Value Based Payment Quality Improvement Program (VBP QIP)
Frequently Asked Questions
- VBP QIP FAQs is also available in Portable Document Format (PDF, 207KB)
As of 7/12/2016
| Item # | Category | Question | Response |
|---|---|---|---|
| 1 | Application | Are MCOs able to participate in the program? | Yes, all MCOs may seek to participate in this program so long as the MCO serves the Medicaid population. |
| 2 | Application | Is the Application equivalent to the letter of intent? | Yes, the applications are the equivalent of a letter of intent to participate in VBP QIP. |
| 3 | Application | What exactly is DOH looking for in the submitted initial application? | DOH expects each MCO to outline what the VBP system would look like for a distressed provider. At a minimum, DOH expects each MCO to respond to each section of the application. MCOs approved to participate will need to also develop governance documents and Facility transformation templates. |
| 4 | Application | Do the MCOs need to resubmit an application every year? | No, the MCOs will not need to re-submit an application each year of the program. Only new MCOs looking to participate in VBP QIP will need to submit an application. |
| 5 | Application | Can any Facility apply to be in VBP QIP? | Facilities do not need to apply to participate in VBP QIP. Qualified Facilities were selected and approved by DOH to participate. Only MCOs need to apply to participate in the program. |
| 6 | MCO-PPS- Facility Assignment | What factors are being considered for pairing MCOs to PPSs/Facilities? | In order to pair the MCOs to PPSs, DOH first looked at the Plan to PPS attribution and then at the Facility's attribution. DOH then looked at the amount of dollars that needed to be flowed through MCOs and attempted to mitigate any wide variations in the Per Member Per Month (PMPM) rate calculation to the best of its ability. |
| 7 | MCO-PPS- Facility Assignment | Is the attribution based on the attribution to the PPS or the facility? | The attribution is calculated at the PPS level. Estimated need dollar amounts are applied to the Facilities which are then used to calculate the rates for the PMPM. |
| 8 | MCO-PPS- Facility Assignment | Will the Department approve programs or transformation plans associated with VBP QIP? | DOH will only weigh-in on Governance Plans to be developed by the MCOs; not the Facility Plans. However, DOH will look to issue a template that the VBP QIP participants can leverage to create individual Facility Plans. Though the MCO has ultimate approval authority, DOH expects the partners to collaborate, meaning the MCO should reach out to the PPS for its input. |
| 9 | MCO-PPS- Facility Assignment | If more than one MCO is working with the same PPS, to what degree can the MCOs collaborate on milestones and metrics? | In the rare case that a single Facility is working with more than one MCO through its PPS for VBP QIP, DOH expects the MCOs to collaborate with each other. The Facility should not be made to create more than one separate Facility Plan, so milestones and metrics should align between the MCOs. In general, the MCOs can collaborate to the extent that their collaboration ensures that the Facility is not put under undue pressure because it is working with more than one MCO. |
| 10 | MCO-PPS- Facility Assignment | Is this program restricted to Facilities that are or were once part of VAPAP? | Currently only previously eligible VAPAP Facilities are participating in VBP QIP. |
| 11 | Structure and Timeline | When does Year 1 start for metrics and payments? How are the years in the DOH vision attributed? | Year 1 is State Fiscal Year (SFY) 2015-2016, thus it starts April 2015. Year 2 will be SFY 2016-2017 and accordingly starts April 2016, and so on for all future years of the program. |
| 12 | Structure and Timeline | How long will VBP QIP run for? | VBP QIP will be a 5-year program that runs in line with DSRIP. |
| 13 | Structure and Timeline | When will VBP QIP payments begin? | For Group 1 VBP QIP participants, payments have begun. For Group 2 Facilities, DOH has issued the first payment to the MCOs in July 2016. |
| 14 | Structure and Timeline | When do the VBP QIP contracts need to be finalized for Group 2 participants, who joined the Program in April 2016? | DOH expects the MCOs, PPS, and Facilities in Group 2 to have a contract or an agreement in place by July 1 st , 2016. |
| 15 | Structure and Timeline | What are the MCOs specifically administering related to VBP QIP? | The MCOs will be overseeing the transformation of the Facility to a VBP model consistent with the Department's VBP Roadmap. Specifically, the MCO will monitor the Facility to ensure that it meets program objectives, and will forward payment based on the achievement of these milestones. |
