Legislative Issues Public Policy News

A Weekly Publication Of HCAHCAHCAHCAHCAHome Care Association of New York State

Helping New YorkersFeel RightAt Home

ASAPVolume 19, No. 42 November 14, 2014

Inside Inside Inside Inside Inside ASAPASAPASAPASAPASAP

See FIDA p. 2

UPCOMINGEDUCATIONDon’t miss out onthese importantprograms comingin December!

Dec. 5 Program Will Help Make

Sure You Are Ready For FIDADo you serve dual-eligible beneficiaries? Would you like to knowmore about getting your agency FIDA-friendly?

In December, the state will begin the process of enrollingabout 170,000 dual-eligible recipients into speciallyapproved managed care FIDA plans that will coordinateservices paid both by Medicare and Medicaid.

Are you ready for this major change in service delivery?

If you could use more information, ideas, tips to get startedand some potential networking contacts, then you willcertainly not want to miss HCA’s Are Your Ready ForFIDA? conference, just a few weeks away on December 5

in Albany.

Home care providers will need to strike up new contractualarrangements and navigate entirely different systems of

Brush Up on ACA, Wage, Exec

Comp & Other Legal Questions

During Dec. 10 Program on

Home Health Legal Updates

Now is a time like no other when home careagencies find themselves flooded with majorlegal questions streaming from a cascade ofstate and federal regulations.

The Affordable Care Act’s (ACA) ‘employermandate,’ the Department of Labor ’s‘companionship exemption’ changes, the state’slimits on executive compensation and

See LEGAL p. 3

Dec. 5 HCA Program Will Help Make Sure You Are Ready For FIDA....1Brush Up on Burning Legal Questions During Dec. 10 Program..........1Save the Date for Upcoming Education “Bootcamps”.......................3HCA Participates in OMIG Call on LTHHCP Audit Protocols..............4OMIG Holds Webinar on Annual Certification Process........................5Call for Nominations to HCA’s Board of Directors..............................5Coming Soon: HCA’s Financial Condition Survey.................................6Response Needed on ‘Companionship Exemption’ Survey..............72012 LHCSA Statistical Report Due November 21...............................7Deadlines, Timelines, Release Dates & More...............................8-9Cap Report Trends Medicaid Spending to State’s Projections..........10PHHPC Committee Reviews CHHA and LHCSA Applications..........11DSRIP Update...................................................................................11CMS to Hold Dec. 16 Call on 2015 F2F Process................................11OCR Issues Bulletin on HIPAA Privacy in Emergency Situations........12Advisory Issued on Pneumococcal Vaccine Recommendations.........12CMS Posts Hospice Updates..............................................................13OASIS Updates for Home Health Agencies......................................13NGS Updates: SMRC Appeals, ICD-10 Testing Next Week...............14HRA Issues Alert on Nursing Home Conversions.............................15HEAP Opens November 17................................................................15Publications................................................................................15

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ASAP is a weekly publication of the Home Care Association of NewYork State (HCA). Unless otherwise noted, all articles appearing inASAP are the property of the Home Care Association of New YorkState. Reuse of any content within this newsletter requires permissionfrom HCA.

Joanne Cunningham, jcunningham@hcanys.org

Roger L. Noyes, Director of Communications, rnoyes@hcanys.org

Al Cardillo, Executive Vice President, Policy & Programs, acardillo@hcanys.org

Patrick Conole, Vice President, Finance & Management, pconole@hcanys.org

Andrew Koski, Vice President, Program Policy and Services, akoski@hcanys.org

Laura Constable, Senior Director, Membership & Operations, lconstable@hcanys.org

Lynda Schoonbeek, Director of Education, lschoonbeek@hcanys.org

Mercedes Teague, Finance Manager, mteague@hcanys.org

Jenny Kerbein, Director of Governance and Special Projects, jkerbein@hcanys.org

Billi Hoen, Manager, Meeting and Events, bhoen@hcanys.org

Teresa Brown, Administrative Assistant, tbrown@hcanys.org

President:

Editor:

388 Broadway, 4th Floor, Albany, NY 12207Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org

Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

FIDA continued from p. 1

payment, regulatory oversight, service authorization, quality management andmore. This daylong conference is designed to help you.

HCA has gathered the state’s preeminent experts on FIDA to give youbackground and help you navigate all of the strategic decisions that you willneed to make. Topics include:

• Calling All Home Care Provider Agencies – Are You Ready for FIDA?

• New York State’s Perspective with Jason Helgerson, Medicaid Director,New York State Health Department

• How Do I Get Started?

• Data Is King.

• Structuring Your Agency to Be Ready for FIDA.

Online registration is at: https://www.eventville.com/search/groups.asp?CoordinatorGroupId=1002199Download the brochure here: http://www.hca-nys.org/documents/FIDABrochure12-5-14.pdf

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administrative expenditures – not to mention the wage parity law –are all changing the equation for your labor costs, human resourcesmanagement, and overall administration of your home care program,with huge legal implications.

On December 10, HCA has assembled a roster of state and federallegal experts for a daylong Home Health Legal Updates conferencewhich will provide a crash course on all of these legal hot topics,including the latest updates from the courts and any new regulatorydecisions that continue to change the applicability of theserequirements.

We’ll also discuss how to avoid pitfalls, and offer insights on how tomeet the challenges ahead.

Make sure your staff is well versed in all of these priority areas duringthis must-attend event for home health leaders, finance managers,human resource administrators and compliance officers.

Register online here: https://www.eventville.com/search/groups.asp?CoordinatorGroupId=1002199Download the brochure here: http://www.hca-nys.org/documents/HomeHealthLegalUpdateBrochure.pdf

Save the Date for Upcoming “Bootcamp” Programs

HCA is asking members to save the date for the following “SurvivalBootcamp” programs that are being planned for January andFebruary in New York City.

On January 8, we will offer a program on ways for Licensed HomeCare Services Agencies to maintain a compliant and effectiveworkforce in a managed care environment.

On February 12, we have invited the U.S. Department of Laborand state Department of Labor to provide information on changesin labor rules related to the elimination of the federal “companionshipexemption” and other regulations that affect home care providers.In addition, the New York City Department of Consumer Affairswill brief members on the city’s Paid Sick Leave law.

