Region 2 Annual Fall institute John W. Gahan Jr. New York State Department of Health 1 Agenda Pre-Reform Rates Updates/timeframes Reform Rates 4/1/2010 10/1/2010 – Blended Rates Potentially Preventable Readmissions (PPR’s) New Psych Methodology FMAP Payment Reductions DSH Audit Update and Process Questions and Answers New York State Department of Health 2 Pre-Reform Rates Initial 2009 rates: General items included Capital 2007 volume, etc. Worker Retention reconciliation Updates to 2009 rates 2008 and 2009 volume Including LOS relief and added bed appeals 2008 and 2009 actual capital Worker Retention reconciliation – 2008 and 2009 Retro publication Old appeals New York State Department of Health 3 Reform Rates 4/1/2010 Rates: Updated statewide base price for some minor corrections New Transition amounts Divided by 2008 paid claims Workers Comp/No Fault Rates trended 2010-11 budget delinked items effective 4/1/2010 Rebasing adjustment in Medicaid rates not applicable to WC/NF rates ($154.5M) New York State Department of Health 4 Blended Rates effective 10/1/2010 New York State Department of Health 5 Phase II – Blend FFS and MC Effective October 1, 2010 and forward DOH has established a single statewide base price that combines Medicaid FFS and MC based on updated 2008 data. The blended base price per discharge will be established based on targeted statewide Medicaid inpatient hospital expenditures from both Medicaid FFS and MC, and the new reform rate variables (i.e. GME, WEF, case mix, etc.) New York State Department of Health 6 Reform Rate Components Statewide Base Price (SBP) $6,399 $6,171 $6,304 Institution-Specific Adj Factor 1.0196 1.0323 1.0266 Adjusted SBP $6,524 $6,370 $6,472 APR-DRG CMI 1.1516 0.7462 0.9272 Pmt/discharge (excl. GME) $7,513 $4,754 $6,001 Total GME/discharge $2,791 $1,739 $2,206 Non-Comparables $402 $86 $225 Avg. pmt/discharge $10,706 $6,579 $8,432 Total Spending $3.253B $2.313B $5.566B New York State Department of Health * The blended rate does not reflect actions enacted in the 2010-11 Budget, including Potentially Preventable Readmissions (PPRs). 7 Funding Reallocations The blended rate will result in increased FFS savings (from $225M) and increased payments to hospitals related to MC services, based on 2008 utilization (savings will still net to $225M). $225 million (and the $154 million across-the-board reduction) in gross Medicaid savings will be retained across both FFS and MC sectors and does not “double-up”. Funds will need to be shifted in the Budget to accommodate this dynamic. New York State Department of Health 8 Hospital Transition II Pool (Continued) A Transition II Pool will be established to provide an additional $150 million over 3 years ($75M/$50M/$25M) to further assist hospitals to adjust operations consistent with state health care priorities and revenue streams. Additional $37.5M for the period 10/20/10 through 3/31/11 Transition funds will be phased out consistent with Transition Pool I, however, these monies will be reinvested back into the base price. Allocation of these funds will be consistent with Transition Pool I (setting a threshold floor percentage – 10.45%) based on FFS losses and allocated through FFS claims only. New York State Department of Health 9 Hospital Transition II Pool (Continued) In year one, the blended base price will be reduced to generate $75M in additional savings. The new base price will be $6,202 (from $6,304). Includes public facilities, who were previously excluded from receiving funds from Transition Pool I. New York State Department of Health 10 Reform Rate Components Statewide Base Price (SBP) $6,399 $6,171 $6,202 Institution-Specific Adj Factor 1.0196 1.0323 1.0266 Adjusted SBP $6,524 $6,370 $6,367 APR-DRG CMI 1.1516 0.7462 0.9272 Pmt/discharge (excl. GME) $7,513 $4,754 $5,903 Total GME/discharge $2,791 $1,739 $2,188 Non-Comparables $402 $86 $225 Avg. pmt/discharge $10,706 $6,579 $8,316 Total Spending $3.253B $2.313B $5.490B New York State Department of Health * The blended rate does not reflect actions enacted in the 2010-11 Budget, including Potentially Preventable