| 16 | Structure and Timeline | What is the purpose of the VBP QIP MCO Governance Plan? | The purpose of the Governance Plan is to document a detailed outline of the MCOs plan for program governance over the 5 years of VBP QIP. The administration of the program and evaluation of the Facility's progress is the main role of participating MCOs, so the Governance Document is to be a thorough plan that oversees a smooth transition to VBP. |
| 17 | Structure and Timeline | How will the VBP QIP MCO Governance Plan be assessed and scored? | DOH previously provided feedback for each of the MCO's Governance plan, which DOH expects each MCO to act upon by making the suggested improvements. DOH's feedback was not a formal score, but was designed to provide guidance on where the State felt that the MCO's Governance Plan could be improved. If the MCO wishes to receive technical assistance from the State, the MCO can request such and the State will provide it. Group 1 Governance Plans are due to DOH on September 16, 2016. Group 2 Governance Plans are due to DOH on December 10, 2016. |
| 18 | Structure and Timeline | What is the role of the MCOs throughout VBP QIP? | As described in the VBP QIP DY2 Guidance Webinar held on June 8, 2016, the role of the MCO is as follows:
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| 19 | Structure and Timeline | What is the role of the PPSs throughout VBP QIP? | As described in the VBP QIP DY2 Guidance Webinar held on June 8, 2016, the role of the PPS is as follows:
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| 20 | Structure and Timeline | Does DOH envision a one-to- one relationship between MCO and Facility? | This will almost always be the case, but there may be instances where this may not be true depending on current quality pool payments and other complexities. |
| 21 | Structure and Timeline | In the VBP QIP Governance Document, what is the difference between a baseline metric and milestone? | In the Governance Document, milestones are tasks, deliverables, or states of progress that only require reported to achieve successful completion. Metrics are measured to determine performance, and performance of a certain degree above the Facility's baseline is required to achieve successful completion. |
| 22 | Structure and Timeline | In the light of phase 2 VBP QIP contracting, are phase 1 VBP QIP milestones valid? | Yes, VBP QIP phase 1 milestones will still be valid once all participants move to phase 2. The phased approach to VBP QIP's development was initially developed to separate the 'pre-VBP/program design' and 'post-VBP/program implementation' sections of the program from each other. Phase 1 VBP QIP contracts were to cover the duration of the program before VBP contracts between Facilities and MCOs were in place, and phase 2 VBP QIP contracts were to cover the period after that, during which the Facilities and their MCOs would have level 1 (or greater) VBP contracts in place. |
| 23 | Structure and Timeline | Is there an MCO Governance Plan template? | No. However, DOH distributed a revised VBP QIP Governance Plan Scorecard for MCOs to use when completing their Governance Plans. Additionally, DOH provided guidance on Governance Plan components in the VBP QIP application. If further clarification is necessary, DOH recommends that Plans contract their respective Associations. |
| 24 | Structure and Timeline | What is the difference between VBP and VBP QIP performance measures for Pay for Reporting (P4R) in DY1-DY2 and Pay for Performance (P4P) during DY3- DY5? | The purpose of VBP QIP is to transition financially distressed Facilities to VBP, improve their quality of care, and as a result, achieve financial sustainability over the duration of the Program. The measures established in the Facility Plan should reflect the purpose of VBP and align to the metrics in the VBP Roadmap provided by DOH. |
| 25 | Facility Plan | Do the transformation plans for VBP QIP already exist? | No. As part of the Program, each MCO will be responsible for developing a Facility VBP Plan template for the Facility to complete, with guidance and support from their MCO and PPS. Facilities who are involved in VAPAP may already have a transformational plan. However, these plans were developed based on transforming to become financially sustainable primarily in the short-term, but do not include information on transitioning to VBP. This is what will need to be addressed in the VBP QIP transformational plan. While some content from the VAPAP plan can likely be used, a new Plan will need to be developed by each Facility entering VBP QIP from VAPAP. In addition, DOH provided recommendations for to the MCOs to build the Facility VBP Plan Templates, and 1 st year VBP QIP MCOs have developed Facility Plan templates that can be shared with new participants. |