Program brochures will be finalized soon; in the meantime, markyour calendars for these blockbuster programs.

These are in addition to a previously announced December 11 program that will focus on surviving complianceand audit requirements, and ways to contain your workers’ compensation costs. The registration form is athttp://www.hca-nys.org/documents/SurvivalBootcampDec11-ComplianceandAudit.pdf.

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HCA Participates in OMIG Call on LTHHCP Audit Protocols

Today, HCA participated in a conference call with the state Office of the Medicaid Inspector General (OMIG)and other provider associations to provide feedback on draft revised audit protocols for the Long TermHome Health Care Program (LTHHCP).

A primary change in the draft protocol is the time period proposed for audit. The revised protocols proposeto cover periods of service prior to December 31, 2012, while the current audit protocols cover servicesdelivered prior to December 31, 2010. OMIG said that the extended audit for LTHHCP specifically isbecause LTHHCP patients are targeted for transition to managed care and the additional audit period wouldcapture the full period prior to the transition. HCA, however, indicated that virtually all other communitybased Medicaid patients have also been transitioned to managed care, and questioned why the LTHHCPprotocols would cover a different period from other settings. Certified Home Health Agency (CHHA)protocols only cover services delivered prior to December 31, 2010. OMIG agreed to review this issue.

Some of the other changes in the LTHHCP proposed protocol revisions include:

• Revised regulatory and program citations.

• New language on the first page background section.

• An increase from 120 days to 180 days for completion of the DMS-1 from a previously completedone.

• If the patient is receiving skilled and home health aide services, the RN or appropriate therapist mustmake an onsite visit (does not have to be a supervisory visit) and the home health aide does not have tobe present. However, the onsite visit must occur within two weeks prior to the date of services (anearlier version included 30 days prior but had to be a supervisory visit). This is similar to the CHHAaudit protocols. HCA had earlier raised objections about reducing the “30-day window” to two weekswhen the CHHA protocols were finalized, but the OMIG did not incorporate the change. It is thusapplying this same standard to the LTHHCP.

• If the patient is not receiving skilled services, the nurse must make a supervisory visit every 60 dayswhile the aide is providing care. This is similar to the CHHA protocols.

• The protocol covering supervision of personal care aides (PCA) has been revised to reflect the languagein the PCA audit protocols whereby nursing supervision visits are required every 90 days. In certaincounties, however, the protocol states that nursing supervision may only be required every six months,particularly for level one services.

HCA also raised concerns about OMIG applying the same audit protocols for home care providers undermanaged care as under Medicaid fee-for-service when their responsibilities and timeframes differ undermanaged care. OMIG said it is aware of the differences and will take them into account in such audits andlook to HCA and other associations for guidance.

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

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OMIG Holds Webinar on

Annual Certification Process

This week, the Office of the MedicaidInspector General (OMIG) held a webinarentitled “OMIG’s ComplianceCertification Process: December Annual& Enrolling Provider.”

The materials and audio version of theprogram are at http://www.omig.ny.gov/resources/webinars (webinar no. 23).

Most home care and other health careproviders are required to submit twocompliance certification statements toOMIG every December. Each certificationform will be available for completion fromDecember 1 to December 31 and OMIGsuggests that they be submitted during themiddle of December to avoid any delays.

First, providers who receive or make atleast $5 million in state Medicaidpayments (not including Medicaidmanaged care payments) during a federalfiscal year (October 1 to September 30)are required to certify that they are incompliance with the federal DeficitReduction Act (DRA).

The following document outlines whichfunds count towards the $5 millionthreshold: http://downloads.cms.gov/cmsgov/archived-downloads/SMDL/downloads/SMD032207Att1.pdf.

Under the DRA, these providers must:

• Establish written policies andprocedures that provide detailedinformation to their employees,management, contractors, andagents about federal and state falseclaims acts, whistleblowerprotections, and policies and

Call for Nominations to HCA’s Board

HCA is accepting nominations for our Board ofDirectors. Nominations are due February 2.

The Board’s principal task is to promote andimplement a vision and strategic policy direction for thehome care industry and the Association. Our Board iscomposed of 25 Directors who represent a variety ofprovider member organizations including CHHAs,MLTCs, LTHHCPs, Hospices, and LHCSAs. Inaddition, non-provider members (such as alliedorganizations or individuals knowledgeable in homecare, etc.) may also be elected to the Board of Directors.

HCA Board of Directors meetings are held five timesper year; however, the Chairperson may convene theBoard throughout the year by conference call. A BoardMember’s appointment is for a two-year term and thebylaws allow up to four consecutive two-yearappointment terms.

Board Members may be invited to participate in BoardCommitteeswhich includethe Executive,NominatingandGovernance,and Financeand InvestmentCommittees.

For moreinformation,pleasedownload thecall fornominations atthe back of thisweek’s ASAPand pleaseconsider anexceptionalcandidate forservice on your Association’s board.

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Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

procedures for detecting and preventing fraud, waste,and abuse.

• Include in an employee handbook (if any) specificdiscussion on federal and state false claims acts,whistleblower protections, and the provider’s policiesand procedures for detecting and preventing fraud,waste, and abuse.

• On or before January 1 of each year, certify that: theymaintain written policies; any employee handbookincludes materials, required under the DRA mandate;the materials have been properly adopted andpublished by the health care entity; and the materialshave been disseminated to employees, contractors, andagents.

More information on the DRA certification is athttp://www.omig.ny.gov/compliance/certification.

Secondly, home care and other health care providers mustcomplete and submit a state form, the New York State SocialServices Compliance Program Certification (by December 31 ofeach year) to certify that a compliance program is in place thatmeets the state’s requirements, including eight elementsoutlined at http://www.omig.ny.gov/mandatory-provider-compliance-programs-faqs. The form covers the period of2014.

Some important information about the certification processpresented during the webinar includes:

• The forms cannot be submitted until December 1.

• Separate certification forms must be submitted foreach of the provider’s Federal Employer IdentificationNumbers (FEIN).

• The certifying official on the state form should not bethe agency’s compliance officer, but it can be thecompliance officer on the DRA certification.

