Value Based Payment Quality Improvement Program (VBP QIP)
Update Webinar
- Webinar also available in Portable Document Format (PDF)
December 2016
Today´s Agenda
- VBP QIP Updates
- Looking Ahead
- Final Thoughts
VBP QIP Updates
VBP QIP Financing Update
MCOs received two separate advances which provided funding through December 2016 for program implementation.
Additionally, the Department recently received approval for the April 2016 rate package.
- These rates contain funding retro to April 1, 2016 and for the remainder of SFY 2016-17 on prospective basis.
- The MCOs are scheduled to receive the funds on Wednesday, December 28, 2016.
The official recoupment of advances will occur in late January or early February 2017.
Note: The Department recouped advances made to MCOs in error before it had loaded the April 2016 rate package. The Department rectified this issue to ensure that MCOs have sufficient funds to implement the program.
Please e-mail bmcr@health.ny.gov with any questions that you may have regarding this issue.
VBP QIP Governance Documents
Group 2 MCO Governance Documents were due on Friday, December 9th, 2016.
DOH is set to release their reviews of the Group 2 MCOs’ Governance Documents by Friday, February 17th, 2017.
- DOH will provide feedback to MCOs, which they can use to further solidify their approach for overseeing their VBP QIP program.
- Strong governance documents not only reinforce the integrity of the program, but also set the operational and administrative expectations of the VBP QIP partners.
Based upon scoring, MCOs may need to or choose to update their Governance Documents. Updates will need to be submitted to DOH by Friday, March 24, 2017.
|top of page|VBP QIP Facility Plans
Group 2 VBP QIP Facility Plans were due on Friday, December 9th, 2016.
DOH is currently in the process of finalizing a VBP QIP Facility Plan Best Practices document.
- The document will outline innovative practices that participants may choose to adopt into their Facility Plans.
- Document will also provide additional state guidance on the following topics:
- Measure Selection
- Measure Reporting
- Measure Evaluation
- Funds Flow (P4R vs. P4P Distribution)
- Penalties & Credits
- Contracting Thresholds (All should always be the goal)
The Facility Plan Best Practices document is scheduled to be released to VBP QIP participants on Tuesday, January 17th, 2017.
- DOH highly recommends that partners review the document and consider making updates to their Facility Plans based on the recommendations in the Facility Plan Best Practices document.
- Immediately after the release of the document, DOH will be looking to schedule individual meetings with each VBP QIP facility and their VBP QIP partners to discuss the document as well as other observations that were made during DOH’s review of the Facility Plans.
Revised Facility Plans are to be submitted to DOH by Wednesday March 15th, 2017.
- Documents are to be submitted to the VBP QIP inbox (vbp_qip@health.ny.gov).
VBP QIP Timeline Update
Due to the time needed to not only update VBP Facility plans, but also to enter into meaningful VBP Arrangements, the decision was made to adjust the VBP QIP timeline:
- The deadline for facilities to be in Level 1 VBP contracts with ALL of its contracted Medicaid MCOs has shifted from the original deadline of April 1st, 2017 to April 1st, 2018.
- Two additional milestones have now been added to the VBP QIP Timeline.
Inability to meet these deadlines will result in financial penalties to facilities. - VBP QIP facilities must provide VBP QIP MCO partner & DOH with letters of intent to sign VBP Level 1 VBP contracts agreements with ALL of its Medicaid MCO partners by April 1st, 2017.
- LOI template will be provided by DOH in early January 2017.
- DOH expects facilities to submit a separate LOI for each Medicaid MCO partner.
- Facilities must have at least one Level 1 VBP contract signed by July 1st, 2017.
| Milestone | Due Date |
|---|---|
| DOH distributes the Facility Plan Guidance Packet to VBP QIP partners | January 17, 2017 |
| Monthly VBP QIP Update Webinar | January 18, 2017 |
| DOH Arranges Facility Plan Discussions with MCO/PPS/Facility Partnerships | January 23-31, 2017 |
| DOH reviews VBP QIP MCO Governance Document and distributes Scorecard to MCOs (Group 2) | February 17, 2017 |
| VBP QIP DY3 Guidance Released | March 10, 2017 |
| Facilities submit their updated, MCO approved, Facility Plan to DOH | March 15, 2017 |
| MCOs submit a revised VBP QIP Governance Document to DOH for review (Group 2) | March 24, 2017 |
| Facilities must provide DOH with LOIs to sign Level 1 VBP contracts with all MCOs by 4/1/2018 | April 1, 2017 (DY3) |
| Facilities must have at least one Level 1 VBP contract signed | July 1, 2017 |
| Facilities must have Level 1 VBP contracts signed with ALL their Medicaid MCO partners | April 1, 2018 |
Acronyms:
MCO – Managed Care Organizations
PPS – Performing Provider Systems
DOH – Department of Health
DY – Demonstration Year
Looking Ahead
VBP QIP DY 3 Guidance Packet
Similar to the VBP QIP Demonstration Year (DY) 2 Guidance Packet that DOH distributed to participants, DOH plans on releasing a VBP QIP DY3 Guidance Packet.
- The purpose of this document is to provide VBP QIP participants information they need to progress into the third year of the program.
