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HCA Gains Intro of Bill to Limit EPS Rebasing

Legislative intro occurs as DOH posts interim EPS rates, retroactive to April 1  

As the state legislative session enters its final days, HCA, working with association partners, has succeeded in advancing bipartisan legislation (S.5878 Hannon/A.8171 Gottfried) that would limit the impact of CHHA Medicaid rebasing for the Episodic Payment System (EPS).

The introduction of this legislation occurred at the same time that the Department separately posted the interim EPS rebasing rates to the Health Commerce System (HCS).

When CHHA EPS went into effect in 2011, the statute required a rebasing of the reimbursement rates every three years, beginning in 2015. The Department of Health’s calculations had previously called for an aggregate cut in reimbursement of $30 million and this fiscal impact was incorporated into the 2015-16 state budget. However, no actual language was included in the current state budget to set forth or limit the cut, and the Department has since advanced a more expansive plan for implementation of a rebasing methodology that would financially imperil CHHAs and the home care infrastructure overall.

The Department’s plan calls for reductions well beyond the $30 million amount built in the 2015-16 state fiscal plan, wielding across-the-board cuts of 12 percent on an interim basis, retroactive to April 1, 2015 through September 30, 2015, at which point the Department plans to revise the payment levels to complete the 2015 rebasing process.

Just this afternoon, the state Department of Health (DOH) posted the interim rebasing rates to reflect this 12 percent reduction to the current 2009 base year EPS payment rates. These rates, together with the accompanying Dear Administrator Letter (DAL), can be viewed by selecting the following item in the Rate Publication Selection List drop-down: “2015 CHHA EPS Interim Rebasing Adj-June 9, 2015.” The DAL provides additional detail on DOH’s interim 12 percent reduction to the current 2009 base year EPS rates (from April 1, 2015 through September 30, 2015) as well as a rate sheet showing each respective EPS rate code between 4810 through 4920 and the applicable interim rate associated with each code.

The purpose of S.5878/A.8171 is to limit any rebasing reductions to the level prescribed under the state fiscal plan.

HCA has joined allied associations on a memorandum supporting amendments to the rebasing process. The memo, signed by HCA, LeadingAge New York and the New York State Association of Health Care Providers, states: “While we oppose any such cuts to home care through the rebasing methodology, we are concerned that, absent language circumscribing the amount of the cut in the fiscal plan agreement, home care is vulnerable to the Department’s fiscal action.”

Please see the memo here.

The memo adds: “Home care cannot sustain such cuts, especially in the context of the myriad changes, new policies and models being implemented by the state which directly depend on home care services, and which require home care investments, not cutbacks.”

This legislation is the latest bill advanced by HCA to support the home care system during this year’s legislative session. As we enter the final week of session, HCA will be sending an action alert as soon as tomorrow with specific instructions for advocacy on this bill and others that must be passed by the close of session (one week from today, on June 17) to achieve a successful state legislative session for home care. Please stay tuned for details and be sure your government-relations and executive staff are ready to make calls to the Legislature.

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