• It is a violation of statutory and regulatoryrequirements to not submit certification statements.

HCA advises members to listen to the webinar as it reviews allquestions and parts of both certification forms.

Coming Soon: HCA’s

Financial Condition

Survey It’s almost time again for homecare members to completeHCA’s annual home care

Financial Condition Survey,

which we will be sending to

members in the coming days.

As you know, this survey is acritical part of our 2015advocacy. Your answers will beanalyzed and included in our2015 home care financialcondition report, which weshowcase for our AdvocacyDay program and throughoutthe year. Our yearly financial conditionreport combines data fromHCA’s Medicaid claims andcost analyses, along with youraggregate survey answers to tellthe whole story about what ishappening financially in NewYork’s home care industry.(Here’s last year’s report: http://www.hca-nys.org/documents/NewYorkStateofHomeCare.pdf.)

Be on the lookout for moreinformation coming soon, andbe sure to participate in thisimportant effort.

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Member Assistance Needed on ‘Companionship Exemption’ Survey

HCA members are urged to complete a survey we developed in conjunction with LeadingAge NY, who is alsosurveying its members, on the potential fiscal impact of new federal wage and hour requirements starting January1, 2015 as a result of changes to the federal Fair Labor Standards Act (FLSA). The survey is at https://www.surveymonkey.com/s/FVG89PH. As covered in numerous communications to members, the U.S. Department of Labor has eliminated the“companionship exemption” for agencies that provide aide services. One of the ramifications is that aides whowork overtime in New York State must be paid at time-and-a-half of their regular wage instead of time-and-a-halfof the minimum wage. In addition, there are new record-keeping requirements for agencies employing “live-in”aides to track their actual hours worked, meal times and sleep time. Your responses to the survey will be kept strictly confidential. HCA and LeadingAge NY will use only aggregatedata to advocate for additional Medicaid funding for home care providers, managed care plans and workers. We need you to complete the survey questions by Tuesday, November 17. Thanks for taking the time to participatein this important advocacy tool.

2012 LHCSA Statistical Report Due on November 21

HCA reminds members that the 2012 Licensed Home Care Services Agency (LHCSA) Statistical Report is dueon November 21.

LHCSAs providing services in Assisted Living Programs (ALPs) must submit a Statistical Report for theirnon-ALP patients and a separate Statistical Report for their ALP patients.

The state Department of Health (DOH) encourages providers to submit the reports earlier than November21, as it anticipates system delays and longer wait times for support if providers wait until the due date.

The Certified Home Health Agency/Long Term Home Health Care Program Statistical Report and HospiceCost and Utilization Report for 2013 are expected to be released on November 17 and will be due January 9,2015.

All reports must be submitted electronically through the Health Commerce System (HCS). Questions shouldbe directed to HCStatRpts@health.state.ny.us.

HCA has published a list of other upcoming due dates and timetables on pages 8 and 9. The list includesimplementation timetables and other important policy occurrences on the horizon.

For more information, please contact the HCA Policy staff.

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Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

Statistical & Cost Reports

• 2012 LHCSA Statistical Reportreleased: October 6; due November21

• 2013 CHHA/LTHHCP StatisticalReport released: November 17; due:January 9, 2015

• 2013 Hospice Cost and UtilizationReport released: November 17; due:January 9, 2015

• 2013 LHCSA Statistical Reportreleased: December 8; due: January30, 2015

DSRIP

• Updated DSRIP Project Planapplication posted: November 12

• Capital Restructuring Financingapplication posted: November 14

• Third round of init ial attributionresults posted: mid-November

• Applicant Conference regarding theCapital Restructuring Financingprogram: November 21

• Submission of f inal partner lists:November 24

• Project Plan Application Toolpublished: November 28

• Vital Access Provider ExceptionResults published: early December

• Final attribution results released:mid-December

• Capital Restructuring Financingapplication due: mid-December

• Project Plan applications submitted:December 22

• Project Plan applications posted andpublic comments start: December 24

• Public comment period on ProjectPlan applications ends: January 26,2015

• Independent Assessor recommendationsmade public: February 2, 2015

• Implementation plan due from PerformingProvider Systems (PPSs): March 1, 2015

• Project Plan awards made: early March2015

• DSRIP year 1 begins: April 1, 2015

• First year 1 payment to PPSs: mid-April

2015

MLTC Transition

• Chenango, Cortland, Livingston, Ontario,Steuben, Tioga, Tompkins and Wayne:November

• Genesee, Orleans, Otsego and Wyoming:December

• Chautauqua, Chemung, Seneca, Schuyler,Yates, Allegany and Cattaraugus: January2015

• Clinton, Essex, Franklin, Hamilton,Jefferson, Lewis and St. Lawrence:February 2015

• DISCOs (Developmental DisabilitiesIndividual Support and Care CoordinationOrganization) Finance Section of Start-up

grant applications due: November 20

Conflict Free Evaluation and EnrollmentCenter Timeline

• Brooklyn, Queens, Nassau and StatenIsland: November

• Westchester and Suffolk: February 2015

• Columbia, Dutchess, Putnam, Rockland,Orange, Ulster, Greene, Sullivan, Warren,Washington, Saratoga, Fulton,Montgomery, Schoharie, Schenectady,Albany, Rensselaer, Erie, Monroe andOnondaga: March 2015

• Tompkins, Cortland, Tioga, Broome,Chenango, Otsego, Delaware, Wayne,Ontario, Livingston, Seneca, Cayuga,

(Note: some of these dates are draft, and subject to change, others are not.)

