DOH update on the April 2018 MDS Case-Mix Data Collection

Carl J. Pucci and Nancy Leveille in Finance & Reimbursement

NYSHFA participated in a call with the DOH this afternoon, September 26, 2018, following our Town Hall meeting this morning with SNF members. The Department validated the key points discussed on our agenda items from this morning. They are as follows:

On September 17th the DOH issued a DAL stating that it will be collecting MDS data for three census dates (January 25, April 25, 2018 & July 25, 2018) for the January 1, 2019 rates. This initiative is a result of the 2018-19 Enacted State Budget initiative to “rationalize nursing home case mix increases.” Within the 2018-19 Enacted State Budget, the State scored this plan at a $15M all-funds savings. As such, the DOH will be promulgating a methodology in the near future that will be utilized to secure no more than $15M in CMI savings. These funds will be collected in the first quarter of 2019 through the January 1, 2019 rates.

Therefore, the calculations that SNF have been conducting on their MDS scores during the April 25 census date period are very important to review, but the DOH is only looking at this time to capture the $15M that was enacted with the 2018 NYS Budget. They will be determining how to pull the $15M from this period from all SNF collectively.

Their intention is not to bankrupt any SNF, but just to meet the requirement of this year’s budget.

As we have discussed previously with members, DOH is allowing up until Thursday, September 27, 2018 to correct any MDS that may have errors in them for the April 25th census date period. If you have corrections, they need to be submitted as you normally do to CMS. These are corrections that may include missing a diagnosis, treatments, MD orders etc. that were not noted in your original submitted MDS to CMS for that resident. You must follow the directions for corrections noted in the MDS RAI manual Chapter 5 Section 5.7. Additionally, please note the Modification Request Section in Chapter 5 starting on page 5-11 related to the Assessment Reference Dates(ARD). There are very specific limitations for ARD.

The DOH is freezing the MDS data submitted for the census collection date of April 25, 2018 by September 28, 2018 for the purposes of the Medicaid rate setting for this year. Therefore, even though a SNF has the ability to correct MDS or submit missed MDS over a 3-year period, the data collected for the April 25 date is for NYS rate setting purposes and thus are freezing the data for that reason.

If a SNF missed submitting an MDS for a resident, they can submit a late MDS to CMS, but that MDS must begin on the current date that you noted the assessment was missed. Therefore, you cannot set an ARD back to before the April 25, 2018 time period. Consequently, if you missed one, you must start it on the current date. This is also outlined in the MDS RAI manual.

DOH will not take phone calls requesting changes to a SNF’s case mix at this time. They are going to review the data that is submitted through the normal process: whereby MDS’ are transmitted to CMS and then sent from CMS to the DOH.

NYSHFA also recommended to members this morning, the need to review each MDS before it is submitted to ensure that they are as accurate as possible. NYSHFA encourages SNF to consistently run each residents MDS’ RUG score, prior to submission, to validate you are capturing all the services you provided, not just during the case mix census date timeframes. 

Tomorrow, we will send out via e-mail the taped version of our EXTRA SNF member only Town Hall Meeting from this morning and any additional information we discussed. If you were unable to connect earlier, you will have the ability to listen to the presentation. Our regularly scheduled Town Hall Meetings are on the third Thursday of each month at 11:00 am. NYSHFA sent out the calendar in August for the fall schedule and we email you the Tuesday before each session with its agenda and call-in number. If for some reason you are not aware of our monthly town hall meetings, we ask that you contact Nancy Knapp at Nknapp@NYSHFA.org. to ensure your correct email is on file with us. 

NYSHFA CONTACT: 

Carl J. Pucci
Chief Financial Officer
518-462-4800 x36 

Nancy Leveille, RN, MS
Executive Director
518-462-4800 x20