This week, the General Assembly approved Gov. Ralph Northam’s $20 per day add-on to Medicaid nursing facility reimbursement during the COVID-19 emergency. DMAS has informed VHCA-VCAL that once the governor signs the budget for the current year, which should be imminent, the implementation of the add-on can proceed. In advance of these steps being completed, this week VHCA-VCAL participated in multiple discussions with DMAS regarding the implementation of the add-on.

While the following is still preliminary, it is based on a draft guidance document from DMAS after these conversations with us and with the managed care plans. Until the guidance is formally provided by DMAS, you should only use this information for planning purposes.

The $20 per day add-on will be provided as a separate lump sum payment outside of the normal claims processing. In other words, the actual rates will not be changed to reflect an additional $20 per day. Claims will process normally and the add-on reimbursement will be through a separate roster billing process. Once finalized and fully approved, nursing facilities will use a spreadsheet template to submit Medicaid NF recipients with covered days for the period of March 12 through March 31 separately for each relevant payer (FFS and/or any of your residents’ CCC Plus MCOs).

We advocated for keeping the fields in the spreadsheet to a minimum, but they will likely include:

• Provider Name
• NPI
• Patient Last, First Name
• Medicaid Policy Number (if different from ID)
• Medicaid ID
• From and Thru dates
• Number of days claimed

An “Expected Payment” will populate automatically by multiplying the number of days by $20 and will total across all residents claimed. That total amount will then be paid. Once the template is finalized, you will be able to submit the March 12-31 add-on roster (we think in the next several days).

Because this is outside the normal claims processing systems, the CCC Plus plans are requesting a one-time submission of banking information for all your facilities and a copy of W-9s. We are recommending you do this as soon as possible (even before the DMAS guidance is finalized).  These should be sent encrypted to:

DMAS has informed us that the first payment by the MCOs may be delayed while the banking information is set-up. We are working to improve that outlook, but that is why we are recommending you provide that information as quickly as possible. Once set up, there will be expectations as to how long the payer can take to provide the payment, but the actual time will be driven primarily by when in the payment cycle the spreadsheets are provided (like your normal claim processing expectations).

Once this initial March submission occurs, NFs will follow the process above on a monthly basis, submitting the month’s recipients by the end of the first full week of the following month (i.e., April add-on claims would be submitted by May 8).

A few notes:

• DMAS is to be copied on the spreadsheet submissions to each of the MCOs
• Multi-facility providers are being asked to centrally bill all its facilities on one sheet (facilities distinguished and amounts totaled by NPI). EFT/check processes you provide will be followed for each facility represented.
• We are seeking clarification, but it appears NFs can include days for individuals not yet billed normally (for pending MDS assessments, etc.), but not for those with a pending eligibility status (subsequently, when they achieve eligibility, they could be included on a “current” add-on submission for retroactive days March 12 forward not yet billed).
• Hospice days will be included for the add-on, but how they are claimed will be different for FFS and CCC Plus.
  • CCC Plus: hospice days should be included on the same sheet with non-hospice days, as the MCOs pay the NFs directly for those days already – no distinction appears necessary (we have pushed back on a request to identify these, but will know for sure soon).
  • FFS: Because hospices are federally required to receive the payments for recipients residing in NFs, the $20 per day must first go to the hospice and then be passed through to the NF when the NF bills the hospice. As such, the NF will be asked to provide separate tabs by hospice provider with hospice days under FFS and subsequently bill the hospice for those days with the $20 add-on included.
• Reconciliation will occur with both DMAS (FFS) and the MCOs, but not until the end of the emergency period (with appropriate run-out).
• To the extent the $20 per day continues past June 30, 2020, DMAS is reserving the right to re-evaluate whether to incorporate the add-on into the actual rate

This is as much detail as we have today. Email Steve Ford with questions, but for now, it may be best to wait for a subsequent communication with the finalized guidance and templates.