the CCC Dual Eligible Program

I urge all Virginia providers who will be participating in the Commonwealth Coordinated Care Dual Eligible pilot program to attend this training by the VHCA.  

Please join us for the Virginia Health Care Association's conference on June 17th & 18th at the DoubleTree by Hilton Hotel Richmond - Midlothian. This educational program, T-Minus: Preparing for the Launch of the Commonwealth Coordinated Care Program is designed to bring the latest information about Virginia's Commonwealth Coordinated Care (CCC) program to our members.

Nursing facilities will hear directly from the care management teams for the three Medicare-Medicaid Plans (MMPs) about their own perspectives and plans for care management and coordination for dual eligible beneficiaries enrolled in the CCC.  Attendees will also hear about important legal considerations that providers should understand about this new program. On day two, leaders from the Department of Medical Assistance Services and the Office of the Secretary of Health and Human Resources will brief attendees on key CCC operational and implementation developments. The program will conclude with a discussion of important managed care operational strategies that nursing facilities should evaluate.

At the conclusion of this program, participants will be able to:

• Identify key Commonwealth Coordinated Care operational and financial issues of importance to nursing facility providers.
• Understand the core legal documents and agreements that serve as the foundation for the Commonwealth Coordinated Care program.
• Be aware of how the Commonwealth Coordinated Care will impact beneficiary post-acute care options for skilled services.
• Understand how the Commonwealth Coordinated Care program launch will impact the facility's resident population receiving long term care services.
• Describe the care management approaches of each of the three MMPs contracted for the Commonwealth Coordinated Care program.
• Identify important operational strategies for successful participation in the Commonwealth Coordinated Care program.

Who Should Attend?  Administrators, DONs, MDS Coordinators, Therapy Managers, Social Workers, Discharge Planners, Corporate Clinical, Operations and Finance Staff.

Registration and brochure information for T-Minus: Preparing for the Launch of the Commonwealth Coordinated Care Program is now available online.

Here is the latest update on the project by VHCA:

Commonwealth Coordinated Care Update

On May 28th, the Department of Medical Assistance Services (DMAS) communicated that problems had been discovered in the beneficiary assignment approach utilized to assigned dual eligibles to an individual Medicare-Medicaid Plan (MMP) within the Tidewater region of the Commonwealth Coordinated Care (CCC) program.  As a result, it appears that an unspecified number of individuals now receiving services in nursing facilities located within the Tidewater region will receive letters from the CCC enrollment broker, Maximus, indicating that they have been reassigned to a new MMP.  Based upon earlier DMAS projections of the number of dual eligible beneficiaries receiving nursing facility services in Tidewater, we estimate that as many as 600 individuals could be subject to the MMP reassignment.  The May 28th communication indicates that for the individuals being reassigned, their CCC coverage will begin August 1, 2014, one month later than previously announced.  The DMAS communication does not indicate how, or if, providers will be notified about which of their residents have been reassigned.

The DMAS announcement further indicates that the effective date for the start of coverage for beneficiaries automatically or passively enrolled in the Richmond/Central CCC region has been moved back one month to September 1, 2014.  Launch dates in the three remaining CCC regions remain the same.

REVISED RULES PROPOSED ON CIVIL MONETARY PENALTIES

https://www.federalregister.gov/articles/2014/05/12/2014-10394/medicare-and-state-health-care-programs-fraud-and-abuse-revisions-to-the-office-of-inspector

REVISED RULES PROPOSED ON CIVIL MONETARY PENALTIES

The Office of the Inspector General (OIG) has published a proposed rule, seeking comments on revisions to the rules associated with Civil Monetary Penalties (CMP) for fraud and abuse. The Affordable Care Act significantly expanded OIG's authority to protect Federal healthcare programs from fraud and abuse. The proposed rule codifies the changes for:

• Failure to grant OIG timely access to records
• Ordering or prescribing while excluded
• Making false statements, omissions, or misrepresentations in an enrollment application
• Failure to report and return an overpayment
• Making or using a false record or statement that is material to a false or fraudulent claim

MDSC:  when you modify an MDS and it lowers the PPS RUG, that is an overpayment that must be returned to the treasury. There is no time limit on returning overpayments.

CMS Fact Sheet: SNF Proposed Rule

Fact sheets: Proposed fiscal year 2015 payment and policy changes for Medicare Skilled Nursing Facilities

Date

2014-05-01

Title

Proposed fiscal year 2015 payment and policy changes for Medicare Skilled Nursing Facilities

For Immediate Release

Thursday, May 1, 2014

Contact

press@cms.hhs.gov

Proposed fiscal year 2015 payment and policy changes for Medicare Skilled Nursing Facilities

Overview
On May 1, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule [CMS-1605-P] outlining proposed Fiscal Year (FY) 2015 Medicare payment rates for skilled nursing facilities (SNFs). The FY 2015 proposals and other issues discussed in the proposed rule are summarized below.