| 26 | Facility Plan | What happens if the MCOs do not approve of the Facility VBP Plans that are approved by the PPSs? | DOH is aware that there may be disagreements between the MCOs and the PPSs related to the transformation plans developed by the Facilities for VBP QIP. DOH expects the MCOs and PPSs to work together and come to a consensus with the Facilities to identify a plan that is mutually agreed upon by all the parties involved. |
| 27 | Facility Plan | What level of detail is DOH expecting in the Facility Plan? | Each Facility VBP Plan needs to demonstrate how the Facility will transform to VBP consistent with the Department's VBP Roadmap. The Facility VBP Plans should be prepared by the Facilities in a collaborative effort with the MCOs and PPSs. Each Plan will be different, depending on the template developed by the MCO. The Facility VBP Plan will focus on achieving three goals: financial sustainability, transition to VBP, and improved quality of care. The Plan must be reviewed and approved by the MCO and PPS. It is expected that these Plans will be living documents and will change as the details around VBP are further established. DOH will continue to provide further guidance on what the expectations will be regarding updates to these plans. |
| 28 | Facility Plan | Can the Facility Plan template, provided by DOH in DY1, be used for DY2? | DOH provided a Facility Plan template to MCOs in DY1 that can be used by Group 2 MCOs entering VBP QIP in DY2. Like with the Group 1 MCOs, the Facility Plan template should be customized by each MCO to fit its own program. The template should be used by Facilities to create their Facility Plan. |
| 29 | Contracts and Plans | Do you envision a model contract between the MCO, PPS, and Facility? | DOH has collaborated with the Hospital and Health Plan Associations to provide a contractual template to facilitate VBP QIP contracting. Ultimately, it is the responsibility of the MCO, PPS, and Facilities to negotiate contracts that are acceptable to all parties to facilitate the implementation of their individual program. |
| 30 | Contracts and Plans | Does DOH envision the use of contractual provision obligating MCOs to disburse funds to the PPS only upon demonstration by the Facility that the benchmarks have been met? | DOH expects contractual provisions, such as achievement of metrics, to be included in the VBP QIP agreements to govern the distribution of funds. |
| 31 | Contracts and Plans | Are the dollar amounts being contracted for known? Is there a set amount that would flow through one of these contracts? | An amount will be built into the MCO's premium based on the estimated need of the VBP QIP Facilities. |
| 32 | Contracts and Plans | Will DOH consider deeper involvement or an escalation process for Facilities that do not make progress toward the agreed upon goals set forth in their Facility Plans? | It is first and foremost the responsibility of the MCO to oversee the implementation of VBP QIP by its paired Facilities. DOH should be notified in the case that any party is not meeting their responsibilities. This includes Facilities not meeting their goals set forth in the Facility Plans, and also MCOs and PPS that fail to provide oversight and guidance to the Facility. |
| 33 | Contracts and Plans | Will contracting be for a specific sub population? | No, the singular VBP QIP contract between the Facility, its PPS, and its MCO (or, in special cases, multiple MCOs) will cover the entire program, inclusive of all of the Facility's operations, and inclusive of all of the patient populations it serves. |
| 34 | Contracts and Plans | What happens a contract between an MCO and PPS expires within the 5 years of VBP QIP and are not renewed? | The State expects MCOs, PPS, and Facilities to either renew contracts over the course of the Program or create a contract that lasts for the Program's duration. Ultimately, it is the responsibility of the participants to negotiate contracts that are acceptable to all parties, so that all aspects of the Program can progress uninterrupted. |