Readmissions (PPRs). The statewide base price includes a reduction of $100 to fund the full 11 first yr. ($75M) of the transition II pool. Impact of Reform on Transition Hospitals (Dollars in Millions) # of Hospitals Total Impact Transition Funds* Net Impact 12/1/2009 Rate (FFS and MMC) 66 ($219.1) $75.0 ($144.1) 10/1/2010 Blended Rate (FFS and MMC) 78 ($322.8) $150.0 ($172.8) 10/1 Blended Rate (FFS and MMC) Original Transition ONLY 7 ($4.3) $4.4 $0.1 10/1 Blended Rate (FFS and MMC) Transition II ONLY 12 ($112.5) $23.7 ($88.8) 10/1 Blended Rate (FFS and MMC) Both Transition Pools 59 ($206.0) $121.9 ($84.1) *Transition II allocation based on FFS losses only. New York State Department of Health 12 Potentially Preventable Readmissions (10 NYCRR 86-1.37) A Potentially Preventable Readmission (PPR) is a readmission within 15 days that is clinically related to the initial hospital admission Excludes behavioral health at the initial admission; major or metastic malignancies; multiple trauma; burns; neonatal; obstetrical; and discharges with a status of “left against medical advice” Includes readmissions for fee-for-service and Medicaid managed care Will begin discussions with stakeholders to incorporate behavioral health PPRs beginning 4/1/12 New York State Department of Health 13 PPRs - Methodology 2010-11 Budget requires this proposal to generate $47M in full annual, gross, savings (in 2011-12) $37.1M related to FFS readmissions; $9.9M related to MMC readmissions To generate these savings, the following method is used: Using 2007 data, a risk adjusted model identifies hospital specific “excess readmissions” (observed rate is in excess to the expected rate) A readmission adjustment factor is computed using the ratio of aggregate payments related to the excess readmissions to the aggregate payments for all non-behavioral health discharges This adjustment factor is prospectively applied to the applicable hospital’s case payment and per diem rates on discharges beginning 7/1/10; implemented in 10/1/2010 rates. The reduction % will be applied to the statewide base price, DME, and noncomparables New York State Department of Health 14 New York State Department of Health 15 Background Legislation A new inpatient psychiatric reimbursement methodology was passed in the 2009-10 Medicaid reform legislation Implementation date Initially planned for December 1, 2009 The executive budget delayed it to April 1, 2010 Revised start date is October 20, 2010 Task Force The psychiatric payment methodology was developed through a joint initiative with representatives from DOH, OMH, GNYHA, HANYS Goal Utilizing a Medicare-like approach, develop a reimbursement strategy to pay more appropriately for inpatient psychiatric admissions and address length of stay Maintain Budget Neutrality The operating payments for inpatient psychiatric services under the current system and under the new methodology will be budget neutral Transition A $25 Million annual investment as a result of rebasing to 2005 costs will be used for transitioning to the new methodology New York State Department of Health 16 Impetus for Change: Current System’s Weaknesses Cost base is 1981, non-Medicare payers Outdated Inpatient costs attributable to Medicaid patients not recognized Same per diem rate throughout the stay Higher costs for initial work up, and lower costs later in the stay not recognized No incentives for length of stay reduction (NYS is twice the national average) Doesn’t recognize different levels of mental health care service provided Doesn’t recognize observable , systematic cost differences in Office of Mental Health’s priority areas Rural hospitals, adolescents, presence of mental retardation, and physical comorbidities Payments based on hospital-specific costs do not encourage efficiency New York State Department of Health 17 New Methodology: Highlights Applicable to Article 28 exempt psychiatric inpatient hospitals and exempt units Major constructive change in the way inpatient psychiatric rates are calculated and how Medicaid claims are paid after October 1, 2010 A modernized approach making