VHCA has offered comments to the Department of Medical Assistance Services (DMAS) on two reforms of the Medicaid program with impact on nursing centers. The first reform, Medicaid Managed Long Term Services and Supports (MLTSS) represents a new managed care approach to Medicaid long term care recipients and services, including nursing center services.

MLTSS represents a statewide implementation (phased regionally) of mandatory managed care for virtually all Medicaid nursing center residents, among other covered groups. This program is not limited to the dual eligible population, as is the case under Commonwealth Coordinated Care (CCC), and will actually replace CCC for the CCC-eligible population beginning in January 2018. The MLTSS program is currently scheduled to begin its phased implantation as early as March 2017, although DMAS has a significant amount of work to do quickly to meet that schedule.

The second reform, Delivery System Reform Incentive Payment (DSRIP) remains a bit more nebulous in terms of its practical impact on nursing center services. We have previously reported that VHCA staff are closely monitoring DSRIP discussions and are concerned, primarily due to lack of specificity, with two particular components. The first is the creation of new care planning/coordination bodies called Virginia Integration Partners (VIPs). Our concern with VIPs centers around what appears to be creation of an additional layer of care planning/coordination, on top of the interdisciplinary care team already in place at centers, plus the managed care entities required care planning/coordination function. Generally, the managed care coordination function under CCC has been found lacking by nursing centers and has resulted in additional administrative burden. In our comments to DMAS, we expressed concern that VHCA members do not want this repeated and expanded with the VIPs.

The second DSRIP component we are monitoring closely is the discussion around value-based reimbursement. While we understand the concept, it is difficult to understand how such an approach works under Medicaid given the already existing lower-than-cost reimbursement. We have suggested that the concept of rewarding quality improvements could work as a payment enhancement, but not as a “quality withhold” or “episode of care” approach that is based on inadequate reimbursement already. We will continue to monitor these discussions going forward.

DMAS is seeking federal authority to implement these two major reforms in a combined §1115 Demonstration Waiver from the Centers for Medicare and Medicaid Services (CMS). As part of that waiver application, DMAS, and subsequently CMS, must seek public comment on the proposal. DMAS’ initial application was out for public comment through January 6. To read VHCA’s comments in full, click here. If you have any questions or would like more details on these two reforms, contact Steve Ford.