| 35 | Contracts and Plans | Do Facilities need to move to VBP contracting with all of their MCOs or just their paired VBP QIP MCO? | Facilities need to take steps towards transitioning to VBP QIP contracting with ALL of their MCOs to align VBP QIP with DSRIP. The MCO is not responsible for making sure the contracts occur, but is responsible for holding the Facility accountable and being a resource. |
| 36 | Contracts and Plans | What information should a Facility share with its paired MCO regarding other MCO contracts? | Facilities are expected to provide paired MCOs with attestations that they have Level 1 VBP contracts with all other MCOs that they work with by the beginning of DY3 of VBP QIP. |
| 37 | Contracts and Plans | When are Facilities expected to enter Level 1 contracting? | Facilities should enter Level 1 VBP contracts with its Medicaid MCOs by April 2017 (the start of DY3). The only exception to a Level 1 VBP contract between MCOs and the Facility could be when an MCO's patient population is insignificant compared to Facility's total population. The MCO should consult with the PPS to ensure that any exceptions do not impact the PPS's objective, and that the Facility still maintains compliance with the VBP Roadmap. |
| 38 | Contracts and Plans | According to DOH, what will constitute a "small" patient population for which a Facility would not need to enter in a Level 1 VBP contract with an MCO? | Facilities should enter Level 1 VBP contracts with all of its MCOs. However, the Department understands that there are instances, in the case of small populations, where it is not appropriate to enter VBP contracts. DOH does not have a specific number or a percentage of patient population that would be considered "small/insignificant." Facilities and their VBP QIP partners should perform their own analysis to make this determination. The MCO should consult with the PPS to ensure that any exceptions do not impact the PPS's objective, and that the Facility still maintains compliance with the VBP Roadmap. |
| 39 | VBP QIP Disbursement | How do you envision the division of the dollars when multiple PPSs deal with a Facility? | In most cases, a Facility is paired with one PPS and one MCO. Though there are some special cases where more than one MCO is paired with the same Facility, there is never a case where multiple PPS are paired with the same Facility. |
| 40 | VBP QIP Disbursement | Will the PPS' receive an administration fee as well? | No, at this time the PPSs will not receive an administration fee for participating in this program. PPSs were rewarded bonuses in their DSRIP Applications for taking on distressed partners, giving the PPS a higher valuation. Beyond helping ensure the stability of providers and the health system in the PPS's region, PPS are also expected to work with these distressed partners in their VBP QIP transformation in exchange for the aforementioned bonus. |
| 41 | VBP QIP Disbursement | Should MCOs prepare to provide funding for VBP QIP before payment from DOH? | It is the State's commitment to ensure that MCOs have adequate resources to administrate the Program without having MCOs advance funds prior to receiving programmatic funds from the State. This includes the State releasing funds early, initiating rate adjustments, expediting reconciliations for prior-year payments, and the development of a set funds flow schedule so that all parties can anticipate and plan for payment. |
| 42 | VBP QIP Disbursement | Will there be a guidance issued about how the funds should be accounted for when they are flowed down to the Facilities? Are MCOs expected to monitor the funds moving to the Facility? | DOH will be looking for the MCOs to report in the Medicaid Managed Care Operating Report (MMCOR) on the flow of funds for VBP QIP. There will be accountability via cost reports and in that manner the funds will be reconciled and validated. It is important to have a complete tracking system of the funds being flowed down from the MCO to the PPS and ultimately to the Facility. |
| 43 | VBP QIP Disbursement | What type of audit authority will ensure that the money gets to the Facilities and that they are used towards VBP? | Both MCOs and PPSs will be held accountable for the flow of funds through MMCOR reporting. The MCO is responsible for sending money to the PPS and making sure the money is then transferred to the Facility, but once a Facility meets its milestones, it is awarded a performance payment that can be used as it sees fit without MCO oversight. The MCO is not responsible for auditing the Facility's expenditure of VBP QIP payments. The MCO's responsibility is to be a resource to the Facility, as it monitors and evaluates the Facility's progress throughout the 5 years of VBP QIP. |
