First, I’d like to thank everyone who attended my FHCA Annual Conference session on updates and strategies for the new Medicaid Prospective Payment System (PPS). Hopefully attendees gained valuable information that will help make the transition to PPS easier to navigate and less stressful. Since returning from Conference, we have received many questions regarding some of the information Tom Parker and I presented related to transition and first year of PPS reimbursement. Here are a few of the more prominent questions and answers, or at least the most up-to-date responses, until the Agency for Health Care Administration (AHCA) releases the Long Term Care Plan in the coming weeks.
Q: I understand the additional funds provided by the 2018 Florida Budget will not cover the entire rate period through September 30, 2019. Is that correct?
A: That is correct. The additional funding of approximately $140 million dollars appropriated by the 2018 Legislature for PPS transition was a one-time appropriation and will expire June 30, 2019. Unless the 2019 Legislative Session appropriates (and the new Governor approves) the same amount or more during the next session, Medicaid rates for those providers that are not on a hold-harmless rate will potentially see their rate decline by several dollars a day effective July 1, 2019. Therefore, it is vital that everyone take advantage of the Lobby Days sponsored by FHCA next year during Session to make your voices heard and retain the funding necessary to provide quality care for your residents.
Q: Am I going to receive a rate sheet from AHCA that I can use to prove my rate effective October 1?
A: Yes, the Agency for Health Care Administration (The Agency) is planning to issue rate sheets with sufficient detail that can be provided to banks, lenders, underwriters, etc. as proof of the rate in effect until June 30, 2019.
Q: Is my hold-harmless rate set for the next three years or is it subject to change?
A: The hold-harmless rate is subject to change for any retro-active adjustments such as final audit adjustments on open audits, audit appeal determinations, interim rate settlements, etc. that would impact the cost report used to set the rate effective September 1, 2016. The change to the hold harmless rate will be made on the next rate setting effective date following the determination. For example, if your 12/31/2015 cost report was used to set the September 1, 2016, rate and a final audit report is issued December 1, 2018, that is not appealed, your hold harmless rate will be recalculated based on the audit findings and compared to your new PPS calculated rate to determine your rate for October 1, 2019.
Q: How is the hold-harmless rate calculated for the rebasing that will occur in 2021?
A: The Agency will use your latest audited cost report on file in 2021 to calculate a new cost-based rate for your facility subject to targets and ceilings as determined by The Agency. Your hold-harmless rate for the October 1, 2021 rate setting will be 95% of the new cost-based rate.
Q: Is it possible that the cost report I just submitted with a fiscal year end of December 31, 2017, will be audited for PPS purposes?
A: It is possible that your most recently submitted cost report will be audited for PPS purposes. The Agency has not specifically set a “cut-off” for dates of acceptance for cost reports that will be audited for PPS.
Q: Can I get a breakdown of my quality scoring points across the various measures?
A: The Agency is planning on releasing a quality scoring sheet across each measure in the coming weeks that will allow a provider to see how they score on each measure.
As we move closer to the transition date of October 1, we will continue to monitor the status of the new Long Term Care Plan the Agency will release in August and post questions and answers through this blog. For more detailed information and guidance about how you can manage your individual resources and maximize your potential under PPS, consult your friendly reimbursement specialist.