- DY3 Guidance will primary focus on VBP contracting efforts that need to be in place by the start of DY4 (April 1, 2018)
The Packet is expected to be released by Friday, March 10th, 2017.
If participants would like to see specific guidance in the DY3 Guidance packet please email the VBP QIP inbox (vbp_qip@health.ny.gov) no later than Friday, January 27th, 2017 with your suggestions.
- Associations are a good resource to relay information to DOH as well as an asset to participants to who want to better understand programmatic expectations
Contracting VBP: Top 4 Steps for Beginners
| 1 | Assess your readiness; address issues to be able to start at Level 1 |
| 2 | Understand what types of contracts you want to engage in based on the services you provide, the attributed population and outcome measures that impact savings, and the potential for realizing savings |
| 3 | Familiarize yourself with and utilize available resources (data from the State, technical assistance from potential partnering contractors, etc.) |
| 4 | Choose the partners that will help you succeed and that are adequate for the contracts you chose – build your partnerships |
Bolded print signifies priorities that facilities should be focusing on immediately
Facilities Responsibilities Going into DY3
Heading into DY3, VBP QIP facilities must:
- Review all current Medicaid MCO contracts
- Identify provisions which need modification to meet roadmap requirements for VBP contracts of Level 1 or above
- Re-assess network adequacy for chosen VBP arrangement
- Negotiate which provisions need modifications with the MCOs
- Review/Develop baseline budgets
- Develop and execute contracts with each MCO
- Evaluate the potential of joining larger VBP partnerships
Facilities do not need to send their VBP contract(s) with other MCOs to their VBP QIP MCO partner
- Facilities should provide an attestation to their VBP QIP MCO partner, signed by contracting VBP MCO stating that the MCO is in a Level 1 VBP contract with the facility for the other VBP contracts established.
Final Thoughts
Important Information
VBP Support Materials
VBP Resource Library:
- Path: DSRIP Homepage → Value Based Payment Reform → VBP Resource Library
- Link: https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/vbp_library
VBP Website:
- Path: DSRIP Homepage → Value Based Payment Reform
- Link: https://www.health.ny.gov/health_care/medicaid/redesign/dsrip/vbp_reform
Thank you for your continued support with VBP QIP!
- The next VBP QIP Update Webinar is scheduled for Wednesday, January 18st from 2:00 pm – 3:00 pm.
- Please let DOH know of any topics that you would like discussed during next month´s webinar by submitting your requested topics to the VBP QIP inbox (vbp.qip@health.ny.gov).
- The remainder of this webinar is reserved for Q&A and an open forum session.
For any further questions, please contact the VBP QIP inbox: vbp.qip@health.ny.gov
|top of page|Appendix A
Provider Contract Key Terms
Out of the entire list of terms these are the most important:
1. Payment Adjustments
- Need to understand how these activities will be handled (for example, the timeframe and notice requirements and payment implications)
- Timely filing of claims
- Adjustments to payments
- Claim disputes and dispute resolution
- Retroactive enrollments
- Recoupments
2. Insurance
- MCOs will require providers to have malpractice insurance and general liability insurance
- Provider should understand its insurance limits and policy restrictions (Is contractual indemnification allowed?)
3. Indemnification and Liability
- Contractual indemnification – mutuality
- An MCO can´t transfer liability for its own acts onto a health care provider
- Joint and several liability
4. Term and Termination
- Automatic renewal or defined contract term
- "For cause" versus "without cause" termination
- Standard for material breach
- Length of notice for termination and non–renewal
- Due process rights
5. Representations and Warranties
- Valid corporation and properly licensed, certified or designated by DOH, OMH or OASAS (licensure obligations can also apply to employees of the provider)
- Legally binding and enforceable
- Neither provider nor employees have been suspended or terminated from a federal healthcare program or convicted of a criminal offense related to Medicaid or Medicare
6. Amendment
- Mutual agreement, automatic or upon 30 days´ notice without objection
- Changes due to regulatory requirements
7. Assignment
- On notice or with consent
- Change of control
8. Notice to MCO in the event the provider has:
- Any lapse, revocation, termination or suspension of license
- Any lapse, revocation or cancellation of insurance
- A disciplinary action initiated by a government agency
- Excluded, suspended, debarred or sanctioned from a federal program
- A grievance or legal action filed by an enrollee against the provider
- An investigation, conviction or plea for fraud, a felony, or a misdemeanor
9. Dispute Resolution / Litigation
- Claim disputes vs. other disputes
- Venue and choice of law
- Internal dispute resolution mechanism
- Timeframe for resolution
- Identify key management titles with the authority to resolve disputes
- Alternative dispute resolution or mediation
- Binding or non-binding
- American Arbitration Association, American Health Lawyers Association, etc.
10. MCO´s right to monitor and audit its participating provider
Below are some of the key provisions covered by Law. Providers should expect their MCO to include these in the VBP Contracts:
- Provisional credentialing
- Medical necessity appeals
- External appeals
- Limits on prior authorization
- Prudent layperson
- Prompt pay – timeframes and interest
- Overpayments
- Claim submission timeframes and exceptions
- No balance billing of consumers
- Continuity of Care
- Term and Termination
- Sharing of enrollee medical records and other personal health information, including HIV, substance abuse (SA), and mental health (MH) records
- Consent obtained on Medicaid enrollment application
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