| 44 | VBP QIP Disbursement | Will the distribution and proportion of funds change as other Facilities enter the program? | Yes, both the distribution and proportion of funds can change as other Facilities enter the VBP QIP, and as Facilities transform and gain financial stability through VBP. DOH will provide updated annual figures for VBP QIP Facilities every year. |
| 45 | VBP QIP Disbursement | How will the money be distributed over the 5 years of the program? | Each year will have its own distribution. It is expected that each year of the program will have an amount allocated for distribution. However, the distribution to the Facilities may differ based on the need and the number of participants. DOH expects to develop a set funds flow schedule so all parties can better anticipate and plan for payment. |
| 46 | VBP QIP Disbursement | Will the proposed 5% administrative fee be offered to the MCOs? | The current proposed administrative fee is 5% of the total transaction. |
| 47 | VBP QIP Disbursement | Do you see the 5% administrative fee increasing with time since the MCOs see that there will be more work as they move from just paying for reporting to being more involved in the program? | At this time, only the current proposed administrative fee of 5% of the total transaction is being considered. |
| 48 | VBP QIP Disbursement | Will payments pursuant to this program be segregated for cost reporting and other purposes? | Payments for this program will be segregated on the MCOs' Premium Schedule Bs and addendum schedules for cost reporting and other purposes within the cost reports (MMCOR). For those plans participating in the VBP QIP program, the cost report reporting directions can be found in the MMCOR Instructions located in the Healthcare Financial Data Gateway (HFDG) within the Health Commerce System (HCS). |
| 49 | VBP QIP Disbursement | Will a gross up of premium be added on to cover any required statutory reserves? | Yes, a gross up of premium will be added to cover any required statutory reserves. |
| 50 | VBP QIP Disbursement | Are VBP QIP budget amounts determined on a hospital-by- hospital basis? | Yes, VBP QIP allocations are determined by looking at each Facility and working with the Health Economics Team at OPCHSM to understand the level of financial distress that the Facility is in. Then calculations are done to determine the amount of money needed to sustain the Facility and allow them to move towards VBP contracting. For these calculations, DOH uses historical data, audits, budgets, and other sets of financial information to determine the VBP QIP funding amount. |
| 51 | VBP QIP Disbursement | For Group 2 VBP QIP participants starting in April 2016, what is the earliest date for funding? | As soon as all the contracts are signed, and Managed Care agreements are finalized, then funding can flow in terms of the State share advance. DOH expects a July first payment |
| 52 | Other | If an MCO doesn't participate will they see a rate cut to help fund VBP QIP? Is the 5% over and above what is in the April 2015 rate? | No, MCOs will not experience a rate cut should it choose to not participate in VBP QIP. The 5% on the transaction is over and above what will be noted in the April 2015 rate. |
| 53 | Other | Will there be a specific line item where VBP QIP funds can be tracked? | Yes, there will be a specific line item to identify the VBP QIP funds within the MMCOR. There will be segregated adjustments in the MCOs' Schedule B's and addendum schedules so that MCOs can see the funds that are associated with surplus, taxes, additional administration, and what is flowed down to the Facilities. |
| 54 | Other | Will the rates be sent to CMS for approval? | Yes, the rates will be sent to CMS for approval. |
| 55 | Other | Will payments pursuant to this program not be counted toward minimum loss ratio (MLR) calculation? | No, at the moment the VBP QIP funds will count towards the MLR calculation. Should this change, DOH will provide guidance to the MCOs. |
| 56 | Other | Will the payments pursuant to this program affect total funding otherwise planned for the Medicaid quality incentive? | The payments under VBP QIP will not affect total funding planned for the existing Medicaid quality incentive program premium add-on. |
| 57 | Other | Is the program going to be based on shared savings, shared risk, or both? | It could be either, or both, depending on the MCO- Facility contract. See the DOH's VBP Roadmap for more detail on the kinds of VBP contracts available for MCOs and Facilities to enter into as the Facility transitions to VBP. |
| 58 | Other | Does this program affect the upper payment limit? | No, VBP QIP payments do not affect the upper payment limit. |