Changes to Payment Rates under the SNF Prospective Payment System (PPS)
Based on proposed changes contained within this rule, CMS projects that aggregate payments to SNFs will increase by $750 million, or 2.0 percent, from payments in FY 2014, which represents a higher update factor than the 1.3 percent update finalized for SNFs last year. This estimated increase is attributable to 2.4 percent market basket increase, reduced by the 0.4 percentage point multifactor productivity adjustment required by law.

Wage Index Update
On February 28, 2013, the Office of Management and Budget (OMB) issued OMB Bulletin No. 13-01, which contained a number of significant changes related to the delineation of Metropolitan Statistical Areas, Micropolitian Statistical Areas, and Combined Statistical Areas, and guidance on uses of the delineation of these areas. To align with these changes, CMS is proposing revisions to the wage index based on the newest OMB delineations for the FY 2015 SNF PPS wage index. CMS is also proposing to use the new OMB delineations to identify a provider’s urban or rural status for the purpose of determining which set of rate tables would apply to the provider. This is consistent with other Medicare payment rules which will also include similar revisions this year as a result of the new OMB delineations.

In an effort to mitigate the potential negative wage index impacts for some providers of this proposed adoption of the revised OMB delineations, CMS is proposing to implement these changes by providing a one-year transition with a blended wage index for all providers. The wage index for each provider would consist of a blend of 50 percent of the FY 2015 wage index using the current OMB delineations and 50 percent of the FY 2015 wage index using the revised OMB delineations. A similar transition wage index was used when CMS adopted the OMB’s Core-Based Statistical Area (CBSA) definitions in FY 2006.

Change of Therapy assessment policy update
The Change of Therapy (COT) Other Medicare Required Assessment (OMRA) is used to classify a resident into a new resource utilization group (RUG) when, based on the therapy services provided during the previous seven days, the resident no longer qualifies for the RUG into which they are currently classified for payment. Recently, some providers have raised concerns regarding a technical aspect of the rules governing when the COT OMRA may be completed, which generally limits the use of the COT OMRA to instances where the resident is already classified into a therapy RUG.

Therefore, CMS is proposing a revision to the current COT OMRA policy to address this concern, which would permit providers to use the COT OMRA to reclassify a resident into a therapy RUG from a non-therapy RUG, but only in certain limited circumstances.

Civil Monetary Penalties
The proposed rule provides clarification of statutory requirements under Section 6111 of the Affordable Care Act regarding the approval and use of Civil Money Penalties (CMPs) imposed by CMS against nursing facilities. We clarify that states may use federal CMP funds only after obtaining prior approval from CMS, and may not use these funds if CMS has disapproved their intended use, or use these funds for purposes other than to support activities that benefit residents as specified in statute. CMS also proposes that States provide more public transparency on the projects that have been funded by CMP funds.

The proposed rule went on display on May 1 at the Federal Register’s Public Inspection Desk and will be available under “Special Filings,” at http://www.federalregister.gov/inspection.aspx.

For further information, see http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/index.html. Public comments on the proposal will be accepted until June 30, 2014.

SNF Pepper Reports Now Available On-line

Program for Evaluating Payment Patterns Electronic Report     The Q4FY13 release of your new Skilled Nursing Facility (SNF) Program for Evaluating Payment Patterns Electronic Report (PEPPER), with statistics through September 2013, is now available for download through the Secure PEPPER Access page atPEPPERresources.org. To obtain your SNF's PEPPER, the Chief Executive Officer, President or Administrator of your SNF should:  Review the Secure PEPPER Access Guide. Visit the Secure PEPPER Access page at PEPPERresources.org. Review the instructions and obtain the information required to authenticate access. Click on the button to Access the Secure Portal. Complete all the fields. Download your PEPPER.  The SNF PEPPER will be available to download as a Microsoft Excel file for approximately one year. The previous Q4FY12 SNF PEPPER, originally released in August 2013, will be made available via the Secure PEPPER Portal in the summer of 2014; an email notification will be sent when these PEPPERs are available. New for this release in the SNF PEPPER: The "State" comparison group now includes all SNFs in a state. Previously, the "State" comparison group included all SNFs in a state that were in the same MAC jurisdiction. As a result, state percentiles will be available for most SNFs; state percentiles will differ from the previous PEPPER release.   For more information, visit the SNF Training and Resources section ofPEPPERresources.org. About PEPPER PEPPER is an educational tool that summarizes provider-specific data statistics for Medicare services that may be at risk for improper payments. Providers can use the data to support internal auditing and monitoring activities. Visit PEPPERresources.org to access resources for using PEPPER, including recorded web-based training sessions, a sample SNF PEPPER and the current SNF PEPPER User's Guide, which are available on the SNF "Training and Resources" page. PEPPER is distributed by TMF® Health Quality Institute under contract with the Centers for Medicare & Medicaid Services. Do you have questions or comments about PEPPER or need help obtaining your report? Visit our Help Desk to request assistance with PEPPER. Provide your feedback or suggestions regarding PEPPER through our feedback form.  The PEPPER Team