South Dakota Department of Human Services



South Dakota Nursing Facility Rate Review ProjectStakeholder Meeting #8 - NotesJanuary 29, 202011:00 AM CT – 12:30 PM CTCall-in/Webinar Information:Location:Drifters - 325 Hustan Ave, Ft. Pierre, SD, 57532 and via Webinar/Conference CallParticipants: Name?PositionRhondaBurrisProgram Specialist, Long Term Services and Supports, DHSLorenDiekmanCEO/President, Jenkins Living CenterGregEvansAudit Manager, Budget and Finance, DHSDaveHalfertySenior Manager, Myers and StaufferDenice HouletteDirector, Budget and Finance, DHSGilJohnsonVP Business Development, SDAHOChristine LewisManager, Myers and StaufferTomMartinecDeputy Secretary, DHSJodieMitchellFinance Manager/Community Controller, Rapid City RegionalJesseNazeCFO, Fall River Health ServicesAmyPerryPartner, Myers and StaufferSakuraRohlederFiscal and Program Analyst, SD Legislative Research CouncilJeffSteggerdaConsultant, Brighton Consulting GroupYvetteThomasDirector, Long Term Services and Supports, DHSGoals: Review survey analysis and model updates. Discuss property reimbursement, extraordinary care, and PDPM implementation planning.Agenda:Welcome/Roll CallMinutes from January 8, 2020 meetingPlease review and provide feedback by close of business 1/30/20Rate Study SurveyResponses – no additional responses were received Initial Analysis. Went over Provider Survey Slides. There were 38 out of 106 facilities submit survey on time. Some facilities may have had challenges to why they didn’t get it in. From the data was hoping to see what the costs are and try to take these costs and put them into the rates maybe as an add-on. May go back and ask for additional surveys. Holidays may have played a role in the low response. Some new costs are a regulatory requirement. Providers could be outsourcing cost like PBJ. Other costs could be unfunded mandates, administrative burden, medical record systems, etc. Facilities may have added additional staff. If members have other items to add, email us and we can look into adding them to the survey. Cost report data would have been helpful to determine per diem. Current analysis doesn’t take into account large or small facilities.Capital Lease Costs – Reimbursement may have been falling behind. Limits on step up in basis. Allowable lease costs. Never recognize the current value of the lease. It is a Medicaid system issue. A facility may have $200,000 and recognize costs are only $90,000. Property costs wouldn’t be recognized because they aren’t in the system. Three different limits applied to the costs. 20 or more lease buildings. Possible to do item:Explain how lease costs are limitedReview cost data that is already available, line F-6 may include what we need.Determine what questions to ask to validate what we think we know.Medical Director Costs seemed very low. Could again look at costs reported on cost report and then determine what follow up questions need to be asked to validate or supplement what we think we know.Rate Parameters DiscussionBase Rate Parameters – additional limit parameters for Access Critical and 638 facilitiesAdded Access Critical facilities (8) in the state and (2, only one participating) 638 facility.No direct care limits or ceiling for AC or 638 NFs. Capital ceiling is same as all other providers. AC subject to ceiling of 105% of median for other cost centers. AC facilities are also allow to have an overall rate increase of up to 10% as opposed to the 8% increase limit on other facilities. There is no overall limit increase for the 638 facilities. Decided that it wouldn’t be beneficial to include the parameters in the rate modeling but we need to add the statistics calculations so we can compare rates and cost coverage for these facilities to other groups.Property ReimbursementSuggestions for modeling different property optionsSo far haven’t modeled anything.Greg talked about history of the limit calculation. Options for property reimbursement pare current costs to the current ceiling with additional inflation.Look at current costs with a limit based on a percentage above median.Determine a new limit from RSMeans or other market data.Use a price-based calculation (lots of negatives to this including the likely scenario that older under-maintained homes receive excessive reimbursement). Other suggestions, what have you seen in other states. Send email with other options.Extraordinary CareExpenditure AnalysisDave talked about the Extraordinary Care slides showing total costs, average cost per facility, and costs for each category of qualifying criteria.Greg explained what would qualify as extraordinary care. Certain services qualify, including Wound Vac, ventilator residents, extensive care, TBI, behavioral issues. Must contact the State to determine if qualify for extraordinary care rate. It’s a tedious process. Would like to eliminate the administrative burden and reduce the subjectivity of this aspect of the reimbursement system. Some categories are rather inconsequential such as the Wound Vac group.Others have objective criteria such as TBI, and ventilator groups.The extensive services group is interesting since it seems to indicate that the resident-specific acuity adjustment is not adequate. MSLC will attempt to analyze this group by looking at the RUG categories they fall into and what fraction of the total Medicaid residents in those categories and covered through extraordinary care. It could be that an adjustment to the RUG index could account for the additional reimbursement being paid through extraordinary care.The behavioral issues group seems to have the most potential for addressing through a rate adjustment methodology. Could use the BIMs score or CPS score like Georgia does as a potential proxy/replacement for the behavioral health group. They determine the percentage of Medicaid residents that can be identified as having significant cognitive issues and then calculate an add-on to the Medicaid rate that reflects that percentage. For South Dakota the adjustment could just be resident specific since the acuity adjustment is resident specific already.Send email with any other suggestions. PDPM ImplementationDraft MDS data setLast week CMS released what will be effective Oct. 1.Section G was removed from all assessments but the Optional State Assessment (OSA) as expected.OSAs will be the only way to get section G data after 10/1/20 in order to maintain the current RUG based acuity adjustment.Optional State Assessment (OSA)MSLC has tested RUG calculations using OSA data and it has worked fine.CMS has assured Greg that it will continue to calculate RUG values using OSA data and return that information to the state through the CMS data extract.MSLC still suggests that would be a good idea to collect OSA data prior to Oct 1 to verify data can run through the system and pull over correctly. This could be done on a voluntary basis or the state could require OSA beginning 7/1/20.CMS has stated that the OSA option will be maintained indefinitely but not forever.The OBRA assessments will include section GG data which will enable the modeling of PDPM nursing acuity calculations. This will eventually allow for modeling acuity adjustments based on the 25 nursing categories included in PDPM but it will take time to accumulate the data needed to complete modeling.Amy mentioned that Tennessee plans to submit an appeal to CMS to keep section G on the OBRA assessments. They have invited other states to join them in this effort. Although the section G data would provide the Medicaid data needed for RUG calculations without requiring the OSA, overall acuity could still not be measured since section G is not included on the Medicare assessments either. DHS may want to consider modifying the appeal to include continuing section G on all assessments.Follow-up Plan/Future MeetingsNext Meeting –February 12, 2020 via conference call/webinarOutstanding IssuesCost reporting adjustments- any changes needed to the cost report to capture data. Although options for adjusting the cost report will likely evolve from further discussion of other issues, it would be good to start considering changes the workgroup might want to recommend. ................
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