| 59 | Other | How will the State handle the coordination of communication between DOH and VBP QIP participants as well as between program participants? | To ensure an environment that promotes open dialogue and transparency, DOH expects to continue having one-on-one conversations with all VBP QIP participants. DOH also plans to develop an all-parties contact list, which will have main points of contact from each participant, and will distribute this list to all of the program's participants. Moving forward, DOH will be sure to inform participants of all Program developments in a timely manner as well as create a channel to ensure that DOH is immediately made aware of any party that is not fulfilling its programmatic obligations. DOH will also hold a monthly open forum WebEx every third Wednesday of each month for all participants to attend. |
| 60 | Other | What are the next steps for Group 2 MCOs participating in VBP QIP? | DOH has approved certain MCOs to participate in VBP QIP. MCOs are expected to reach out to their paired Facilities and begin contract negotiations. Upon execution of contract agreements, MCOs should gather PPS input and then develop Facility Plan templates that will be sent to Facilities for completion. |
| 61 | Other | Are Facilities required to submit monthly financial reports to MCOs? | DOH expects Facilities to report on contractual obligations with their VBP QIP paired MCOs. |
| 62 | Other | What should a Facility do if it does not want to contract with an MCO / participate in VBP QIP? | A Facility should contact DOH immediately if it does not want to contract with an MCO or participate in the Program. Please note, VBP QIP is a voluntary program. There are few, if any, alternative programs for financial distressed Facilities. |
| 63 | Other | Is VBP QIP in compliance with State and Federal regulations? | Yes. VBP QIP is in compliance with State and Federal regulations. The Medicaid Director, Jason Helgerson, issued a formal letter to Program participants at the initiation of VBP QIP, which stated that the Program is in compliance with State and Federal Regulations. The State stands by this letter and affirms that the design of the program and the payments that have been made for the prior year are in compliance as implemented. The State will monitor the program to ensure its continued compliance with State and Federal law. |
VBP QIP DY1 (SFY2015-16) Pairings Table
| MCO | PPS | Facility |
|---|---|---|
| Fidelis | Maimonides Medical Center Montefiore Hudson Valley Collaborative Nassau Queens Performing Provider System, LLC Refuah Community Health Collaborative Westchester Medical Center |
Interfaith Medical Center Kingsbrook Jewish Medical Center Montefiore-Mount Vernon Nyack Hospital St. John´s Episcopal Good Samaritan Hospital Suffern Bon Secours Charity Health Good Samaritan Hospital Suffern |
| HealthFirst | Advocate Community Providers | Brookdale Hospital |
| MVP | Montefiore Hudson Valley Collaborative Westchester Medical Center |
Montefiore - New Rochelle Health Alliance (Benedictine) |
| United Health Plan | Maimonides Medical Center | Wyckoff Heights Medical Center |
VBP QIP DY2 (SFY2016-17) Pairings Table
| MCO | PPS | Facility |
|---|---|---|
| Affinity | Advocate Community Providers Montefiore Hudson Valley Collaborative |
Brookdale Hospital St. Joseph´s Hospital |
| Amerigroup | Nassau Queens Performing Provider System, LLC | Brookdale Hospital |
| Excellus | Central New York Collaborative, Inc. Finger Lakes Performing Provider Systems, Inc. Mohawk Valley PPS |
Lewis County General Hospital St. James Mercy Hospital Orleans Community Hospital Wyoming County Community Health A O Fox Memorial Hospital |
| Fidelis | Maimonides Medical Center Montefiore Hudson Valley Collaborative Nassau Queens Performing Provider System, LLC Westchester Medical Center |
Interfaith Medical Center Kingsbrook Jewish Medical Center Montefiore-Mount Vernon Nyack Hospital St. John´s Episcopal Bon Secours Charity Health Good Samaritan Hospital Suffern |
| HealthFirst | Advocate Community Providers | Brookdale Hospital |
| MVP | Montefiore Hudson Valley Collaborative Westchester Medical Center |
Montefiore - New Rochelle Health Alliance (Benedictine) |
| United Health Plan | Central New York Care Collaborative, Inc. Maimonides Medical Center |
Rome Memorial Hospital Wyckoff Heights Medical Center |
| WellCare | Montefiore Hudson Valley Collaborative | St. Luke´s Hospital - Cornwall |
| TBD * | OneCity Health | NYC Health and Hospitals |
* Pairings still under review
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