Deadlines, Timelines, Release Dates & More

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Yates, Schuyler, Chemung,Steuben, Chautauqua,Cattaraugus, Allegany, Wyoming,Genesee, Orleans and Niagara:April 2015

• Jefferson, Oswego, Lewis, Oneida,Herkimer, Madison, St. Lawrence,Franklin, Clinton, Essex and

Hamilton: May 2015

FIDA

New York City and Nassau

• Announcement letter sent toMLTC members in New York Cityand Nassau explaining that theymay enroll into a FIDA plan:December

• Enrollment becomes effective inFIDA for those who voluntarilyenrolled in December: January 1,2015

• 90-day notice mailed withinformation about right to enrollor opt out and passive enrollmentto those who did not voluntarilyenroll in FIDA: phased-in Januaryto May 2015

• 60-day notice mailed withinformation about right to enrollor opt out and passive enrollment:Phased-in February to June 2015

• 30-day notice mailed withinformation about right to enrollor opt out and passive enrollment:phased-in March to July 2015

• Passive enrollment/automaticassignment to a FIDA plan willoccur for those who have notenrolled or opted out: phased-in

April to August 2015

Suffolk and Westchester

• Announcement letter sent toMLTC members in Suffolk and

Westchester explaining that they mayenroll into a FIDA plan: March 2015

• Enrollment becomes effective in FIDA forthose who voluntarily enrolled in March:April 1, 2015

• 90-day notice with information aboutright to enroll or opt out and passiveenrollment mailed to those who did notvoluntarily enroll in FIDA: April 1, 2015

• 60-day notice mailed with informationabout right to enroll or opt out and passiveenrollment: May 1, 2015

• 30-day notice mailed with informationabout right to enroll or opt out and passiveenrollment: June 1, 2015

• Passive enrollment/automatic assignmentto a FIDA plan will occur for those whohave not enrolled or opted out: July 1,2015

Wage Parity

• Quarterly wage parity certif ication formscovering December 1, 2014 to February28, 2015 due from Licensed Home CareServices Agencies to their contractors:December 1

• New wage parity levels in effect for LongIsland and Westchester: March 1, 2015

• Annual wage parity certif ications coveringMarch 1, 2015 to February 29, 2016 duefrom Certif ied Home Health Agencies,Long Term Home Health Care Programsand Managed Care Organizations to DOH:March 1, 2015

• Quarterly wage parity certif icationscovering March 1 to May 31, 2015 duefrom Licensed Home Care ServicesAgencies to their contractors: March 1,

2015

Minimum Wage & Overtime

• Increases from $8.00 per hour to $8.75 perhour: December 31, 2014

• Aides must be paid time-and-a-half of

their regular pay rate: January 1, 2015

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Latest Global Cap Report Compares Medicaid Spending Levels to Projections

The state Department of Health (DOH) has issued its August 2014 Medicaid Global Spending Cap report. Itshows spending to be $5 million less than projected for the current fiscal year through August. (The current fiscalyear began on April 1 and ends March 31.)

DOH’s estimated spending amount for this five-month period was $7.038 billion versus an actual spendingamount of $7.033 billion. The cap for the entire fiscal year is $17 billion.

DOH’s report is at http://www.health.ny.gov/health_care/medicaid/regulations/global_cap/monthly/sfy_2014-2015/docs/august_2014_report.pdf.

For DOH’s reporting purposes, home care services are lumped into the category labelled “Other Long Term Care.”According to the report, that category was $1 million over projections for the five-month period ending August 1– a difference between projected spending of $295 million and actual spending of $296 million. In prior reports,this category has been below projected spending and HCA will seek further information on this change.

Medicaid Managed Care was $37 million under the projection of $4.877 billion for this period, according to thereport.

The report does not provide an explanation for the spending patterns in “Other Long Term Care.” However, it doesprovide the following “variance highlights” for Medicaid Managed Care spending:

• Mainstream Managed Care was $18 million, or 0.5 percent, under projections. “The variance is primarilydriven by the migration of Family Health Plus recipients into mainstream managed care plans. Thetransition appears to be occurring at a slower rate than anticipated.”

• Long Term Managed Care was $19 million under projections through August. “Total enrollment in theprogram is ... 2.8 percent below expected levels.”

In its prior Global Spending Cap report, DOH established a cap of $574 million in 2014-15 for “Other Long TermCare.” However, in the April and May Global Cap reports, DOH had earlier estimated that “Other Long TermCare” services would be $605 million in 2014-15. HCA has yet to receive an explanation from DOH as to whythis estimate was reduced by $29 million in the June and July reports.

HCA will take this issue up with DOH during our home health reimbursement meeting next week and as the statebegins its budget preparations for the coming year. We will also use our own data capabilities – through theSalient Interactive Miner software and other means – to drill down further into the home care spending levels aspart of this discussion to ensure that home care is not adversely impacted by the state’s interpretation of the data.

DOH’s report also provides other data on Medicaid enrollment changes, accounts receivable data, enrollment inthe state’s health care exchange, and various state Medicaid savings initiatives.

For more information, please contact a member of HCA’s Policy staff.

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PHHPC Committee Reviews CHHA and LHCSA Applications

This week, the Public Health and Health Planning Council (PHHPC) Establishment and Project ReviewCommittee made recommendations on a number of Certified Home Health Agency (CHHA) and LicensedHome Care Services Agency (LHCSA) applications. The Committee approved the following applications andsent them to the full Council to consider at its December 4 meeting:

• One CHHA to become the operator of a separate CHHA through a merger;• One CHHA to become the operator of a separate CHHA through a purchase;• Twenty-seven new LHCSAs;• Four LHCSAs for changes in ownership; and• One entity to acquire two other LHCSAs.

The agenda and supporting documents are athttp://www.health.ny.gov/facilities/public_health_and_health_planning_council/meetings/2014-11-13/.

DSRIP Updates

The state Department of Health (DOH) and KPMG will be hosting a conference call to discuss Delivery ReformIncentive Payment (DSRIP) program updates on November 20, 2014 from 2:30 to 4:30 p.m. The call willinclude a 20-minute overview of DSRIP updates followed by a question-and-answer period. To participate, call(888) 892-6166 ten minutes prior to the call start time. The conference identification number is 36234602.

DOH asks participants to review the DSRIP Year 0 key dates on the revised timeline prior to the call. It wasupdated this week at http://www.health.ny.gov/health_care/medicaid/redesign/docs/dsrip_timeline.pdf. Anyquestions may be directed to dsripapp@health.ny.gov.

In other DSRIP updates:

• VAP Exception Appeals: The Vital Access Provider (VAP) Exception Appeals at https://www.health.ny.gov/health_care/medicaid/redesign/dsrip_safety_net_definition.htm have been updatedwith files that were missed. If you have any questions or comments, please contact BVAPR@health.ny.gov.

