Have you ever struggled to keep up with the dynamic and ever-changing healthcare environment? HW&Co. is here to help. We have compiled the following timely questions and answers to help Nursing Facilities (NF) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IID). Please contact us for assistance if you have any questions regarding these or any other issues.

Topics included in this issue with the corresponding effective/due date:
• 08/01/16: New 9401 Process (see article under Revenue Cycle Update)
• 10/01/16: New PPS Rates Effective
• 10/15/16: HW&Co. Benchmarking Reports Available
• 11/14/16: First Payroll Based Journal (PBJ) Submission Due
• 11/14/16: First Quarter 2017 Franchise Permit Fee (FPF) Due for ICF-IID
• 11/28/16: New CMS Requirements of Participation (ROP) Effective
• 12/01/16: New Department of Labor (DOL) Overtime Rules Effective
• 12/15/16: First Quarter 2017 Franchise Permit Fee (FPF) Due for NFs
• 01/01/17: Ohio NF Medicaid Rates Recalculated for Case Mix Adjustment
• Ongoing: Revenue Cycle Updates

Have you downloaded the new Medicare PPS Rates that were effective 10/1/2016?
The new Medicare PPS rates were effective on 10/1/16. Click here to download the rates from our website for all Ohio CBSAs, effective 10/1/16 to 9/30/17. Be sure to remind your billing personnel that these new rates need to be entered into your system prior to closing accounts receivable for October.
We can calculate an estimated Medicare rate for budgeting based upon the new rates. If you would like an estimate, please contact your HW Healthcare Advisor and provide us with your year-to-date RUG-IV days.

Are the 2015 HW&Co. Benchmarking Reports available?
Yes! The 2015 Benchmarking reports for Ohio NFs and ICF-IIDs are now available. HW&Co. Benchmarking Reports include an overview of your facility’s expenses, census, and staffing data presented in a format that provides for an easy comparison to your peers, other facilities in your county, peer group, and state-wide averages. This invaluable report can assist you with budgeting, planning, and ultimately succeeding in this competitive environment. Please contact us to learn more about the reports.

Are you prepared for the first required Payroll Based Journal (PBJ) electronic submission?
The first required PBJ electronic submission for all NFs is due by 11/14/16. Facilities are required to submit staffing data, by employee by day, for the period 7/1/16 to 9/30/16 for all direct care employees and contractors that had interpersonal contact with residents. The Centers for Medicare & Medicaid Services (CMS) has not yet announced the penalty for failure to submit but has stated it will consider “a good faith effort” by facilities that have registered and submitted staffing and census data, even if the submission is not 100% accurate. Merely registering by the deadline will likely not be sufficient to reflect a “good faith effort.” Please see our previous newsletter for more information on the PBJ requirements.

Do you know what the fiscal year 2017 Ohio franchise permit fees (FPF) are?
The nursing facility franchise permit fee for fiscal year 2017 (FY17) increased to $12.44 for beds 1-200 and $9.02 for beds over 200. The higher fee was a result of the increase in Medicaid rates at 7/1/16. The FY17 ICF-IID franchise permit fee is $18.02. The due date for the first FY17 franchise fee payment is 11/14/16 for ICF-IIDs and 12/15/16 for NFs. Remaining FY17 payments for both are due on 2/14/17, 5/15/17, and 8/14/17. Please note, Medicaid providers will no longer receive a hard copy of the franchise permit fee assessments in the mail. You must retrieve your assessments through the MITS portal. The assessments can be found under the correspondence tab and then “Letter Search.” They are titled “Nursing Home Franchise Fee cover letter.” The assessments will still be mailed for Non-Medicaid providers since they don’t use MITS.

11/28/16 is approaching fast. Are you ready for the new CMS Requirements of Participation (ROP)?
On 10/4/16, CMS published major changes to the Medicare Requirements of Participation (ROP) for NFs. The new regulations are so numerous that there is a three- year phase-in period. However, Phase 1 regulations must be implemented by 11/28/16. Getting ready for the changes will require a great deal of work for all NFs. You may need to contact your Association for implementation tools or seek legal assistance to ensure you are ready, especially if you are currently in your survey window.

