MedPAC and MACPAC Reports
Pete Van Runkle
BPeriodically, the Medicare Payment Advisory Commission (MedPAC) and the Medicaid and CHIP Payment and Access Commission (MACPAC) report to Congress on issues within their respective jurisdictions. These reports are purely advisory and typically do not generate Congressional action. Good thing, because once again MedPAC is recommending cuts to SNFs, this time by eliminating the market-basket update for two years. MedPAC also recommends implementing the Centers for Medicare and Medicaid Services’ proposed new SNF reimbursement system (which AHCA opposes) in Federal Fiscal Year 2020. As always, MedPAC focuses exclusively on SNF Medicare margins and does not factor its statutorily required finding that overall margins are a miniscule 1.6% into its recommendations. On the MACPAC side, the report includes a listing of potential Medicaid savings measures but does not make recommendations on them. For more information, please see AHCA’s brief on the two reports.
NIC Report Shows Lower SNF Census
Pete Van Runkle
A report from the National Investment Center for Seniors Housing and Care (NIC), based on a data reported by a sample of 1,400 SNFs in 18 companies shows that occupancy nationally in the fourth quarter of 2016 fell more than 1.5% from the previous year, to 81.8%.Total census bounced between 84% and 86% from 2012, when NIC began compiling these data, to 2014. The data are not broken down by state. Other findings in the latest report include that skilled and quality mix both declined, although both are within the historical ranges for the past few years. Medicaid utilization grew to more than 66% nationally, a 1.26% jump. NIC determined that Medicaid rates grew on average by 1.8%, but Medicare managed care rates fell 9%, which actually is a smaller decline than from 2014 to 2015. NIC’s figures show that Medicare fee-for-service rates hovered between $504 and $517 per day from 2012 to 2016, but Medicare Advantage rates declined steadily from $476 to $422 over the period.
New 9401 Posted for Clearance
Diane Dietz
As anticipated, the Ohio Department of Medicaid (ODM) has posted a new ODM 09401 Facility Communication form for public comment. As reported in previous NewsBites, OHCA is hopeful this will be the final iteration of the 9401 since the form, and process for using it, changed following the August 1, 2016 launch of the Ohio Benefits eligibility system for the Aged Blind and Disabled (ABD) Medicaid population. Kim Donica, ODM Chief, Bureau of Long Term Care, communicated in her clearance memo the key changes to the ODM 9401. According to her memo, those include:
- Removing excess facility information from Section II such as address and telephone number
- Removing Level of Care (LOC) Exemption and LOC Validation fields
- Removing additional data fields related to reporting changes to the CDJFS that could affect an individual’s Medicaid eligibility
- Updating submission instructions to include directions for both Fee-For-Service and Managed Care individuals
Donica further noted that the information that has been removed from the ODM 9401 related to Medicaid eligibility will be incorporated into a new form (ODM 10203) that can be utilized by any Medicaid recipient or their authorized representative to report changes to the CDJFS. This new form is currently being developed and put through a separate clearance process, but a draft version has been included in the ODM clearance package for reference. To review the draft ODM 09401 Facility Communication form in clearance, please click here. Comments are due by Wednesday, March 22, 2017. OHCA will continue to await further information from ODM on when the pre-recorded training webinar on the use of the 9401 by nursing facilities will be posted to the ODM website.
Online Uploading of 2016 Year End Cost Reports
Debbie Jenkins
The Ohio Department of Medicaid has posted on its website a recorded webinar training for providers and accounting firms on the uploading of cost reports in the MITS portal. Included on the website is a .pdf version of the presentation. Earlier training covered the process for obtaining security access based on defined roles. This training covers the actual process to upload the cost report in MITS and the required attestation.
Our partners at HW&Co. attempted to upload a cost report in MITS and experienced an issue that we’d like you to be aware of. Apparently, once the cost report was uploaded under one provider number, the system sent a notification to all providers in which the user had access to this role and not just the provider under which the cost report was being submitted. ODM has been notified of this issue.
CMS Indicates Increase in SNF Denials; Tips for Improvement
Diane Dietz
According to the 2015 Comprehensive Error Rate Testing (CERT) Report, the denial rate for Skilled Nursing Facilities (SNFs) increased from 6.9% in 2014 to 11% in 2015 due to missing or incomplete certification/recertification information. The major reason for claims being denied is failure to obtain certification and recertification statements from physicians or NPPs. The routine admission order established by a physician is not a certification of the necessity for post hospital extended care services for purposes of the program. Specifically:
- Statement must contain need for skilled services that can only be provided in SNF/swing-bed on a daily basis for a condition patient was treated for in prior hospital stay
- Must include physician’s dated signature (printed name if signature is illegible)
In addition, recertifications should include:
- Expected length of stay
- Explanation if continued need for services is for a condition that arose after SNF admission
- Any plans for home care
Some resources to assist providers in complying with proper documentation and billing requirements to help avoid these denials include the following:
MLN Guidance on Comprehensive Error Rate Testing (CERT): Skilled Nursing Facility(SNF) Certifications and Recertification
SNF Billing Reference Fact Sheet
Medicare Fee-For-Service 2015 Improper Payments Report, page 18
Medicare Fee-For-Service 2014 Improper Payments Report, page 19
Medicare Provider Enrollment Revalidation – Cycle 2; Not to be Confused with Medicaid Revalidation
Diane Dietz
MLN SE 1605 on the Medicare revalidation process was updated to include a table to better illustrate the timeline providers can expect to experience through this revalidation process. Please note, that Medicare revalidation is completely separate from Medicaid revalidation and both processes need to be completed independent of each other. For more information on the Medicaid revalidation process including a helpful FAQ and the list of upcoming revalidations for 2017 and 2018, please click here.
Medicaid Once Again Accepting New Trading Partners
Diane Dietz
The Ohio Department of Medicaid (ODM) had a hold on accepting new trading partners due to moving to a new HP platform. ODM is now accepting applications for new trading partners here. Questions can be directed to the EDI Support team at OhioMCD-EDI-Support@hpe.com