• Revised Draft DSRIP Plan Application materials: DOH has posted redline versions of the DSRIPPlan Application materials, a summary of the feedback from the public comment period with responses,as well as a complete listing of all public comments received athttps://www.health.ny.gov/health_care/medicaid/redesign/dsrip_project_plan_application_draft.

CMS to Host Dec. 16 Call on 2015 F2F Certification Process

The U.S. Centers for Medicare and Medicaid Services (CMS) is hosting a national call on December 16, from1:30 to 3 p.m., to discuss the new patient certification requirement for home health agencies under the 2015 homehealth prospective payment system (HHPPS) final rule. The new requirements go into effect January 1, 2015.

Last week, HCA provided the membership with a detailed memo on the newly finalized HHPPS athttp://www.hca-nys.org/policy_memos/documents/CMS2015FinalRuleMemo.pdf.

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This session will include a benefit overview and information about patient eligibility, certification and recertificationrequirements (including the required face-to-face encounter), resources and more.

The target audience for this call includes: home health agencies, physicians who certify patients for the Medicarehome health benefit, hospital/skilled nursing facility discharge planners, and non-physician practitioners whoare allowed to perform Medicare home health face-to-face encounters.

Registration for the call is now available at http://www.eventsvc.com/blhtechnologies.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

OCR Issues Bulletin on HIPAA Privacy in Emergency SituationsBulletin issued as part of federal government’s response to the Ebola situation

Because of the recent outbreak of Ebola, the U.S. Department of Health and Human Services (HHS), Office forCivil Rights (OCR), has provided a bulletin to outline the ways in which patient information may be sharedunder the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule in an emergency situation,and to remind providers that the protections of the Privacy Rule are not set aside during an emergency.

OCR’s bulletin is at http://www.hhs.gov/ocr/privacy/hipaa/understanding/special/emergency/hipaa-privacy-emergency-situations.pdf.

The HIPAA Privacy Rule protects the privacy of patients’ health information (protected health information) butis balanced to ensure that appropriate uses and disclosures of the information still may be made when necessaryto treat a patient, to protect the nation’s public health, and for other critical purposes. Please also see http://www.hhs.gov/ocr/privacy/hipaa/understanding/special/emergency/index.html.

Since the outbreak of Ebola in New York, HCA has remained in daily communications with state and regionalhealth emergency preparedness entities, and is in regular receipt of DOH situation reports and updates.

HCA will notify the home care community as soon as the state Department of Health (DOH) issues any home-care-specific guidance and we will ask for providers’ feedback to HCA on any new or revised long-term infection-control protocols that may be developed as a result of Ebola.

For further information, contact the HCA Policy staff.

Advisory Issued on Pneumococcal Vaccine Recommendations

The state Department of Health (DOH) has posted a Health Advisory on new pneumococcal vaccinerecommendations for adults age 65 and older.

The recommendations include:

• Adults 65 or older who have not previously received any pneumococcal vaccine or whose vaccinationhistory is unknown should receive a dose of the pneumococcal conjugate vaccine (PCV13, Prevnar-13),

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followed 6 to 12 months later by a dose of the pneumococcal polysaccharide vaccine (PPSV23,Pneumovax23).

• Adults 65 or older who have previously received PPSV23, on or after age 65 years, should receive PCV13at least one year after their most recent dose of PPSV23.

• Adults who received PPSV23 before age 65 years should receive PCV13 on or after age 65 years and atleast one year after the dose of PPSV23, followed by a second dose of PPSV23 6 to 12 months after thedose of PCV13, and at least 5 years after the first dose of PPSV23.

• Currently, Medicare Part B covers only one dose of pneumococcal vaccine, either PCV13 or PPSV23 butnot both, for adults 65 years of age or older.

The recommendations are posted on the Health Commerce System at https://commerce.health.state.ny.us/public/hcs_login.html.

CMS Posts Hospice Updates

The U.S. Centers for Medicare and Medicaid Services (CMS) recently posted the following hospice transmittals(or Change Requests).

• Change Request 8923 (http://tinyurl.com/pykp5om) corrects remittance advice remark code N211 toindicate that an appeal is allowed in cases where a Medicare Administrative Contractor (MAC) determinesthat a hospice is ineligible for an exception to the Notice of Election (NOE) timely filing requirement. Thechange is to be implemented on April 6, 2015. CR 8923 also makes some minor clarifications aboutproper billing of non-reimbursable services and changes for the non-covered days associated with anNOE that is not filed timely.

• Medlearn Matters Article SE 1321 (http://tinyurl.com/lo2f5rs) has been revised and addresses billingof Part B services for hospice-enrolled beneficiaries, including guidance on the proper modifiers thatshould be used. CMS has clarified certain references, including changing any references to “hospicediagnosis” to “hospice prognosis.”

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

OASIS Updates for Home Health Agencies

OASIS-C1/ICD-9 has been approved by the Office of Management and Budget (OMB) and will become effectiveon January 1, 2015. The final, OMB-approved version will soon be posted at http://cms.hhs.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/OASIS/index.html?redirect=/oasis/.

The re-hospitalization measures will not be reported in January 2015; they are scheduled for inclusion in the July2015 refresh to consolidate planned Home Health Compare enhancements.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

14

NGS Updates: SMRC Appeals, ICD-10 Testing Next Week

National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), hasrecently posted the following information to its website.

Appealing a Supplemental Medical Review Contractor (SMRC) Denial

Providers were previously informed that StrategicHealthSolutions, LLC is the SMRC under contract withthe U.S. Centers for Medicare and Medicaid Services (CMS) to lower improper payment rates and increaseefficiencies of the medical review functions under Medicare and Medicaid.

The following new denial reason codes are to be used when the SMRC denies claims:

• 55M01: Documentation did not support medical necessity.

• 55M02: Information required to make payment was missing.

• 55M03: Information requested was not received.

These can be appealed after the adjustment has finalized showing the claim denial. An appeal will not beaccepted if the denial has not processed. The timeframe to appeal is based on the date that the adjustmentprocesses and not the date of the SMRC determination letter.

