The National Council on Medicaid Home Care Hosts a CMS Panel Discussion during the March on Washington
April 4, 2014 10:09 AM
The National Council on Medicaid Home Care – a NAHC affiliate - held an educational session during NAHC’s March on Washington entitled “The Future of Medicaid: CMS Panel of Experts.” The session featured the following panelists:
Edo Banach, Senior Advisor, Acting Director, Models Demonstrations and Analysis Group, Medicare Medicaid Coordination Office (MMCO), Centers for Medicare and Medicaid Services
Dianne Kayala, Technical Director, Disabled and Elderly Health Program Group, Center for Medicaid and CHIP Services, Centers for Medicare and Medicaid Services
Ralph Lollar, Disabled and Elderly Health Programs Group, Center for Medicaid, Centers for Medicare and Medicaid Services
Mr. Banach spoke first, talking about the status of the demonstrations that MMCO was currently implementing, including the Financial Alignment Initiative (FAI) for the dual eligible population. He stated that this demonstration was critical, as the dual eligible population, while constituting only 15% of the total Medicaid population, accounts for 39% of all Medicaid costs. According to Mr. Banach, out of the eight states that have been approved under the FAI, only Massachusetts and Illinois are up and running. He also mentioned that quality measures are in place with the FAI, and that MMCO was working with the National Quality Forum (NQF) to continue to develop these measures. These include some measures that are related to home and community-based services (HCBS) specifically.
Mr. Banach also discussed a MMCO demonstration aimed at reducing preventable inpatient hospitalizations among residents of nursing facilities.
For Mr. Banach’s slides, click here. For Council briefs on dual eligibles, click here.
Ms. Kayala spoke about managed long-term services and supports (MLTSS) implementation nationwide. She remarked that states with at least partial adoption of MLTSS grew from 8 to 16 from 2004 to 2012. Rhode Island adopted voluntary MLTSS at end of 2013.
For Ms. Kayala’s slides, click here. For Council briefs on MLTSS, click here.
Rebalancing Update, HCBS Rule
Mr. Lollar discussed rebalancing long-term services and supports (LTSS) away from institutional care and towards HCBS. He gave a quick status report on the Balanced Incentive Payments (BIP) and Money Follows the Person (MFP) programs.
BIP has been in place since 2011, giving states enhanced Federal Medical Assistance Percentages (FMAPs) depending on the extent to which they rebalance towards HCBS and away from institutional care. Eligible states are those that that spend less than 50% of total Medicaid LTSS expenditures on community LTSS.
States spending less than 25% of total Medicaid LTSS on community LTSS are eligible for a 5% enhanced FMAP, while those spending between 25% and 50% are eligible for 2% enhanced FMAP. Total funding for BIP is not to exceed $3 billion, and the funding will end in 2015 or when all of the funds are expended. The total award is $2.16 billion, with nineteen (19) states having been approved for rewards to date.
MFP provides states with enhanced FMAPs if they develop sustainable HCBS infrastructure. Currently, forty-four (44) states and DC have this program.
For more information on BIP and MFP, click here and here. For a Council brief analyzing the rebalancing statistics in Senator Harkin’s Report to Congress, click here.
Mr. Lollar then gave a synopsis of the new Home and Community-Based Services (HCBS) final rule. For Mr. Lollar’s slides on the HCBS rule, click here. For a previous Council brief on the rule, click here.
Ms. Kayala gave a brief presentation on recent program integrity findings in home care, as reported by the Office of Inspector General of the U.S. Department of Health and Human Services (HHS OIG). She stated that noncompliance ran the gamut and ranged from billing for services not rendered to not providing adequate documentation for services billed.
Reasonable billing/billing for services not rendered. Ms. Kayala stressed the need for “reasonable billing” stating that every nurse and home health aide should reasonably bill for services. For example, a certified nursing assistant working for several different programs and billing more than 8 hours a day would be unreasonable, and indicate billing for services not rendered.
Good documentation. Ms. Kayala stated that good documentation is essential. Without it, CMS treats the event as if it did not happen.
Consolidation of regulation favored. Ms. Kayala also stated that HHS OIG hopes that states will consolidate and harmonize rules better with regard to different care settings (between residential group home and assisted living, for example). She also expressed HHS OIG’s desire for states to consolidate their waiver programs generally. HHS OIG believes that a streamlined approach to waivers will reduce non-compliance generally.
For a recent Council brief on the program integrity initiatives relevant to Medicaid home care in HHS OIG’s Work Plan for 2014, click here. For a recent Council on relevant findings from the HHS OIG’s Annual Report, click here.