As 2018 comes to an end, I’d like to take a brief minute to review the many changes involving reimbursement and financial issues that have and will continue to impact our long term provider friends.
The new “Generator Rule” (Rule) was ratified by the Legislature requiring compliance from skilled nursing and assisted living facility providers. Many problems hindered their ability to comply with the short timeframe, including limited resources and manpower necessary to install, inspect, and certify compliance. The new official deadline for compliance is January 1, 2019. However, providers can still go through the normal variance process to request additional time to become compliant with the Rule.
The 2018 hurricane season was relatively quiet until October 11 when Hurricane Michael made landfall and left a path of damage and destruction along the panhandle of Florida unlike anything ever experienced in North Florida. It was the third most intense hurricane to ever make landfall in the United States. There were approximately 61 skilled nursing facilities comprised of 7,300 beds directly or closely impacted by this disaster. As a result of the Prospective Payment System (PPS) reimbursement methodology, the Agency for Health Care Administration (AHCA) has refused all interim rate requests and maintains there is no provision in the Plan to assist providers damaged by the storm unless the Florida Legislature provides additional funding.
Our thoughts and prayers are still with those valiant providers who continue to provide the highest quality of care to their residents in the face of such tragedy. But this is Florida. We will not only survive, we will work together to make the future safer, more secure, and more heartening for the residents in our charge.
The Prospective Payment System (PPS) reimbursement methodology for Medicaid finally became reality on October 1, 2018. This change is without a doubt the biggest overhaul of the Medicaid reimbursement system for skilled nursing facilities in the state of Florida in 35 years. We worked side by side with the Agency for Health Care Administration (AHCA), FHCA staff, and member clients to develop a system that we hoped would be equitable, easily implemented, and protect providers from struggling financially during transition. We were successful in securing additional funds during the state budget process that allowed for more flexibility and increased overall reimbursement to providers.
As of the penning of this article, the new AHCA Long Term Care Plan is in its final stages and will answer many unanswered questions regarding audits, change of ownership requirements, Fair Rental Value calculations, quality measures, and several other issues important to skilled nursing facility providers. We here at MSL are dedicated to continuing our efforts to inform our clients and FHCA members and assist them in any way with changes as they occur and how to position themselves to succeed under the new reimbursement system.
In 2018, we also saw the re-procurement process of managed care providers for Medicaid claims processing and payments to skilled nursing facility providers. The Statewide Medicaid Managed Care program has undergone several changes that will impact providers over the next five years. The incorporation of new Managed Medical Assistance (MMA) program changes and implementation of a mandatory dental program will also impact providers as they go through the contracting process through the end of the implementation period in February 2019 and beyond.
So, what can we expect in 2019? Challenges for providers include reinstatement of PPS funding through the budget process to maintain adequate rates and PPS strategies on the Medicaid side. For Medicare, a massive overhaul to the reimbursement system comparable to PPS for Medicaid will come October 1 with the implementation of the Patient-Driven Payment Model. We at MSL are dedicated to assisting providers all around the state with reimbursement, financial, and compliance issues as we welcome the New Year.
From all of us at Moore Stephens Lovelace, we wish everyone Happy Holidays and a very happy and successful New Year.