ICD-10 Testing Week: November 17 to 21

Trading partners, billing services, software vendors, and clearinghouses will be able to send test claims for theICD-10 Acknowledgement Testing Week to NGS’s Electronic Data Interchange (EDI) from November 17through November 21, 2014. This testing week allows CMS to analyze testing data. Here’s some importantinformation about submitting test claims:

• Test claims with ICD-10 diagnosis codes must be submitted with current dates of service (i.e., October1, 2014, 2014 through November 21, 2014), since testing does not support future dated claims.

• Test claims will receive the TRN, 999 and 277CA acknowledgements as appropriate, to confirm ifthe claim would be accepted or rejected in the system.

• Testing will not confirm claim payment or produce a remittance advice.

• All test files must have the “T” in the ISA15 field for Test files.

HCA members with questions can contact NGS’s EDI Help Desk at 877-273-4334.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

15

HRA Issues Alert on Nursing Home Conversions

The New York City Human Resources Administration (HRA) has issued a Medicaid Alert on the conversionfrom Medicaid in the community to Institutionalized Medicaid for Medicaid recipients.

Conversion submissions to the HRA Nursing Home Eligibility Division (NHED) are requests forconsumers having active Medicaid community coverage through District 66 (NYC) at the time the consumer isadmitted to a residential health care facility (RHCF). Medicaid coverage is converted to allow payment fornursing home level of care.

Conversion cases cannot receive more than three months of retroactive coverage for nursing home care, fromthe date NHED receives the form LDSS 4495A (Supplement A) accompanied by form MAP 648p. Allconsumers are required to have a 60-month look-back (resource information) and this documentation must beincluded if they: have a greater than a 29-day stay; are permanently placed; or have more than one admissionwithin a 12-month period.

The Alert is at http://www.nyc.gov/marc (password needed).

HEAP Opens November 17

Individuals needing heating assistance can begin applying for New York’s Home Energy Assistance Program(HEAP) on November 17.

Individuals with monthly income up to $2,194 and couples up to $2,869 are eligible. Eligible households canreceive a one-time benefit of up to $625.

The HEAP Heating Equipment Repair and Replacement Component helps eligible low-income homeownersrepair or replace primary heating equipment necessary to keep the home’s primary heating source functional.This component opens November 10, 2014.

Individuals can also be eligible for an emergency benefit if they are in danger of running out of heating fuel orhaving their utility service shut off. Applications for emergency benefits will be accepted beginning January 2,

2015. Households in an energy emergency situation should call their local department of social services forassistance.

For more information, go to http://otda.ny.gov/programs/heap. Questions should be directed to your LocalDepartment of Social Services Office or the NYS HEAP Hotline at 1-800-342-3009.

Publications

• “The Future of Home Health Care: A Workshop,” by the Institute of Medicinehttp://www.iom.edu/Activities/Aging/FutureHomeHealthCare/2014-SEP-30.aspx

• “FLSA Home Care Rule Tool Kit Supplement: An Overview of the Non-Enforcement Period,” by theNational Resource Center for Participant-Directed Services http://tinyurl.com/obxmzc3

Continued on next page

Volume 19, No. 42 November 14, 2014ASAP – a publication of the Home Care Association of New York State

16

Continued from p. 15

• “What Do We Know About Health Care Access and Quality in Medicare Advantage Versus theTraditional Medicare Program?” by the Kaiser Family Foundation http://files.kff.org/attachment/what-do-we-know-about-health-care-access-and-quality-in-medicare-advantage-versus-the-traditional-medicare-program-report

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.

HOME CARE

Home Care Association of New York State

CALL FOR BOARD OF DIRECTOR

NOMINATIONS

2015

MLTCs

CHHA’s

LEADERSHIP

The Home Care Association of New York State (HCA) is actively seeking nominations for its Governing Board.

HCA’s Mission StatementThe Mission of HCA is to promote and enhance the quality, accessibility and availability of home and community based care by empowering our members to meet the needs of the individuals and communities they serve.

Responsibilities of HCA Board of DirectorsThe Board’s principal task is to promote and implement a vision and strategic policy direction for the home care industry and the Association.

Duties of the HCA Board of Directors

• Participating in scheduled Board meetings, assigned ad-hoc workgroups and Association events.

• Providing strategic policy guidance on issues that support cost-effective, efficient, high quality home and community-based care services; and promote home and community-based care as a core integral service that crosses home care settings.

• Representing the broad interests of the entire membership.

About HCA’s Board of DirectorsThe HCA Board is composed of 25 Directors who represent a variety of provider member organizations including CHHAs, MLTCs, LTHHCPs, Hospices, and LHCSAs. In addition, non-provider members (such as allied organizations or individuals knowledgeable in home care, etc.) may also be elected to the Board of Directors. All HCA Board Members are expected to serve the mission and goals of HCA. HCA seeks a Board that represents racial, ethnic, gender and geographical diversity.

Meetings, Terms of Office, and CommitteesHCA Board of Directors’ meetings are held five times per year; however, the Chairperson may convene the Board throughout the year by conference call. A Board Member’s appointment is for a two-year term and the bylaws allow for up to four consecutive two-year appointment terms. Board Members may be invited to participate in Board Committees which include the Executive, Nominating and Governance, and Finance and Investment Committees. In addition to the regularly scheduled meetings, Board Members are asked to attend HCA signature events which include the HCA Annual Membership Meeting, held in May, and HCA’s Advocacy Day, usually held in late January or early February.

HCA Board of Directors Membership Application

Characteristics of CandidatesIn addition, the following personal characteristics are sought in Board candidates:

• Demonstrated leadership potential• Commitment to HCA’s Engagement and Attendance policy which

requires Board Members to routinely participate in scheduled meetings and signature events

• Commitment to HCA’s mission, values, and strategic plan• Consensus builder• Strong interest in public policy discussions and advocacy• Active participant and contributor in meetings and discussions• Authority to vote on items before the Board

Please submit your nomination materials

no later than

February 2.

All nominees must be employed by an HCA

member in good-standing.

