Starting January 1, 2016, new behavioral health Home and Community Based Services (HCBS) became available for adults enrolled in HARPS. These consist of rehabilitation and recovery services such as psychosocial rehab, peer support, family support, residential support employment services, crisis respite, etc. In order to receive HCBS services, a recipient first needs an assessment to determine eligibility and, if eligible, a plan of care.
Providers of HCBS services will bill managed care plans (HARPs) under new rate codes. The plans will, in turn, bill emedny under those same rate codes to receive the reimbursement associated with the services and pass those monies to the provider. In other words, these services will be billed outside of the plans monthly capitation rates for a period no less than two years.
For information on the rate codes and NYC reimbursement levels, see link below: http://www.omh.ny.gov/omhweb/bho/docs/fe e-schedule.xlsx For details on billing for these services, see link below: http://www.omh.ny.gov/omhweb/bho/harpmainstream-billing-manual.pdf
The downstate region consists of NYC, and the counties of Nassau, Suffolk, Westchester, Rockland, Putnam, Dutchess and Orange. The entire downstate region uses the same HCBS rates as NYC. DOH, OMH and OASAS are working to establish rates for the Upstate region and to revise the Downstate rates for several key changes. The proposed revisions, which will need to be approved by CMS before they can be implemented, are outlined in the next few slides.
IMPORTANT: All of the proposed changes, as well as all other revisions for start-up in this presentation, require CMS approval before implementation. At this time, we are uncertain of the timing or outcome of the requested adjustments and any CMS approved changes will be implemented prospectively.
The assumption for the staff work weeks per year used to calculate the HCBS fees is proposed to drop from 48 to 46. If approved by CMS, this proposed change will increase all of the HCBS rates by over 4%. This revision is applied to psychosocial rehab (on top of an additional $1.51 per unit increase described on slide 9). This revision does not apply to the fees for crisis respite, which already assumed 46 work weeks per year, however, we are proposing to re-budget these rates (see slide 10).
This fee is proposed to be revised upward by $1.51 (Downstate) to recognize that face-toface billable time will likely be lower than previously estimated. The percentage of time billable was changed from 60% to 55%, which is the same as that already used for CPST. If approved by CMS, this proposed change combined with the adjustments to work weeks per year equates to an increase of 13% percent for this service.
The Crisis Respite fees were completely rebudgeted to support the program model. If approved by CMS, the short-term fee changed from $306.00 to a proposed fee of $419.51 (Downstate). If approved by CMS, the long-term fee changed from $476.00 to a proposed fee of $649.72 (Downstate).
With the exception of Crisis Respite, all HCBS services are proposed to receive start-up adjustments. If approved by CMS, the start-up equates to: 50% until HCBS system-wide utilization exceeds 55% of estimated full utilization for HARP enrollees 25% until HCBS system-wide utilization exceeds 70% of estimated full utilization for HARP enrollees 10% until system-wide utilization exceeds 85% of estimated full utilization for HARP enrollees The adjustments are to be computed separately for NYC and Rest of State.
The Downstate region shares the same HCBS fees as NYC. The Downstate region consists of NYC, and the counties of Nassau, Suffolk, Westchester, Rockland, Putnam, Dutchess, and Orange. The Upstate HCBS fees are based on a percentage of the Downstate fees i.e., slightly over 89% based on the Upstate to Downstate ratio used for free-standing clinic APG reimbursement.
Program types and associated codes for CFR reporting have been established for each of the new HCBS waiver services. Calculation of units of service varies by program type consistent with the new HCBS fee schedule. HCBS Medicaid services billed and paid under the HARPs are to be reported under the new program codes along with associated costs consistent with CFR reporting requirements.
Program Code Program Name 4610 Ongoing Supported Employment (OSE) 4620 Intensive Supported Employment (ISE) 4630 Transitional Employment 4640 Pre-Vocational Services 4650 Empowerment Services Peer Supports 4660 Education Support Services (ESS) 4670 Intensive Crisis Respite (ICR) 4680 Short-term Crisis Respite 4690 Family Support and Training (FST) 4700 Habilitation 4710 Psychosocial Rehabilitation (PSR) 4720 Community Psychiatric Support and Treatment (CPST)
Program Code Program Name Units of Service 4610 Ongoing Supported Employment (OSE) 15 Minutes 4620 Intensive Supported Employment (ISE) 15 Minutes 4630 Transitional Employment 15 Minutes 4640 Pre-Vocational Services Direct Care/Service Hours 4650 Empowerment Services Peer Supports 15 Minutes 4660 Education Support Services (ESS) Direct Care/Service Hours 4670 Intensive Crisis Respite (ICR) Resident Days 4680 Short-term Crisis Respite Resident Days 4690 Family Support and Training (FST) 15 Minutes 4700 Habilitation 15 Minutes 4710 Psychosocial Rehabilitation (PSR) 15 Minutes 4720 Community Psychiatric Support and Treatment (CPST) 15 Minutes
New HCBS Program Codes for services under the HARP must include associated costs (i.e., Accurate cost allocation for staff time and service levels are critical to ensure accurate reporting). Services provided to Non-HARP eligible individuals and associated revenues and costs should continue to be reported under existing State Aid program codes. During the initial two year HCBS carve-out period, any start-up costs to expand capacity can be reported as eligible expenses for the State Aid grant. OMH expects some gradual growth in underspending as direct services and costs associated with HCBS service provision for HARP individuals shifts under the waiver. At the same time, OMH encourages HCBS providers to focus on efficient service delivery and elimination of unsupported spending to position your agency for ongoing fiscal viability.
OMH will keep the current State Aid grant levels in place for the first two years of HCBS implementation to ensure program stability as capacity is expanded. Upon completion of transition, OMH will phase-out a portion of the State Aid that previously supported individuals who transitioned to HCBS since the funds will be needed to cover costs in the managed care premium. As OMH manages any reductions in State Aid, we will consider providers retaining some funds to address unmet need for the non-harp population being served. NOTE: Since OASAS does not currently fund any of these services, additional HCBS revenue will not result in any decrease in OASAS State Aid.
OMH will be examining CFR and PCS reporting data to evaluate the current service capacity being supported by the State Aid grants and determine reductions as HCBS revenues and the overall program capacity grows. OMH will ultimately transition to a similar reporting framework for HCBS-like services for non-medicaid, dual eligible and uninsured individuals to ensure that State Aid resources are being used effectively.
HCBS Rates are changing but the effective date is uncertain as these are still pending CMS review and approval. Plans are currently negotiating with providers that are positioned to move forward without the rate increases. Delays in participation could result in lost opportunities.