DOH Briefs MLTC Plans, Associations on Recent Rate Changes, Policy Updates

Situation Report | January 18, 2021

The state Department of Health (DOH) held two briefings for Managed Long Term Care (MLTC) plans and association representatives last week on general policy updates as well as the status of MLTC rate adjustments, reconciliations, and premium rate calculations.

At its monthly Managed Care Policy and Planning meeting, DOH representatives presented the latest MLTC enrollment numbers (available in the slide deck here). Plans were also reminded of the following reports and their due dates:

  • The Medicaid Medical Loss Ratio (MLR) Report for State Fiscal Year (SFY) 2017-18 rate adjustments is finalized for all lines of business except Fully Integrated Duals Advantage (FIDA). DOH received additional guidance from the U.S. Centers for Medicare and Medicaid Services (CMS) on October 15 pertaining to resubmission of MLR reports when there is a retroactive rate adjustment. Plans are required to resubmit the report by February 1, 2021.
  • The Medicaid MLR Report for SFY 2019-20 will be posted this month. Plans will have 60 days to complete it.
  • The Fourth Quarter Medicaid Managed Care Operating Reports (MMCORs) for each plan are due April 1, 2021.
  • The Value Based Payment Tracking Report (VBPTR) for the 3rd Quarter of SFY 2020-21 is due February 5, 2021.

DOH representatives also provided an update on the nursing home benefit limitation, including DOH’s planned “Batch Process” disenrollment of members who will be converted to Medicaid fee-for-service (FFS) for ongoing coverage of their long term nursing home care, effective April 1, 2021. DOH told MLTCs to continue working with their members’ associated nursing homes to ensure that the completed LDSS 3559 form (“Residential Health Care Facility Report of Medicaid Recipient Admission/Discharge/Readmission/Change in Status”) or an approved local equivalent has been provided to the local department of social services (LDSS).

Plans were also reminded of the newly issued New York State Medicaid Coverage Policy and Billing Guidance for the Administration of COVID-19 Vaccines Authorized for Emergency Use. The guidance stresses that plans and providers are expected to negotiate a reasonable rate to ensure member access to providers who are qualified to administer the vaccine. DOH noted that there is no payment for the vaccine ingredient but only for the administration of it.

Finance Issues

For the financing meeting, DOH was joined by its contracted actuary, Deloitte.

The following rate adjustments, discussed at the meeting, raise troubling concerns for the financial stability of plans amid a public health emergency that is already causing enormous stresses on the long term care system:

  • COVID-19 rate reductions.
  • Enrollment adjustments to reflect the new nursing home benefit limitation.
  • A nursing home benchmark adjustment to reflect capital budget action.
  • Personal care and consumer directed personal assistant program (CDPAP) benchmark adjustment to reflect previous budget action.
  • Updated acuity factors and risk scores.

HCA has repeatedly raised concerns to the Department about the financial stability of plans and their network providers amid rising costs in the pandemic, new administrative cost burdens, and patients’ increasing clinical acuity. In the lead-up to this week’s state budget release and our upcoming state advocacy programs, HCA is preparing a comprehensive data analysis on system-wide finance trends as part of our three-point advocacy message for financial stability, investment in workforce, and regulatory relief.