Nomination Process and TimelineCandidates should complete the nomination application on the back of this form by February 2, 2015. Candidates applications will be reviewed by the HCA Nominating and Governance Committee. Those candidates selected for consideration will be contacted and vetted for approval by the HCA Board of Directors and the HCA Membership at the Annual Meeting in May.

How to Submit:

Please return• Your completed application (on

the back of this form)• Your current bio/C.V.• A letter of support from your

Board Chair or CEO to: Jenny Kerbein,Director of GovernanceHCA, 388 Broadway, 4th Floor, Albany, NY 12207 or at:jkerbein@hcanys.org, or by fax to (518) 426-8788 by February 2, 2015.

Candidate CriteriaThe Nominating and Governance Committee of HCA’s Board is seeking nominations for Board candidates who have exhibited accomplishments in one or more of the following areas:

• Demonstrated commitment to HCA• Leadership role in an HCA member organization in good standing• Participation in HCA signature events including the HCA Annual

Membership Conference and Advocacy Day

Submit by February 2, 2015

Name of Nominee:____________________________________________________________________________

Title:_______________________________________________________________________________________

Organization:________________________________________________________________________________

Address:____________________________________________________________________________________

City:_______________________________________________________ State:__________ Zip: ____________

Telephone:____________________________________________ Fax: ________________________________

email:______________________________________________________________________________________

Relevant Experience (attach resume):

_________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Areas of expertise/contributions you feel you can make:

___________________________________________________________________________________________ ___________________________________________________________________________________________ ___________________________________________________________________________________________

Why are you interested becoming a member of HCA’s Board of Directors?

______________________________________________________________________________________________________________________________________________________________________________________ ___________________________________________________________________________________________

Have you attended HCA’s Annual Meeting in the past? YES ________ NO _________Have you attended HCA’s Advocacy Day in the past? YES ________ NO _________

FAX completed application along with your bio/C.V. and letter of support by February 2, 2015 to (518) 426-8788; or email to Jenny Kerbein at jkerbein@hcanys.org

HCA Board of Directors Membership Application

A daylong education program offering tools, strategies and information to get your home care agency ready for FIDA managed care plans.

December 5, 2014Albany Marriott

Wolf RoadAlbany, NY

In December, the state will begin theprocess of enrolling about 170,000dual-eligible recipients into speciallyapproved managed care FIDA plansthat will coordinate services paid bothby Medicare and Medicaid. Eligiblebeneficiaries who do not actively enrollor opt out will be “passively enrolled”under a schedule just recently outlinedby the State Department of Health forNYC, Long Island and Westchester.

This is a complex, monumental shift inpayment and service delivery for homecare. And it follows fast on the heels ofthe state’s effort to enroll certainMedicaid beneficiaries into ManagedLong Term Care plans; now, underFIDA, many of these same beneficiarieswill have a new set of decisions tomake, and so do you.

Home care providers will need to strikeup new contractual arrangements andnavigate entirely different systems ofpayment, regulatory oversight, serviceauthorization, quality management andmore.

Are you ready for FIDA? This daylongconference is designed to help you.HCA has gathered the state’spreeminent experts on FIDA to give youbackground and help you navigate allof the strategic decisions that you willneed to make.

December 5, 2014Albany Marriott, Wolf Road, Albany, NY

8:30 amRegistration

9:00 to 9:30 HCA Welcome

9:30 to 10:45amCalling All Home Care Provider Agencies – Are You Ready for FIDA?

Home care providers will be vital partners in FIDA plans, which are incentivized to deliver care efficiently and effectively by looking to cost-effective settings like home care. What are the options for home care agencies to participate in a FIDA plan? What tools and resources will home care agencies need in order to develop their relationships with FIDA plans? Learn how you can prepare for FIDA in your organization.

Margaret Wallingford, President, MA Wallingford and Associates

Continued on next page

AGENDA

10:45am Break

11:00am to NoonNew York State’s Perspective

Hear from New York Medicaid Director Jason Helgerson on how FIDA plans will work and function in the evolving landscape of health care delivery and payment reform, especially as other integrated models like DSRIP and ACOs continue to take shape. Mr. Helgerson is one of the state’s leading health officials overseeing many of the state’s Medicaid redesign and other policy initiatives. His perspective, answers and overall background on the FIDA rollout are “required reading” for your understanding of this major shift in service delivery.

Jason Helgerson, Medicaid Director, New York State Health Department

Noon to 1:00pmNetworking Lunch

1:00 – 2:00 pmHow Do I Get Started?

Even if you have had experience developing partnerships under Managed Long Term Care, the FIDA model represents a whole different ballgame, with new incentives for various types of home care agency models. This session will discuss how to best engage and develop relationships to ensure successful participation in a FIDA for your organization.

Carla Williams, Director, O'Connell & Aronowitz Healthcare Consulting Group

2:00 – 3:00 pmData Is King

Data is one of the most critical resources your agency has to offer in a FIDA relationship. Review the various kinds of data that are already available to you and how to best organize and present it.

Michael Freytag, Managing DirectorBlackTree Healthcare Consulting

3:00 – 4:00 pmStructuring Your Agency to BeReady for FIDA

In this panel session, HCA provider members will discuss ideas for how you should structure your organization so it is FIDA-ready.

Andrea Lazarek-LaQuay, Chief Clinical Officer, VNA Homecare

Hany Abdelaal, Senior Vice President and Chief Medical Officer, Visiting Nurse Service of New York

4:00 pm Closing Comments

AGENDA continued

REGISTRATION FORM – Fax to (518) 426-8788 or Mail to the address below.Please register by November 28.

Name: _____________________________________________________________________________________________

Title:_______________________________________________________________________________________________

Agency:_____________________________________________________________________________________________

Address:____________________________________________________________________________________________

City/State/Zip:______________________________________________________________________________________

Phone:______________________________________ Ext.________________

Fax: __________________________________________________________

Email: ___________________________________________________

PAYMENTPlease check method of payment:

____MasterCard ____VISA ____ American Express ________ Check*

*Make checks payable to HCA Education and Research and mail to: 388 Broadway, 4th Floor, Albany, NY 12207

(checks must be received one week prior to program)

Please print clearly.

