FHCA offers a series of recommendations
By Tom Parker
As previously reported during the 2017 legislative session, the Medicaid Prospective Payment System (PPS) was passed with an implementation date of October 1, 2018. FHCA successfully advocated for the creation of a workgroup that would address potential changes or updates to the PPS after the initial three-year transition period. During end-of-session budget negotiations, the workgroup’s timeline was significantly modified and a December 1, 2017, deadline was established for the report due to the Senate President, Speaker of the House and Governor. The PPS Working Group consists of 11 members appointed by Agency for Health Care Administration (AHCA) Secretary Justin Senior. FHCA has been well represented, with members on the Working Group including:
- Bob Asztalos, Chief Lobbyist, FHCA
- Martin Casper, Nursing Home Consultant, Hampton Court Nursing and Rehabilitation Center
- Scott Hopes, Consultant, Consulate Health Care
- Keith Myers, President and CEO, MorseLife Health System
- Beverly Williams, Shareholder, Richards, Mitchell & Company, PA
- Jennifer Ziolkowski, SVP Finance, Opis Senior Services Group
The Working Group has held three public meetings in which they have addressed a myriad of topics related to the PPS. Members of FHCA’s Senior Clinicians Council and Reimbursement Committee have brought forth a number of ideas that have helped drive meaningful discussion at these meetings.
The position approved by the FHCA Board of Directors has been that PPS should be enacted as passed for the first three years until such time as we have new data that would justify re-evaluating and proposing any potential changes that may be needed. Additionally, any changes should be made prospectively not retroactively to ensure providers have time to adapt to changes prior to those changes having a rate impact. At this point, there is no new data available during AHCA’s and the Legislature’s work regarding PPS that would justify changing the system prior to being implemented. The final report, once available, will be shared with FHCA members and posted on the FHCA website. In addition, the Association will be actively working with the Legislature to ensure no changes to the PPS take place this year and that future changes are applied prospectively.
Adjustments needed to existing targets and ceilings applicable to rate calculations
FHCA believes the specified threshold in the system passed by the Legislature (floor) guards against creating incentives that jeopardize the quality care delivered and limits extreme financial gains. The floors as currently set will ensure funding is used to enhance quality through the Direct and Indirect Care rate components, and no change is needed
Adjustments needed to existing, direct care and indirect care subcomponents
FHCA supports the cost shifts as proposed by the Legislature. The components with the greatest impact on resident quality of life are included in the Direct Care component; costs with a strong impact are included in the Indirect Care component; and costs with the least impact are included in the Operating component.
Development and refinement of quality measures to be used
From the beginning, FHCA has stressed the importance of designing a quality model that is fluid and can be changed as new and more impactful quality measures are developed. To that end, while working with the Legislature, these measures were intentionally left out of statutes to make them easier to change as necessary.
Frequency of rebasing under PPS
FHCA supports the Legislature’s language to rebase every fourth year. This balances budget predictability with an opportunity to change rates as necessary for cost changes.
Exemptions from PPS
FHCA supports the Legislature’s exemptions from the PPS, which include pediatric and government-run facilities. Those facilities should remain reimbursed on a cost basis.
Considerations for supplemental payments as part of PPS
FHCA fully supports both supplemental payments created by the legislation. For several years, there has been tremendous need in Florida to adequately reimburse nursing facilities for providing care to ventilator-dependent patients; this add-on will go a long way to address the need. FHCA believes it is important that AHCA maintains the appropriate policies and procedures to ensure that centers are providing the necessary services to receive this limited add-on. FHCA discussed several other additional add-ons and believes there may be a need to address those in the future but only if there is additional funding to cover them.
Phase-in timeline, including the need for transition payments during phase-in
FHCA supports the five-year transition period that is in the legislation. The three-year period for holding harmless those centers experiencing rate reductions under the new system and the additional two years of limiting losses is a fair amount of time for providers to make the necessary changes to their business model.
Tom Parker is FHCA’s Director of Reimbursement. He can be reached at [email protected].