reimbursement more adequate and equitable New system will pay for the level of service rendered, address length of stay variance, and will be more consistent with how Medicare reimburses for this service Inpatient psychiatric per diem rates will be based on 2005 Medicaid operating costs (per statute) Additional investment of $25M annually over existing inpatient psychiatric expenditures as provided for in the 2009-10 budget to assist hospitals to transition to the new methodology Transition will gradually be phased into the statewide price over the period 10/20/2010-12/31/2014 New York State Department of Health 18 Data Overview Legislation requires use of 2005 Medicaid costs ICR: Best source for provider cost SPARCS: Best source for all-payer case-level data Basis to match case-level charges to ICR Development of departmental ratios of cost to charges (RCCs) More complete reporting of charges compared to 2005 MMIS More secondary diagnoses reported compared to 2005 MMIS MMIS: Best source to determine psychiatric cases One year’s worth of data not reliable enough to estimate systematic determinants of cost New York State Department of Health 19 Model Development: Operating Payment Adjustments Facility-level adjustment: WEF To account for wage differences in hospitals’ labor markets For Oct. 1st: same as acute care Medicaid payment system ECT rate Use the federal rate in effect during the first half of 2010: $281 Severity of illness: Based on DRG relative weights Calculated specifically for psychiatric patients Uses hospital-specific relative value (HSRV) method APR-DRGs to account for four severity levels Consistent with acute care weight methodology All other adjustments: Regression based New York State Department of Health 20 DRGs for Medicaid Psych Patients with Cost Estimates, 2005-2006 DRG Degenerative Nervous System Disorders Exc Mult Sclerosis Nontraumatic Stupor & Coma Cases Days 16 4 Postpartum & Post Abortion Diagnoses w/o Procedure 19 Other Antepartum Diagnoses 92 Mental Illness Diagnosis w O.R. Procedure 66 Schizophrenia 16,882 Major Depressive Disorders & Other/Unspecified Psychoses 11,776 Disorders of Personality & Impulse Control Bipolar Disorders DRG 945 Organic Mental Health Disturbances 33 Childhood Behavioral Disorders 334 Eating Disorders 1,387 Other Mental Health Disorders Drug & Alcohol Abuse or Dependence, Left Against Medical Advice Alcohol & Drug Dependence w Rehab or 368,687 Rehab/Detox Therapy 2,315 156,455 Opioid Abuse & Dependence 200 1,796 Cocaine Abuse & Dependence 12,372 184,020 Alcohol Abuse & Dependence Depression Except Major Depressive Disorder 5,662 56,479 Other Drug Abuse & Dependence Adjustment Disorders & Neuroses Except Depressive Diagnoses 1,539 12,967 Non-Psychiatric DRGs Acute Anxiety & Delirium States New York State Department of Health 541 Cases Days 593 13,284 2,935 55,044 129 3,200 176 3,037 145 997 42 784 686 6,186 968 7,355 629 4,899 420 3,225 209 2,512 3,896 Note: Medicare DRG "psychoses" is split among "schizophrenia," "major depressive disorders & other/unspecified psychoses," and "bipolar disorders" under APR-DRG system. 21 Adjustment Factors for Day Intervals & Interrupted stays LOS Scale: Days 1-4 = 1.20 Days 5-11 = 1.00 Days 12-22 = 0.96 Days 23 & over = 0.92 Interrupted Stays: Readmissions to same hospital within 30 days Payment for first day will be considered day 4 of the stay on the scale and pay @ 1.2 Day 2 will move to 100% New York State Department of Health 22 Comorbidity Adjustment Factors Mental retardation as a secondary diagnosis Adjustment factor = 1.06 One other medial/physical comorbidity Uses ICD-9-CM codes reported on the patient bill Considers secondary diagnoses that are complicating conditions (CC/Major CC) under the MS-DRG system Based on hierarchical condition categories (HCCs) used by various Medicare risk-adjustment methodologies 18 comorbidity groups Applies the highest adjustment factor if there are more than one comorbidity present New York State Department of Health 23 Comorbidity Categories Category Adjustment Factor Cancers 1.09 Protein-Calorie Malnutrition 1.08 Disorders