Credit Card #: ____________________________________ Exp. Date:__________ Security Code: ____________

_____________________________________________________________________________________________________Name and/or Company Name on Card

_____________________________________________________________________________________________________Billing Address of card (including City, State and Zip Code)

_____________________________________________________________________________________________________Authorized Signature

Cancellations received by November 21 are refundable less a 25% administrative fee. Cancellations must be received in writing via e-mail to info@hcanys.org. No refunds after that time or for no shows. Substitutions are permitted.

REGISTRATION FEEHCA Members $219 ________

Non-Members $299 ________

Are You Ready for FIDA?December 5, 2014Albany Marriott, Wolf Road, Albany, NY

FAX TO:  (518) 426‐8788

December 10, 2014The Harvard Club of New York City35 W. 44th Street

New York, NY 10036

Now is a time like no other when home care agencies find themselves flooded with majorlegal questions streaming from a cascade of state and federal regulations.

The Affordable Care Act’s (ACA) ‘employer mandate,’ the Department of Labor’s‘companionship exemption’ changes, the state’s limits on executive compensation andadministrative expenditures – not to mention the wage parity law – are all changing theequation for your labor costs, human resources management, and overall administrationof your home care program, with huge legal implications.

In this one‐day program, HCA has assembled aroster of state and federal legal experts who willprovide a crash course on all of these legal hottopics, including the latest updates from thecourts and any new regulatory decisions thatcontinue to change the applicability of theserequirements. We’ll also discuss how to avoidpitfalls, and offer insights on how to meet thechallenges ahead.

Make sure your staff is well versed in all ofthese priority areas during this must‐attendevent for home health leaders, financemanagers, human resource administrators andcompliance officers.

Home Health Legal UpdatesDecember 10, 2014

8:00am to 9:00am Registration

9:00am to 9:15am Welcome from HCA

9:15am to 10:15amExecutive Order (EO) 38 – How to Navigate the Law

EO 38 places limits on administrative expenses and executive compensation for certain individualsand entities that receive payments from the state, including home health agencies. Although thisregulation has been challenged by HCA and sister organizations, the rules still apply, and theyremain packed with complexities and potential pitfalls. This session will help you understand thelegalities to determine whether or not your organization is compliant, what actions you may needto take and the penalties you may encounter for non‐compliance.

Frank Fanshawe, Partner, Wilson Elser Moskowitz Edelman & Dicker LLP

AGENDA

Agenda continued…

10:15am to 11:15amLegal Challenges to the Wage Parity Regulation

The Home Care Worker Wage Parity regulation, which provides a minimum wage rate for aides, has created major cost challenges for downstate providers. This session will give you the latest on a series of court challenges to the law as well as any updates, if any, related to the new wage levels expected in 2015, the status of state funds and rate adjustments for providers and plans, and other issues. 

Philip Rosenberg, Partner, Nixon Peabody

11:15am to 12:30pmWeighing the Legal and Compliance Issues in Managed Care, FIDA, and DSRIP

On the one hand, state and federal program incentives expect you to partner with health plans and other outside organizations as much as possible. On the other hand, these partnerships raise some potentially challenging legal issues that state and federal policymakers have only addressed in small measure. Learn about the legal issues you may encounter as a managed care collaborator, including any special considerations for your partnership decisions under FIDA and DSRIP. 

Brian McGovern, Partner, Cadwalader, Wickersham & Taft LLP

12:30pm to 1:15pm Lunch

1:15pm to 2:15pmUnderstanding the Companionship Exemption

Effective January 1, 2015, the U.S. Department of Labor will implement its changes to the definition of companionship services. For New York home care providers, this has a major impact on employees and employers in terms of overtime hours and costs and extensive new recordkeeping requirements. DOL has indicated it will hold off on any compliance audits for the first six months of 2015, though providers remain vulnerable to private enforcement – through litigation – for non‐compliance. Learn more about the specific impact of this law for you as a New York State home care provider. 

Stephen Zweig, Partner, Ford & Harrison LLP

2:15pm to 3:15pmWhere Are You on the Employer Mandate? 

Home health agencies are already in the thick of ACA compliance activities for many aspects of the law, but one of the signature elements of ACA is its ‘employer mandate,’ which was originally set to go into effect this year but was delayed until 2015. The mandate, which requires businesses to provide health insurance to their employees or else pay a penalty, includes some transitional provisions to assist employers in achieving compliance. However, the mandate is still being challenged and many questions remain on what it means to be compliant. This presentation will address the issues that are important to all providers and will offer a glimpse of future challenges that may come about.

Danielle White, Associate, Greenberg Traurig LLP

3:15pm to 3:30pm HCA Wrap Up

Home Health Legal UpdatesDecember 10, 2014

Deadline to register is December 1

REGISTRATION FORM  Please register by December 1.

Name: _____________________________________________________________________________________________

Title:_______________________________________________________________________________________________

Agency:_____________________________________________________________________________________________

Address:____________________________________________________________________________________________

City/State/Zip:______________________________________________________________________________________

Phone:______________________________________ Ext.________________  

Fax: __________________________________________________________

Email: ___________________________________________________

PAYMENTPlease check method of payment: 

____MasterCard    ____VISA    ____ American Express ________ Check* 

*Make checks payable to    HCA Education and Research and mail to:                       388 Broadway, 4th Floor, Albany, NY  12207 

(checks must be received one week prior to program)

Please print clearly.

______________________________________________________ Exp. Date:__________  Security Code: ____________Credit Card Number

_____________________________________________________________________________________________________Name and/or Company Name on Card

_____________________________________________________________________________________________________Billing Address of card (including City, State and Zip Code) 

_____________________________________________________________________________________________________Authorized Signature

Cancellations received by December 1 are refundable less a 25% administrative fee. Cancellations must be received in writing via e‐mail to info@hcanys.org.  No refunds after that time or for no shows. Substitutions are permitted.

REGISTRATION FEE

HCA Members $239 ________

Non‐Members $339 ________

Please fax completed form to: (518) 426‐8788 or mail to the address above.  Online registration is available at www.eventville.com/hcanys

Home Health Legal UpdatesDecember 10, 2014The Harvard Club of New York City35 W. 44th Street, New York, NY 10036

Online Registration is available at www.eventville.com/hcanys