Are you ready for the new Department of Labor overtime rules effective 12/1/16?
The Department of Labor made changes that will more than double the salary threshold for exempt employees under the Fair Labor Standards Act that perform certain executive, administrative, or professional duties. The new threshold is $47,476 annually or $913 per week. These new overtime rules go into effect on 12/1/16. These new rules will be challenging as providers may incur more overtime cost without any corresponding increase in reimbursement. Facilities need to review their staffing and be certain they are in compliance with the new rules.

Do you know how your case mix will impact your 1/1/17 Medicaid Rate?
Most Ohio NF providers were happy on 7/1/16 when the statewide average rate increase was over 8%, an almost $15.00 per day increase. All Ohio NF Medicaid rates will be recalculated on 1/1/17 using the average of their 6/30/16 and 9/30/16 case mix scores. Do you want to know the impact of this case mix adjustment on your facility? If you provide your case mix scores, then we can give you an estimate of your 1/1/17 rate change and compare you to your peer group. Contact us if you would like a rate estimate for budgeting purposes.


Did you know that HW&Co. has a team of Revenue Cycle consultants ready to help you?
In any industry, accurate billing and timely collection of receivables is necessary for success. This is especially true in healthcare where receivables are concentrated among payers. The average Ohio nursing home has over 70 percent of its census concentrated in two payers: Medicaid and Medicare. That number is decreasing as census shifts to managed care programs like MyCare Ohio. Concentration among payers is decreasing, but learning the ins and outs of billing a new managed care program presents its own challenges. Our revenue cycle consultants provide a variety of services to help you. Contact us for more information.

Are you having any issues with the new 9401 process?
If you are confused by or are having issues with the new 9401 Process, then you are not alone! Effective August 1, 2016, Ohio Benefits replaced CRISE as the new Medicaid eligibility system. Our Revenue Cycle team is prepared to help you navigate this transition process. Contact us for assistance. The following resources are available on ODM’s website:
ODM 9401 Facility Communication Presentation
ODM 9401 Frequently Asked Questions

Are you aware of the new MyCare Molina edit?
MyCare Molina has announced that they will begin processing their reimbursement based on the lesser of billed charges versus reimbursement allowance. Facilities should verify that their rates for inpatient and ancillary charges submitted on claims are at least set at the allowable reimbursement.
Did you know that Aetna is going to electronic claim submission?
Aetna will no longer be accepting paper claims effective January 1, 2017. This applies to primary and secondary claims. There are many methods for submitting claims electronically, and we could provide a couple of recommendations, just ask!

Are you experiencing Medicare Part B take backs for 2014?
Many facilities are experiencing Medicare Part B take backs for 2014. Facilities should be diligent in managing these recovered payments. After receiving notification from Medicare, the facility has 30 days to submit an appeal. CGS is encouraging appeals to be submitted via MyCGS portal. This system will provide a reference number and you can skip sending out the appeal in a certified mail package. If you are appealing a Medicare Part B claim, you may also get notification from a subsequent coinsurance payer wanting to recoup their payment. These are the result of an automatic electronic crossover. Some of these notifications have appeal information that you may want to complete to delay them recouping funds until the final Medicare determination is made on their portion of the claim payment.

When do Qualified Income Trusts (QIT) need to be set up?
Beginning August 1, 2016 individuals receiving long-term care services who have monthly income over the Medicaid limit of $2,199 may deposit their excess income into a Qualified Income Trust (QIT) to stay eligible for Medicaid. For current residents receiving a Medicaid benefit that are over the income limit, the QIT (fka Miller Trust) does not need to be established until their redetermination of benefits in 2017. However, this requirement must be met immediately for any person applying for Medicaid benefits. The State of Ohio has contracted with Automated Health Systems (AHS) to assist families in this process. AHS representatives are willing to meet with residents at the facility or at a bank, if needed. Click here to access resources on the ODM website.