of Fluid/Electrolyte/Acid-Base Balance 1.06 Other Endocrine/Metabolic/Nutritional Disorders 1.14 Other Hepatitis and Liver Disease 1.09 Peptic Ulcer, Hemorrhage, Other Specified Gastrointestinal Disorders 1.10 Other Musculoskeletal and Connective Tissue Disorders 1.06 Blood Disorders 1.11 Other Developmental Disability 1.20 Brain/Head Injury 1.14 Cardio-Respiratory Failure and Shock 1.16 Acute Coronary Syndrome 1.40 Stroke/Occlusion/Cerebral Ischemia 1.21 Respiratory Illness 1.07 Other Eye Disorders 1.12 Renal Disease 1.10 Complications of Medical Care and Trauma 1.13 Major Organ Transplant Status 1.18 New York State Department of Health 24 Summary of Payment Model Rate Components • • Statewide Price Adjusted by Hospitals’ WEFs Rural adj. factor=1.23 LOS Scale Days 1-4=1.20 Days 5-11=1.00 Days 12-22=0.96 Days 23 & over=0.92 APR-DRG Weight (23 DRGs w/ 4 severity levels each) ECT $281 per treatment adjusted for hospital’s WEF Payment Factors Age: (17 & under=1.08) (18 & over=1.00) x Mental Retardation=1.06 Non-Operating Per Diem (Capital + DME + Transition if applicable) Comorbidity Factor (to address both physical & mental health) 18 comorbidity categories with various payment factors Final total payment Note: Physician fees will be paid separately New York State Department of Health 25 Payment Calculation Example Parameter Variable Statewide per diem rate Facility-level Labor Cost Adj. Wage equalization factor (WEF) Adjustments: Same Population Density Rural location for All Patients Composite facility-level adjustment factor APR-DRG APR-DRG relative weight based on HSRV methodology Pediatric case Mental Retardation Diagnosis Present 1 Cancers 2 Protein-Calorie Malnutrition 3 Disorders of Fluid/Electrolyte/Acid-Base Balance 4 Other Endocrine/Metabolic/Nutritional Disorders 5 Other Hepatitis and Liver Disease 6 Peptic Ulcer, Hemorrhage, Other Specified Gastrointestinal Disorders 7 Other Musculoskeletal and Connective Tissue Disorders Patient-level Comorbidity 8 Blood Disorders Adjustments: Adjustments: Apply 9 Other Developmental Disability Different for Each the maximum of the 10 Brain/Head Injury Patient adjustments if patient 11 Cardio-Respiratory Failure and Shock has multiple 12 Acute Coronary Syndrome comorbidities 13 Stroke/Occlusion/Cerebral Ischemia 14 Respiratory Illness 15 Other Eye Disorders 16 Renal Disease 17 Complications of Medical Care and Trauma 18 Major Organ Transplant Status Maximum adjustment Composite patient-level adjustment factor Facility & case-specific per-diem operating rate 1 Days 1 through 4 5 Days 5 through 11 Day Groups Length of Stay 12 Days 12 through 22 Adjustments 23 Day 23 and beyond LOS and adjusted LOS Day adjustment factor Payment based on per-diem rate ECT payment (adjusted by WEF) Operating Payments Direct GME payment Payment Calculation Operating payment Capital payment Transition payment (TBD) Total payment Opcert 700xxxx 23% DRG 9% 6% 9% 8% 6% 14% 9% 10% 6% 11% 20% 14% 16% 40% 21% 7% 12% 10% 13% 18% 20% 0% -4% -8% 753-3 1 1 - 1.02 1.00 1.02 1.06 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.06 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.10 1.00 1.00 1.10 1.16 $ 709.62 $ 281.00 $ 27.00 10 1 10 4.80 6.00 10.80 1.08 1.08 1.02 n/a $ 10 n/a 33.00 4 6 10 Adjustment $ $ Amount 601.86 $ 612.57 $ 709.62 $ $ $ $ $ $ $ 7,663.88 286.00 615.30 7,949.88 548.20 8,498.08 Summary of Adjustments Category Approx. Value of Adjustments (Million Dollars) WEF 13.3 Rural Adjustment 4.6 APR-DRG Weights 0.3 Pediatric Patients (Under 17 yrs.) 4.9 Mental Retardation Comorbidity 0.4 Other Comorbidities - (use the highest if multiple) 1.5 LOS Scale 3.1 Total 28.1 New York State Department of Health 27 Old vs. New Payment System Existing System • Case mix adjusted operating per diem based on hospital specific cost New System • Operating per diem is based on a statewide price adjusted by hospital’s WEF • Applies APR-DRG weight (4 severity levels) • Applies payment adjustments for pediatric cases, mental retardation, rural hospitals, & physical comorbidities •Pays the same operating per diem rate for each day of service • Operating per diem adjusted by the LOS scale to address varying costs at specific intervals • Separate payment for Electroconvulsive Therapy (ECT) • Reduced payments for readmissions: For readmissions to the same hospital within 30 days, the 1st day of the readmission will be treated as day 4 of the LOS scale with subsequent days continuing onward • Capital and DME paid for each day of service New York State Department of Health • 2005 DME per diem rate trended to Oct. 1, 2010 • Capital: budgeted capital expenses divided by expected days for the rate year 28 Budget Neutrality (Based on 2006 Case Distribution) Currently, the statewide average operating rate is about $637 per day This price will be adjusted downward to about $602 to account for the SIWs, various payment factors and LOS scale in the new methodology so as to maintain budget neutrality Therefore, the existing payments and new payments will be equal in the aggregate Operating Payments Capital Payments New York State Department of Health Existing Payments New Payments $575.1M Risk-adjusted payments: $502.3M ECT payments: $0.2M DME payments: $72.6M As budgeted As budgeted 29 Fiscal Impact Without further adjustments, there would be approximately $46m redistribution of payments Mitigating factors: The State is investing additional $25M into the system Two of the units with large losses already closed Allocation of $25M investment: Period Transition Statewide Rate 10/20/2010 – 12/31/2011 $25M $0 1/1/2012 – 12/31/2012 $17M $8M 1/1/2013 – 12/31/2013 $8M $17M 1/1/2014 – 12/31/2014 $0 $25M New York State Department of Health 30 Distribution Method of $25M Transition Fund 50% (12.5M) based on revenue loss Transition dollars will be allocated such that hospitals will not lose more than approximately 5% revenue from the existing payments to the new payments in year 1 Same method as acute transition 50% (12.5M) based on payment to cost ratio Transition dollars will be allocated to hospitals whose costs are well above their revenues under the new methodology based on 2006 data Thresholds for distribution will be published when final statewide rate is determined Transition funds will be paid through rate adjustments New York State Department of Health 31 Future Updates Rebasing There will be more frequent rebasing of cost data in the future, similar to the acute methodology, including updating the base year, service intensity weights, the payment factors, the LOS scale, and the ECT rate Wage Equalization Factor (WEF) In the future, DOH will consider recalculating WEFs for the inpatient psychiatric rates that will be based on psychiatric data only. If psychiatric only WEFs are implemented, DOH will simultaneously recalculate and implement the acute WEFs to exclude the psychiatric wage and fringe data. New York State Department of Health 32 FMAP Contingency Reductions Section 313 of the Laws of 2010 Gross amount of reduction for local shares @ $282M All Medicaid payments to be reduced for claims processed on or after 9/16/10 – 3/31/2011 Cycle 727 Check dated 9/27/10 Released on 10/13/10 Exemptions: HEAL $’s FQHC’s Other Federal mandated payments (IHS, Refugees, etc.) Reconciliation New York State Department of Health 33 DSH Audit Update Process: Questionnaire: Asking for data related and supporting the DSH assessment Desk vs. Field Audits Hospitals selected for field audits have been notified KPMG will schedule time at facility to review more details of data Deadlines are critical to meet New York State Department of Health 34 DSH Audit Update Timeframes for future years: 2008: Data to be provided before end of year – What should that include? Information due by March 31, 2008 Working with KPMG to develop tool to collect Audits due to be completed 9/30/2011 Report due 12/31/2011 2009 – 2010 Similar time frames as 2008 2011 – Initial year which new method will actually apply Data issues at hospital level need to be corrected: Charges on claims – critical to capture all costs related to Medicaid, Medicaid managed care and uninsured New York State Department of Health 35 New York State Department of Health 36